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esented (Epstein's number one co-conspirator who was actually named as such in the NPA), his housekeeper his pilots Larry Morrison, Larry Visoski, David Rogers, William Hammond and Robert Roxburgh. (Hammond and Roxburgh were not deposed, but the others were.) See depositions of these individuals in various
t the Government to produce all evidence that it possesses supporting these facts, for reasons the victims explain in their contemporaneously-filed Jane Doe NI and Jane Doe #2's Motion for Order Directing the U.S. Attorney's Office Not to Withhold Relevant Evidence. 3 EFTA00210792 Case 9:08-cv-80736-KAM
nted (Epstein's number one co-conspirator who was actually named as such in the NPA), his housekeeper •, his pilots Larry Morrison, Larry Visoski, David Rogers, William Hammond and Robert Roxburgh. (Hammond and Roxburgh were not deposed, but the others were.) See depositions of these individuals in various
at 234-37; Tr. July 11, 2008, 18-19, 22-23, 28- 29? 21. In October 2007, shortly after the initial plea agreement was signed, FBI agents contacted Jane Doe NI. On October 26, 2007, Special Agents and met in person with Jane Doe #1. The Special Agents explained that Epstein would 3 On about August 14, 200
's number one co-conspirator who was actually named as such in the NPA), his housekeeper (LoneIla Ruboyo), his pilots Larry Morrison, Larry Visoski, David Rogers, William Hammond and Robert Roxburgh. (Hammond and Roxburgh were not deposed, but the others were.) See depositions of these individuals in various
that the plea agreement made it impossible to prosecute Epstein federally for his crimes against them, they would have objected to this resolution. Jane Doe NI and Jane Doe #2 thus detrimentally relied on the inaccurate representations of the U.S. Attorney's Office that their cases were still under investi
s number one co-conspirator who was actually named as such in the NPA), his housekeeper (Louel la Ruboyo), his pilots Larry Morrison, Larry Visoski, David Rogers, William Hammond and Robert Roxburgh, (Hammond and Roxburgh were not deposed, but the others were.) See depositions of these individuals in various
ary 2008 and May 2008. At no time before reaching the non-prosecution agreement did the Justice Department notify any victims, including for example Jane Doe NI, about the non-prosecution agreement. The victims were therefore prevented from exercising their CVRA right to confer with prosecutors about the ca
Entities connected to both David Rodgers and Jane Doe NI

Jeffrey Epstein
PERSONLarry Visoski
PERSON
Ghislaine Maxwell
PERSON
Lesley Groff
PERSONLeon Black
PERSON
Marc Rich
PERSON
Alan Dershowitz
PERSON
United States
LOCATION
George W. Bush
PERSON
Bradley Edwards
PERSONLarry Harrison
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSON
Virginia Giuffre
PERSON
Scarlett Johansson
PERSONJack Goldberger
PERSONFBI
ORGANIZATION
Jean-Luc Brunel
PERSON
Paul Cassell
PERSONthe Southern District
LOCATION