Epstein Secrets

From: ' (USAFLS)" </C.USAJOU=FLS/CN=RECIPIENTS/CN=AVILLAFANA> To: ' (USAFLS)" Cc: ' (USAFLS)" Subject: RE: Proposed briefing schedule for Jane Doe case? Date: Fri, 08 Jul 2016 21:22:59 +0000 Importance: Normal Thank you. I have a call in to Brad about the briefing schedule issue and as soon a

sts propounded on December 2, 2015, and December 29, 2015. Some of these may no longer be applicable since the government decided not to assert the Wellcare argument. I am fairly certain Cassell insisted some of the requests for production and for admissions were still relevant. EFTA00211238 « File: 3

From: " To: " Cc: "M, • (USAFLS)" </O=USA/OU=FLS/CN=RECIPIENTS/CN=AVILLAFANA> (USAFLS)" (USAFLS)" Subject: RE: Proposed briefing schedule for Jane Doe case? Date: Fri, 08 Jul 2016 14:09:26 +0000 Importance: Normal The issue is trying to avoid Judge Marra setting his own schedule with a due date 2

sts propounded on December 2, 2015, and December 29, 2015. Some of these may no longer be applicable since the government decided not to assert the Wellcare argument. I am fairly certain Cassell insisted some of the requests for production and for admissions were still relevant. « File: 356_order_amend_

Subject: RE: Proposed briefing schedule for Jane Doe case? Date: Thu, 07 Jul 2016 21:43:16 +0000 Importance: Normal Attachments: 356_order_amend_sched.pdf This is the last amended briefing schedule

sts propounded on December 2, 2015, and December 29, 2015. Some of these may no longer be applicable since the government decided not to assert the Wellcare argument. I am fairly certain Cassell insisted some of the requests for production and for admissions were still relevant. en t: 1 nursaay July ,

ms' Rights Act (CVRA), 18 U.S.C. § 3771, in connection with its handling of Epstein's NPA. Over the next few weeks, your Office stipulated that both Jane Doe 1 and Jane Doe 2 were "victims" of Epstein's crimes for purposes of this petition. For more than seven years now, litigation regarding the petition h

and your Office's legal position correctly, it rests on the case of In re Wellcare Health Plans, Inc., 754 F.3d 1234 (11'h Cir. 2014). In that case, Wellcare was formally charged via a criminal information with conspiracy to defraud Florida healthcare programs. It entered into a deferred prosecution agre

in this matter prior to the arrest or formal charge of a defendant for a federal offense. The government does not intend to introduce evidence as to Jane Doe No. 1 or Jane Doe No. 2's engaging in prostitution or referring underage girls to Epstein, for compensation, as a basis for divesting either Jane Do

0 Importance: Normal Embedded: RE:_Pending_Discovery_Requests_-_narrowed,_amended_discovery_request In light of the government's withdrawal of the Wellcare argument, petitioners withdrew the December 2 and December 29, 2015 requests for admissions. As to the two requests for production served on those s