Epstein Secrets

arie Villafafia Assistant U.S. Attorneys 500 S. Australian Ave., Suite 400 West Palm Beach, FL 33401 (561) 820-8711 Fax: (561) 820-8777 E-mail: Dexter.Lee0,usdoi.gov E-mail: Attorneys for the Government Roy Black, Esq. Jackie Perczek, Esq. Black, Srebnick, Komspan & Stumpf, P.A. 201 South Bisc

on the case (including, but not limited to, federal prosecutors Alexander Acosta, Jeffrey H. Sloman, Matt Menchel, Andy Lourie, Ann Marie Villafana, Dexter Lee, and Bruce Reinhart and state prosecutors Dahlia Weiss, Lana Belolovek, and others involved in the Epstein investigation) and defense attorneys rep

e victims were not properly notified about event during that investigation. 59. RFP No. 25 requests all initial productions that are required under the Federal Rules of Civil Procedure. This is a protective request to ensure that, should it be determined that the Civil Rules apply, they then receive all materials to whic

f 3 CERTIFICATE OF SERVICE I certify that the foregoing document was served on August 16, 2013, on the following using the Court's CM/ECF system: Dexter Lee A. Marie Villafafia 500 S. Australian Ave., Suite 400 West Palm Beach, FL 33401 (561) 820-8711 Fax: (561) 820-8777 E-mail: [email protected] E-

derpinnings; Fiduciary Duty; Claims Against Public Prosecutor, Overriding Need; Attorney Conduct at Issue Suppl. Box 3 P-013842 Email from Dexterr Lee . to Ruth Plagenhoef (OPR), February 25, 2011, 4:31 p.m., Re: request for OPR Investigation — Jeffrey Epstein Non- Prosecution Agreement

e victims were not properly notified about event during that investigation. 59. RFP No. 25 requests all initial productions that are required under the Federal Rules of Civil Procedure. This is a protective request to ensure that, should it be determined that the Civil Rules apply, they then receive all materials to whic

on the case (including, but not limited to, federal prosecutors Alexander Acosta, Jeffrey H. Sloman, Matt Menchel, Andy Lourie, Ann Marie Villafana, Dexter Lee, and Bruce Reinhart and state prosecutors Dahlia Weiss, Lana Belolovek, and others involved in the Epstein investigation) and defense attorneys rep

system: Dexter Lee A. Marie Villafafla 500 S. Australian Ave., Suite 400 West Palm Beach, FL 33401 (561) 820-8711 Fax: (561) 820-8777 E-mail: Dexter.Lec(e)usdoj.gov E-mail: [email protected] Attorneys for the Government Roy Black, Esq. Jackie Perczek, Esq. Black, Srebnick, Korns

ell). Id. The Court then noted: "Because the Court will allow this limited factual development, it is unnecessary to decide here whether the CVRA or the Federal Rules of Civil Procedure provide discovery rights in this context. The Court therefore reserves ruling on [the victims'] motion [for an order directing the Govern

ly incorporating it into a request for production. DATED: October 6, 2014 Respectfully submitted, WILFREDO A. FERRER UNITED STATES ATTORNEY By: DEXTER A. LEE Assistant U.S. Attorne Fla. Bar No. 99 N.E. 4th Street, Suite 300 ATTORNEY FOR RESPONDENT CERTIFICATE OF SERVICE I HEREBY CERTIFY that on Octob

initial disclosures required by the Federal Rules of Civil Procedure, including Rule 26(a)(1). Respondents object because the Court's finding that the Federal Rules of Civil Procedure "govern the general course of this proceeding," does not mean that all requirements governing 4 EFTA00705605 Case 9:08-cv-80736-KAM Do

tion. Respectfully submitted, WIFREDO A. FERRER UNITED STATES ATTORNEY By: s/A. Marie Villafaiia A. MARIE VILLAFAIZIA Florida Bar No. 0018255 DEXTER A. LEE Assistant U.S. Attorney Fla. Bar No. 0936693 99 N.E. Street Miami, Florida 33132 Attorney for Respondent 6 EFTA00601813 Case 9:08-cv-80736-

