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The Government's motion was filed more than one year ago, yet (presumably because of a flurry of other motions) the Court has yet to rule on this particular motion. The practical effect of a lack of a ruling on that motion has been to effectively grant the stay — blocking discovery in this case. Court should rule quickly on that motion and deny that motion. Denying the stay would allow the limited discovery that the Court has previously authorized to move forward in this case, putting the case on a path toward final resolution. + +## BACKGROUND + +As the Court is aware, the victims filed this case alleging Government violations of the CVRA in July 2008. Through more than four years of litigation, however, the Government has refused to reach a stipulated set of facts regarding how it treated the victims. Accordingly, more than eighteen months ago, on March 21, 2011 the victims filed a motion to have their detailed recitation of the facts accepted because of the Government's failure to contest their facts (DE 49). On September 26, 2011, the Court denied that motion on the ground that the victims would instead be allowed limited discovery to develop a factual record (DE 99 at 11). The victims then sent limited discovery requests to the Government. On November 8, 2011, the same day that the production of discovery was due, rather than produce a single item of discovery or stipulate to a single fact, the Government filed a motion to dismiss the victims' case. The Government also filed an accompanying motion for a stay in this case.' + +On December 5, 2011, the victims filed a response to Government's motion to stay. The victims strenuously objected to the Government's approach, alleging specifically that "delay appears to be the Government's motivation for filing the motion to dismiss." DE 129 at 2. The victims went on to recount the fact that the Government had waited three years to file a motion to dismiss, concluding that "as a practical matter, the Government's motion has had the desired effect of delay: While its motion remains pending, the victims have been effectively denied any ability to obtain discovery from the Government." DE 129 at 2-3. + +Now, one year and one day later, the Government's strategy (aided by parallel motions from Jeffrey Epstein) continues to effectively block the victims from obtaining discovery and learning what happened during the Government's plea negotiations with the man who sexually abused them. Indeed, remarkably, the Government has effectively obtained a stay of + +I In an effort to keep the public from learning what it was doing, the Government asked that all of these motions be placed under seal. The victims can see no basis for sealing virtually all of the Government's pleadings. The victims' responses to the Government's sealed pleadings have left in the public Court file. In an effort to make the proceedings in this case more accessible to the public, on February 7, 2012, the victims filed a motion requesting an order from the Court directing the Government to file redacted pleadings in the public court file (DE 150). That motion remains pending. + +proceedings in this case for more than 365 days without the Court even having ruled, one way or the other, on its motion for stay. + +### REOUEST FOR A PROMPT RULING ON - AND DENIAL OF - THE GOVERNMENT'S MOTION FOR A STAY + +This Court should promptly rule on Government's Motion For Stay. For all the reasons explained in the victims response filed on December 5, 2011 (DE 129), the Court should deny that motion for stay. Such a ruling would permit the victims to begin moving forward on discovery in this case, which will help steer the case towards a final resolution. + +The victims stand prepared to move rapidly on the discovery and other issues connected with this case. The victims respectfully request that the Court move this case forward so that they can receive the rights that Congress promised them in the Crime Victims' Rights Act. In the CVRA, Congress directed that crime victims have "[t]he right to proceedings free from unreasonable delay" and the courts must "take up and decide any motion asserting a victim's right forthwith." 18 U.S.C. § 3771(a)(7) & (d)(3). The victims respectfully suggest that the Government's stall tactics are improperly interfering with those rights. The Court should reject those tactics and allow discovery to proceed. + +DATED: December 6, 2012 + +Respectfully Submitted, + +![](_page_3_Picture_4.jpeg) + +Paul G. Cassell + +![](_page_3_Picture_6.jpeg) + +# CERTIFICATE OF SERVICE + +The foregoing document was served on December 6, 2012, on the following using the Court's CM/ECF system: + +![](_page_4_Picture_3.jpeg) + +Roy Black, Esq. Jackie Perczek, Esq. 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United States Partial Ruling + +**Date:** Tue, 27 Sep 2011 16:30:45 +0000 + +**Importance:** Normal + +**Attachments:** DE99\_20110926\_Order\_granting\_in\_part\_Jane\_Does\_CVRA\_claim.pdf + +--- + +Dear Jeff and Alex: Just wanted to pass this along, fyi. Judge Marra issued a partial decision yesterday. + +<> + +[REDACTED] + +Assistant U.S. Attorney + +500 S. Australian Ave, Suite 400 + +West Palm Beach, FL 33401 + +[REDACTED] \ No newline at end of file diff --git a/marker2/ds9/EFTA00205690/EFTA00205690.metadata.json b/marker2/ds9/EFTA00205690/EFTA00205690.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..ce68554db95fcf54329d7421fe4478fffdfbcab2 --- /dev/null +++ b/marker2/ds9/EFTA00205690/EFTA00205690.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205690.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 557, + "elapsed_seconds": 3.28, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 25 + ], + [ + "Span", + 21 + ], + [ + "Line", + 11 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205690" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205691/EFTA00205691.md b/marker2/ds9/EFTA00205691/EFTA00205691.md new file mode 100644 index 0000000000000000000000000000000000000000..8aa98034c03d34f0916e0458a6df1de131dff093 --- /dev/null +++ b/marker2/ds9/EFTA00205691/EFTA00205691.md @@ -0,0 +1,136 @@ +# UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA + +CASE NO. 08-80736-CIV-MARRA/JOHNSON + +JANE DOES #1 AND #2, + +Plaintiffs, + +vs. + +UNITED STATES, + +Defendant. + +/ + +#### ORDER + +THIS CAUSE is before the Court upon Plaintiffs' Motion for Finding of Violations of the Crime Victims' Rights Act (DEs 48, 52), Plaintiffs' Motion to Have Their Facts Accepted Because of the Government's Failure to Contest Any of the Facts (DE 49), Plaintiffs' Motion for Order Directing the U.S. Attorney's Office Not to Withhold Relevant Evidence (DE 50), and Bruce E. Reinhart's Motion to Intervene or in the Alternative for a Sua Sponte Rule 11 Order (DE 79).1 All motions are fully briefed and ripe for review, and the Court has heard oral arguments on all motions. The Court has carefully considered the briefing and the parties' arguments and is otherwise fully advised in the premises. + +The Court is awaiting supplemental briefing on the Motion to Intervene of Roy Black, Martin Weinberg, and Jay Lefkowitz (DE 56) and will rule on that motion after it is fully briefed. Also, because the proposed interveners seek intervention to request a protective order against disclosure of certain correspondences at issue in Plaintiffs' Motion to Use Correspondence to Prove Violations of the Crime Victims' Rights Act and to Have Their Unredacted Pleadings Unsealed (DE 51), the Court will defer ruling on the latter motion until the intervention motion is ripe for review. + +## Background' + +Plaintiffs Jane Doe #1 and Jane Doe #2 are alleged victims of federal sex crimes committed by Jeffrey Epstein in Palm Beach County. Between 2001 and 2007, Epstein sexually abused multiple underage girls at his Palm Beach mansion, including Plaintiffs. In 2006, the Federal Bureau of Investigation ("FBI") opened an investigation into allegations that Epstein was inducing underage girls to engage in sexual acts. The case was eventually presented to the United States Attorney's Office for the Southern District of Florida, which accepted it for investigation. The Palm Beach County State Attorney's Office was also investigating similar allegations against Epstein. Plaintiffs allege that the FBI and U.S. Attorney's Office's investigation developed a strong case for a federal prosecution against Epstein based on "overwhelming" evidence. + +In June 2007, the FBI delivered to Jane Doe #1 a standard victim-notification letter, which explained that the case against Epstein was "under investigation" and notified Jane Doe #1 of her rights under the Crime Victims' Rights Act ("CVRA"). In August 2007, Jane Doe #2 received a similar notification letter. + +In September 2007, Epstein and the U.S. Attorney's Office began plea discussions. The negotiations led to an agreement under which Epstein would plead guilty to two state felony offenses for solicitation of prostitution and procurement of minors for prostitution and the U.S. + +This background discussion is based on the allegations in Plaintiffs' Petition for Enforcement of Crime Victims' Rights Act (DE I) and the Statement of Material Facts in Plaintiffs' Motion for Finding of Violation of the Crime Victims' Rights Act (DEs 48, 52). These allegations are not yet supported by evidence and the Court relies on them here solely to provide the context for the threshold legal issues addressed in this order. As discussed below, further factual development is necessary to resolve the additional issues raised in Plaintiffs' motions. + +Attorney's Office would agree not to prosecute Epstein for federal offenses. On September 24, 2007, Epstein and the U.S. Attorney's Office executed a Non-Prosecution Agreement ("NPA") under these terms. + +Plaintiffs contend that the U.S. Attorney's Office did not confer with them regarding the plea discussions and, in fact, intentionally kept secret the negotiations and the NPA. From September 24, 2007, the day on which the NPA was executed, through June 2008, the U.S. Attorney's Office did not notify either Plaintiff of the existence of the NPA. + +During this period, Plaintiffs communicated multiple times with the FBI and U.S. Attorney's Office, but neither Plaintiff was informed of the NPA. On January 10, 2008, the FBI sent letters to Plaintiffs advising them that "[t]his case is currently under investigation," but failing to disclose the existence of the NPA. On January 32, 2008, Jane Doe #1 met with FBI agents and attorneys from the U.S. Attorney's Office to discuss her abuse by Epstein. The government did not disclose the existence of the NPA. In mid-June 2008, Plaintiffs' counsel contacted the Assistant United States Attorney ("AUSA") handling their case to discuss the status of the investigation. The AUSA did not disclose the existence of the NPA. On June 27, 2008, the U.S. Attorney's Office notified Plaintiffs' counsel that Epstein was scheduled to plead guilty in state court on June 30, 2008. The U.S. Attorney's Office did not disclose the existence of the NPA nor the relationship between Epstein's state plea and the U.S. Attorney's Office's agreement to forgo federal charges. On July 3, 2008, Plaintiffs' counsel sent a letter to the U.S. Attorney's Office stating Jane Doe #1's desire that it bring federal charges against Epstein. + +On July 7, 2008, Jane Doe #1 filed a petition in this Court to enforce her rights under the CVRA! Jane Doe #1 alleged that she believed plea discussions were under way between Epstein and the U.S. Attorney's Office, and that the government, by failing to notify her of this development, had violated her rights under the CVRA. The United States responded to the petition on July 9, 2008, arguing that (1) a federal indictment had never been returned against Epstein and therefore the CVRA did not attach, and (2) nevertheless, the U.S. Attorney's Office had used its best efforts to comply with the CVRA. The government's response also disclosed that the U.S. Attorney's Office had entered into the NPA with Epstein. + +On July 11, 2008, this Court held a hearing on Jane Doe #1's petition, at which Jane Doe #2 was added as a plaintiff. At the hearing, Plaintiffs explained that their petition did not present an emergency and that therefore an immediate resolution was not necessary. On August 14, 2008, the Court held a status conference and ordered the United States to turn over the NPA to all identified victims, including Plaintiffs, and further ordered the parties to work out the terms of a protective order governing the NPA's disclosure. + +This action was relatively inactive for the next year and one-half while