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

ween A. AS , E. , and regarding 7/21/2008 letter from M. Tein announcing plan to stay the civil suits against J. Epstein and notification that B. Reinhart is counsel of record for S. in civil suits (NB: Tein letter is being produced to petitioners' counsel concurrently with production of this privil

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 EFTA00211431 Case 9:08-cv-80736-KAM Document 338-1 Entered on FLSD Docket 08/03/2015 Page 1 of 7 JANE DOE v. UNITED STATE

yrkendall, and J. Richards regarding 7/21/2008 letter from M. Tein announcing plan to stay the civil suits against J. Epstein and notification that B. Reinhart is counsel of record for S. Kellen in civil suits (NB: Tein letter is being produced to petitioners' counsel concurrently with production of this

ea and Villafafia email to Leflcowitz re same B l') 6/23/2008 Villafafia, Kuyrkendall, Richards, cc: Atkinson Senior Email regarding New York Jane Doe and awaiting a response from DAG's office 6/23/2008 Emails between A. Marie Villafaiia, E. Nesbitt Kuyrkendall, J. Richards, K. Atkinson, and R.

yrkendall, and J. Richards regarding 7/21/2008 letter from M. Tein announcing plan to stay the civil suits against J. Epstein and notification that B. Reinhart is counesl of record for S. Kellen in civil suits 7/23/2008 Emails between A. M. Villafana and D. Lee regarding correspondence with counsel for J.

/2008 emails between A.M. Villafafia, J. Sloman, D. Lee, A. Acosta, K. Atkinson. K. Herd, K. Neal, K. Manning, and W. Jacobus regarding response to Jane Doe suit, procedure for filing, and internal office policies Work Product Deliberative Process P-015063 thru P-015069 7/11/2008-7/14/2008 emails b

rkendall, and J. Richards regarding 7/2112008 letter from M. Tein announcing plan to stay the civil suits against .1. Epstein and notification that B. Reinhart is counsel of record for S. Kellen in civil suits (NB: Tein letter is being produced to petitioners' counsel concurrently with production of this

Department's Office of Professional Responsibility (OPR) arising out of a decision by United States District Judge Kenneth A. Marra in the matter of Jane Doe 1 and Jane Doe 2I United States, S.D. Fla. Case No. 08-80736-Civ-Marra; (3) the materials are needed to avoid an injustice in another proceeding, th

yrkendall, and J. Richards regarding 7/21/2008 letter from M. Tein announcing plan to stay the civil suits against J. Epstein and notification that B. Reinhart is counts! of record for S. Kellen in civil suits 7/23/2008 Emails between A. M. Villafaria and D. Lee regarding correspondence with counsel for].