Epstein Secrets

ber 18 2007, 9:14 .), ande Lefkowitz to (September 18, 2007, 8:59 attached Suppl. Box 3 P-013883 E-mail to Acosta, , Any work-product and McMillan, September 18, 2007, 9:31 ., RE: tein Ne otiations Suppl. Box 3 P-013884 Thru P413886 E-mail, to and l=, September 17, 2007 10:35 ., RE:

Document 361 Entered on FLSD Docket 02/10/2016 Page 1 of 57 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 9:08-cv-80736-KAM JANE DOE 1 AND JANE DOE 2, Petitioners, UNITED STATES, Respondent. JANE DOE 1 AND JANE DOE 2'S CONSOLIDATED STATEMENT OF UNDISPUTED MATERIAL FACTS AND MOTI

m letter to Jane Doe 5 also acknowledged the victims' rights under the CVRA at the same time as the Office was not disclosing the NPA's existence to Jane Doe 5 and the other victiim."6 101. In mid-June 2008, Mr. Edwards contacted the line AUSA handling the case to inform her that he represented Jane Doe 1 a

ange Description Privilege(s) Asserted Victims' Objections Suppl. Box 3 P-013883 E-mail, Villafana to Acosta, Lourie, Garcia, Atkinson, and McMillan, September 18, 2007, 9:31 a.m., RE: Epstein Negotiations Atty work-product No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Wa

A-authorized release; Material Severable; Redaction; No Assertion by Victims Box #2 P-008809 Thru P-008847 File folder entitled "[Victim namej/Jane Doe #6" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product

na (September 18, 2007, 8:59 a.m.), attached Atty work-product Suppl. Box 3 P-013883 E-mail, Villafana to Acosta, Lourie, Garcia, Atkinson, and McMillan, September 18, 2007, 9:31 a.m., RE: Epstein Negotiations Atty work-product Suppl. Box 3 P-013884 Thru P-013886 E-mail, Villafana to Garcia

ict of Florida Brad Edwards, Esq., Farmer Jaffe Weissing Edwards Fistos Lehrman Paul G. Cassell S.J. I uinne olle e of Law at the Attorneys for Jane Doe # 1 and Jane Doe # 2 2 EFTA00209307 Case 9:08-cv-80736-KAM Document 216-1 Entered on FLSD Docket 07/27/2013 Page 1 of 14 SUPPLEMENTAL PRIVILEGE

na (September 18, 2007, 8:59 a.m.), attached Atty work-product Suppl. Box 3 P-013883 E-mail, Villafana to Acosta, Louric, Garcia, Atkinson, and McMillan, September 18, 2007, 9:31 a.m., RE: Epstein Negotiations Atty work-product Suppl. Box 3 P-013884 Thru P-013886 E-mail, Villafana to Garcia

e informed the USAO and the FBI that she was not a victim of any offense committed by Epstein, and, as a result, the USAO did not consider informing Jane Doe #2 about the non-prosecution agreement. Except as otherwise admitted above, the government denies Request No. 2(e). 3. Denied. 4. Denied. 5. The

ange Description Privilege(s) Asserted Victims' Objections Suppl. Box 3 P-013883 E-mail, Villafana to Acosta, Lourie, Garcia, Atkinson, and McMillan, September 18, 2007, 9:31 a.m., RE: Epstein Negotiations Atty work-product No Factual Underpinnings; Fiduciary Duty; Crime-Fraud-Misconduct; Wa

FLSD Docket 08/16/2013 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 v. UNITED STATES JANE DOE #1 AND JANE DOE #2'S NOTICE OF FILING OF OBJECTIONS TO PRIVLEGE LOG COME NOW Jane Doe #1 and Jane Doe #2 (also refe

stigation IS 9/10/07- 9/19/07 Entails between Alex Acosta, Jeff Montan, Andrew Laurie, Rolando Garcia, Karen Atkinson, Marie Villafafia, andJohn McMillan regarding plea negotiations 47 9/10/07- 9/11/07 Entails from Marie Viktoria to Gerakl I cfcourt with proposed Non-Prosecution Apvements PI 9/1

Department's Office of Professional Responsibility (OPR) arising out of a decision by United States District Judge Kenneth A. Marra in the matter of Jane Doe 1 and Jane Doe 2I United States, S.D. Fla. Case No. 08-80736-Civ-Marra; (3) the materials are needed to avoid an injustice in another proceeding, th

een Mr. Lefkowitz and myself that any appeal to Washington would be undertaken expeditiously. On September 7, 2007,1, along withFAUSA Sloman, AUSAs McMillan and Villafafta, and FBI agents, met with you, Mr. Lefkowitz, and Ms. Sanchez. I understood that you wished to present federalism-based concerns reg

ttorney Edwards who was informed of these developments and who received both the initial and corrected victim notification letters that were sent to Jane Doe #1. 12. In accordance with the Court's instructions at the status conference of August 14, 2008 and the terms of the Protective Order entered by t

package Work Product Deliberative Process 6(e) Investigative Privilege P-014069 9/10/2007 email from Marie Villafaila to Jeff Slornan and John McMillan regarding Acosta inquiry about FBI investigation into State grand jury proceeding Work Product 6(e) Investigative Privilege P-014070 thru P-01

Work Product Deliberative Process P-014440 12/11/2007 email from Marie Villafaila to Jeff Sloman and Alex Acosta regarding call with lawyer for Jane Doe #2 (T.M.) Work Product Deliberative Process P-014441 12/12/2007 emails between Marie Villafafta, Frederica Devlin, and Bob Senior regarding plan