Plaintiffs litigated civil actions against Epstein. After those cases settled, Plaintiffs attempted to resolve their CVRA dispute with the U.S. Attorney's Office. On March 18, 2011, after the parties' settlement efforts failed, Plaintiffs filed a series of motions, which the Court now addresses in turn, along with Bruce E. Reinhart's Motion to Intervene. + +&#x27;Jane Doe #2 joined this action after Jane Doe # I filed the initial Petition for Enforcement of Crime Victims' Rights Act. + +#### I. Motion for Finding of Violations of the Crime Victims' Rights Act + +The CVRA was designed to protect victims' rights and ensure them involvement in the criminal justice process. United States v. Moussaoui, 483 F.3d 220, 234 (4ih Cir. 2007); Kenna v. U.S. Dist. Court, 435 F.3d 1011, 1016 (9th Cir. 2006) ("The [CVRAJ was enacted to make crime victims full participants in the criminal justice system."). The statute enumerates the following eight rights: + +- (1) The right to be reasonably protected from the accused. +- (2) The right to reasonable, accurate, and timely notice of any public court proceeding, or any parole proceeding, involving the crime or of any release or escape of the accused. +- (3) The right not to be excluded from any such public court proceeding, unless the court, after receiving clear and convincing evidence, determines that testimony by the victim would be materially altered if the victim heard other testimony at that proceeding. +- (4) The right to be reasonably heard at any public proceeding in the district court involving release, plea, sentencing, or any parole proceeding. +- (5) The reasonable right to confer with the attorney for the Government in the case. +- (6) The right to full and timely restitution as provided in law. +- (7) The right to proceedings free from unreasonable delay. +- (8) The right to be treated with fairness and with respect for the victim's dignity and privacy. + +18 U.S.C. § 3771(a). + +If a prosecution is underway, the CVRA grants victims standing to vindicate their rights in the ongoing criminal action. 18 U.S.C. § 3771(d)(3). If, however, a prosecution is not underway, the victims may initiate a new action under the CVRA in the district court of the + +district where the crime occurred.' Id. The statute also tasks the district courts and the prosecutors with the responsibility of protecting these rights. See 18 U.S.C. § 3771(b)(1) ("[T]he court shall ensure that the crime victim is afforded the rights described in subsection (a)."); § 3771(c)(1) ("Officers and employees of the Department of Justice . . . shall make their best efforts to see that crime victims are notified of, and accorded, the rights described in subsection (a)."). + +Here, Plaintiffs first argue that as a matter of law the CVRA's protections attach before a formal charge is filed against the criminal defendant. Accordingly, Plaintiffs contend that the CVRA applied here and that the U.S. Attorney's Office violated their CVRA rights; namely, their rights to confer, to be treated with fairness, and to accurate and timely notice of court proceedings. Based on these violations, Plaintiffs request that this Court set a briefing schedule and hearing on the appropriate remedy, which according to Plaintiffs is to invalidate the nonprosecution agreement. + +The United States argues that as a matter of law the CVRA does not apply before formal charges are filed, i.e., before an indictment or similar charging document, and therefore does not apply here because formal charges were never filed against Epstein. The United States further argues that even if the CVRA applied here, the U.S. Attorney's Office complied with its requirements. + +The Court first addresses the threshold issue whether the CVRA attaches before the government brings formal charges against the defendant The Court holds that it does because the + +Here, because no criminal case was pending, Plaintiffs filed their petition as a new matter in this judicial district, which the Clerk of Court docketed as a civil action. + +statutory language clearly contemplates pre-charge proceedings. For instance, subsections (a)(2) and (a)(3) provide rights that attach to "any public court proceeding ... involving the crime." Similarly, subsection (b) requires courts to ensure CVRA rights in "any court proceeding involving an offense against a crime victim." Court proceedings involving the crime are not limited to post-complaint or post-indictment proceedings, but can also include initial appearances and bond hearings, both of which can take place before a formal charge. By way of example, under Rule 5(a)(1)(A) of the Federal Rules of Criminal Procedure, upon arrest the defendant must be taken before a magistrate judge "without unnecessary delay" for an initial appearance. If the arrest takes place on a weekday, "without unnecessary delay" will typically require that the initial appearance occur the following morning, which will often be within twenty-four hours of arrest. See United States v. Mendoza, 473 F.2d 697, 702 (56 Cir. 1973) (holding that the government satisfied Rule 5's "without unnecessary delay" requirement by bringing the defendant before the magistrate judge on the first weekday morning following the arrest). By contrast, Rule 5(b) requires that where the defendant is arrested without a warrant, the government must file the complaint "promptly." The Supreme Court has interpreted "promptly" under Rule 5(b) as generally requiring that the complaint be filed within forty-eight hours of arrest. Cnty. Of Riverside v. McLaughlin, 500 U.S. 44, 56-57 (1991). It is therefore possible that where the defendant is arrested on a weekday without a warrant, the initial appearance—which may also involve the detention or bond hearing under Rule 5(d)(3)—will take place before the government files the criminal complaint. + +Subsection (cX1) requires that "Officers and employees of the Department of Justice and other departments and agencies of the United States engaged in the detection, investigation, or + +prosecution of crime shall make their best efforts to see that crime victims are notified of, and accorded, the rights in subsection (a)." (Emphasis added). Subsection (c)(I)'s requirement that officials engaged in "detection [or] investigation" afford victims the rights enumerated in subsection (a) surely contemplates pre-charge application of the CVRA. + +Subsection (d)(3) explains that the CVRA's enumerated rights "shall be asserted in the district court in which a defendant is being prosecuted for the crime or, if no prosecution is underway, in the district court in the district in which the crime occurred." (Emphasis added). If the CVRA's rights may be enforced before a prosecution is underway, then, to avoid a strained reading of the statute, those rights must attach before a complaint or indictment formally charges the defendant with the crime. + +This interpretation is consistent with other federal decisions that have addressed the scope of the CVRA. For instance, in In re Dean, 527 F.3d 391 (5\* Cir. 2008), the court held that subsection (a)(5)'s "right to confer" applied before any prosecution is underway. Id. at 394. Specifically, the court explained: + +The district court acknowledged that "there are clearly rights under the CVRA that apply before any prosecution is underway." Logically, this includes the CVRA's establishment of victims' reasonable right to confer with the attorney for the Government." At least in the posture of this case (and we do not speculate on the applicability to other situations), the government should have fashioned a reasonable way to inform the victims of the likelihood of criminal charges and to ascertain the victims' views on the possible details of a plea bargain. + +Id. at 394 (internal citation and quotation marks omitted). Federal district courts have reached similar conclusions. See, e.g., United States v. Rubin, 558 F. Supp. 2d 411, 417 n.5 (E.D.N.Y. 2008) (discussing victims' "ability to seek pre-prosecution relief' under the CVRA); United States v. Okun, No. 08-132, 2009 WL 790042, at '2 (E.D. Va. Mar. 24, 2009) ("[T]he Fifth + +Circuit has noted that victims acquire rights under the CVRA even before prosecution. This view is supported by the statutory language, which gives the victims rights before the accepting of plea agreements and, therefore, before adjudication of guilt."); United States v. BP Prods N. Am. Inc., No. 07-434, 2008 WL 501321, at \*11 (S.D. Tex. Feb. 21, 2008) ("There are clearly rights under the CVRA that apply before any prosecution is underway."), mandamus denied in part, In re Dean 527 F.3d 391 (5ih Cir. 2008). + +The United States argues that because the CVRA accords rights related to "any court proceeding," 18 U.S.C. §§ 3771(b)(1), (d)(3), and "in the case," § 3771(b)(5), the CVRA applies only after formal charges are filed. The Court finds this argument unavailing. First, as discussed above, "court proceedings" can occur before formal charges are filed. Similarly, subsection (a)(5)'s reference to the right to confer with "the attorney for the Government in the case," is not limited to post-charge proceedings, as the United States is represented by attorneys in each criminal case at, for example, initial appearances and bond hearings.' Last, the government's interpretation ignores the additional language throughout the statute that clearly contemplates pre-charge protections, such as subsection (c)(1)'s mandate that U.S. agencies involved at the "detection" and "investigation" stage use their best efforts to accord victims their enumerated rights under the CVRA and subsection (d)(3)'s provision that victims may vindicate their CVRA + +For this reason, the Court respectfully disagrees with the interpretation adopted in In re Petersen, No. 10-298, 2010 WL 5108692 (N.D. Ind. Dec. 8, 2010), upon which the United States relies. See id. at \*2 (holding that a "victim's `right to be treated with fairness and with respect for [his or her] dignity and privacy' may apply before any prosecution is underway and isn't necessarily tied to a `court proceeding' or `case,'" but concluding that "the right 'to confer with the attorney for the Government in the case' ... arise[s] only after charges have been brought against a defendant and a case has been opened"). But see In re Dean, 527 F.3d at 394 (holding that under subsection (a)(5), "the government should have fashioned a reasonable way to inform the victims of the likelihood of criminal charges"). + +rights even if "no prosecution is underway." See United States v. DBB, Inc., 180 F.3d 1277, 1281 (11ih Cir. 1999) ("[W]e read the statute to give full effect to each of its provisions. We do not look at one word or term in isolation, but instead we look to the entire statutory context.") (citation omitted). + +The Court also rejects the United States' argument that pre-charge CVRA rights could impair prosecutorial discretion and decision-making. Any encroachment into the prosecutors' discretion is expressly limited by the CVRA itself, which provides: "Nothing in this chapter shall be construed to impair the prosecutorial discretion of the Attorney General or any officer under his direction." 