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

5 thru P-013989 6/14/2007-6/21/2007 emails between 6(e) Work Product Deliberative Process Investigative Privilege and regarding addendum to Pros Memo, grand jury presentation and changes to indictment, and meetin with counsel for E stein P-013990 thru P-013991 6/26/2007 email from to , Work

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 EFTA00211411 Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page 1 of 18 JANE DOE v. UNITED STAT

P-013989 6/14/2007-6/21/2007 emails between Marie Villafafia, Karen Atkinson, Andrew Lourie, Matt Menchel, and Jeff Sloman regarding addendum to Pros Memo, grand jury presentation and changes to indictment, and meeting with counsel for Epstein 6(e) Work Product Deliberative Process Investigative Pr

ile folder with signed sealed Orders, and light green file folder with Exhibits to Motion to Unseal Grand Jury Materials notes, White binder with Jane Doe 1 and Jane Doe 2's Consolidated Statement of Undisputed Material Facts and Motion for Partial Summary Judgment with Incorporated Memorandum of Law Bo

Wexner (file folder) Kastigar Letters (file folder) 2703 Motion & Order-Cingular (red file folder) Grand Jury Transcripts (redwell) with folders Pros Memo (file folder) labeled Duplicate Proposed Jury Instructions for Violations of 18 USC 2423(b) (Travel in Interstate or Foreign Commerce to Engage in

JD#2 was 14 when she was brought to JE's home in 2001. JD#1 told JD#2 that she could make $300 for giving a massage to a man in Palm Beach. JD# 1 2 Jane Doe #1 was brought to JE's home by Ghislainc Maxwell after Maxwell met her at Mar a Lago. Jane Doe #1 was 15 at the time of her first contact with JE an

sage" for Epstein, but she did recruit two other girls. One has not yet been interviewed, and the other iffillffirwho was discussed in the original Pros Memo. Becauslaterformed only one massage and remained fully clothed, I have not charged 9 EFTA00234513 any substantive offenses related to her, but I

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

ocess 47 6/14/2007-6/21/2007 emails between Marie Viilafalla, Karen Atkinson, Andrew Lourie, Matt Menchel, and Jeff Sloman regarding addendum to Pros Memo, grand jury presentation and changes to indictment, and meeting with counsel for Epstein 6(e) Work Product Deliberative Process Investigative P

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 SDNY_GM_02742819 EFTA_00229468 EFTA01325032 Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page

P-013989 6/14/2007-6/21/2007 emails between Marie Villafafia, Karen Atkinson, Andrew Lourie, Matt Menchel, and Jeff Sloman regarding addendum to Pros Memo, grand jury presentation and changes to indictment, and meeting with counsel for Epstein 6(e) Work Product Deliberative Process Investigative Pr

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 SDNY_GM_02742859 EFTA_00229508 EFTA01325052 Case 9:08-cv-80736-KAM Document 329-1 Entered on FLSD Docket 06/23/2015 Page

P-013989 6/14/2007-6/21/2007 emails between Marie Villafafia, Karen Atkinson, Andrew Lourie, Matt Menchel, and Jeff Sloman regarding addendum to Pros Memo, grand jury presentation and changes to indictment, and meeting with counsel for Epstein 6(e) Work Product Deliberative Process Investigative Pr

ect: Addendum to Pros Memo Hi all — I have attached hereto an addendum to the Pros Memo ad ing some of the • ' • cems that you raised regarding Jane Doe #6. I have not sent this directly to the book containing the pros memo and the attachments. li , but I would ask add it to On another note, we ha

From: Sent: u ay, June 14, 2007 2:14 PM To: Subject: Addendum to Pros Memo Hi all — I have attached hereto an addendum to the Pros Memo ad ing some of the • ' • cems that you raised regarding Jane Doe #6. I have not sen

m trash pulls, the flight manifests from Epstein's private lanes, and testimony from the girls about how the appointments were made. So, if called Jane Doe ake an appointment on January 1st; Epstein traveled to Florida on January 2nd; and Weaned Jane Doe #12 on 18 EFTA02857620 January 3rd (when they wer

JD#2 was 14 when she was brought to JE's home in 2001. JD#1 told JD#2 that she could make $300 for giving a massage to a man in Palm Beach. JD#1 2 Jane Doc #1 was brought to JE's home by Ghislaine Maxwell after Maxwell met her at Mar a Lago. Jane Doe #1 was 15 at the time of her first contact with JE an

er "massage" for Epstein, but she did recruit two other girls. One has not yet been interviewed, and the other i aho was discussed in the original Pros Memo. BecausMerformed only one massage and remained fully clothed, I have not charged 9 EFTA02857664 any substantive offenses related to her, but I h