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ney General or any office under his direction.'" Id. at *2 (quoting 18 U.S.C. § 3771(d)(6)). For these reasons, the Court should deny the motion of Jane Doe 1 and Jane Doe 2 to discover and use the plea negotiation letters as evidence. PART II MR. EPSTEIN'S PLEA NEGOTIATIONS ARE PRIVILEGED AND NOT DISCO
residence in Palm ne. Once at the 7 entered the room he robe, both e. Both ANDRIANO only in their :e alone with WILD, dole. After _eved that ANDRIANO the massage but she EPSTEIN paid WILD Prior to departing the residence, WILD provided her telephone number to one of EPSTEIN's assistants, ELEJAN
that worked for EPSTEIN. They drove WILD to a Shell Gas Station located near Okeechobee Boulevard and the Florida Turnpike. and taller. The R). ANDRIANO told y could make money by WILD that she could E. WILD, who was to turning sixteen :LD's first contact rued eighteen. s residence in Palm ne.
of a federal case, but I don't recall discussing that at the time. 35 I had never before used a non-prosecution 34 As I noted in my filings in the Jane Doe' United States litigation, I had concerns about informing the victims that part of the negotiations involved securing for them the right to obtain d
AND SHALL NOT BE DISCLOSED EXCEPT IN CONNECTION WITH A LEGAL PROCEEDING. EFTA00225554 RICHARD WILLITS, ESQ. NCYFIFICATION OF IDENTIFIED VICTIM ANDRIANO JULY 10, 2008 PAGE 2 OF 2 of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom
EY EPSTEIN, by and through his undersigned counsel, moves this Court for an extension of time until August 21, 2009, to file Responses to Plaintiff Jane Doe's Motions to Compel Responses to Request to Produce, Answers to Request for Admissions, and Answers to Interrogatories, pursuant to Local Rule 7.1 A.1
NO.: 08-80993-CIV-MARRA/JOHNSON JANE DOE NO. 7, Plaintiff, JEFFREY EPSTEIN Defendant. CAROLYN MARGARET CASE NO.: 08-80811-CI V-MA RRAtIOIINSON ANDRIANO, Plaintiff, JEFFREY EPSTEIN Defendant. EFTA00599374 JANE DOE, CASE NO.: 08-80893-CIV-MARRA/JOHNSON Plaintiff, JEFFREY EPSTEIN et al, Defend
Entities connected to both Jane Doe and ANDRIANO

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSONJack Goldberger
PERSON
United States
LOCATION
Alan Dershowitz
PERSON
George W. Bush
PERSONLeon Black
PERSON
A. Marie Villafana
PERSONRobert C. Josefsberg
PERSONRichard Horace Willits
PERSON
Virginia Giuffre
PERSONRoy Black
PERSONFBI
ORGANIZATION
Lake Worth
LOCATION
Palm Beach Gardens
LOCATIONFlorida Bar
ORGANIZATION
Harvey Weinstein
PERSONHerman
PERSON
Michael Jackson
PERSON