18 U.S.C. § 3771(d)(6). As the court explained in Rubin, "there is absolutely no suggestion in the statutory language that victims have a right independent of the government to prosecute a crime, set strategy, or object to or appeal pretrial or in limine orders .... In short, the CVRA, for the most part, gives victims a voice, not a veto." 558 F. Supp. at 418; see also BP Prods N. Am., 2008 WL 501321, at \*15 ("Even under an expansive approach, the reasonable right to confer on a proposed plea agreement and the government's obligation to provide notice of that right is subject to the limit that the CVRA not impair prosecutorial discretion."). Thus, to the extent that the victims' pre-charge CVRA rights impinge upon prosecutorial discretion, under the plain language of the statute those rights must yield. + +Having determined that as a matter of law the CVRA can apply before formal charges are filed, the Court must address whether the particular rights asserted here attached and, if so, whether the U.S. Attorney's Office violated those rights. However, the Court lacks a factual record to support such findings and must therefore defer ruling on these two issues pending the limited discovery discussed below. + +## II. Motion to Have Their Facts Accepted Because of the Government's Failure to Contest Any of the Facts + +For the reasons stated on the record at the August 12, 2011 hearing on this motion, the Court will deny Plaintiffs' request to have their facts accepted as true. + +#### III. Motion for Order Directing the U.S. Attorney's Office Not to Withhold Relevant Evidence + +Plaintiffs request an order from the Court "directing the U.S. Attorney's Office not to suppress material evidence relevant to this case." (DE 50 at 1). Specifically, Plaintiffs seek all information and material known to the government that may be favorable to the victims regarding possible violations of their rights under the CVRA. The United States opposes the motion, arguing that neither the CVRA nor the Federal Rules of Civil Procedure impose a duty upon the U.S. Attorney's Office to provide evidence to Plaintiffs here. + +At the August 12, 2011 hearing on this motion, the United States agreed that this Court, under its inherent authority to manage this case, could impose discovery obligations on each party. Because the Court finds that some factual development is necessary to resolve the remaining issues in this case, it will permit Plaintiffs the opportunity to conduct limited discovery in the form of document requests and requests for admissions from the U.S. Attorney's Office. Either party may request additional discovery if necessary. + +Because the Court will allow this limited factual development, it is unnecessary to decide here whether the CVRA or the Federal Rules of Civil Procedure provide discovery rights in this context. The Court therefore reserves ruling on Plaintiffs' motion. + +## IV. Bruce E. Reinhart's Motion to Intervene or in the Alternative for a Sua Sponte Rule 11 Order + +Bruce E. Reinhart seeks leave to intervene as a party-in-interest under Rule 24(b) of the Federal Rules of Civil Procedure. Reinhart seeks to intervene to file a motion for sanctions based on allegedly "unfounded factual and legal accusations made about Movant in Plaintiffs' Motion for Finding of Violations of the Crime Victims' Rights Act." (DE 79 at 1). In that motion, Plaintiffs alleged that Reinhart, a former Assistant U.S. Attorney, "joined Epstein's payroll shortly after important decisions were made limiting Epstein's criminal liability" and improperly represented Epstein victims in follow-on civil suits. (DE 48 at 22). Plaintiffs contend that such conduct "give[s], at least, the improper appearance that Reinhart may have attempted to curry [favor] with Epstein and then reap his reward through favorable employment." (DE 48 at 23). Reinhart takes great offense to these accusation—which he contends are false, irrelevant to the CVRA claims, and gratuitous—and seeks intervention to rebut these allegations and move for sanctions. + +Under Rule 24(b) of the Federal Rules of Civil Procedure, "the court may permit anyone to intervene who ... has a claim or defense that shares with the main action a common question of law or fact." It is "wholly discretionary with the court whether to allow intervention under Rule 24(b) and even though there is a common question of law or fact, or the requirements of Rule 24(b) are otherwise satisfied, the court may refuse to allow intervention." In re Bayshore Ford Trucks Sales, Inc., 471 F.3d 1233, 1246 (11th 2006). The Court will deny Reinhart's request to intervene. + +First, the Court finds that Reinhart's claim does not share a common question of law or fact with the CVRA action. Reinhart claims that two paragraphs of Plaintiffs' forty-page motion make groundless and bad-faith accusations against his integrity and character. However, the veracity of Plaintiffs' two paragraphs—i.e., whether Reinhart used his position at the U.S. Attorney's Office to ingratiate himself with Epstein and advance his career in private practice—involves no common questions with the Plaintiffs' claims that the U.S. Attorney's Office violated their CVRA rights through the process in which it entered into the NPA with Epstein. Indeed, Reinhart's motion argues that the allegations against him are "irrelevant" and that Plaintiffs "do[] not make any effort to connect these allegations to the relief [they] seek[]." (DE 79 at 2). + +Second, even if these accusations shared common questions with Plaintiffs' CVRA claims, the Court would exercise its discretion and deny intervention. The Court cannot permit anyone slighted by allegations in court pleadings to intervene and conduct mini-trials to vindicate their reputation. Absent some other concrete interest in these proceedings, the Court does not believe that the allegations here are sufficiently harmful to justify permissive intervention. Reinhart has publicly aired his opposition to and denial of Plaintiffs' contentions, both on this docket and in open court, and the Court finds that further proceedings on this issue are unwarranted. For the same reason, the Court declines to conduct a sua sponte Rule 11 inquiry. + +## Conclusion + +For the foregoing reasons, it is hereby ORDERED AND ADJUDGED that Plaintiffs' Motion for Finding of Violations of the Crime Victims' Rights Act (DEs 48, 52) is GRANTED IN PART. The Court concludes that the CVRA can apply before formal charges are filed. The + +Court defers ruling on the merits of Plaintiffs' CVRA claims until the parties complete the discovery ordered herein. + +It is further ORDERED AND ADJUDGED that Plaintiffs' Motion to Have Their Facts Accepted (DE 49) is DENIED. + +The Court reserves ruling Plaintiffs' Motion for Order Directing the U.S. Attorney's Office Not to Withhold Relevant Evidence (DE 50) pending the discovery ordered herein. + +It is further ORDERED AND ADJUDGED that Bruce E. Reinhart's Motion to Intervene or in the Alternative for a Sua Sponte Rule 11 Order (DE 79) is DENIED. + +DONE AND ORDERED in Chambers at West Palm Beach, Palm Beach County, Florida this 26ih day of September, 2011. + +> rZ ge KENNETH A. 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I was planning on meeting over at the FBI. + +In light of request, I will reschedule at a time that works for + +do you want to attend? + +AUSA + +From: (USAFLS) + +Sent: Friday, October 07 2011 02:56 PM + +To: (USAFLS); (USAFLS) + +Subject: RE: Epstein + +Has someone talked to yet about the meeting? I know that he is scheduled to give a mandatory ethics lecture that morning in Miami. + +From: (USAFLS) + +Sent: Frida October 07, 2011 2:22 PM + +To: (USAFLM ; . (USAFLS) + +Cc: (USAFLM); (USAFLS) + +Subject: RE: Epstein + +Thanks I am also including his familiarity with some of the legal issues we face. Thanks. on this e-mail given + +From: (USAFLM) + +Sent: Friday, October 07, 2011 2:20 PM + +To: aril= (USAFLS); (USAFLS) + +Cc: (USAFLM) + +Subject: Epstein + +I am the AUSA from the MDFL assigned to the Epstein matter. In that regard, and I have arranged for a meeting in West Palm Beach for a full debriefing on all issues. I would like to include in that meeting, which we have set for October 27, 2011. + +Regards, \ No newline at end of file diff --git a/marker2/ds9/EFTA00205705/EFTA00205705.metadata.json b/marker2/ds9/EFTA00205705/EFTA00205705.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..636b66eee4286022139dfb67634e0f5b87e622c9 --- /dev/null +++ b/marker2/ds9/EFTA00205705/EFTA00205705.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205705.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1182, + "elapsed_seconds": 1.34, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 83 + ], + [ + "Line", + 41 + ], + [ + "Text", + 29 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205705" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205706/EFTA00205706.md b/marker2/ds9/EFTA00205706/EFTA00205706.md new file mode 100644 index 0000000000000000000000000000000000000000..8160f95a6832f0d61dd16c734ba26465d7f86650 --- /dev/null +++ b/marker2/ds9/EFTA00205706/EFTA00205706.md @@ -0,0 +1,71 @@ +To:"- (USAFLS)" < + +Subject: Re: Epstein + +Date: Fri, 07 Oct 2011 19:23:51 +0000 + +Importance: Normal + +is starting a trial. I will see what I can do on Tuesday. + +AUSA + +From: (USAFLS) + +Sent: Friday, October 07,\_201103:21 PM + +To: . (USAFLS); (USAFLS) + +Subject: RE: Epstein + +Sure. But given the timetable created by the Jane Does' discovery request, do you think it would be possible to meet earlier than October 27th? If some district (whether MDFL or some other district) with venue and jurisdiction over the offenses is going to evaluate potential criminal charges and is willing to confer with Jane Does as part of that evaluation, it seems to me that it would be helpful to know that sooner rather than later for purposes of the CVRA litigation and the contemplated motion to dismiss. What do you think? + +By the way, was the MDFL given a copy of the NPA? I think they should be made aware that they should carefully review it to ensure that they do not run afoul of it. + +• + +From: (USAFLS) + +Sent: Frida October 07, 2011 3:11 PM + +To: (USAFLS); (USAFLS) + +Subject: Re: Epstein + +No, I just talked to yesterday afternoon and he wanted to discuss the underlying investigation. I was planning on meeting over at the FBI. + +In light of request, I will reschedule at a time that works for + +IS do you want to attend? + +AUSA + +From: (USAFLS) + +Sent: Friday, October 07 2011 02:56 PM + +To: (USAFLS); (USAFLS) + +Subject: RE: Epstein + +Has someone talked to yet about the meeting? I know that he is scheduled to give a mandatory ethics lecture that morning in Miami. + +Thanks I am also including mail given his familiarity with some of the legal issues we face. Thanks. on this e- + +From: (USAFLM) + +Sent: Frida October 07 2011 2:20 PM + +To: (USAFLS); (USAFLS) + +Cc: (USAFLM) + +Subject: Epstein + +I am the AUSA from the MDFL assigned to the Epstein matter. In that regard, Marie Villafana and I have arranged for a meeting in West Palm Beach for a full debriefing on all issues. I would like to include Lee in that meeting, which we have set for October 27, 2011. + +Regards, + +Assistant U.S. Attorney + +Fort Myers Division, MDFL \ No newline at end of file diff --git a/marker2/ds9/EFTA00205706/EFTA00205706.metadata.json b/marker2/ds9/EFTA00205706/EFTA00205706.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..431992bbb8b5d6651e2b7c9920c582a7a27d17aa --- /dev/null +++ b/marker2/ds9/EFTA00205706/EFTA00205706.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205706.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2096, + "elapsed_seconds": 1.41, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 81 + ], + [ + "Line", + 40 + ], + [ + "Text", + 29 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 42 + ], + [ + "Line", + 22 + ], + [ + "Text", + 13 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205706" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205708/EFTA00205708.md b/marker2/ds9/EFTA00205708/EFTA00205708.md new file mode 100644 index 0000000000000000000000000000000000000000..90b3345889f1b6b78b2be32f06bf59a6df4c9018 --- /dev/null +++ b/marker2/ds9/EFTA00205708/EFTA00205708.md @@ -0,0 +1,13 @@ +Subject: Time for a call? + +Date: Tue, 11 Oct 2011 17:09:25 +0000 + +Importance: Normal + +Attachments: DE105\_20111010 Jane\_Does\_Motn\_for Excess\_Pages\_re\_Suppl\_Briefing.pdf; DE106- 1\_Transcript\_of New\_York\_Sex\_Offender Registration\_hearing.pdf; DE106\_20111010 Jane\_Does\_Resp\_to\_Suppl\_Briefing.pdf + +M - I am in Bogota, but I can easily give you a call. Just let me know what time works for you. Also, here are the items just filed by the learned professor. And, I just got a voicemail from Jay Lefkowitz (Mr. Epstein's lawyer). He didn't say why he was calling. + +«DE105\_20111010 \_Jane Does Motn for Excess Pages re Suppl Briefing.pdf>> <> «DE106\_20111010 \_Jane Does Resp to Suppl Briefing.pdf>> + +![](_page_0_Picture_6.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00205708/EFTA00205708.metadata.json b/marker2/ds9/EFTA00205708/EFTA00205708.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f15249643432ff9fe3605a3661850d54396a47ca --- /dev/null +++ b/marker2/ds9/EFTA00205708/EFTA00205708.metadata.json @@ -0,0 +1,60 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205708.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 811, + "elapsed_seconds": 0.44, + "image_assets": [ + "_page_0_Picture_6.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 26 + ], + [ + "Line", + 12 + ], + [ + "Text", + 6 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205708" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205708/_page_0_Picture_6.jpeg b/marker2/ds9/EFTA00205708/_page_0_Picture_6.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..97d0cfb16c4d198668658e815c637e5373b4f359 --- /dev/null +++ b/marker2/ds9/EFTA00205708/_page_0_Picture_6.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:fd387a3316b4454e805ce374648c54b16e69b9b783d6433d2bd31e33426c8d2d +size 6150 diff --git a/marker2/ds9/EFTA00205709/EFTA00205709.md b/marker2/ds9/EFTA00205709/EFTA00205709.md new file mode 100644 index 0000000000000000000000000000000000000000..45ceb709927679a131dec0d7f6924a1d8f385616 --- /dev/null +++ b/marker2/ds9/EFTA00205709/EFTA00205709.md @@ -0,0 +1,49 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA + +Case No. 08-80736-Civ-Marra/Johnson + +JANE DOE #1 and JANDE DOE #2 + +v. + +UNITED STATES + +## JANE DOE #1 AND JANE DOE #2'S UNOPPOSED MOTION FOR FIVE EXTRA PAGES TO RESPOND TO SUPPLEMENTAL BRIEFING IN SUPPORT OF MOTION TO INTERVENE BY ROY BLACK ET AL. + +COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to move this Court to allow them five extra pages beyond the twenty-page limit to respond to the Supplemental Briefing in Support of Motion to Intervene of Roy Black, Martin Weinberg, and Jay Lefkowitz (DE 94) and the government response thereto (DE 100). The motion is unopposed. + +In support of the motion, the victims note that initial Supplemental Briefing from Epstein they are responding to (DE 94) is 23 pages long. The Government's response (DE 100) supports many of Epstein's arguments and is 11 pages long. As a result, the victims have a total of 33 pages that they need to respond to. The victims require 25 pages to set forth all of their arguments and authorities on the issues addressed in the briefs. The victims have discussed this motion with counsel for Epstein and the Government, and they do not oppose the motion. + +## CONCLUSION + +For all the foregoing reasons, the Court should allow Jane Doe #1 and Jane Doe #2 an additional five pages (a total of 25 pages) to respond to the Supplemental Briefing in Support of Motion to Intervene of Roy Black, Martin Weinberg, and Jay Lefkowitz (DE 94) and the government response thereto (DE 100). + +DATED: October 10. 2011 + +Respectfully Submitted, + +5/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. + +Fort Lauderdale, Florida 33301 + +and + +Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the Universit of Utah + +Salt Lake City, UT 84112 + +Attorneys for Jane Doe #1 and Jane Doe #2 + +## CERTIFICATE OF SERVICE + +The foregoing document was served on October 10, 2011, on the following using the Court's CM/ECF system: + +A. Marie Villafafia Assistant U.S. Attorney + +West Palm Beach, FL 33401 + +Attorney for the Government + +Roy Black, Esq. Jackie Perczek, Esq. Black, Srebnick, Komspan & Stumpf, P.A. + +Miami, FL 33131 Attorneys for Proposed Intervenors Roy Black et al. \ No newline at end of file diff --git a/marker2/ds9/EFTA00205709/EFTA00205709.metadata.json b/marker2/ds9/EFTA00205709/EFTA00205709.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..59ec6961cad644eaa11e5fc58ce47bf9dc719795 --- /dev/null +++ b/marker2/ds9/EFTA00205709/EFTA00205709.metadata.json @@ -0,0 +1,231 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205709.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 2295, + "elapsed_seconds": 0.75, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF FLORIDA", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 199.512, + 98.82 + ], + [ + 412.1432800292969, + 98.82 + ], + [ + 412.1432800292969, + 127.353515625 + ], + [ + 199.512, + 127.353515625 + ] + ] + }, + { + "title": "JANE DOE #1 AND JANE DOE #2'S UNOPPOSED MOTION FOR FIVE EXTRA \nPAGES TO RESPOND TO SUPPLEMENTAL BRIEFING IN SUPPORT OF MOTION \nTO INTERVENE BY ROY BLACK ET AL.", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 75.888, + 263.25 + ], + [ + 536.25927734375, + 263.25 + ], + [ + 536.25927734375, + 306.60357666015625 + ], + [ + 75.888, + 306.60357666015625 + ] + ] + }, + { + "title": "CONCLUSION", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 261.936, + 85.05 + ], + [ + 349.8327941894531, + 85.05 + ], + [ + 349.8327941894531, + 99.9735107421875 + ], + [ + 261.936, + 99.9735107421875 + ] + ] + }, + { + "title": "CERTIFICATE OF SERVICE", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 223.38, + 84.24 + ], + [ + 388.9544677734375, + 84.24 + ], + [ + 388.9544677734375, + 99.603515625 + ], + [ + 223.38, + 99.603515625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 46 + ], + [ + "Line", + 23 + ], + [ + "Text", + 6 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 45 + ], + [ + "Line", + 22 + ], + [ + "Text", + 9 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 29 + ], + [ + "Line", + 15 + ], + [ + "Text", + 6 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205709" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205712/EFTA00205712.md b/marker2/ds9/EFTA00205712/EFTA00205712.md new file mode 100644 index 0000000000000000000000000000000000000000..0db1a292eb76ddd2269a9264e09a3b3ddd5e9c4e --- /dev/null +++ b/marker2/ds9/EFTA00205712/EFTA00205712.md @@ -0,0 +1,721 @@ +## EXHIBIT A + +SUPREME COURT NEW YORK COUNTY + +TRIAL TERM PART 66 + +x THE PEOPLE OF THE STATE OF NEW YORK: INDICTMENT # : 30129/2010 • + +AGAINST + +JEFFREY EPSTEIN + +Defendant. + +## BEFORE: + +x SORA HEARING + +111 Centre Street New York, New York 10013 January 18, 2011 + +HONORABLE RUTH PICKHOLZ Justice of the Supreme Court + +## APPEARANCES: + +For the People: CYRUS R. VANCE, JR., ESQ., New York County District Attorney One Hogan Place New York, New York 10013 BY: JENNIFER GAFFNEY, ESQ. Assistant District Attorney + +For the Defense: KIRKLAND & ELLI, LLP 153 East 53rd Street New York, New York 10022 BY: JAY LEFKOWITZ, ESQ. SANDRA MUSUMECI, ESQ. + +> Vikki J. Benkel Senior Court Reporter + +C4 + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +COURT CLERK: This is number two on the calendar, matter of Jeffrey Epstein. + +Your appearances please. + +MS. GAFFNEY: Jennifer Gaffney for the People. + +Good afternoon, Your Honor. + +MR. LEFKOWITZ: Jay Lefkowitz and Sandra Musumeci for Mr. Epstein. + +THE COURT: Mr. Epstein is not here. + +MR. LEFKOWITZ: That's correct. + +THE COURT: Are you waiving his appearance? + +MR. LEKWOWITZ: Yes. + +MS. GAFFNEY: Your Honor, this case is on for a SORA hearing this afternoon. + +The People did receive the board's recommendation of a Level Three. However, we received the underlying information from them and also had some contact with Florida, and we don't believe that we can rely on the entire probable cause affidavit. + +Idon't know if the board sent that to you as well. + +THE COURT: I don't know why you cannot rely on it. + +MS. GAFFNEY: Because in Florida of all of the victims in that probable cause affidavit, they actually only went forward on one case. There was only an indictment for + +one victim and that is what the defendant plead to. + +So it is unlike a situation where everything was indicted and then we get to sort of assess points for all of the victims, if it was part of a plea bargain. They did not actually choose to go forward on any except for the one victim. + +So under the board guidelines, the risk assessment interim guidelines, it actually says, you know, by way of contrast if an offender is not indicted for an offense, it is strong evidence that the offense did not occur and I don't think -- + +THE COURT: Do you find that if somebody is not indicted it is strong evidence that it did not occur? + +MS. GAFFNEY: I don't know that we can rely on it as clear and convincing evidence if the prosecutor's office never went forward on it. The prosecution said that the victims, although they spoke to the police early on, did not cooperate with them. So we don't have any follow up information. + +THE COURT: But the board found a Level Three. + +I have to tell you, I am a little overwhelmed because I have never seen the prosecutor's office do anything like this. I have never seen it. I had a case with one instance it was a marine who went to a bar, and I wish I had the case before me, but he went to a bar and a 17 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +year old, he was an adult obviously, he was aMarine, a 17 year old came up to him and one thing lead to another and he had sex with her and the People would not agree to a downward modification on that. + +So I am alittle overwhelmed here because I see -- Imean I read everything here, I am just a little overwhelmed that the People are making this application. + +Icould cite many many, I have done many SORAs much less troubling than this one where the People would never make a downward argument like this. + +MS. GAFFNEY: I agree with Your Honor, it is incredibly unusual for us to make a downward argument. But the problem is the one thing that we have from the board is it seems to be in contradiction to their own guidelines which if something was not indicted, you are not supposed to rely on it. + +THE COURT: They obviously took that into consideration. + +MS. GAFFNEY: And I tried to reach -- I reached the authorities in Florida to try to see if they had all the interview notes or other things that we can then subsequently rely on that might be considered clear and convincing evidence, if they had interviewed these women on their own, and they never did. No one was cooperative and they did not go forward on any of the cases and none of them + +were indicted. So I don't know. + +THE COURT: And you spoke to the prosecutor? + +MS. GAFFNEY: The actual prosecutor left the office. I spoke to the prosecutor that took over the case. + +THE COURT: Maybe you can find the prosecutor that left the office. + +You have done more in other cases looking into it. I have never seen the prosecutor's office do this. I have to tell you, I am shocked. + +MS. GAFFNEY: Right, but I spoke to the prosecutor that took over the case and they don't have anything, any affidavits, any statements, any notes. + +THE COURT: Why don't you speak to the prosecutor that did do the case, I am sure you could find that prosecutor. + +MS. GAFFNEY: I can find her, but based upon what the other prosecutor said, they did not speak to that prosecutor either. + +THE COURT: You did not speak to the prosecutor yourself, you did not speak to them, that is hearsay. You did not speak to the prosecutor that handled the case. + +MS. GAFFNEY: That's right. + +THE COURT: I don't think you did much of an investigation here. + +MS. GAFFNEY: I mean I called the prosecutor. + +Even though the first prosecutor left, presumably the prosecutor's office has the file. + +THE COURT: I would still call the prosecutor. + +MS. GAFFNEY: Anything from these women they would have forwarded it to us. + +THE COURT: I don't know that, I think you have to speak to the prosecutor. + +But be that as it may, I hear your argument. + +Anything else? + +MS. GAFFNEY: I mean that is why I don't think we can, I don't think we are entitled to rely on this because they did not go forward. + +THE COURT: The board made a recommendation. + +MS. GAFNEY: Correct. + +MS. MUSUMECI: May I speak, Your Honor? + +THE COURT: Yes. + +MS. MUSUMECI: Good afternoon. + +I would like to bring a few additional points to Your Honor's attention that don't come across in the board recommendation. + +The first is that Mr. Epstein is not a resident of New York, unlike most of these out of state, he has not changed his address and moved to New York, he maintains a vacation home in New York. His primary residence is the U.S. Virgin Islands. + +He is registered in the U.S. Virgin Islands, he has been since his release from jail. He notifies the Virgin Island authorities every time he leaves that jurisdiction. Virgin Island authorities rated him at the lowest level of registration. + +He also registered in Florida, which is the state of this particular offense, and the only reason that this conviction is even before Your Honor. + +The offense for which he was convicted is not a registrable offense in New York. He is only registrable here arguably because based on the provision of SORA that says if a crime is registrable in the state of conviction, then it is registrable here in New York. And the Florida authorities that considered that rated him at the lowest level of their SORA statute. + +He additionally has a vacation home in New Mexico and is registered in New Mexico. The New Mexican authorities when they considered his offenses, determined he need not register at all. Nevertheless, he has voluntarily registered with New Mexico and maintains that registration. + +Additionally, because of his possession of a vacation home in New York, he has been voluntarily registered with New York SOMU, the Sex Offender Monitoring Unit since May of this year. He notifies them whenever he comes to travel to New York. He never comes to New York for + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +more than seven days or at least he has not since he has been registered. He has no intention to ever be here for longer than a period of ten days. + +Like I said, he does notify the authorities when he is here. He fully understands the reason for voluntary registration, he wants to be compliant with the Federal SORA law which requires wherever you own aproperty to register. + +To require Mr. Epstein to register as a Level Three offender in New York would actually require him to come to New York more than he does normally, it would require him to come every 90 days and renew his registration. + +He is very diligent in registering with New York authorities. + +All of the other jurisdictions that have considered his case have determined that he either not register at all or register at the lowest level, and he has been more than compliant with all of those requirements. + +Your Honor, we would join in the prosecutor's application. + +THE COURT: I am sure you would. + +MS. MUSUMECI: By way of background, we have been in contact with the prosecutor's office on this matter since Ibelieve certainly since Mr. Epstein got his notification, which I believe was in August. We have met with the + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +prosecutor and provided numerous materials for the prosecutor to consider. We have included in that a deposition from the detective who headed this investigation who acknowledged in a sworn deposition that the lead prosecutor who originally had the case, whose name I cannot pronounce, Lanna Belohlavek, I apologize for the mispronunciation, said to the detective after her investigation, there are no real victims here. + +All of the alleged conduct that is cited in the board's write up was commercial conduct. All of the alleged conduct the women went voluntarily, there are no allegations of force certainly none. + +THE COURT: There was no allegation of force in the marine either, who met a girl in a bar, a young girl 17, there was no force there. + +MS. MUSUMECI: It is our understanding that the prosecutor in Florida conducted a full investigation, as full as she was able with the cooperation afforded by these complainants, and determined that the only case that she could present to the grand jury was this indictment for a non registrable offense then -- + +THE COURT: But it is registrable here. + +I don't know what you mean non registrable offense. + +MS. MUSUMECI: Let me explain, Your Honor. + +Mr. Epstein plead to two charges, one was an indictment which is an offense that is not registrable, it is a Florida indictment for -- + +THE COURT: Then why does he have to register here? + +MS. MUSUMECI: It was a second offense that he plead to -- + +THE COURT: That is registrable. + +MS. MUSUMECI: That is registrable. + +That offense was by information and that is the only registrable offense, that is what the DA's office is considering in doing their scoring. + +The indictment which was the only case that the prosecutor even prosecuted through grand jury is not even a registrable offense. + +THE COURT: He plead guilty to a registrable offense. + +MS. MUSUMECI: Yes. + +THE COURT: What did he plead guilty to? + +MS. GAFFNEY: He plead guilty to the procuring a person under 18 for prostitution. + +THE COURT: Procuring a person under 18 for prostitution. + +MS. GAFFNEY: Right. + +THE COURT: Haw old was she? + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +MS. GAFFNEY: It appears the first time they met she was either 16 or 17, then for the remainder of their relationship she was probably 17. + +THE COURT: Haw long was their relationship? + +MS. GAFFNEY: She met, she gave him approximately 15 massages, including with sexual contact, and ultimately when she is 17 had intercourse with him. + +THE COURT: She is a child. + +MS. MUSUMECI: Your Honor, I would note that under SORA it is clear that prostitution offenses are only registrable when in fact by clear and convincing evidence the women or victim is 17, is under 17. + +THE COURT: Well, she met him at 16, he procured her at 16 from what I read. + +MS. MUSUMECI: There is evidence we challenged. + +THE COURT: He plead guilty to that, didn't he? + +MS. MUSUMECI: He plead guilty to under 18, which is the law in Florida, which is a different standard than what the law is in New York. And there is no evidence, there is no clear and convincing evidence as to her specific age at the time of the specific conduct. + +THE COURT: Well, the DA just told me she was most likely 17, she just said it on the record. + +MS. MUSUMECI: Your Honor, we agree that the evidence is that she was 17 on the one occasion she had + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +consensual intercourse with him and 17 is not registrable or criminal under New York law. + +And the prostitution aspect of having intercourse with a 17 year old is not registrable conduct. + +THE COURT: Why does he have to register here? + +MS. GAFFNEY: Because it is a register able offense in Florida, New York State board of examiners -- + +THE COURT: Recognizes it. + +MS. GAFFNEY: Recognizes it, yes. + +THE COURT: I have had many cases like that where it was not registrable here but it was in the state where the person came from and New York recognized that. + +MS. MUSUMECI: Your Honor, we are not saying that he should not register. Mr. Epstein has already registered and recognizes his duty to register. + +THE COURT: I am glad of that, very glad of that. + +I am sorry he may have to come here every 90 days. + +He can give up his New York home if he does not want to come every 90 days. + +Anything else? + +I rely on the board. + +MS. MUSUMECI: Your Honor, we would reserve our right to appeal Your Honor's ruling. + +THE COURT: Of course, do so. + +MS. GAFFNEY: For the record, Your Honor, he is + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +going to be deemed a Level Three sex offender with no designation, correct? + +THE COURT: Correct. + +MS. MUSUMECI: For purposes of the appeal I believe that Your Honor -- + +THE COURT: Give me the board's scoring. + +The board has scored use of violence the least, 10. + +Sexual contact with victim, 25. I agree. + +Number of victims, three or more. He only plead guilty to one, but apparently there were more than one and I think the People concede that although they say it was not reliable. + +Duration of offense, conduct with victim, continuing course of sexual misconduct, the People have told me it was continuing for 20 points. + +Age of victim 11 through 16, he got 20 points for that, and she was 16 at the time. + +Other victim characteristics, there was no mental disable or helplessness. I agree. + +Relationship with victim stranger, 20 points. + +Age at first act of sexual misconduct, 20 or less. They scored him zero on that. + +Number and nature of prior crimes, no history, they scored him five on that. + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +Recency of prior offense less than three years, they gave him zero. + +Drug or alcohol abuse history, they gave him zero. + +Acceptance of responsibility, they gave him zero. + +Conduct while confined, they gave him zero. + +And supervision, they gave him zero. + +Living employment situation, zero. + +They gave him 130 points, which is the highest level, and I agree with that. + +MR. LEFKOWITZ: If I could be heard for one moment. + +It appears that the state board made its determination based on access to a police report in Florida. + +The prosecutor, the lead prosecutor, the lead sex crimes prosecutor in Palm Beach made a determination that the complainants and the police report itself was not credible and decided not to prosecute on the basis of all of that. + +In addition, there has been through the course of the last few years some civil litigation, as you might imagine, involving these matters and we now have sworn testimony in evidence from the complainants themselves disclaiming much of what appears in the police report. + +So, Your Honor, we would submit and this is not to make light in any way of the conduct what Mr. Epstein did or + +1 what Mr. Epstein plead guilty to, but with respect to +2 everything and that is why Mr. Epstein voluntarily +3 registered in New York even though there is a question about +4 whether he has any obligation just as a jurisdictional +5 matter, but Your Honor, with respect to the appropriate +6 level for him to register, we would submit Your Honor that +7 the evidence simply does not support the foundation of the +8 state's determination. + +9 THE COURT: You have made a very clear record and +10 you have your right to appeal. + +11 I feel the board looked into all of this, made +12 their recommendation, found him to have 130 points and I see +13 no reason to disturb that. + +14 Thank you. + +15 +16 I, Vikki J. Benkel, a Senior Court Reporter in and for +17 the State of New York, do hereby certify that the foregoing +18 transcript is true and accurate to the best of my knowledge, +19 skill and ability. + +![]()22 Vikki J. 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"debug_data/EFTA00205712" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205728/EFTA00205728.md b/marker2/ds9/EFTA00205728/EFTA00205728.md new file mode 100644 index 0000000000000000000000000000000000000000..374f02acc19373e9e227ccb9faa386f07656829a --- /dev/null +++ b/marker2/ds9/EFTA00205728/EFTA00205728.md @@ -0,0 +1,243 @@ +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA + +Case No. 08-80736-Civ-Marra/Johnson + +JANE DOE #1 and JANE DOE #2 + +v. + +UNITED STATES + +### JANE DOE #1 AND JANE DOE #2'S RESPONSE TO SUPPLEMENTAL BRIEFING IN SUPPORT OF MOTION TO INTERVENE OF ROY BLACK. MARTIN WEINBERG, AND JAY LEFKOWITZ + +COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to respond in opposition to the supplemental briefing of defense attorneys Roy Black, Martin Weinberg, and Jay Lefkowitz to intervene in this case under Fed. R. Civ. P. 24(a) (DE 94) ("supplemental briefing"). + +The victims continue to oppose the defense attorneys' motion to intervene in this civil CVRA enforcement action (DE 56) for all the reasons that they have articulated in their previous opposition (DE 78). Yet even though the defense attorneys have not been permitted to intervene, they have proceeded to brief the merits of arguments that they would present if the Court were to grant intervention, including most recently new "supplemental" briefing on the discoverability of plea negotiation correspondence. While the victims continue to believe that their arguments against the defense attorneys intervening are meritorious, out of an abundance of caution and to expedite this case, the victims now respond to the defense attorneys' new claims on the merits. + +The defense attorneys claim that the victims cannot use at trial (or even discover preliminarily) correspondence between them and the U.S. Attorney's Office arranging a highly unusual and secretive non-prosecution agreement. The victims have already explained at length why the correspondence between Epstein's lawyers and government prosecutors is simply not confidential material to which any kind of privilege or other protection could attach. See Jane Doe #1 and Jane Doe #2's Response to Motion to Intervene (DE 78) at 4-6. Perhaps recognizing the strength of the victims' response, the defense attorneys now raise a new "supplemental" argument that a privilege somehow follows from either (1) Federal Rule of Evidence 410 or (2) a purported "common law privilege" for "plea negotiations" that the attorneys ask the Court to create under Federal Rule of Evidence 501. The defense arguments are meritless for multiple, independent reasons. + +With regard to Rule 410, the defense attorneys' efforts to invoke Rule 410 is simply premature. The rule bars only admissibility of information at trial, not collection of information through discovery. Accordingly, discovery is proper now and admissibility issues can be sorted out later. + +Second, this Court previously ruled in the civil case against Epstein that Rule 410 does not bar discovery of the correspondence. Epstein is collaterally estopped from re-litigating this same issue. + +Third, in any event, Rule 410 is simply inapplicable. The plain language of the rule covers admissibility into evidence of "any statement made in the course of plea discussions with an attorney for the prosecuting authority which do not result in a plea of guilty." Fed. R. Evid. 410(4) (emphasis added). Epstein's plea discussions did result in a plea of guilty, and accordingly the rule does not apply. + +Fourth, the victims intend to use the correspondence to prove that the Government violated the CVRA violations and that various remedies are accordingly appropriate. Because Rule 410 only bars evidence from being admitted into evidence "against the defendant" who participated in plea discussions, the victims are (at the very minimum) entitled to obtain and use the correspondence in litigation with the Government. + +Fifth, Rule 