Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 31 of 51 2:008777-008808 Protected from discovery by grand jury secrecy and opinion work product privilege. 2:008809-008847 Protected from discovery by grand jury secrecy and opinion work product privilege. 2:008848-008862 Protected from discovery by grand jury secrecy and opinion work product privilege. 2:008863-008890 Protected from discovery by grand jury secrecy and opinion work product privilege. 2:009104-009111 Protected from discovery by opinion work product privilege. 2:009126-008134 Protected from discovery by grand jury secrecy and opinion work product privilege. 2:009135-009141 Protected from discovery by grand jury secrecy and opinion work product privilege. 2:009141A-00914 1C Protected from discovery by grand jury secrecy and opinion work product privilege. 2:009142-009152 Protected from discovery by grand jury secrecy and opinion work product privilege. 2:009153-009156 Protected from discovery by grand jury secrecy and opinion work product privilege. 2:009157-009208 Protected from discovery by grand jury secrecy and opinion work product privilege. 2:009209-009213 Protected from discovery by grand jury secrecy and opinion work product privilege. 2:009214-009271 Protected from discovery by grand jury secrecy and opinion work product privilege. 2:009272-009354 Protected from discovery by opinion work product privilege. 2:009355-009403 Protected from discovery by opinion work product privilege. 2:009404-009536 Protected from discovery by opinion work product privilege. 2:009537-009574 Protected from discovery by opinion work product privilege. 2:009575-009603 Protected from discovery by opinion work product privilege. 2:009604-009711 Protected from discovery by opinion work product privilege. 31 EFTA00086475
Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 32 of 51 2:009820-009965 Protected from discovery by opinion work product privilege. 2:009966-010096 Protected from discovery by grand jury secrecy and opinion work product privilege. 2:010097-010276 Protected from discovery by opinion work product privilege. 2:010277-010394 Protected from discovery by opinion work product privilege. 2:010395-010488 Protected from discovery by opinion work product privilege. 2:010489-010509 Protected from discovery by opinion work product privilege. 2:010510-010525 Protected from discovery by opinion work product privilege. 2:010526-010641 Protected from discovery by opinion work product privilege, The correspondence between the Government and Epstein's counsel is not privileged and should be produced. The Government must certify that it has been produced. 2:010642-010650 Protected from discovery by opinion work product privilege. 2:010651-010659 Protected from discovery by grand jury secrecy and opinion work product privilege. 2:010660-010757 Protected from discovery by grand jury secrecy and opinion work product privilege. 2:010758-010793 Protected from discovery by opinion work product privilege. 2:010794-010829 Protected from discovery by opinion work product privilege. 2:010830-010853 Protected from discovery by opinion work product privilege. 2:010854-010876 Protected from discovery by opinion work product privilege. 2:010877-010920 Protected from discovery by opinion work product privilege. 2:010921-011049 Protected from discovery by opinion work product privilege. 32 EFTA00086476
Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 33 of 51 2:011050-011212 Protected from discovery by opinion work product privilege. 2:011213-011237 Protected from discovery by opinion work product privilege. 2:011238-011319 Protected from discovery by opinion work product privilege. 2:011320-011361 Protected from discovery by opinion work product privilege. 2:011362-011374 Protected from discovery by opinion work product privilege. 2:011375-011456 Protected from discovery by opinion work product privilege. 2:011457-011626 Protected from discovery by opinion work product privilege. 3:011627-011662 Protected from discovery by opinion work product privilege. 3:011663-012361 Protected from discovery by grand jury secrecy and opinion work product privilege. 3:011699-011777 Protected from discovery by grand jury secrecy and opinion work product privilege. 3:011778-011788 Produce victim identities. Document does not exhibit the mental impressions of counsel but rather the cumulation of facts. Petitioners should be provided with the victim identities under an appropriate protective order. 3:011789-011879 Protected from discovery by opinion work product privilege. 3:011880-011922 Protected from discovery by opinion work product privilege. 3:011923-011966 Protected from discovery by opinion work product privilege. The underlying correspondence between Government and Epstein's counsel should be produced without attorney annotations. The Government must certify that Petitioners have this correspondence. 3:011967-012016 Protected from discovery by opinion work product privilege. 33 EFTA00086477
Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 34 of 51 3:01217-012055 Protected from discovery by grand jury secrecy. 3:012056-012088 Protected from discovery by grand jury secrecy. ' 3:012089-012129 Protected from discovery by grand jury secrecy. 3:012130-012150 Protected from discovery by grand jury secrecy. 3:012151-012167 Protected from discovery by grand jury secrecy. 3:012168-012170 Protected from discovery by grand jury secrecy. 3:012171-012173 Protected from discovery by grand jury secrecy. 3:012174-012176 Protected from discovery by opinion work product privilege. Final versions of sent correspondence should be produced. The Government must certify whether Petitioners have any sent version of this correspondence. 3:012177-012178 Protected from discovery by opinion work product privilege. 3:012179-012188 Protected from discovery by grand jury secrecy and opinion work product privilege. 3:012362-012451 Protected from discovery by grand jury secrecy and opinion work product privilege. 3:012451-012452 Produce victim identities. Document does not exhibit the mental impressions of counsel but rather the cumulation of facts. Petitioners' need outweighs investigative privilege. Petitioners should be provided with the victim identities under an appropriate protective order. 3:012453-012623 Protected from discovery by grand jury secrecy and opinion work product privilege. 3:012624-012653 Production not necessary; documents are not relevant or likely to lead to the discovery of materials relevant to this CVRA litigation. The Court has reviewed the content of the FBI "302's," which are forms prepared by FBI agents to document interviews. These interview reports summarize the various victims' interactions with Epstein, and do not indicate a conveyance of information from the FBI to the victims regarding the likelihood of prosecution. 34 EFTA00086478
Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 35 of 51 3:012654-012864 Protected from discovery by opinion work product privilege. 3:012865-013226 Protected from discovery by grand jury secrecy and opinion work product privilege. 3:013227 Production not necessary; not relevant or likely to lead to the discovery of materials relevant to this CVRA litigation. Involves OPR investigation into Epstein's allegation that certain prosecutors had conflicts of interest. Not relevant to victims' CVRA rights. 3:013228-013230 Production not necessary; not relevant or likely to lead to the discovery of materials relevant to this CVRA litigation. Involves OPR investigation into Epstein's allegation that certain prosecutors had conflicts of interest. Not relevant to victims' CVRA rights. 3:013231-013239 Production not necessary; not relevant or likely to lead to the discovery of materials relevant to this CVRA litigation. Involves OPR investigation into Epstein's allegation that certain prosecutors had conflicts of interest. Not relevant to victims' CVRA rights. 3:013240 -O13247 Production not necessary; not relevant or likely to lead to the discovery of materials relevant to this CVRA litigation. Involves OPR investigation into Epstein's allegation that certain prosecutors had conflicts of interest. Not relevant to victims' CVRA rights. 3:013248-013251 Protected from disclosure by the attorney-client privilege; also not relevant or likely to lead to the discovery of materials relevant to this CVRA litigation. 3:013252-013253 Protected from disclosure by the attorney—client privilege; also not relevant or likely to lead to the discovery of materials relevant to this CVRA litigation. 3:013254-013257 Protected from disclosure by the attorney—client privilege; also not relevant or likely to lead to the discovery of materials relevant to this CVRA litigation. 3:013258-013259 Protected from disclosure by the attorney-client privilege; also not relevant or likely to lead to the discovery of materials relevant to this CVRA litigation. 3:013260-013262 Protected from disclosure by the attorney-client privilege; also not relevant or likely to lead to the discovery of materials relevant to this CVRA litigation. 35 EFTA00086479
Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 36 of 51 3:013263-013271 Protected from discovery by attorney-client and opinion work product privilege; also not relevant or likely to lead to the discovery of materials relevant to this CVRA litigation. 3:013272-013278 Protected from disclosure by the attorney—client privilege; also not relevant or likely to lead to the discovery of materials relevant to this CVRA litigation. S:013279 013280 Protected from discovery by opinion work product privilege. S:013281 Protected from discovery by opinion work product privilege. S:013282-013283 Protected from discovery by opinion work product privilege. S:013284 Protected from discovery by opinion work product privilege. S:013285-013289 Protected from discovery by opinion work product privilege. S:013290-013292 Protected from discovery by opinion work product privilege. 8:013293-013299 Protected from discovery by opinion work product privilege. The portions of this correspondence between the Government and Epstein's counsel should be produced. The Government must certify that Petitioners have been provided with these outside correspondences. S:013300-013303 Protected from discovery by opinion work product privilege. 5:013304-013325 Protected from discovery by opinion work product privilege. 8:013326-013329 Protected from discovery by opinion work product privilege. S:013330-013333 Protected from discovery by opinion work product privilege. S:013334-013337 Protected from discovery by opinion work product privilege. 36 EFTA00086480
Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 37 of 51 5:013342-013350 Protected from discovery by opinion work product privilege. The underlying correspondence between Epstein's counsel and the Government should be produced without attorney annotations. The Government must certify that Petitioners have been provided with these outside correspondences. S:013351-013361 Protected from discovery by opinion work product privilege. The underlying correspondence between Epstein's counsel and the Government should be produced without attorney annotations. The Government must certify that Petitioners have been provided with these outside correspondences. S:013362-013366 Protected from discovery by opinion work product privilege. Any version of the letter actually sent to Epstein's counsel should be produced. Government must certify whether it has been produced. S:013367-013372 Protected from discovery by opinion work product privilege. Any version of the letter actually sent to Epstein's counsel should be produced. Government must certify whether it has been produced. S:013373-013503 Protected from discovery by opinion work product privilege. S:013504-013507 Protected from discovery by opinion work product privilege. S:013508-013514 Partially protected from discovery by opinion work product privilege. Only the top portion of P- 013509 contains materials internal to the Government—a one-sentence email between two United States Attorneys. The Government must certify that Petitioners have the remainder of P-013509 and P- 013510-013514, as these communications are between the Government and Epstein's counsel. 37 EFTA00086481
Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 38 of 51 $:013515-013525 Protected from discovery by opinion work product privilege. Any final version of the letter actually sent to Epstein's counsel should be produced. Government must certify whether it has been produced. S:013526-013527 Protected from discovery by opinion work product privilege. S:013528-013530, 013532-013537 Protected from discovery by opinion work product privilege. S:013531 Protected from discovery by grand jury secrecy. S:013538-013553 Protected from discovery by opinion work product privilege. S:013554-013608 Protected from discovery by opinion work product privilege. S:013609-013615 Protected from discovery by grand jury secrecy. S:013616-013621 Protected from discovery by opinion work product privilege. S:013622-013643 Protected from discovery by opinion work product privilege. S:013644-013653 Protected from discovery by opinion work product privilege. S:013654-013745 Protected from discovery by opinion work product privilege. S:013747-013810 Protected from discovery by opinion work product privilege. S:013811-013833 Protected from discovery by opinion work product privilege. S:013834-013835 Protected from discovery by opinion work product privilege. S:013836-013837 Protected from discovery by opinion work product privilege. S:013838-013841 Protected from discovery by opinion work product privilege; also not relevant material or likely to lead to discovery of material relevant to the instant CVRA litigation. The underlying correspondence between Epstein's counsel and the Government should be produced without attorney annotations. The Government must certify that Petitioners have been provided with these outside correspondences. 38 EFTA00086482
Case 9:08-cv-80736-KAM Document 330 Entered on PLSD Docket 07/06/2015 Page 39 of 51 S:013842 Protected from discovery by opinion work product privilege; also not relevant material or likely to lead to discovery of material relevant to the instant CVRA litigation. S:013843-013844 Protected from discovery by opinion work product privilege. 3:013845-013846 Protected from discovery by opinion work product privilege. S:013847-013849 Protected from discovery by opinion work product privilege. S:013850 Protected from discovery by opinion work product privilege. S:013851-013853 Protected from discovery by opinion work product privilege. S:013854 Protected from discovery by opinion work product privilege. S:013855 Protected from discovery by opinion work product privilege. S:013856-013857 Protected from discovery by opinion work product privilege. S:013858 Protected from discovery by opinion work product privilege. 3:013861-013865 Protected from discovery by opinion work product privilege. S:013866 Protected from discovery by opinion work product privilege. 5:013867-O13868 Protected from discovery by opinion work product privilege. S:013869 Protected from discovery by opinion work product privilege. S:013870-013871 Produce; not protected from discovery by any privilege. Only the top portion of the email chain contains correspondence internal to the Government, and this does not divulge any mental impressions or legal theories. The rest of the email chain is between the Government and Epstein's counsel. It should be produced. 39 EFTA00086483
Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 40 of 51 S:013872 Protected from discovery by opinion work product privilege. Besides internal Government correspondence, contains one email correspondence between the Government and Epstein's counsel, which will be produced at P-013870-013871. S:013873 Protected from discovery by opinion work product privilege. S:013876-013877 Partially protected from discovery by opinion work product privilege. The email correspondence at P—013877 is between the Government and Epstein's counsel, and not privileged. The Government must certify that Petitioners have been provided with these outside correspondences. S:013878-013879 Protected from discovery by opinion work product privilege. S:013880-013882 Partially protected from discovery by opinion work product privilege. Only the top two email correspondences are internal to the Government. The remaining emails, starting at the bottom of P-013880 and running through P-013882, are between the Government and Epstein's counsel, and should be produced. The Government must certify that Petitioners have been provided with these outside correspondences. S:013883 Protected from discovery by opinion work product privilege. S:013884-013886 Protected from discovery by opinion work product privilege. 5:013887 Protected from discovery by opinion work product privilege. S:013888 Protected from discovery by opinion work product privilege. S:013889-013890 Protected from discovery by opinion work product privilege. S:013891 Protected from discovery by opinion work product privilege. 40 EFTA00086484
Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 41 of 51 S:013894-013898 Protected from discovery by opinion work product privilege. S:013899 Protected from discovery by opinion work product privilege. 5:013900-013901 Protected from discovery by opinion work product privilege. S:013902 Protected from discovery by opinion work product privilege. S:013903-013904 Identical to the email chain at S:013870-013871, and should likewise be disclosed. S:013905 Partially protected from discovery by opinion work product privilege. Email correspondence at bottom of page between Government and Epstein's counsel should be produced. The Government must certify that Petitioners have been provided with these outside correspondences. 5:013906 Protected from discovery by opinion work product privilege. S:013909-013911 Not relevant or likely to lead to material relevant to the instant CVRA litigation. 5:013912-013914 Not relevant or likely to lead to material relevant to the instant CVRA litigation. S:013915-013918 Not relevant or likely to lead to material relevant to the instant CVRA litigation. S:013919-013921 Not relevant or likely to lead to material relevant to the instant CVRA litigation. S:013922-013924 Not relevant or likely to lead to material relevant to the instant CVRA litigation. S:013925-013927 Not relevant or likely to lead to material relevant to the instant CVRA litigation. The final version of this letter, which is addressed to Petitioners' counsel, should be available to Petitioners. S:013928-013930 Not relevant or likely to lead to material relevant to the instant CVRA litigation. The final version of this letter, which is addressed to Petitioners' counsel, should be available to Petitioners. 41 EFTA00086485
Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 42 of 51 S:013931-013933 Not relevant or likely to lead to material relevant to the instant CVRA litigation. The final version of this letter, which is addressed to Petitioners' counsel, should be available to Petitioners. S:013934-013936 Not relevant or likely to lead to material relevant to the instant CVRA litigation. S:013937-013939 Not relevant or likely to lead to material relevant to the instant CVRA litigation. The final version of this letter, which is addressed to Petitioners' counsel, should be available to Petitioners. S:013940-013942 Not relevant or likely to lead to material relevant to the instant CVRA litigation. S:013943 Not relevant or likely to lead to material relevant to the instant CVRA litigation. S:013944 Not relevant or likely to lead to material relevant to the instant CVRA litigation. S:013945 Not relevant or likely to lead to material relevant to the instant CVRA litigation. S:013946 Not relevant or likely to lead to material relevant to the instant CVRA litigation. 5:013947 Not relevant or likely to lead to material relevant to the instant CVRA litigation. S:013948-013951 Not relevant or likely to lead to material relevant to the instant CVRA litigation. S:013952-013953 Not relevant or likely to lead to material relevant to the instant CVRA litigation. S:013954-013955 Not relevant or likely to lead to material relevant to the instant CVRA litigation. S:013956-013969 Protected from discovery by opinion work product privilege. S:'13970-13971 Protected from discovery by opinion work product privilege; also, not relevant or likely to lead to material relevant to this CVRA litigation. S:13972 Protected from discovery by opinion work product privilege. S:13973-13976 Protected from discovery by opinion work product privilege. The Government's Second Supplemental Privilege Log begins here. (DE 329-1). 42 EFTA00086486
Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 43 of 51 S:13977-13979 Protected from discovery by opinion work product privilege. S:13980 Protected from discovery by opinion work product privilege. S:I3981 Protected from discovery by opinion work product privilege. S:13982 Protected from discovery by opinion work product privilege. S:I3983-13984 Protected from discovery by opinion work product privilege. S:13985-13989 Protected from discovery by opinion work product privilege. S:13990-I 3991 Protected from discovery by opinion work product privilege. S:13992-13994 Protected from discovery by opinion work product privilege. S:13995-14010 Protected from discovery by opinion work product privilege; also, not relevant or likely to lead to material relevant to this CVRA litigation. S:S:14011-14025 Protected from discovery by opinion work product privilege. S:14026-14027 Protected from discovery by opinion work product privilege. S:14028-14030 Protected from discovery by opinion work product privilege. S:14031-01432 Protected from discovery by opinion work product privilege. S:14033 Protected from discovery by opinion work product privilege. S: 14034 Protected from discovery by opinion work product privilege. S: 14035 Protected from discovery by opinion work product privilege. S: 14036 Protected from discovery by opinion work product privilege. S:14037 Protected from discovery by opinion work product privilege. 43 EFTA00086487
Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 44 of 51 S:14038-14041 Protected from discovery by opinion work product privilege. 5:14042 Protected from discovery by opinion work product privilege. S:14043-14044 Protected from discovery by opinion work product privilege. 5:14045-14046 Protected from discovery by opinion work product privilege. 5:14047 Protected from discovery by opinion work product privilege. 5:14048 Protected from discovery by opinion work product privilege. 5:14049-14050 Protected from discovery by opinion work product privilege. 5:14051 Protected from discovery by opinion work product privilege. 5:14052 Protected from discovery by opinion work product privilege. 5:14053 Protected from discovery by opinion work product privilege. S:14054 Protected from discovery by opinion work product privilege. 5:14055 Protected from discovery by opinion work product privilege. 5:14056 Protected from discovery by opinion work product privilege. S:14057 Protected from discovery by opinion work product privilege. 5:14058 Protected from discovery by opinion work product privilege. S:14059-1406I Protected from discovery by opinion work product privilege. S:14062-14068 Protected from discovery by opinion work product privilege. S:14069 Protected from discovery by opinion work product privilege. S:I4070-14074 Protected from discovery by opinion work product privilege. 44 EFTA00086488
Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 45 of 51 S:14075-14089 Protected from discovery by opinion work product privilege. S:14090-14102 Protected from discovery by opinion work product privilege. S:14103-14107 . Protected from discovery by opinion work product privilege. S:14108-14134 Protected from discovery by opinion work product privilege. S:14135-14149 Protected from discovery by opinion work product privilege. S:14150-14156 Protected from discovery by opinion work product privilege. 5:14157-15160 Protected from discovery by opinion work product privilege. 5:14161 Protected from discovery by opinion work product privilege. S:14162-14170 Protected from discovery by opinion work product privilege. S:14171-14174 Protected from discovery by opinion work product privilege. S:14175-14203 Protected from discovery by opinion work product privilege. S:14204-14205 Protected from discovery by opinion work product privilege. 8:14206-14216 Partially protected from discovery by opinion work product privilege. The portions of the email chain from Epstein's counsel are not privileged. The Government mast certify that this outside correspondence has been produced. S:I4217-14238 Partially protected from discovery by opinion work product privilege. The portions of the email chain from Epstein's counsel are not privileged. The Government must certify that this outside correspondence has been produced. 5:14239-14242 Protected from discovery by opinion work product privilege. S:14243.14251 Protected from discovery by opinion work product privilege. 45 EFTA00086489
Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 46 of 51 S:14252-14275 Partially protected from discovery by opinion work product privilege. The portions of the email chain from Epstein's counsel are not privileged. The Government must certify that this outside correspondence has been produced. 5:14276 Protected from discovery by opinion work product privilege. S:I4277-14282 Protected from discovery by opinion work product privilege. S:14283-14284 Protected from discovery by opinion work product privilege. S:I4285-14298 Protected from discovery by opinion work product privilege. S:14299-14307 Protected from discovery by opinion work product privilege. S:14308-14310 Protected from discovery by opinion work product privilege. S:14311-14329 L Partially protected from discovery by opinion work product privilege; outside correspondence and P- 014315-014316 must be produced. The Government must certify that the outside correspondence has been produced. The correspondence at P-014315- 014316 must be produced; this fact-based material is not opinion work product as it does not reveal the mental impressions of counsel, and the court finds that Petitioners have a compelling need for the information contained therein. This need also outweighs any deliberative-process privilege that may apply. It not protected by the attorney-client privilege, as the Government has not demonstrated that FBI agen provided this information in an attempt to secure legal advice or a legal opinion from the United States Attorney's Office. The correspondence must be produced pursuant to an appropriate protective order. 46 EFTA00086490
Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 47 of 51 S:14330-14337 Partially protected from discovery by opinion work product privilege. The portions of the email chain from Epstein's counsel are not privileged. The Government must certify that this outside correspondence has been produced. S:14338-14354 Protected from discovery by opinion work product privilege. S:14355-14361 Protected from discovery by opinion work product privilege. S:I4362-14402 Protected from discovery by opinion work product privilege. S:14403-14414 Protected from discovery by opinion work product privilege. 5:14415-14420 Protected from discovery by opinion work product privilege. 5:14421- 14428 Protected from discovery by opinion work product privilege. 5:14429-14439 Protected from discovery by opinion work product privilege. S: 14440 Protected from discovery by opinion work product privilege. S:14441 Protected from discovery by opinion work product privilege. S:14442 Protected from discovery by opinion work product privilege. 5:14443 Protected from discovery by opinion work product privilege. 5:14444 Protected from discovery by opinion work product privilege. S:14445.14447 Protected from discovery by opinion work product privilege. S:I4448-14454 Protected from discovery by opinion work product privilege. S:14455-14456 Protected from discovery by opinion work product privilege. S:I4457-14464 Protected from discovery by opinion work product privilege. 47 EFTA00086491
Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 48 of 51 S:14486 Protected from discovery by opinion work product privilege. S:14487 Protected from discovery by opinion work product privilege. S:I4488-14499 Protected from discovery by opinion work product privilege. S:14500 Protected from discovery by opinion work product privilege. 8:14501-14506 Protected from discovery by opinion work product privilege. 8:14507-14508 Protected from discovery by opinion work product privilege. S:14509-14519 Protected from discovery by opinion work product privilege. S:14520 Produce. The Government has not supported its assertion of attorney-client privilege: the email does not, in and of itself, demonstrate that it was a communication between an attorney and clients regarding the provision of legal services or legal advice. Petitioners' need for this material outweighs any deliberative process or investigative privilege that may apply. 5:14521.14522 Protected from discovery by opinion work product privilege. 8:14523 Protected from discovery by opinion work product privilege. S:14524-14550 Protected from discovery by opinion work product privilege. 48 EFTA00086492
Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 49 of 51 S:1455I Produce. The Government has not supported its assertion of attorney-client privilege: the email, authored by an FBI agent, does not indicate that it is a client communication seeking legal services or advice from an attorney, the United States Attorney's Office. Petitioners' need for this material outweighs any investigative privilege that may apply. This must be produced pursuant to an appropriate protective order. S:I4552 Protected from discovery by opinion work product privilege. 5:14553-14556 Protected from discovery by opinion work product privilege. S:14557 Production not necessary as not relevant or likely to lead to material relevant to this CVRA litigation. S:14558 Protected from discovery by opinion work product privilege. S:I4559-14562 Protected from discovery by opinion work product privilege. S:I4563-14565 Protected from discovery by opinion work product privilege. 5:14566-14568 Protected from discovery by opinion work product privilege. 5:14569-14573 Protected from discovery by opinion work product privilege. 5:14574-14583 Protected from discovery by opinion work product privilege. 5:14584-14622 Protected from discovery by opinion work product privilege. S:14623-14627 Protected from discovery by opinion work product privilege. 5:14628 Protected from discovery by opinion work product privilege. 5:14629 Protected from discovery by opinion work product privilege. 49 EFTA00086493
Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 50 of 51 S:14630-14631 Protected from discovery by opinion work product privilege. S:I4632-14646 Protected from discovery by opinion work product privilege. S:I4647-14649 Protected from discovery by opinion work product privilege. S:14650-14653 Protected from discovery by opinion work product privilege. S:I4654-14655 Protected from discovery by opinion work product privilege. S:I4656-14665 Protected from discovery by opinion work product privilege. S:14666-14693 Protected from discovery by opinion work product privilege. S:I4694-14706 Protected from discovery by opinion work product privilege. S:14707-14711 Protected from discovery by opinion work product privilege. S:14712-14716 Protected from discovery by opinion work product privilege. 5:14717-14721 Protected from discovery by opinion work product privilege. 5:14722-14727 Protected from discovery by opinion work product privilege. S:14728-14742 Protected from discovery by opinion work product privilege. S:14743-14780 Protected from discovery by opinion work product privilege. S:14781-14800 Protected from discovery by opinion work product privilege. S:14801-14810 Protected from discovery by opinion work product privilege. S:14811-14829 Protected from discovery by opinion work product privilege. S:14830-14837 Protected from discovery by opinion work product privilege. S:14838-14843 Protected from discovery by opinion work product privilege. 50 EFTA00086494
Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 51 of 51 S:14844-1485I Protected from discovery by opinion work product privilege. S:]4852-14864 Protected from discovery by opinion work product privilege; also not relevant or likely to lead to material relevant to this CVRA litigation. Involves self-reporting to OPR regarding Epstein's allegation that certain prosecutors had conflicts of interest. Not relevant to victims' CVRA rights. S:I4865 Protected from discovery by opinion work product privilege. S:14866-I4883 Protected from discovery by opinion work product privilege. 5:14884-14886 Protected from discovery by opinion work product privilege. S:14887-14894 Protected from discovery by opinion work product privilege. S:14895-14900 Protected from discovery by opinion work product privilege. 5:14901-14906 Protected from discovery by opinion work product privilege. S:14907-14911 Protected from discovery by opinion work product privilege. S:14912-I4919 Protected from discovery by opinion work product privilege. 5:14920-14923 Protected from discovery by opinion work product privilege. The Government notes that a redacted version has been produced to Petitioners. (DE 329-1 at 18). Only the unredacted version is privileged. 51 EFTA00086495
Case 9:08-cv-80736-KAM Document 361-27 Entered on FLSD Docket 02/10/2016 Page 2 of 4 DECLARATION OF 1. My name is • and I was born in 2. I was paid by Jeffrey Epstein to interact sexually with him as a minor on dozens of occasions in his mansion in Palm Beach, Florida from around 2002 to 2005, and also to bring him other girls who were my approximate age for the same purposes. I understand that evidence collected from Epstein's home showed conclusively that I was there as a minor, along with many other underage girls. Given how many girls Epstein was sexually abusing, there could not have been any doubt in anyone's mind that had access to the testimonial and other evidence that Epstein sexually molested me as a minor (and many others). 3. My son was very young when the FBI came to speak with me the first time. I did not know what to do and I was scared. I called Epstein, who told me not to worry and that he would hire an attorney for me. I believed that if I told the truth about what happened at Epstein's house, the policel That made me really scared. 4. Through the attorney that Jeffrey Epstein obtained for me, it was arranged for me to give a statement to the prosecutor investigating Epstein. 5. While with the attorney Epstein obtained for me I gave a statement to the prosecutor that was favorable to Epstein. The prosecutors knew the truth because of the volume of evidence they had, and they continued to recognize me as a victim of Epstein's crimes. 6. I had been greatly intimidated, which is why I could not be truthful initiall and I wanted to end the threat of the possibility of My involvement with Epstein from a very young age was a deep, dark secret and Epstein told me to keep it a secret. I knew that I was expected to keep it a secret. 7. The more I thought about what was going on, the more I realized that what Epstein had done to both me and my friends was wrong and that anyone who was not very wealthy would be punished. At this time, I EFTA00086496
Case 9:08-cv-80736-KAM Document 361-27 Entered on FLSD Docket 02/10/2016 Page 3 of 4 wanted Epstein held accountable the same way anyone else would be. I spoke about this with one of m friends around May 2008. I then called an attorney, around June 2008, understanding that he was hired to get the prosecutors to talk to us and hear the truth from me. That was especially important to me because I was finally represented by someone other than Epstein's attorney and wanted to talk to the prosecutors about everything I knew. 8. The prosecutors had a lot of information revealing the truth about the situation at Epstein's house. I had lot of information, too, because I was one of the young teenagers who had brought many other young teenagers to Epstein for the purpose of getting paid by Epstein. I wanted to assist the prosecutors in the investigation. I hired Mr. to let them know that I was cooperative and ready to tell them all of the helpful information I had. I understood that Mr. did that. 9. I authorized Mr. to join me in the lawsuit against the U.S. Attorney's Office to enforce my rights and to try to get me my chance to confer with the prosecutors before Mr. Epstein took a plea or the case was resolved in any way. I just wanted to be treated fairly in the process. 10. When Epstein pled guilty to a state crime at the end of June 2008, no one notified me that his plea had anything to do with my case against him. I did not know, for example, that this plea had some connection to a crime he committed against me particularly. In fact, at this young age, I had no idea what was going on and nobody tried to explain it to me. 11. In Jul 2008 • • I learned for the first time at that hearing that the prosecutors worked out some sort of secret deal with Epstein that might block his prosecution for crimes against me. It also appeared that there was a lot of continued communication between Epstein and the U.S. Attorney's Office. I was really upset that the U.S. Attorney's Office seemed like it would not talk with me or the other victims about what was going on. It was easier to get them to talk to me when I was represented by Epstein's attorney. EFTA00086497
Case 9:08-cv-80736-KAM Document 361-27 Entered on FLSD Docket 02/10/2016 Page 4 of 4 12. I wanted to see this secret deal that the Government had with Epstein, but they would not give it to me Later, the other victims and I finally got to see the secret deal after the judge forced the prosecutors to show it to us. 13. I understand that I did not initially help the investigation by speaking on Epstein's behalf untruthfully. But I was intimidated and had good reason — reasons that I think everyone who was talking to me could obviously see. Also, the agents and attorneys obviously had a lot of evidence that provided proof of what Epstein had actually done. Epstein was still supporting me, providing me a lawyer and in my mind protecting me, so I was in a position where I felt I had to say certain things. And Epstein expected me to say those things. 14. Once I wanted to cooperate and tried to cooperate, I was never given the opportunity to confer with prosecutors from the time they were informed by my attorney that I was a cooperating witness. I was never told about the secret deal until after it was already concluded. I would have had my attorney object if I had been given the chance. 15. I don't feel like I was treated fairly in this process. And I know Epstein got a really good plea deal because he is rich and powerful. That doesn't seem fair either. Executed this O h , day of January, 2015. EFTA00086498
EISENBERG & FOUTS, P.A. Attorneys At Law JAMES L EISENBERG Florida Bar Board Certified Criminal Trial Lawyer National Board Of Trial Advocacy Certified Criminal Trial Advocate KM LI ALOE FOUTS One Clearlake Centre, Suite 704,250 Australian Avenue South, West Palm Beach, FL 33401 Fax: September 21, 2006 Asst. U.S. Attorney 500 South Australian Avenue, Suite 400 West Palm Beach, FL 33401 Re: =Subpoena fora Dear M, Please allow me to confirm my latest e-mail to you. I did receive your e-mail of last week with attachments and pegged them on to my client. At this time, I can only say that my client does not want to do ei q of your suggestions. She does not want to give a statement under the irnmuni ed with its Kastigar exception and she does not want to test 5'h Amendment grounds. With this client, I am sorry, but I must have a formal grant of m it y f.re she will say anything. GOVERNMENT EXHIBIT Case No. 08-80736-CV-MARRA P-000146 EFTA00086499
