Epstein Secrets

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

Thru P-012150 Declaration of Joseph Recarey 6(e) Box #3 P-012151 Thru PM 12167 Ex Parte Declaration Number One in Support of United States' Response to Motion to Quash Subpoenas 6(e) Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation

and documents subject to privacy rights of victims who are not parties to this litigation Box #2 P-006221 Thru P-006222 File folder entitled 'JANE DOE #12" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6

x #3 P-012130 Thru P-012150 Declaration of 6(e) Box #3 P-012151 Thru P-012167 Ex Parte Declaration Number One in Support of United States' Response to Motion to Quash Subpoenas 6(e) Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation

; Doe II - Clerk's Notice of Reassignment 04/13/2009 RDC Receipt and review Doe ll's offer of settlement 04/13/2009 MJP Review and analysis of Jane Doe's Response in Opposition to Motion to Slay 04/14/2009 RDC E-mails; review motions/responses re: Pacer on #2-7; Response to Stay 04/14/2009 RDC Co

mail correspondence regarding reply in support of Motion to Quash 0.40 hr $120.00 04/15/2009 RHB Legal research regarding case law in Plaintiffs Response to Motion to Quash 1.10hr $330.00 04/15/2009 RHB EW - Review Amended Complaint regarding criminal allegations 0.50 hr $150.00 04/15/2009 RHB EW - Draft Reply

the University of Utah 332 S. 1400 E. Salt Lake City, Utah 84112 (801) 585-5202 Fax: (801) 585-6833 E-mail: [email protected] Attorneys for Jane Doe # 1 and Jane Doe # 2 2 EFTA00211386 Case 9:08-cv-80736-KAM Document 212-1 Entered on FLSD Docket 07/19/2013 Page 1 of 23 PRIVILEGE LOG Bates Ra

Thru P-012150 Declaration of Joseph Recarey 6(e) Box #3 P-012151 Thru P-012167 Ex Parte Declaration Number One in Support of United States' Response to Motion to Quash Subpoenas 6(e) Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation

and documents subject to privacy rights of victims who are not parties to this litigation Box #2 P-006221 Thru P-006222 File folder entitled 'JANE DOE #12" containing meta-analysis of all phone, travel, and grand jury data related to that victim/witness for indictment preparation Work product 6

x #3 P-012130 Thru P-012150 Declaration of 6(e) Box #3 P-012151 Thru P-012167 Ex Parte Declaration Number One in Support of United States' Response to Motion to Quash Subpoenas 6(e) Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation

3268 Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake Cit Utah 84112 Fax: E-mail: Attorneys for Jane Doe # 1 and Jane Doe # 2 2 EFTA00223826 Case 9:08-cv-80736-KAM Document M-1 Entered on FLSD Docket 07/19/2013 Page 1 of 23 PRIVILEGE LOG Bates Rang

Thru P-012150 Declaration of Joseph Recarey 6(e) Box #3 P-012151 Thru P-012167 Ex Parte Declaration Number One in Support of United States' Response to Motion to Quash Subpoenas 6(e) Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation

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

Thru P-012150 Declaration of Joseph Recarey 6(e) Box #3 P-012151 Thru P-012167 Ex Parte Declaration Number One in Support of United States' Response to Motion to Quash Subpoenas 6(e) Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation

d to opposing counsel upon lift of stay by I Id' Circuit] Box #2 P-008536 Thru P-008542 Handwritten attorney notes to prepare for interview of Jane Doe #2 Work product Investigative Privilege Contains information subject to privacy rights of victims who are not parties to this suit Box #2 P-00

"Him P-012150 Declaration of Joseph Recarey 6(e) Box #3 P-012151 Thru P-012167 Ex Pane Declaration Number One in Support of United States' Response to Motion to Quash Subpoenas 6(e) Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation