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ve, Jane Doe 2 clearly stated her opposition to assisting the investigation, much less a prosecution. She was not alone. As noted in Special Agent Kuyrkendall's Declaration, many victims expressed reservations about assisting in the investigation. For example, Special Agent Timothy Slater described how on
eady was intense press coverage of the case, including efforts to publicly identify victims. As noted above and in the Declaration of Special Agent Kuyrkendall, and even in the letters from Jane Doe 2's counsel (Exs. 2 and 5), the victims who had been interviewed in the federal investigation were most conce
n. Exhibits designated by a letter are attached to the Government's Response and Opposition to Petitioners' Motion for Partial Summary Judgment and Cross-Motion for Summary Judgment. 2 EFTA00799607 Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 4 of 176 individuals who had been identified as p
those victims who have never reached out and asked to confer. Neither Jane Doe 1 nor Jane Doe 2 ever contacted AUSA Villafafia or FBI Special Agent Kuyrkendall regarding the case, despite being provided their phone numbers and addresses. D.E. 403-19,915. Since the Court's statutory interpretation of the te
MARY JUDGMENT Respondent United States of America, by and through its undersigned counsel, files its Reply to Petitioners' Response to Government's Cross-Motion for Summary Judgment, and states: I. JANE DOE 2 CLEARLY EXPRESSED HER DESIRE NOT TO BE TREATED AS A VICTIM OF EPSTEIN During the Government's investigation into Jeff
o obtain information from Jane Doe No. 2. Ex. B; Ex. S,11 6-12. On April 24, 2007, Jane Doe No. 2 was interviewed by FBI Special Agents E. Nesbitt Kuyrkendall and Jason Richards and AUSA Marie in the presence of her attorney, James Eisenberg, Esq. Ex. C; Ex. R, 5; Ex. S, ¶ 12. Jane Doe No. 2 described he
ATE OF SERVICE I HEREBY CERTIFY that on June 2, 2017, the foregoing Response and Opposition to Petitioners' Motion for Partial Summary Judgment and Cross-Motion for Summary Judgment was filed with the Clerk of the Court and served on counsel on the attached service list using CM/ECF. is/Dexter . Lee 31 EFTA00211748 SERVICE
those victims who have never reached out and asked to confer. Neither Jane Doe 1 nor Jane Doe 2 ever contacted AUSA Villafafia or FBI Special Agent Kuyrkendall regarding the case, despite being provided their phone numbers and addresses. D.E. 403-19,915. Since the Court's statutory interpretation of the te
MARY JUDGMENT Respondent United States of America, by and through its undersigned counsel, files its Reply to Petitioners' Response to Government's Cross-Motion for Summary Judgment, and states: I. JANE DOE 2 CLEARLY EXPRESSED HER DESIRE NOT TO BE TREATED AS A VICTIM OF EPSTEIN During the Government's investigation into Jeff
to obtain information from Jane Doe No. 2. Ex. B; Ex. S, 6-12. On April 24, 2007, Jane Doe No. 2 was interviewed by FBI Special Agents E. Nesbitt Kuyrkendall and Jason Richards and AUSA Marie Villafafia, in the presence of her attorney, James Eisenberg, Esq. Ex. C; Ex. R, I 5; Ex. S, q 12. Jane Doe No. 2
ATE OF SERVICE I HEREBY CERTIFY that on June 6, 2017, the foregoing Response and Opposition to Petitioners' Motion for Partial Summary Judgment and Cross-Motion for Summary Judgment was filed with the Clerk of the Court and served on counsel on the attached service list using CM/ECF. Is/Dexter A. Lee Dexter A. Lee Assistant U
o obtain information from Jane Doe No. 2. Ex. B; Ex. S,11[6-12. On April 24, 2007, Jane Doe No. 2 was interviewed by FBI Special Agents E. Nesbitt Kuyrkendall and Jason Richards and AUSA Marie Villafafia, in the presence of her attorney, James Eisenberg, Esq. Ex. C; Ex. R, 15; Ex. S, ¶ 12. Jane Doe No. 2 d
ATE OF SERVICE I HEREBY CERTIFY that on June 2, 2017, the foregoing Response and Opposition to Petitioners' Motion for Partial Summary Judgment and Cross-Motion for Summary Judgment was filed with the Clerk of the Court and served on counsel on the attached service list using CM/ECF. Is/Dexter A. Lee Dexter A. Lee Assistant U
Entities connected to both Kuyrkendall and Cross-Motion for Summary Judgment

A. Marie Villafana
PERSON
Jeffrey Epstein
PERSON
Kenneth Marra
PERSON
Alexander Acosta
PERSON
Jeffrey Sloman
PERSON
Dexter Lee
PERSON
Bradley Edwards
PERSONJane Doe
PERSON
United States
LOCATION
Department of Justice
ORGANIZATION
George W. Bush
PERSONLeon Black
PERSONMaria Farmer
PERSONthe Southern District
LOCATION
Jay Lefkowitz
PERSON
Paul Cassell
PERSON
Ken Starr
PERSON
Scarlett Johansson
PERSONFISTOS & LEHRMAN
ORGANIZATIONJames Eisenberg
PERSON