EISENBERG & FOUTS, P.A. Attorneys At Law JAMES L EISENBERG 0011alli Bar Board Cmilflui Criminal Thal Lawyer &Sakai Board Of Trial Advocacy Corilltrd Criminal Trial Advocate KAI LI ALOE POUTS OneClearlako Cenfro,Suito 704, 250 Australian Avenue So u lb, Wesi Palm Beach, FL 3340i Fax: February 12, 2007 Asst. U.S. Attorney 500 South Australian Avenue, Suite 400 West Palm Reach, FL 33401 Re: Dear for As always, it was a pleasure speaking to you the other . Pursuant to out telephone conference I am writs this letter to ffer my concerns fo oul she testify without immunity before a Therefore, allow me to reiterate that U refuse to voltuttarily cooperate with the federal government. She has a good faith basis for position under the Fifth Amendment to the United States Constitution. We, of coins; do not live or work in a vacuum. We have read many inflammatory remarks the Town of Palm Beath Police Chief has made to the media about the state court's handling of the Jeffrey Epstein investigation. The police chiefs remarks frighten both myself and my client I am aware that the own police have prepared documents to charge at least one of Mr. Epstein's lady friends. in state court. If they can push to have one lady charged I remain unconvinced that they do not have the ability or political clout to push to have other ladies such as Ms charged. The proffered facts that raise my concerns are being provided via this proftbr letter. Pursuant to our telephone conference agreement, this letter and its contents cannot be used against Mr. NM MMIlis not at all certain of dates. She does remember meeting Mr. Epstein about three years ago. She is not certain of her age, it could have been when she was sixteen, A girlfriend asked her if she wanted a job giving massages. Ms..Magreed because she had knowledge of massages through her mother, who was a masseuse. Mt. went to Mr. Epstein's house via told. Ms. s girlfriend instructed Ms. hat, if asked, she had to tell Mr. Epstein that she was eighteen years old. The friend was nineteen years old and Illlooked old for her age, so passing for eighteen was not a problem. At Case No. 08-80736-CV-MARRA P-003730 EFTA00086500
the home Ms anet Mr. Epstein and later gave him a massage. The friend had told Ms. I N to give the message topless. Mr. Epstein told that if she were at all uncomfortable being topless, not to do it and it was not a requireme employment as a masseuse. Ms never touched Mr. Epstein in a sexual way and Mr. Epstein never touched Meat all. At one point, Mr. Epstein did ask Ms. !Cher age. Ms. Minsisted that she was eighteen years old. Msalicontinue,d to see Mr. Epstein over time and massages were given in a similar fashion. She was later asked If her friend ted to work in a similar way and she asked some girls who did give Mr. Epstein massages. M never asked to bring girls of any age to Mr. Epstein's home. When she did have her friends come over, she instructed all of them that if asked, they insist that they were eighteen years old. She is not certain at all of any of these girls' real ages. In summary, our concern is that if the government believes that Mr. Epstein committed some federal offense, then Ms could he considered a co-conspirator. We believe no crime was committed.. The Fifth Amendment was not intended to protect the guilty, however, It was enacted to protect citizens who fear prosecution notwithstanding their innocence. Our fear of any prosecution, especially ' ligh i f the Town police chiefs public remarks, is clearly in good faith. Case No. 08-80736-CV-MARRA P-003731 EFTA00086501
EISENBERG & FOUTS, P.A. Attorneys At Law JAMES L. EISENBERG Florida Bar Board Certified Criminal Mal Unger Nallonal Board Ot Trial Advocacy Certified Criminal Trial Advocate KM LI ALOE FOUTS One Clearlako Centre, Suite 704,250 Australian Avenue Soul li,West Palm Beach, F1,3340I February 1, 2007 Asst U.S. Attorney 500 South Australian Avenue, Suite 400 West Palm Beach, FL 33401 Re: Grand Jury Subpoena fbiln Dear Ji l I received your letter dated January 24, 2007 with regard t I must admit I forced myself to wait several days to respond in order to "cool o an l no say anything I would regret later. Now that time has passed, allow me to respond appropriately. 1. If you want to force Ms. IIII , to come to the to personally invoke her Fifth Amendment ri its she will be there. That does remain her position. My o st is that isovid . I will be there, but I am not should not have It is this type of attitude, that your paid t and Ms. office refuses to accept the fact that it is Ms s decision not to cooperate with the government that u sets her. office fails to recognize that merely coming to court is a problem for like Ms d, under these circumstances, appears to be a waste of time at best and, in her mind, persona unussment 2. Rest assured that there is no conflict of interest in my representation of Ms In this ease I have always been asked and always will exercise independent judgment to follow my client's independent will. The remainder of your questions as to this matter are really none of the Government's business. 3. 1 will share with you that one of the reasons for our firm position that Mr will invoke her Fifth Amendment right and choose not to voluntarily cooperate with the Government is our concern that the Government is not exercising independent judgment in this case. The history of this case has been in the newspapers. The case is being prosecuted in State court. Despite the state court prosecution, the Town of Palm Beach Police Chief went on what can only be Case No. 08-80736-CV-MARRA P-003732 EFTA00086502
, Asst. U.S. Attorney February 1, 2007 Page Two described as a public rampage in the newspaper when the case was not prosecuted to his liking that reminded me of a small child having a public temper tantrum. In my thirty years of experience, I have never seen a law enforcement officer like this publicly make what appeared to be a political case in the newspaper for a prosecution and publicly criticize anyone who got in his way, including the elected State Attorney. This resulted in a federal investigation on a topic no one remembers the Federal Government ever being interested in prosecuting before. Although I am certain that you personally have not had your decision-making process compromised, the appearance that your office is being influenced by the Town of Palm Beach Police Chiefs agenda is very real. Under these circumstances.! don't see bow any lawyer could advise any client to voluntarily cooperate. Of special concern is that the Town of Palm Beach Police have promoted prosecuting at least one of the girls who allegedly gave massages. One final thought. My client and my fear that Ms. could be prosecuted is enhanced by the demand for the personal appearance made in your letter. Your initial Kastiger letter. fell far short of granting the functional equivalent of DOJ immunity. Several months ago I was given the dis impression through our conversations that you were going to obtain DOJ immunity for Ms Now the government is changing course for no apparent reason. This leads to speculation that the only reason for the turnabout is that prosecution in either state or federal court is being considered by someone. directed at you personally. 1 want to repeat that you have always treated us with ur office should advise the Town Police Chief to act in a similar fashion. Case No. 08-80736-CV-MARRA P-003733 EFTA00086503
U.S. Department of Justice United States Attorney Southern District ofFlorida DELIVERY BY HAND James L. Eisenberg, Esq. 250 S Australian Ave, Ste 704 West Palm Beach, FL 33401-5007 Dear Jim: 500 South Australian Ave.. Suite 400 Wert Palm Beach, FL 33401 ($61) 820-8711 Facsimile: January 24, 2007 Re: Federal- have enclosed a new subpoena fora As I mentioned earlier, Ms. s not a target of this investigation and the United Sta her testimony solely as a vie 'm/witness. During our last conversation regarding Ms you indicated that she was unwilling to speak with us pursuant to a Kastigar letter and that she also was unwilling to speak with the Mftand intends to invoke the Fifth Amendment if questioned. Please confer with her to confirm whether this remains her position. If it is, please advise in writing. Even if Ms. MU inclined to invoke her Fifth Amendment rights, she must still appear pursuant to the subpoena so that I may ask her questions that would not require the invocation of the Fifth Amendment. If she still invokes, I intend to move to compel her answers. If you or your client is unavailable on February 6, 2007, please let me know of another Tuesday when you are available. I also am concerned about a potential conflict of intereatin your representation of Ms. In case of future litigation regarding this issue, please provide me with ilhimiation ng who is paying (directly Or indirectly) for your services on behalf of Ms. the scope of your representation and whether you are taking direction on this matter from anyone other than Ms.M. If any formal or informal:joint defense agreements exist, whether in writing or otherwise, please provide a copy of such agreements. lithe agreement is purely oral, please provide a written summer)/ of its terms. Case No. 08-80736-CV-MARRA P-003736 EFTA00086504
JAMES EISEN13ERG, ESQ. JANUARY 24, 2007 PAGE 2 I look forward to your response. Sincerely, R. Alexander Acosta nited States Attome By: Assistant United States Attorney Case No. 08-80736-CV-MARRA. P-003737 EFTA00086505
This subpoena is issued upon application United States District Court SOUTHERN DISTRICT OF FLORIDA TO: a SUBPOENA TO TESTIFY SUBPOENA FOR: PERSON X DOCUMENTS OR OBJECTS] YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District Court at the place, date and time Specified below. PLACE: United States District Courthouse 701 Clematis Street West Palm Beach, Florida 33401 ZOOM • DATE AND TIME: February 6, 2007 1100Pnit YOU ARE ALSO COMMANDED to bring with you the following document(s) or object(s): *Please coordinate your compliance with this subpoena and confirm the date and time , and location of our a earance with Special Aget , Federal Bureau of Investigation, Telephone: This subpoena shall remain in effect until you are granted leave to depart by the court or by an officer acting on behalf of the court. DRIB: January 23, 2007 Name Address and Phone Number of Assistant U.S. Attorney Assistant U.S. Attorney 500 So. Australian Avenue, Suite 400 West Pahnlle c FL 334014235 Pax: 'If not applicable, enter "none." Tobstsid •• PO d1Agtle Case No. 08-80736-CV-MARRA FORM ORD-227 P-00,316$ EFTA00086506
U.S. Department of J ustice United States Attorney Southern District of Florida 500 South Australian Ave., Suite 400 Wert Palm Beach, FL 33401 (S60820-871/ Facsimile: February 5, 2007 DELIVERY BY HAND do James L. Eisenberg, Esq. 250 S Australian Ave, Ste 704 West Palm Beach, FL 33401-5007 Re: Testimony of Dear Ms... This letter confirms the understanding between yourself and the United States Attorney's Office for the Southern District of Florida. You have represented that you will truthfully answer questions of the federal government in its investigation of the procurement of prostitutes, amongst others. You will supply complete and truthful i o • a i o r is t e attorneys and law enforcement officers of the federal government and to any ich may conduct an investigation, as well as in any other proceeding rela to or growing out of this investigation. The obligation of tnithful disclosure includes your obligation to provide the attorneys and law enforcement officers of the federal government with any documents, records or other tangible evidence within your custody or control relating to the matters about which you are questioned. You will neither attempt to protect any person or entity through false information or omission, nor falsely implicate any person or entity. No statements provided by you on this date in this matter pursuant to this agreement will be offered into evidence in any eri mi nal case against you, except during aprosecution for perjury and/or giving a false statement. HoWever, i fit is determined that you have materially violated any provision of this agreement, all statements made by you shall be admissible in evidence against you in any proceeding. The federal government remains free to use information derived from the testimony directly or indirectly for the purpose of obtaining leads to other evidence, whic may e used against you. You expressly waive any right to claim that such evidence should not be introduced because it was obtained as a result of the grand Jury testimony. Furthermore, the federal government may use statements made in the grand jury testimony and all evidence derived directly or indirectly therefrom for the purpose of cross-examination, if you testify at any trial or if you Case No. 08-80736-CV-MARRA P-003739 EFTA00086507
FEBRUARY 5,2007 PAGE 2 suborn testimony that contradicts your prior statements and testimony. No additional promises, agreements and conditions have been entered into other than those set forth in this letter and none will bo entered into unless in writing and signed by all parties. Sincerely, R. Alexander Acosta United States Attorney PY: Assistant United States Attorney have read this agreement and discussed it with my attorney, and I hereby acknowledge that it fully sets forth my agreement with the office of the United States Attorney for the Southern District of Florida. I state that there have been no additional promises, agreements or representations made to me by any officials of the United States in connection with this matter. Dated: February 2007 West Palm Beach, Florida Witnessed by: James L Eisenber Bs . Attorney fo Case No. 08-80736-CV-MARRA P-003740 EFTA00086508
U.S. Department of Justice United States Attorney Southern District orlorida SOO South Australian Avo,'Suite400 West Palm Bleach, AL 33401 fracsItnt February 5, 2007 PELIVERY BY HAND James L. Eisenberg, Esq. 250.8 Australian Ave, Ste 704 West Palm Beach, FL 33401-5007 Rer Dear Mr. Eisenberg: I am writing to clarify the ground rules for• the interview with your client ("your client"), to occur February , 2007. As I mentioned earlier, Ms. s not a target or subject of this investigation, but instead is being interviewed solely as a victim/vvitness. However, to address your concern aboµt criminal exposure, if your client complies with every provision of this agreement, then the United States Attorney's (Met for the Southern District of Florida ("this Office") will treat all statements made by your client during the interview as statements made pursuant to Rule 11(0 of the Fedora' Rules of Criminal Procedure. This is not a grant of immunity, which can be given only with approval of the Justice Department, but protects your client from having the statements made by her during the interview from being used against her directly. To guard against any misunderstandings concerning the interview of your client, this letter sets forth the terms of this agreement. . Your client agrees to be fully interviewed, that is, to provide information concerning your Client's knowledge of, and participation in criminal activity, including but not limited . to the procurenient of prostitutes: The protection, of till latter applies to an interview that will be conducted by this Office, Special Agents of the Federal Bureau of Investigation, and any other federal law enforcement agency this Office may require. Under this agreement, no information disclosed by your olient during the interView will be offered in evidence against her in any criminal or civil proceeding, provided that your• client complies with this agreement and that the information your client furnishes is truthfhlEcomplete, and accurate. If, however, your client gives materially false, incomplete, or misleading information; Case No. 08-80736-CV-MARRA P-003741 EFTA00086509
JAM MEER°, Pao. PAGE 2 then this Office may use such information in any matter or• proceeding and your client is subject to prosecution for perjury, obstruction of. justice, and making. false statements to. government agencies. Any such prosecution maybe based upon infoimation prOvided by your client during the course of the interview, and such infertnation, including your client's statements, will be admissible against your client in any grand jury or other proceeding. • The government also may use statements made by your client in the interview and all evidence derived directly or indirectly therefrom for the purpose of impeachment or cross-examination if she testifies at any trial or hearing, and/or in any rebuttal case against your client in a criminal trial in which she is a defendant or a witness. These provisions are necessary to ensure that your client does not make or offer any false representation or statement in any proceeding or to a government agency or commit perjury during any testimony. Your .client further agrees that attorneys for the United States may be present at the interview, and agrees not to seek.disqualification of any such government attorney from any proceeding or trial because'of their participation at the interview. ' The entire agreement. between the United States and your client is set forth in this letter. No additional promises, agreements, or conditions have been entered into and none will be entered into unless in writing and signed by all parties. If the foregoing accurately reflects- the understanding and •agreement between this Office and your client, it is requested that you and your client execute this letter as provided below. Sincerely, R. Alexander AcOsta United States Attorney By: Assistant United. States Attorney I have received this letter from my attorney, lames.L. Eisenberg, Esquire, have read it and discussed it with my attorney, and I hereby acknowledge that it fully sets forth my understanding andagreerbent with the Office of the United States Attorney for.the Southern Case No. 08-80736-CV-MARRA P-003742 EFTA00086510
James L. EISENBERG ESQ. RE: FEBRUARY 2, PAGE .3 District of Florida. I state that there have been no additional promises or representations made to me by any official of the United States Government or by my attorney in connection with this matter. Dated: Witnessed by: James L. Eisenberg, Esquire Case No. 08-80736-CV-MARRA P-003743 EFTA00086511
U.S. Department of Justice Authorization for Reimbursement of Unusual Expenses of Fact Witnesses Request for Unusual Expense(s) of Fact Witness (For United Stales Attorneys Office Use Only) Control if 2. Court Docket Number Peen Illitfiriti Al LOA OU rig S. Contact Prim tms Pam 1:1• ••••••••••• 7. Witness Name & one 0. SSN 8. Vendor Name & Address, Phone It, TIN/SSN 9. Payment t6 be made to: 10. Recelpt/invoice Is: 11. Type of Unusual Expense: 12. Explanation: K Medically Necessary Item (Attached Supporting Statement) ID Excess Lodging/Per Diem K Travel & Transportation K Pretrial Conference Waiver K Other 18. Start Date of Service (dOlDANR) 2 41O 7 18. Juslifidabon: 14. End Date of Service (MO/DANR) 2-4 /0 7 15. Amount 17.1 hereby certify that the expenses and services listed on this docuMent are appropriate and are within the Federal laws and regulations. I fully understand that I can be held personally gable or besubject to disciplinary action for Improperly using government funds or services that exceed delegated authority or that violate Federal laws or regulations. Signature of Requesting AUSA Data 18. Nellie& Title of Approving Official 19. Date (MO/DANR) 20. Signature of Approving Official Case No, 08-80736-CV-MARRA — CIFWE Form P-003744 EFTA00086512
U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave, Suite 400- West Palm Beach, Florida 33401 Facsimile FACSIMILE COVER SHEET TO: JIM EISENBERG, ESQ. DATE: February 5, 2007 FAX NO. 561 659-2380 # OF PAGES: PHONE NO. RE: U.S. ATTORNEY FROM: ASSISTANT PHONE NO. commugNTsc EH 17in f pc' ( 14-e cjae1 x/Aili- a d 6 it' L htive_ chwr inaink (4,1}—&- fil/tia / PAL. Case No. 08-80736-CV-MARRA P-003745 EFTA00086513
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA NORTHERN (WEST PALM BEACH) DIVISION IN RE: SEALED ORDER On Application of the United States Attorney for the Southern District of Florida, and it appearing to the satisfaction of the Court: 1. That has been called to testify and to provide other information before . the United States District Court for the Southern District of Florida, and 2. That in the judgment of the said United States Attorney, 'as refused to testify and provide other information on the basis of her privilege against self-incrimination; and 3. That in the judgment of the said United States Attorney, the testimony and other information from may be necessary to the public interest; and 4. That the aforesaid Application has been made with the approval of the Assistant Attorney General in charge of the Criminal Division of the Department of Justice or a duly . . designated Acting Assistant Attorney General, pursuant to the authority vested in him by Title 18, United States Code, Section 6003, and Title 28, Code of Federal Regulations, Sections 0.175 and 0.132(e). NOW, THEREFORE, it is ordered pursuant to Title 18, United States Code, Section 6002, that I give testimony and provide other information which she refus • • el. EFTA00086514
.1 provide on the basis of her privilege against self-incrimination, as to all matters about which she may be interrogated before said United States District Courtl as well as any subsequent proceeding or trial. However, no testimony or other information compelled under this Order (or any information directly or indirectly derived from such testimony or other information) may be used againstMI in any criminal case, except a prosecution for perjury, giving a false statement, or otherwise failing to comply with this Order. IT IS FURTHER ORDERED the this Order shall be SEALED in accordance with Fed. R. Crim. P. 6(e)(6), except that a copy of this Order shall be provided to counsel for the United States, who may disclose the existence of the Order to the witness, to counsel for the witness, and to law enforcement officers engaged in the investigation Those persons may review the Order, but may not retain a copy of the Order, nor may they disclose the existence of the Order to any others. DONE and ORDERED this /.‘ day of cc: AUSA 2 DONALD M. MIDDLEBROOKS UNITED STATES DISTRICT JUDGE EFTA00086515
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA NORTHERN (WEST PALM BEACH) DIVISION FGJ NO. 07-103 (WPB) IN RE: GRAND JURY PROCEEDINGS SEALED ORDER This matter comes before the Court on the United States' Sealed Motion for Permission to Disclose Grand Jury Material. The Court has considered the Motion and attachments thereto, and finds that the United States has shown a "particularized need" for the limited disclosure of materials related to matters occurring before the Grand Jury. The Court further finds that the United States has shown that: (1) the materials are needed to avoid an injustice in another proceeding, that is, Jane Doe 1 and Jane Doe 2 v. United States, S.D. Fla. Case No. 08-80736- Civ-Marra; (2) the need for disclosure is greater than the need for continued secrecy; and (3) the request is structured to cover only needed materials. Accordingly, the United States Attorney's Office for the Southern District of Florida may disclose Exhibit 7 to its Motion for Permission to Disclose Grand Jury Material, and file those in the public portion of the Court file in S.D. Fla. Case No. 08-80736-Civ-Marra. Furthermore, Exhibits 4, 5, and 6 to the government's Sealed Motion for Permission to Disclose Grand Jury Material are already part of the public portion of the Court file in S.D. Fla. EFTA00086516
Case No. 08-80736-Civ-Marra. The government has not sought to remove them from the public portion of that Court file, and they remain part of the public record in that matter. IT IS SO ORDERED. DONE AND ORDERED in chambers this day of May, 2017, at West Palm Beach, Florida. DANIEL T. K. HURLEY SENIOR UNITED STATES DISTRICT JUDGE CC: AUSA EFTA00086517









