deny the amendment. II. Discussion “The decision whether to grant leave to amend a complaint is within the sole discretion of the district court.” Laurie v. Ala. Ct. Crim. Apps., 256 F.3d 1266, 1274 (11th Cir. 2001). “The court should freely give leave when justice so requires.” Fed. R. Civ. P. 15(a)(

ONEY,ANNE RICARDEL,JOSEPH A SILVERS,LAURIE S ZUVER,DICK FIX,A H STERLING

ion do you have?" Conversely, in an episode of his TV series, Lou/e he reversed such roles. After leaving a bar with an especially aggressive woman, Laurie (played by Melissa Leo), that he had inadvertently met earlier, she performs fellatio on him in her pickup truck, then insists that he in turn HOUS

ope ty Nohai Cecllla Noonan, Tim *Redactions for personal contact information . Oates, Simi rletto iill"e I l • if - - 0 ·• •t t: ... ,. Laurie •~11·u11 Marella ~rice OKwen Edmunds, Tom & ale *Redactions for personal contact information .;::. -..J .1 l ' Pashc:ow, Stacey I> I

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eny the amendment. II. Discussion "The decision whether to grant leave to amend a complaint is within the sole discretion of the district court." Laurie v. Ala. Ct. Crim. Apps. 256 F.3d 1266, 1274 (11th Cir. 2001). "The court should freely give leave when justice so requires." Fed. R. Civ. P. 15(a)(2

deny the amendment. H. Discussion "The decision whether to grant leave to amend a complaint is within the sole discretion of the district court." Laurie v. Ala. Ct. Crim. Apps. 256 F.3d 1266, 1274 (11th Cir. 2001). "The court should freely give leave when justice so requires." Fed. R. Civ. P. 15(a)(2

bly, after we objected to these overly broad and intrusive requests. Deputy Chief Andrew Laurie denied knowledge of Ms. Villalima's actions and Mr. Laurie commendably sought to significantly narrow the list of documents requested. In a subsequent court filing. Ms. Villafana referred to our agreement to

C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Thursday, August 02,2007 4:55 PM To: Sloman, Jeff (USAFLS); Menchel, Matthew (USAFLS); Laurie, Andrew (USAFLS) Subject: Draft Response to Letter Here is a draft. I put tomorrow's date on it so Matt will have time to talk to Alex. 070802 Sa

Villafafia to R. Garcia, A. Laurie re negotiation strategy; ■ 9/14/07 e-mail from A. Marie Villafafia to J. Sloman, A. Acosta, R. Garcia, A Laurie, K. Atkinson, S. Ball re proposed plea agreement and Information Page 53 of 69 EFTA00208735 Case 9:08-cv-80736-KAM Document 224-1 Entered on FL

the United States Attorney's Manual that require prior notification to Washington necessary to seek a lawyer's records). We once more requested Mr. Laurie to intervene. Despite these efforts. followed up with a subpoena liar Mr. Epstein's confidential medical records served directly on his chiropracto

f 10 on the part of the movant, . . . undue prejudice to the opposing party by virtue of allowance of the amendment, [and] futility of amendment.'" Laurie, 256 F.3d at 1274 (quoting Foman I. Davis, 371 U.S. 178, 182 (1962)). In addition to considering the effect of amendment on the parties, the court

f 10 on the part of the movant, . . . undue prejudice to the opposing party by virtue of allowance of the amendment, [and] futility of amendment.'" Laurie, 256 F.3d at 1274 (quoting Foman I. Davis, 371 U.S. 178, 182 (1962)). In addition to considering the effect of amendment on the parties, the court

Suite 400 West Palm Beach, FL 33401 Phone 561 209-1047 Fax 561 820-8777 Tracking: 29 EFTA00224228 Recipient Road Menchel. Matthew (USAFLS) Laurie, Andrew (USAFLS) Read: 8/3/2807 11:08 AM Sloman. Jett (USAFLS) Atkinson. Karen (USAFLS) Read: 8/3/2007 10:17 AM 30 EFTA00224229

to be present, and also provided counsel with a list of the statutes that were the subject of the investigation. On June 26, 2007, Mr. Menchel, Mr. Laurie, AUSA Villafana, and FAUSA Sloman, and two FBI agents met with Alan Dershowitz, Roy Black, Gerald Lefcourt, and Lilly Ann Sanchez. During that meet

6 Villafatia Guy Lewis Email re representation of Jeffrey Epstein I 10/31/2006 Villafaria Guy Lewis Email chain to set up call HI 11/8/2006 Laurie, Villafaila' cc: Menchel Sloman Email re Lilly Ann Sanchez/representation of Jeffrey Epstein I I Privileged Confidential Page 2 of 51 Contains

ding when to use "a" versus "the" and other minutiae. When you and I could not reach agreement, you repeatedly went over my head, involving Messrs. Laurie, Menchel, Siemer), and Acosta in the negotiations at various times. In any and all plea negotiations the defendant understands that his options are

Monday? Please let me know and I'll forward some proposed times to see if we can put the two gentlemen together for a visit. Thank you very much! Laurie Laurie Eisenhart Executive Assistant to Nathan Myhrvold E - T F c El all all "Genius is eternal patience." Michelangelo -AA A - -trA. I /-,

From: Lesley Groff <MIMIII > To: Laurie Cameron < MII > Subject: Jeffrey Epstein Date: Tue, 07 Jan 2014 18:34:44 +0000 Hi Laurie...jeffrey would like to speak with you...please give him a call! thanks, lesley EFTA00376659

deny the amendment. IL. Discussion “The decision whether to grant leave to amend a complaint is within the sole discretion of the district court.” Laurie v. Ala. Ct. Crim. Apps., 256 F.3d 1266, 1274 (11th Cir. 2001). “The court should freely give leave when justice so requires.” Fed. R. Civ. P. 15(a)(2