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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
6. The correspondence further discussed a possible plea disposition that would make it hard for a judge to see what was happening: Andy [i.e., AUSA Andrew Laurie] recommended that some of the timing issues be addressed only in the state agreement, so that it isn't obvious to the judge that we are trying to c
ns. The term "victim" means any person that the Government identified as a possible victim of a sex offense committed by Jeffrey Epstein, including Jane Doe 1, 2, 3, and 4, all victims identified in attachment to the non-prosecution agreement entered into by Epstein, and any other person that the Governme
it of any kind to any United States Attorney or Assistant United States Attorney, including but not limited to Alex Acosta, Matthew Menchel, and/or Andrew Laurie, prior to Epstein's plea in June of 2008. upplemental Discovery Request 4. Any emails or other documents, including those circulate within the FBI
tream aircraft owned by Hyperion Air, Inc. (201) On or about August 18, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe #17. (202) On or about August 19, 2005, Defendant wk/a placed one or more telephone calls to a telephone used by Jane Doe #17. (203) On or about
ter have no relation to the allegations against Mr. ISpstein. Notably. affix we objected to these overt broad and intrusive requests. Deputy Chief Andrew Laurie denied knowledge of Ms. s actions and Mr Laurie commendably so t igni tiara ly narrow the list of documen requested. In a subsequent court filin
Entities connected to both Jane Doe and Andrew Laurie

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSON
Paul Cassell
PERSONJack Goldberger
PERSON
United States
LOCATION
Alan Dershowitz
PERSONthe Southern District
LOCATIONMaria Farmer
PERSON
George W. Bush
PERSONLeon Black
PERSONSouthern District
LOCATION
Alexander Acosta
PERSON
A. Marie Villafana
PERSONRobert C. Josefsberg
PERSON
Department of Justice
ORGANIZATION
Prince Andrew
PERSONRoy Black
PERSON
Jay Lefkowitz
PERSONFBI
ORGANIZATION