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. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 and JANE DOE #2, Plaintiffs, 1. UNITED STATES OF AMERICA, Defendant. NOTICE OF' OBJECTION Petitioners Jane Doe 1 and Jane Doe 2 have moved for disclosure of settlement letters between the U.S. Attorney's Office and the lawyers who represented Jeffrey Epstein du
AM Document 56 Entered on FLSD Docket 04/07/2011 Page 2 of 19 Non-Prosecution Agreement reached between the U.S. Attorney's Office and Mr. Epstein. Jane Doe 1 and Jane Doc 2 also seek other unspecified relief, which they call "appropriate remedies," for the government's purported failure to keep them invol
d by the government arc subject to a protective order prohibiting their disclosure. In the related case 9:08-CV-80893 (the case where Jane Doe I and Jane Doe 2 sued Mr. Epstein for money), the Magistrate Judge prohibited Jane Doe 1 and Jane Doe 2 EFTA00177187 Case 9:08-cv-80736-KAM Document 56 Entered on
jury. Pursuant to Fed. R. Crim. P. 6(c), the Government cannot confirm or deny the accuracy of those allegations. Likewise, portions of Exhibit A to Docket Entry 48 refer to matters occurring before the Grand Jury. Notwithstanding Petitioners' citations to the First Amendment and the interest of the press an
ult in a disposition of the charges in the next several days." [CVRA Petition, DE 1, 13]. Claiming to be wrongfully excluded from those discussions, Jane Doe 1 asserted the violation of her CVRA rights to confer with federal prosecutors; to be treated with fairness; to receive timely notice of relevant cou
ntiffs MOTION Jane Doe #1 and Jane Doe #2's Motion for Order Directing the U.S. Attorney's Office Not to Withhold Relevant Evidence Jane Doe #1 and Jane Doe &filed by United States of America. (Lee, Dexter) (Entered: 05/30/2011) 06/17/2011 fd Notice of Supplemental Authority ma& Plaintiffs MOTION for Sum
s MOTION for Hearing filed by United States of America. (Lee, Dexter) (Entered: 04/08/2011) 04/08/201 1 a 04/08/2011 ...... a ) SYSTEM ENTRY — Docket Entry 63 restricted/scaled until further notice. (dj) (Entered: 04/08/2011) 04/08/2011 6 SYSTEM ENTRY — Docket Entry 64 restricted/sealed until further
age 2 of 4 judicial notice of a similar motion and its attachments filed at Docket Entry 12 in the separate case filed in this court by the name of JANE DOE, a/k/a. JANE DOE NO. 1 v. JEFFREY EPSTEIN et al. Case NO. 08-80804-CIV-MARRADOMISON 5. This evidence is relevant and critical to the prosecution of
se 9:08-cv-8L .1-KAM Doom_ ..t 22 Entered L. FLSD Docket Oth . )2008 Page 2 of 4 judicial notice of a similar motion and its attachments filed at Docket Entry 12 in the separate case filed in this court by the name of JANE DOE, a/k/a. JANE DOE NO. 1 v. JEFFREY EPSTEIN et al. Case NO. 08-80804-CIV-MARRADOM
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 10 EFTA00208124
jury. Pursuant to Fed. R. Crim. P. 6(e), the Government cannot confirm or deny the accuracy of those allegations. Likewise, portions of Exhibit A to Docket Entry 48 refer to matters occurring before the Grand Jury. Notwithstanding Petitioners' citations to the First Amendment and the interest of the press an
empting to negotiate with the government for more than 30 months. As set forth in the Procedural History Section of the United States' Opposition to Jane Doe #1 and Jane Doe #2's Motion for Finding of Violations of the Crime Victim Rights Act("CVRA"), at the last hearing on the Petitioners' Emergency Peti
e the trial." Focusing just on the second half of that Rule, for now, as the United States has explained since the very start of the litigation, in Docket Entry No. 19, on August 1, 2008, and as admitted by Petitioners during the hearing on August 14, 2008, no additional facts are needed. The only material f
ng (but not limited to) . Because Epstein used a means of interstate commerce and knowingly traveled in interstate commerce to engage in abuse of Jane Doe #1 and Jane Doe #2 (and the other victims), he committed violations of federal law, including repeated violations of 18 U.S.C. § 2422. (DE48 at 3-4
» One thought on the "statement of undisputed facts," I would not respond to it at all in this response, I would only discuss it in the response to Docket Entry 49 ("Jane Does Motion to Have Their Facts Accepted Because of the Government's Failure to Contest Any of the Facts.") First I would hammer the fact
empting to negotiate with the government for more than 30 months. As set forth in the Procedural History Section of the United States' Opposition to Jane Doe #1 and Jane Doe #2's Motion for Finding of Violations of the Crime Victim Rights Act("CVRA"), at the last hearing on the Petitioners' Emergency Peti
e the trial." Focusing just on the second half of that Rule, for now, as the United States has explained since the very start of the litigation, in Docket Entry No. 19, on August 1, 2008, and as admitted by Petitioners during the hearing on August 14, 2008, no additional facts are needed. The only material f
ding (but not limited to) . Because Epstein used a means of interstate commerce and knowingly traveled in interstate commerce to engage in abuse of Jane Doe #1 and Jane Doe #2 (and the other victims), he committed violations of federal law, including repeated violations of 18 U.S.C. § 2422. (DE48 at 3-4
. One thought on the "statement of undisputed facts," I would not respond to it at all in this response, I would only discuss it in the response to Docket Entry 49 ("Jane Does Motion to Have Their Facts Accepted Because of the Government's Failure to Contest Any of the Facts.") First I would hammer the fact
/2011 Page 1 of 2 • aitadedataa% • AND ASSOCIATES October 9, 2008 United States Attorney's Office 99 N.E. 4th Street Miami, Florida 33132 Re: Jane Doe # and Jane Doe #2 v. United States of America Case No.: 08-80736-CIV- Dear I am writing to call to your attention two potentially false statements t
jury. Pursuant to Fed. R. Crim. P. 6(e), the Government cannot confirm or deny the accuracy of those allegations. Likewise, portions of Exhibit A to Docket Entry 48 refer to matters occurring before the Grand Jury. Notwithstanding Petitioners' citations to the First Amendment and the interest of the press an
• aitadedataa% • AND ASSOCIATES October 9, 2008 Dexter Lee, AUSA United States Attorney's Office 99 N.E. 4th Street Miami, Florida 33132 Re: Jane Doe # and Jane Doe #2 United States of America Case No.: 08-80736-CIV-MARRA/JOHNSON Dear Mr. Lee: I am writing to call to your attention two potential
jury. Pursuant to Fed. R. Crim. P. 6(e), the Government cannot confirm or deny the accuracy of those allegations. Likewise, portions of Exhibit A to Docket Entry 48 refer to matters occurring before the Grand Jury. Notwithstanding Petitioners' citations to the First Amendment and the interest of the press an
Entities connected to both Jane Doe and Docket Entry

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSON
Paul Cassell
PERSON
Scarlett Johansson
PERSON
United States
LOCATIONthe Southern District
LOCATIONMaria Farmer
PERSONRobert D. Critton
PERSON
George W. Bush
PERSONLeon Black
PERSON
Ghislaine Maxwell
PERSON
Salt Lake City
LOCATION
A. Marie Villafana
PERSON
Department of Justice
ORGANIZATION
Prince Andrew
PERSONRoy Black
PERSON
Jay Lefkowitz
PERSONMartin Weinberg
PERSON
the University of Utah
ORGANIZATION