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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
.' As a fourth and final illustration, the victims requested information about why the U.S. Attorney's Office for the Southern District of Florida (USAO-SDFL) was "conflicted out" of considering issues relating to the Epstein matter, as well as any information that developed about that conflict after the
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
d.6 As a fourth and final illustration, the victims requested information about why the U.S. Attorney's Office for the Southern District of Florida (USAO-SDFL) was "conflicted out" of considering issues relating to the Epstein matter, as well as any information that developed about that conflict after the
are not aware of any authority requiring us to obtain and/or disclose this information. Request 11 — A Complete, Unredacted Copy of FBI 302 Bearing Bates Numbers SDNY_GM_00114982-00114993: The Government has produced this particular version of the document in the form in which it received the documen
Page: EFTA00030573 →estigation and prosecution of Jeffrey Epstein, as set forth in greater detail in that letter, the Government intends to gather certain martials from USAO-SDFL and conduct targeted searches of that material aimed at identifying potential Giglio or 3500 material for victims or witnesses relevant to this pro
Page: EFTA00030573 →Entities connected to both Bates and USAO-SDFL

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONJeffrey Pagliuca
PERSON
Prince Andrew
PERSONLaura Menninger
PERSON
Denver
LOCATION
Michael Cohen
PERSON
Bradley Edwards
PERSON
United States
LOCATIONJane Doe
PERSONthe Southern District
LOCATION
Paul Cassell
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSON
Kenneth Marra
PERSONFBI
ORGANIZATION
Christian Everdell
PERSONLeon Black
PERSON
Scarlett Johansson
PERSON
George W. Bush
PERSON