410 makes plea bargaining statements admissible "in any proceeding wherein another statement wade in the course of the same plea discussions has been introduced and the statement ought in fairness be considered contemporaneously with it." Fed. R. Evid. 410. The Government has made clear that it intends to introduce considerable evidence about the course of plea discussions in this case in support of its position. As a matter of fairness, the victims are therefore entitled to discover evidence from the Government that might support their position. + +In addition to their Rule 410 argument, the defense attorneys quickly advance a fallback argument — that the Court should create a heretofore unrecognized "common law privilege" under Rule 501 of the Federal Rules of Evidence. This claim also lacks merit. + +First, the Court cannot create a "common law" plea bargaining privilege that would overturn limits that Congress crafted in Rule 410. Congress extended protection only to plea discussions "which do not result in a plea of guilty." Fed. R. Evid. 410(4) (emphasis added). Whatever the Court's "common law" rulemaking authority maybe, it certainly does not extend to trumping specific language in the Federal Rules of Evidence. + +Second, no such "common law" privilege exists. While the defense attorneys frequently allude to "constitutional considerations" that supposedly undergird plea bargain, the simple fact remains that "there is no constitutional right to plea bargain." Weatherford v. Bursey, 429 U.S. 545, 561 (1977). The Court should not exalt to privileged status negotiations that merely serve the administrative convenience of the parties over the important value of truth seeking. + +The Government has also filed a response to the supplemental briefing of the defense attorneys (DE 100), in which it claims that its plea bargaining correspondence with Epstein's lawyers is confidential work product material. The Government's arguments are without merit for three reasons. First, as the victims have previously explained, all the correspondence is discoverable because the CVRA requires the Government to makes its "best efforts" to support the victims. 18 U.S.C. § 3771(c)(1). Second, the CVRA bars the Government from erecting an adversarial work product privilege against the victims when they are attempting to secure information to protect their CVRA rights. Third, entirely apart from the CVRA, work product protections only extend to confidential materials. If the Government wishes to litigate this issue, it must prepare a privilege log. But the correspondence with defense attorneys is simply not confidential and therefore not protected by the work product doctrine. + +## I. THE CORRESPONDENCE BETWEEN THE GOVERNMENT AND EPSTEIN IS NOT PROTECTED FROM DISCOVERY BY FEDERAL RULE OF EVIDENCE 410. + +The defense attorneys claim that, under Fed. R. Evid. 410, the victims cannot seek discovery of plea bargaining correspondence between them and the Government. Their arguments are unavailing. + +# A. RULE 410 DOES NOT BAR DISCOVERY OF THE CORRESPONDENCE. + +The defense attorneys' reliance on Rule 410 is simply premature. By its plain terms, the rule bars only admissibility of information at trial against the defendant who made the plea - the Rule does not apply to the discovery phase at all. See Fed. R. Evid. 410 (barring use of certain "evidence" in a "civil or criminal proceeding"). Accordingly, the victims can discover the correspondence now and the court can sort out trial admissibility issues later. + +#### B. EPSTEIN IS COLLATERALLY ESTOPPED FROM RELITIGATING THE APPLICABILITY OF RULE 410. + +As the Court is well aware, the issue of whether the correspondence was somehow protected by Rule 410 was thoroughly litigated by the defense attorneys' client (Jeffrey Epstein) more than a year ago, and Epstein's arguments were more appropriate in the previous case (where he was actually a party to the litigation and the information discovered would likely be admitted against him). This Court rejected Epstein's arguments against disclosure in that case as well, including his argument that Rule 410 blocked disclosure. See, e.g., Jane Doe v. Epstein, doc. #462 at 10, Case No. 9:08-CV-80119-ICAM (Feb. 4, 2010). + +The defense attorneys now propose to relitigate the very same issue of Rule 410's applicability in this case. Their effort to revisit the issue is barred by the doctrine of collateral estoppel because: "(1) the issue at stake is identical to the one involved in the prior proceeding; (2) the issue was actually litigated in the prior proceeding; (3) the determination of the issue was critical and necessary to the earlier judgment; and (4) the party against whom collateral estoppel is asserted had a full and fair opportunity to litigate the issue in the prior proceeding." In re MDL-1824 Tri-State Water Rights Litigation, 644 F.3d 1160, 1202 (11th Cir. 2011). + +## C. RULE 410 DOES NOT APPLY IN THIS CASE BECAUSE THE PLEA DISCUSSIONS LEAD TO A GUILTY PLEA. + +In any event, at any ultimate proceeding in this case, Rule 410 will simply be inapplicable. Because "Rule 410 is an exception to the general principle that all relevant evidence is admissible at trial, see Fed.R.Evid. 402, its limitations are not to be read broadly." United States v. Barrow, 400 F.3d 109, 116 (2d Cir. 2005). The plain language of the rule is narrowly written to cover only a "statement made in the course of plea discussions with an attorney for the prosecuting authority which do not result in a plea of guilty." Fed. R. Evid. 410(4) (emphasis added). Obviously, a prerequisite to applying the rule is a case where no plea of guilty resulted. See, e.g., United States v. Ruhkowsi, 814 F.2d 594, 596 (11th Cir. 1987) (discussing application of the rule in situations where "plea negotiations . . . broke down" and case went to trial); United States v. Gonzalez, 608 F.3d 1001 (7th Cir. 2010) cert. denied, 131 S. Ct. 952 (2011) (allowing use of plea discussions against a defendant who pleaded guilty because Rule 410(4) "makes admissions in plea bargaining inadmissible only if the plea bargaining either does 'not result in a plea of guilty"); United States v. Kerik, 531 F.Supp.2d 610, 618 (S.D.N.Y. 2008) (Rule 410 "only excludes statements made in plea discussions that do not result in a plea of guilty. As such, the rule does not apply here because Mr. Kerik eventually pleaded guilty."). Here, of course, Epstein's plea discussions did result in a plea of guilty. As the Court is well aware, Epstein engaged in extensive discussions with the U.S. Attorney's Office in an effort to obtain a non-prosecution agreement. And ultimately he did obtain such an agreement — in exchange for pleading guilty to two state offenses. + +The terms of the non-prosecution agreement the victims are challenging make it quite clear that Epstein's plea discussions "result[ed] in a guilty plea." The agreement recites that "Epstein seeks to resolve globally his state and federal criminal liability and Epstein understands and acknowledges that, in exchange for the benefits provided by this agreement, he agrees to comply with its terms, including undertaking certain actions with the State Attorney's Office." Non-Prosecution Agreement at 2. The agreement goes on to specifically provide Epstein shall plead guilty to two offenses: + +"Epstein shall plead guilty . . to the Indictment as currently pending against him in the 15th Judicial Circuit in and for Palm Beach County (Case No. 2006-cf-009495AXXXMB) charging one (1) count of solicitation of prostitution, in violation of Fl. Stat. § 796.07. In addition, Epstein shall plead guilty to an Information filed by the States Attorney's Office charging Epstein with an offense that requires him to register as a sex offender" that is, the solicitation of minors to engage in prostitution, in violation of Florida Statutes Section 796.03." + +Id. at 3 (emphases added). And, as the Court knows, Epstein did ultimately plead guilty to those two Florida offenses pursuant to the agreement.' Accordingly, Rule 410 gives Epstein no ability to block the victims from discovery and use of his attorneys' plea discussions because those discussions "result[ed] in a guilty plea.s2 + +I Rule 410 draw no distinction between pleas in federal court and pleas in state court. See, e.g., United States v. Chapman, 954 F.2d 1352, 1360 (7th Cir. 1992) (applying rule to discussions over "withdrawn state plea"); United States v. Kerik, 531 F.Supp.2d 610 (S.D.N.Y. 2008) ("Rule 410 applies in federal proceedings to statements made in connection with prior state pleas"); see also United States v. Holmes, 794 F.2d 345, 349 (8th Cir.1986) (permitting the admission of a guilty plea from state court in a federal proceeding). + +2 Because Epstein's lawyers are claiming that the correspondence is protected by Rule 410, they bear the burden of establishing all necessary facts for the application of the rule. If Epstein's lawyers claim that the plea discussions somehow did not result in a plea of guilty, the victims request a hearing under Fed. R. Evid. 104(a) to dispute this preliminary question of fact. + +Rather than address this obvious point, Epstein's lawyers engage in subterfuge. In their supplemental pleading, the lawyers claim that the correspondence with the U.S. Attorney's Office is protected by "the express language of Rule 410." DE 94 at 3. Yet, they cleverly paraphrase the "express language" of the rule in a way that avoids quoting the critical limiting language that restricts Rule 410 to discussions "which do not result in a plea of guilty." Fed. R. Evid. 410(4). See DE 94 at 4-5 (discussion of Rule 410 that fails to discuss the limitation of the rule to negotiations "result[ing] in a plea of guilty"). The express language of the Rule does not prevent the victims from introducing the correspondence in support of their claims about plea discussions concerning Epstein because he pled guilty.; + +## D. RULE 410 DOES NOT APPLY HERE BECAUSE THE VICTIMS WILL USE THE CORRESPONDENCE AGAINST (IF ANYONE) THE GOVERNMENT. + +Rule 410 is also inapplicable here because it would, at most, bar admissibility of the correspondence into evidence "against the defendant who made the plea" — i.e., against Jeffrey Epstein. But the victims intend to obtain and use the correspondence to seek relief from the Government. Accordingly, the Rule cannot be used to bar the victims from obtaining discovery of this information. + +By its plain terms, Rule 410 only bars the admission of evidence "against the defendant who made the plea." The purpose underlying this rule to "promote negotiations by permitting defendants to talk to prosecutors without sacrificing their ability to defend themselves if no disposition is reached." United States v. Barrow, 400 F.3d 109, 116 (2d Cir.2005) (emphases + +The express language of Rule 410 also makes clear that "derivative evidence" is never excluded from a proceeding. See United States v. Ruhkowsi, 814 F.2d 594, 599 (11th Cir. 1987). + +added). Thus, the Rule has no application where the discussions are being used not against a defendant but rather against the Government. See United States v. Biaggi, 909 F.2d 662, 691 (2d Cir. 1990). + +Here, the victims intend to use the correspondence against any argument the Government may make in this civil action seeking to enforce their CVRA rights.4 They intend to use the correspondence to prove initially that the Government violated their rights. Having proven a violation of their rights, they will then seek various remedies concerning the Government. To provide a straightforward example, one (quite modest) remedy that they will ask the Court to impose on the Government is an order directing the U.S. Attorney's Office write a letter of apology to the victims for deliberately violating their rights. Clearly the victims' use of the correspondence to prove that the Government did not afford them their rights and that such a remedy is appropriate lies outside Rule 410's ambit. + +Of course, the victims in this case seek far more than a letter of apology from the Government. As they have made clear throughout this litigation, they also intend to ask for the Court to impose (among other things) the one remedy that will most directly respond to the Government's violation of their rights: invalidation of the non-prosecution agreement so that they can confer with the Government about the possibility of actually prosecuting Epstein for the sex offenses he committed against them. Epstein's lawyers claim that any such use would be a use "against" the defendant and therefore covered by this language in Rule 410.5 This claim, + +4 As explained in Section III.B below, the victims do not believe they stand in an adversarial posture with the Government, as Congress has obligated the Government to use its "best efforts" to protect the CVRA rights of crime victims. 