." As the Court acknowledged, this is not a civil case, it is a proceeding under the CVRA, which is meant to accompany criminal litigation. As such, the Federal Rules of Civil Procedure do not apply, including the disclosure rules at Fed. R. Civ. P. 26.2 The third request, for all documents distributed to persons outside

uction. Respectfully submitted, WIFREDO A. FERRER UNITED STATES ATTORNEY By: s/A. Marie Villafaiia A. MARIE VILLAFARA Florida Bar No. 0018255 DEXTER A. LEE Assistant U.S. Attorney Fla. Bar No. 0936693 99 N.E. 4th Street Miami, Florida 33132 (305) 961-9320 Fax: (305) 530-7139 E-mail: dexter.lee@usd

." As the Court acknowledged, this is not a civil case, it is a proceeding under the CVRA, which is meant to accompany criminal litigation. As such, the Federal Rules of Civil Procedure do not apply, including the disclosure rules at Fed. R. Civ. P. 26.2 The third request, for all documents distributed to persons outside

O HAC VICE. For United States of America, Respondent: Ann Marie C. Villafana, LEAD ATTORNEY, United States Attorney's Office, West Palm Beach. FL; Dexter Lee, LEAD ATTORNEY, United States Attorney's Office, Miami, FL. For Roy Black, Intervenor: Jacqueline Perczek, Roy Eric Black, Black Srebnick Kornspan

76 2015 U.S. Dist. LEXIS 87203, * already served their Rule 26(a)(1) disclosures (DE 266 at 13), and although this Court has repeatedly held that the Federal Rules of Civil Procedure "govern the general course of this proceeding," the Government maintains that the rule governing initial disclosures in civil litigation

ge From: (USAFLS) Imailt Sent: Wednesday, February 11, 2015 8:49 AM To: Roy Black Subject: Re: Your phone call Hi Roy. Thanks for your message. Dexter wants to participate in the call so it is helpful to have a roadmap of the discussion points. We will call your office at 2:00. If there is a better

orcement proceeding because it is not a "civil action" against the Government. To be sure, this Court has determined that convenience dictates that the Federal Rules of Civil Procedure "govern the general course of this proceeding." See DE 257 at 3. But that procedural determination does not alter the substance of this ca

rra, pursuant to Notice, taken before Victoria Aiello, Court Reporter, pages 1-32. For the Plaintiff: Bradley Edwards, Esquire For the Defendant: Dexter Lee, AUSA , AUSA OFFICIAL REPORTING SERVICES, LLC (954) 467-8204 EFTA00184732 Case 9:08-cv-80736-KAM Document 361-63 Entered on FLSD Docket 02/10/20

e victims were not properly notified about event during that investigation. 59. RFP No. 25 requests all initial productions that are required under the Federal Rules of Civil Procedure. This is a protective request to ensure that, should it be determined that the Civil Rules apply, they then receive all materials to whic

tr.if"'" • Case 9:08-cv-80736-KAM Docurnor450L1A w Eptyppeop FLSD Docket 03121/2011 Page 1 of 2 • aitadedataa% • AND ASSOCIATES October 9, 2008 Dexter Lee, AUSA United States Attorney's Office 99 N.E. 4th Street Miami, Florida 33132 Re: Jane Doe # and Jane Doe #2 United States of America Case No.

itioners. PETITIONERS HAVE NO RIGHT TO DISCOVERY UNDER THE FEDERAL RULES OF CIVIL PROCEDURE Petitioners argue they arc entitled to discovery under the Federal Rules of Civil Procedure, but they point to no particular rule, or case, which provides that such a discovery rights exists. Instead, petitioners seize upon the g