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the Government (Bates 0001-04), court pleadings filed by the victims themselves or other victims, by Epstein, or by news media organizations (e.g., Bates 00142-88, 00229-31, 281-311, 00668-69), public court rulings on Epstein related matters (e.g., Bates 0008-10, 0012-14. 0036-86, 00190-228), public
cuments apply to which of the victims' document production requests. Instead, the Government has simply taken more than 13,000 pages of documents, Bates stamped them in no particular order (or at least no order that the victims can discern), and then asserted that they are all privileged for various
f Florida, the District of EFTA00179741 Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 44 of 64 New Jersey, and/or the District of Columbia. For this one discovery request only, please include all relevant grand jury transcripts and evidence collected by the grand jury. DEFINITIONS For
he privilege logs that the Government has produced that OPR generated a great deal of correspondence (at least 46 pages) regarding this request. See Bates P- 013909 to P-013955. Of course, improper influences being brought to bear on the Epstein prosecution would support the victims' allegations that t
f Florida, the District of EFTA00081158 Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 44 of 64 New Jersey, and/or the District of Columbia. For this one discovery request only, please include all relevant grand jury transcripts and evidence collected by the grand jury. DEFINITIONS For
he privilege logs that the Government has produced that OPR generated a great deal of correspondence (at least 46 pages) regarding this request. See Bates P- 013909 to P-013955. Of course, improper influences being brought to bear on the Epstein prosecution would support the victims' allegations that t
f Florida, the District of EFTA00208650 Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 44 of 64 New Jersey, and/or the District of Columbia. For this one discovery request only, please include all relevant grand jury transcripts and evidence collected by the grand jury. DEFINITIONS For
he privilege logs that the Government has produced that OPR generated a great deal of correspondence (at least 46 pages) regarding this request. See Bates P- 013909 to P-013955. Of course, improper influences being brought to bear on the Epstein prosecution would support the victims' allegations that t
f Florida, the District of EFTA00615911 Case 9:08-cv-80736-KAM Document 265-1 Entered on FLSD Docket 10/20/2014 Page 44 of 64 New Jersey, and/or the District of Columbia. For this one discovery request only, please include all relevant grand jury transcripts and evidence collected by the grand jury. DEFINITIONS For
tion Branch, U.S. Army Litigation Division where I oversaw FOIPA litigation for the U.S. Army. I am an attorney registered in the State of Ohio and the District of Columbia. (2) In my official capacity as Section Chief of RIDS, I supervise approximately 237 FBI employees, supported by approximately 91 contractors, who
Page: EFTA00015220 →processed prior to July 2019 consecutively as "03956-1 through 03956-11571." These records are referred to in this declaration collectively as the Bates-stamped or Bates-numbered records.' I On the pages released in full or in part, these " In contrast, records processed after July 2019 were not Bate
Page: EFTA00015232 →Entities connected to both Bates and the District of Columbia

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Prince Andrew
PERSONJeffrey Pagliuca
PERSON
Michael Cohen
PERSONSouthern District
LOCATION
Department of Justice
ORGANIZATION
Denver
LOCATION
Bradley Edwards
PERSONLeon Black
PERSON
George W. Bush
PERSON
Virginia Giuffre
PERSONMaria Farmer
PERSON
Donald Trump
PERSONthe Southern District
LOCATIONJane Doe
PERSON
Colorado
LOCATION
Scarlett Johansson
PERSON
Julie K. Brown
PERSON