18 U.S.C. § 3771(c)(1). + +5 Notably, the Government does not argue in its pleading that any use of the information + +however, assumes that the Rule 410 bars every court action that might ultimately have some collateral, harmful effect on a defendant. But Rule 410 is much more narrowly drafted forbidding not uses that may eventually harm the defendant, but instead more narrowly admissibility of plea negotiations into evidence "against" the defendant in a "civil or criminal proceeding." At this point, Epstein is not a party to the CVRA proceeding, and therefore it is not possible for any use of this correspondence to equate to forbidden admissibility of evidence "against" him. For this reason as well, the rule is inapplicable. + +## E. RULE 410 DOES NOT APPLY HERE BECAUSE OTHER STATEMENTS WILL BE INTRODUCED AND, IN FAIRNESS, THE CORRESPONDENCE SHOULD BE CONSIDERED AS WELL. + +Rule 410 will also ultimately be inapplicable at trial because it contains a "completeness" exception. Even for plea bargain discussions protected by Rule 410, a plea bargain statement is admissible "in any proceeding wherein another statement made in the course of the same plea discussions has been introduced and the statement ought in fairness be considered contemporaneously with it." Fed. R. Evid. 410. The Government has already made it quite clear in its pleadings that it will introduce certain statements about the course of the plea negotiations. Rule 410 thus entitles the victims to respond by introducing other aspects of the plea negotiations. + +Rule 410's completeness rule requires the court to determine whether, when one statement about plea discussions is introduced, other statements ought to in fairness be introduced as well. While it is too early to say for certain what arguments the Government will make at any ultimate proceeding to determine whether it violated the victims CVRA rights, from + +against it would somehow violate Rule 410. See U.S. Response to Supplemental Briefing at 3. + +all indications the Government intends to introduce many statements about the timing and course of plea discussions. For example, in its response to the victims' summary judgment motion, the Government makes clear that it intends to argue that it properly conferred with the victims over an 18 month period of time. See U.S. Response to Jane Doe #1 and #2's Motion for Finding Violations of the CVRA at 37 (arguing that between August 2006 and January 2008 government prosecutors and agents "went above and beyond the minimum statutory requirements" in conferring with victims about plea negotiations). Similarly, the Government intends to dispute that it sent false notices to the victims about the case being "under investigation" because plea discussions had not reached a final conclusion at that time. Id. at 41 (arguing that "[d]uring the time that Epstein was challenging the NPA, the investigation continued and agents were able to conduct" witness interviews). The Government also intends to take the position that it reasonably stopped making notifications to the victims, because if Epstein did not plead guilty and there was a trial, Epstein would cross-examine the victims about payments they would have received pursuant to the non-prosecution agreement. Id. at 42. + +It is simply unfair for the Government to be able to pick and choose from all the events surrounding the plea negotiations only those that support its case, while depriving the victims of the opportunity to even discover information that might bolster their case. See Frontier Ref:, Inc. v. Gorman-Rupp Co., Inc., 136 F.3d 695, 704 (10th Cir. 1998) (a litigant cannot use privilege "as both a sword and shield by selectively using the privileged documents to prove a point but then invoking the privilege to prevent an opponent from challenging the assertion."). And Rule 410 in particular blocks such a one-sided approach. Instead, under the Rule, the victims are entitled to show the full course of plea discussions at any ultimate hearing in this case about whether the + +Government violated their CVRA rights. And the victims are certainly entitled, at this earlier juncture in the case, to obtain all relevant information that they might ultimately be able to use to disprove the Government's defenses.° + +### II. THE CORRESPONDENCE BETWEEN THE GOVERNMENT AND EPSTEIN IS NOT PROTECTED FROM DISCOVERY BY SOME KIND OF "COMMON LAW" PLEA BARGAINING PRIVILEGE. + +For all the reasons just given, Rule 410 does not bar the victims from discovering correspondence about how the non-prosecution agreement was reached. Perhaps recognizing the weakness of this argument, Epstein's lawyers present the fallback claim that some sort of "common law" privilege for "plea bargaining" bars discovery into the correspondence. This argument, too, lacks any merit. + +## A. The Courts Cannot Create a "Common Law" Privilege That Overrules the Specific Contours of Rule 410. + +Epstein's lawyers ask the Court to invent some sort of new "common law" privilege under Federal Rule of Evidence 501. Rule 501 does allow federal courts some opportunity to + +Additionally, the correspondence may become important if the Court allows Epstein to make a belated entry into the case and raise various defenses. Epstein's legions of lawyers can be expected to advance all manner of legal and factual arguments — even claims that are simply untrue. For example, in a desperate attempt to avoid registering as a convicted sex offender in New York, Epstein recently had his attorneys represent to the New York County Supreme Court that "the prosecutor in Florida conducted a full investigation . . . and determined that the only case that she could present to the grand jury was this [single] indictment for a non registrable offense . . . ." People of New York v. Epstein, No. 30129/2010 (N.Y. Cnty. Sup. Ct. Jan. 18, 2011), hearing transcript at 9 (transcript attached to his pleading as Exhibit A). Epstein's attorneys also — quite astonishingly — stated "there are no real victims" in Florida. Id. And in what can only be described as a false statement to the New York court, Epstein's lawyers stated: "there has been through the course of the last few years some civil ligation . . . involving these matters and we now have sworn testimony in evidence from the complainants themselves disclaiming much of what appears in the [Florida] police report." Id. at 14. Given Epstein's penchant for bending the truth, the victims are entitled to all the correspondence as a safeguard against him advancing similar inaccurate arguments in this case. + +create new privileges. The Supreme Court has been clear, however, that courts must "not create and apply an evidentiary privilege unless it "promotes sufficiently important interests to outweigh the need for probative evidence. Inasmuch as testimonial exclusionary rules and privileges contravene the fundamental principle that the public has a right to every man's evidence, any such privilege must be strictly construed." University of Pennsylvania v. E.E.O.C., 493 U.S. 182, 189 (1990) (internal quotations omitted). + +While Epstein's lawyers do not cite the controlling legal standard for creating a privilege in this Circuit. The Eleventh Circuit has strongly cautioned that "the rule in this circuit is that a new privilege should only be recognized where there is a `compelling justification.' International Horizons, Inc. v. The Committee of Unsecured &editors, 689 F.2d 996, 1004 (11th Cir.1982) (quoting In re Dinnan, 661 F.2d 426 (5th Cir.1981)). The Eleventh Circuit has explained that this stringent rule arises from the federal courts' disfavor of privileges and from the policy of construing privileges narrowly, so as to protect the "search for truth." 689 F.2d at 1003 (quoting United States v. Nixon, 418 U.S. 683 (1974)). + +Here the Court has strong reason to be skeptical of a new plea bargaining privilege. The transparent purpose behind Epstein's lawyers' "common law" effort is to avoid the specific limitations contained in Rule 410. See Sections I.0 through I.E, supra (discussing language in Rule 410 requiring that the negotiations not have "result[ed] in a plea of guilty," that the negotiations be introduced "against" the defendant in a "proceeding," and that fairness not require "contemporaneous" introduction of all aspects of the negotiations). But the Supreme Court has made clear that courts must be "especially reluctant to recognize a privilege in an area where it appears that Congress has considered the relevant competing concerns but has not provided the privilege itself. The balancing of conflicting interests of this type is particularly a legislative function." University of Pennsylvania v. E.E.O. C., 493 U.S. 182, 189 (1990) (internal quotation omitted). The Court should not use the general provisions of Rule 501 to effectively supersede the detailed limitations in Rule 410. + +## B. No "Common Law" Privilege for Plea Bargaining Exists. + +Even if the Court were willing to entertain the idea that it should embark on an exercise of "common law" privilege making, no common law privilege exists for plea bargaining. While the defense attorneys frequently allude to "constitutional considerations" that supposedly undergird plea bargaining, the simple fact remains that "there is no constitutional right to plea bargain." Weatherford v. Bursey, 429 U.S. 545, 561 (1977); accord United States v. Barrentine, 591 F.2d 1069, 1078 (5h Cir. 1979). To be sure, the courts tolerate plea bargaining because it helps reduce the workload of congested criminal dockets. But common law rulemaking should not be used as an excuse to exalt negotiations that merely serve administrative convenience over the far more important search for truth.' + +Perhaps recognizing that tenuousness of raising plea bargaining over truth-seeking values, Epstein's lawyers attempt to repackage their proposed privilege as a "common law mediation" privilege. Supplemental Briefing at 16. There is no need for such a privilege in the Southern District of Florida to protect true mediation. A local rule already protects confidentiality in court-annexed mediation. See Local Rule 16.2(G)(2). Epstein's lawyers, + +To be sure, as the Government points out, effective defense counsel should always explore plea bargaining opportunities. See Gov't Resp. at 7 (citing Padilla v. Kentucky, 130 S.C.t 1473, 1485 (2010)). But this is a far cry from proving there is a "right" to plea bargaining or that protecting plea bargaining opportunities is more important than, for example, protecting congressionally-mandated crime victims' rights conferred in the CVRA. + +however, do not cite this rule, because they know their plea bargaining discussions with government attorneys fall outside its protections. + +Epstein's lawyers also implicitly concede that there is no well-established "common law" support for a mediation privilege, as they are able to cite only a smattering of cases (three in total over the last 32 years) recognizing such a privilege. None of these cases are from the Eleventh Circuit, which (unlike other jurisdictions) requires a strong showing of "compelling" justification before a new privilege can be created. International Horizons, Inc. v. The Committee of Unsecured Creditors, 689 F.2d 996, 1004 (11th Cir.1982) ("compelling" justification required to interfere with the search for truth in federal cases). Moreover, none of the three cases cited involve plea bargaining in criminal cases — presumably because that subject is already directly covered in detail in Rule 410. Finally, these cases involve situations where a court thought it important to create "confidentiality and trust between participants in a mediation proceeding." Epstein's Supplemental Briefing at 17 (citing Folb v. Motion Picture Ind. Pension & Health Plans, 16 F.Supp.2d 1164, 1175 (C.D. Cal. 1998) (emphasis added)). Here, of course, the parties to the plea discussion (Epstein and the Government) are attempting not to create a privilege between themselves, but rather to block third parties harmed by their actions from discovering what they have done. + +Make no mistake about the sweeping position that Epstein's attorneys are advancing: They claim that the defense attorneys and the Government can conspire between themselves to arrange for secret plea discussions in violation of congressionally-mandated crime victims' rights in the CVRA and then block the crime victims from obtaining the information that would prove the violation that has happened. Such a privilege