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e 102. Some of the correspondence that is being withheld by the Government under the deliberative process privilege concerns an investigation that the Justice Department's Office of Professional Responsibility (OPR) opened with' regard to the Epstein case. This investigation was undertaken at the request of the victim
de: a) All documents, correspondence, and other information collected by the Office of Professional Responsibility (OPR) and any other component of the Justice Department (including the FBI) in response to the victims' letter; b) All documents, correspondence, witness statements, and other information collected as pa
tment accordingly sent various issues related to the Epstein case (and, on information and belief, issues related to Jane Doe #1 and Jane Doe #2) to the Department of Justice and to a United States Attorney's Office in another District. Please provide all documents, correspondence, and other information regarding the pote
vilege log with its objections annotated (D.E. 224-1); (2) a motion to compel production of documents that are not privileged, numbering eight pages D.E. 225; (3) a twenty-four page, single-spaced affidavit of petitioners' counsel, addressing the EFTA00179785 Case 9:08-cv-80736-KAM Document 230 Ent
so contained my direct dial telephone number, the direct dial telephone number of the case agent, Nesbitt Kuyrkendall, and the telephone number for the Justice Department's Office for Victims of Crime. (Id.). Both Jane Doe 1 and Jane Doe 2 also received letters from the FBI's Victim-Witness Specialist, which were sent o
ocket 06/02/2017 Page 25 of 176 Exhibit 1 EFTA00799629 Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 26 of 176 U.S. Department of Justice United Slates Attorney Southern District of FlOrida DELIVERY BY BAND James L. Bamberg, Esq. 250 S Australian Ave, Ste104 West Palm Beach, FL 33
the person whom Petitioners refer to as "Jane Doe 5" also had been approached by the investigative team in 2007 but refused to speak with them. (See D.E. 14 at 1 3.) Regardless of the perceived strength of the corroborating evidence, it was and remains my professional opinion as an experienced prosec
Counsel to file the subject Correspondence he wishes to make public under seal with the appropriate institution (e.g. the State Court proceeding and the Justice Department), and obtain a ruling from that institution on the use to which such Correspondence can be put, said Motion is granted. However, to the extent Epste
2010 the United States District Court entered a Final Order in the above-captioned case dismissing the action with prejudice and closing the case. (D.E. #211). In said Order, Judge Marra stated "[tie Court shall retain jurisdiction to enforce the terms of the parties' settlement and the joint stipul
Counsel to file the subject Correspondence he wishes to make public under seal with the appropriate institution (e.g. the State Court proceeding and the Justice Department), and obtain a ruling from that institution on the use to which such Correspondence can be put, said Motion is granted. However, to the extent Epste
2010 the United States District Court entered a Final Order in the above-captioned case dismissing the action with prejudice and closing the case. (D.E. #211). In said Order, Judge Marra stated "[t]he Court shall retain jurisdiction to enforce the terms of the parties' settlement and the joint stipu
disability ceases. The six-year limitations period in section 2401(a) "applies to all civil actions whether legal, equitable, or mixed." Spannaus U.S. Department of Justice 824 F.2d 52, 55 (D.C. Cir. I987)(citations omitted). Moreover, the Eleventh Circuit has recognized that, "[u]nlike an ordinary statute of limitatio
ates: I. PETITIONERS' MOTION TO ADD TWO ADDITIONAL PARTIES SHOULD BE DENIED AS UNTIMELY This action was commenced by Jane Doe #1 on July 7, 2008 (D.E. I). The Court ordered the Government to file a response by July 9, 2008, which was done. On July 11, 2008, the Court held a hearing on the emergenc
Counsel to file the subject Correspondence he wishes to make public under seal with the appropriate institution (e.g. the State Court proceeding and the Justice Department), and obtain a ruling from that institution on the use to which such Correspondence can be put, said Motion is granted. However, to the extent Epste
2010 the United States District Court entered a Final Order in the above-captioned case dismissing the action with prejudice and closing the case. (D.E. #211). In said Order, Judge Marra stated "[t]he Court shall retain jurisdiction to enforce the terms of the parties' settlement and the joint stipu
d period, in and around January 2008, there can be no dispute that Epstein's attorneys aggressively sought review of the NPA at higher levels within the Department of Justice, seeking relief from the obligations Epstein had undertaken in that agreement. First, he raised challenges to the United States Attorney's exercise
ined that, after the NPA was signed in September 2007, four victims were contacted and the provision for a federal restitution remedy was discussed. D.E. 14,1 8. When Epstein's attorneys learned of this, they complained that the Government was incentivizing the victims to overstate their involvement
Counsel to file the subject Correspondence he wishes to make public under seal with the appropriate institution (e.g. the State Court proceeding and the Justice Department), and obtain a ruling from that institution on the use to which such Correspondence can be put, said Motion is granted. However, to the extent Epste
2010 the United States District Court entered a Final Order in the above-captioned case dismissing the action with prejudice and closing the case. (D.E. #211). In said Order, Judge Marra stated "[tie Court shall retain jurisdiction to enforce the terms of the parties' settlement and the joint stipul
Counsel to file the subject Correspondence he wishes to make public under seal with the appropriate institution (e.g. the State Court proceeding and the Justice Department), and obtain a ruling from that institution on the use to which such Correspondence can be put, said Motion is granted. However, to the extent Epste
2010 the United States District Court entered a Final Order in the above-captioned case dismissing the action with prejudice and closing the case. (D.E. #211). In said Order, Judge Marra stated "[t]he Court shall retain jurisdiction to enforce the terms of the parties' settlement and the joint stipu
d period, in and around January 2008, there can be no dispute that Epstein's attorneys aggressively sought review of the NPA at higher levels within the Department of Justice, seeking relief from the obligations Epstein had undertaken in that agreement. First, he raised challenges to the United States Attorney's exercise
ined that, after the NPA was signed in September 2007, four victims were contacted and the provision for a federal restitution remedy was discussed. D.E. 14,1 8. When Epstein's attorneys learned of this, they complained that the Government was incentivizing the victims to overstate their involvement
Entities connected to both Department of Justice and D.E.

Jeffrey Epstein
PERSON
United States
LOCATION
Prince Andrew
PERSONthe Southern District
LOCATION
Alexander Acosta
PERSON
Ghislaine Maxwell
PERSONSouthern District
LOCATIONFBI
ORGANIZATIONLeon Black
PERSON
George W. Bush
PERSON
Donald Trump
PERSON
Kenneth Marra
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSON
Virginia Giuffre
PERSONJane Doe
PERSON
Bill Clinton
PERSON
New York
LOCATION
Julie K. Brown
PERSON
Alan Dershowitz
PERSON