Epstein Secrets

SERVICE LIST Jane Does 1 and 2'. United States, Case No. 08-80736-CIV-MARRA/MATTHEWMAN United States District Court, Southern District of Florida Brad Edwards, Esq., Farmer Jaffe Weissing Edwards Fistos Lehrman Paul G. Cassell S.J. I uinne olle e of Law at the Attorneys for Jane Doe # 1 and Jane Doe #

istrict Court, Southern District of Florida Brad Edwards, Esq., Farmer Jaffe Weissing Edwards Fistos Lehr

view, with e-mail from Lisa Howard to Ruth Plagenhoef (May 5, 2011, 11:08 a.m.), and Plagenhoef to Howard (May 5, 2011, 11:10 a.m.), and Howard to Plagenhoef (May 5, 2011, 10:41 a.m.), attached Deliberative Process Privilege Attorney Work Product Suppl. Box 3 P-013944 E-mail, Plagenhoef to Howard, M

2011, 11:19 a.m., RE: Re-write of Epstein letters for your review, with e-mail from Lisa Howard to Ruth Plagenhoef (May 5, 2011, 11:08 a.m.), and Plagenhoef to Howard (May 5, 2011, 11:10 a.m.), and Howard to Plagenhoef (May 5, 2011, 10:41 a.m.), attached Deliberative Process Privilege Attorney Work P

already entered a binding non-prosecution agreement with Jeffrey Epstein. The government is without 6 EFTA00191204 knowledge of precisely when "Bradley J. Edwards was working on a letter to the U.S. Attorney's Office concerning the need to federally prosecute Epstein for sex offenses committed against Jane Do

rally prosecute Epstein for sex offenses committed against Jane Doe #1 and Jane Doe #2," and, accordingly, the government denies the assertion that Edwards worked on that letter on July 3, 2008. Except as otherwise admitted above, the government denies Request No. 12. 13. (a) The government admits that

2011, 11:19 a.m., RE: Re-write of Epstein letters for your review, with c-mail from Lisa Howard to Ruth Plagenhoef (May 5, 2011, 11:08 a.m.), and Plagenhoef to Howard (May 5, 2011, 11:10 a.m.), and Howard to Plagenhoef (May 5, 2011, 10:41 a.m.), attached Deliberative Process Privilege Attorney Work P

view, with c-mail from Lisa Howard to Ruth Plagenhoef (May 5, 2011, 11:08 a.m.), and Plagenhoef to Howard (May 5, 2011, 11:10 a.m.), and Howard to Plagenhoef (May 5, 2011, 10:41 a.m.), attached Deliberative Process Privilege Attorney Work Product Suppl. Box 3 P-013944 E-mail, Plagenhoef to Howard, M

d JANE DOE No. 2 r. UNITED STATES AFFIDAVIT OF BRADLEY J. EDWARDS, ESQ. REGARDING NEED FOR PRODUCTION OF DOCUMENTS 1. I

ion of the materials at issue. DATED: August 16.2013 Respectfully Submitted, /s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 Flori

2011, 11:19 a.m., RE: Re-write of Epstein letters for your review, with e-mail from Lisa Howard to Ruth Plagenhoef (May 5, 2011, 11:08 am.), and Plagenhoef to Howard (May 5, 2011, 11:10 am.), and Howard to Plagenhoef (May 5, 2011, 10:41 a.m.), attached Deliberative Process Privilege Attorney Work P

Page 69 of 70 Bates Range Description Privilege(s) Asserted Victims' Objections Plagenhoef to Howard (May 5, 2011, 11:01 a.m.), and Howard to Plagenhoef (May 5, 2011,10:41), attached Suppl. Box 3 P-013945 E-mail, Plagenhoef to Howard, May 4, 2011, 5:01 p.m., RE: draft letters in Epstein matter,

t: RE: OPR complaint Hi Ruth, I'm just writing to see what the status is regarding the OPR inquiry that has been initiated into the Epstein matter. Brad Edwards and I would like to update our clients. Also, I am wondering if we can be helpful in providing any information to you in the inquiry. We know a lot

To: Plagenhoef, Ruth (OPR); (USAFLS) Cc: Brad Edwards Subject: RE: OPR inquiry - request for informati

Brad, We can talk today or tomorrow. I am in the office both days. Thanks. From: Paul Cassell [mailto: Sent: Wednesday, May 04, 2011 3:36 PM To: Plagenhoef, Ruth (OPR); (USAFLS) Cc: Brad Edwards Subject: RE: OPR inquiry - request for information - - when can chat? Ruth — Thanks. — When can we chat