would, among other things, directly conflict + +with the statutory command of Congress that crime victims must be "treated with fairness," 18 U.S.C. § 3771(a)(8), a statute which obviously trumps any claim by a convicted sex offender that his efforts to work out a secret plea deal with the Government is somehow entitled to greater protection. For all these reasons, the Court should reject the defense attorney's suggestion that it should invent a new "mediation privilege" to apply to the plea bargaining discussions in this case. + +## III. THE WORK PRODUCT DOCTRINE DOES NOT COVER CORRESPONDENCE BETWEEN PROSECUTORS AND DEFENSE ATTORNEYS. + +The Government's response to the defense attorney's supplemental briefing (DE 100) itself raises new issues about whether the victims will be able to obtain the correspondence (or, indeed, any information from the Government). After the Court ruled that the victims were entitled to discover relevant information (DE 99 at 10), the victims asked the Government to voluntarily provide them with at least some documents. In response, however, the Government told the victims that all of the relevant information — including presumably the correspondence — is privileged from production and that the Court will need to determine, "on a document-bydocument basis" (Gov't Resp. at I) whether any of the materials in the Government's possession falls outside the work product doctrine. The Court should reject the Government's sweeping claim that all correspondence (and other information) is protected by the work product doctrine. + +### A. The Court Should Now Grant the Victim's Still-Pending Motion for an Order Directing the U.S. Attorney's Office Not to Suppress Relevant Evidence. + +In its order allowing discovery, the Court "reserve[d] ruling" (DE 99 at11) on the victims' Motion for an Order Directing the U.S. Attorney's Office Not to Withhold Relevant Evidence. The victims respectfully renew their motion (DE 50). Of course, if the Court decided to grant this motion, it would obviate the need for any kind of "document-by-document" review of the relevant information that the Government continues to withhold. + +### B. The CVRA Requires the Government to Work Cooperatively to Protect the Victims' Rights and Thus Bars the Government from Interposing an Adversarial Work Product Defense. + +The Government argues that the work-product doctrine it is asserting prevents the victims from obtaining any information relevant to their CVRA claim. In doing so, the Government fundamentally misunderstands its role under the CVRA. The Government seems to believe that it stands in an adversarial posture to the victims and therefore it can simply interpose the same sorts of litigation barriers it would deploy against a criminal defendant seeking discovery of Government documents. But the CVRA does not place victims and the Government on opposite sides of CVRA enforcement. Instead, the Act obligates the Government to work together with victims to enforce CVRA rights. In such a cooperative world, the Government cannot erect a "work product" barrier to CVRA enforcement. + +The CVRA specifically directs Justice Department prosecutors to make their "best efforts" to protect victims' rights. Title 18 U.S.C. § 3771(c)(I) commands that "[officers and employees of the Department of Justice and other departments and agencies of the United States engaged in the . . . prosecution of crime shall make their best efforts to see that crime victims notified of, and accorded, the rights described in [the CVRA]" (emphases added). Underscoring this "best efforts" obligation, the CVRA even allows prosecutors to bring their own actions to enforce victims' CVRA rights. Title 18 U.S.C. § 3771(d)(1) provides: "The crime victims . . and the attorney for the Government may assert the rights described in [the CVRA]" (emphasis + +added). Of course, the attorney for the Government can never bring an action on behalf of a criminal defendant. Thus, unlike when they prosecute criminal defendants, Justice Department prosecutors are statutorily obligated to work with crime victims. + +In light of the fact that Congress requires prosecutors and victims to cooperate to protect CVRA rights, in cases (such as this one) seeking to enforce CVRA rights the Government cannot raise adversarial work-product objections under the Federal Rules of Criminal Procedure. Those rules govern the antagonistic relationship inherent in a criminal prosecution. With regard to discovery, the rules only cover discovery "upon a defendant's request." Fed. R. Crim. P. 16(a)(1) (emphasis added). The discovery rules allow a criminal defendant to obtain limited information from the Government, including specifically his confession, his prior criminal record, tangible objects (i.e., contraband or other evidence), and reports of scientific tests. Fed. R. Crim. P. 16(a)(1)(A)-(F). Against that backdrop, the rule cited by the Government — Fed. R. Crim. P. 16(a)(2) — prevents a criminal defendant from forcing disclosure of "internal government documents made by an attorney for the government or other government agent in connection with investigating or prosecuting the case." In this case, though, it is not a criminal "defendant" trying to obtain information in an effort to obtain an acquittal, but rather plaintiff crime victims seeking information to enforce their CVRA rights. Accordingly, by its plain terms, Rule 16 simply doesn't apply. And even if it somehow did apply, it only covers documents made "in connection with investigating or prosecuting the case" — i.e., documents about the "case" in which the discovery request is made (here Jane Doe #1 and #2 v. United States). Here, the victims are seeking (among other things) correspondence about an earlier case — i.e., documents related to the Jeffrey Epstein investigation and non-prosecution in which the + +Government violated their CVRA rights. For this reason as well, the criminal rule simply doesn't apply. + +Perhaps recognizing that it will not be able to avoid producing documents under the Federal Rules of Criminal Procedure, the Government immediately cites the Federal Rules of Civil Procedural as well. Gov't Resp. at 5 (citing Fed. R. Civ. P. 26(b)(3)(B)). But if the Government is going to seek the civil rules' protections, it also needs to satisfy those rules' burdens. For example, despite repeated requests from the victims spanning several years, the Government has yet to even make any initial disclosures under the civil rules. See Fed. R. Civ. P. 26(a)(1)(A) ("a party must, without await awaiting a discovery request, provided to the other parties" various things relevant to the case). The victims long ago made their initial disclosures to the Government under the civil rules, but the Government continues to refuse to reciprocate. If the Government is going to maintain that the civil rules operate to give it certain discovery protections, it must satisfy all of its discovery obligations as well. + +In any event, as with the criminal rules, the civil rules are designed to create protections in an adversarial setting. The rule cited by the Government — Fed. R. Civ. P. 26(b)(3)(A) provides that "ordinarily . . . a party may not discover documents and tangible things that are prepared in anticipation of litigation or for trial by or for another party or its representative . . . ." This privilege "does not exist to protect a confidential relationship, but rather to promote the adversary system by safeguarding the fruits of an attorney's trial preparations from the discovery attempts of the opponent." U.S. v. American TeL and Tel. Co., 642 F.2d 1285, 1299 (D.C. Cir. 1980) (emphasis added). While the victims have listed the government in the caption of this enforcement action, they certainly do not regard the Government as their "opponent" — and under + +the regime created by the CVRA, prosecutors and victims are not "opponents" that would create the proper circumstances for a work product privilege. As explained above, the CVRA requires the Government to use its "best efforts" not to oppose crime victims but rather to "accord" them their rights under the CVRA. 18 U.S.C. § 3771(c)(1). + +Underscoring the conclusion that work product does not apply is the nature of the correspondence at issue in these pleadings. The correspondence is between prosecutors and defense attorneys negotiating a plea arrangement. It was, at most, prepared in anticipation of a criminal prosecution being filed by the Government against Epstein — in other words, a contemplated criminal prosecution that would have been styled United States v. Epstein. Whatever work product claim would exist in that case, it does not extend to this — entirely separate — civil case. See Hendrick v. Avis Rent A Car System, Inc., 916 F.Supp. 256, 259 (W.D.N.Y.,1996) (no work product existed because "the documents sought 'were not prepared in anticipation of this particular litigation' (citing Bartley v. Isztzu Motors, 158 F.R.D. 165, 167 (D.Colo.1994) (emphasis added)). For all these reasons, the Court should give effect to the cooperative structure created in the CVRA and flatly reject the Government's suggestion that it can interpose an adversarial work product claim to block the victims from discovering correspondence with Epstein's defense attorneys. + +### C. If the Court Allows the Government to Raise Work Product Claims, then the Government Must Prepare a Detailed Privilege Log and Bear the Burden of Establishing Its Position on a Document-by-Document Basis — a Burden It Cannot Meet With Regard to the Correspondence. + +If the Government is allowed to raise a work product claim, the procedures associated with such claims are familiar. As the Government concedes, it would be required to prove protection on a "document-by-document" basis. Gov't Resp. at 1. The way such documentspecific issues are litigated is through a privilege log. See Fed. R. Crim. P. 26(b)(5)(A)(ii). The Court's Local Rules spell out requirements for a privilege log. The Government should describe (among other things) the type of document, the general subject matter of the document, the date of the document, and the author and addressee of the document or correspondence. Local Rule 26(g)(3). The privilege log must be detailed enough to allow the victims to respond to the Government's assertion of privilege. See, e.g., Avgoustis v. Shinseki, 639 F.3d 1340, 1345-46 (Fed. Cir. 2011) ("privilege logs were insufficiently detailed when they merely stated "Fax: Whistleblower article" or "Summary of Enclosures" and justified the privilege by characterizing the documents as "attorney-client communication[s]" without explanation.") (citing United States v. Constr. Prods. Research, Inc., 73 F.3d 464, 473 (2d Cir.1996)).8 + +Once the Government has cataloged the documents in its privilege log, it then bears the burden of proving the applicability of the privilege. See In re Professionals Direct Ins. Co., 578 F.3d 432 (6ih Cir. 2009); Boogie v. McClure, 332 F.3d 1347, 1358 (11th Cir. 2003). The victims will, of course, later respond in detail to any specific assertions the Government makes, But it is obvious that the Government cannot assert a valid work product privilege for any of the correspondence it carried on with defense attorneys for Epstein. + +8 Similarly, if the defense attorneys are allowed to intervene in this case to assert privilege, they must then provide a privilege log on a document-by-document basis. + +9 In briefly responding here to arguments raised by the Government, the victims are not waiving any responses they might later make to specifically-asserted work product claims. In particular, on a document-by-document basis, the victims reserve their right to argue that the documents are not work product materials and, in any event, that they have a "substantial need for the materials to prepare [their] case and cannot, without undue hardship, obtain the[] substantial equivalent by other means." Fed. R. Civ. P. 26(b)(3)(A)(ii). + +For starters, the issue of whether the correspondence was somehow protected against discovery was thoroughly litigated by Epstein more than a year ago. This Court rejected Epstein's arguments against disclosure. Jane Doe v. Epstein, doc. #462, Case No. 9:08-CV-80119-ICAM (Feb. 4, 2010).10 That ruling by the Court then is, to say the least, persuasive authority on the Government's identical argument here. + +Moreover, correspondence with an adversary in a criminal prosecution is not the kind of confidential information that is even arguably covered by work product. Work product covers only "reports, memoranda, and other internal government documents made by an attorney for the government . . . in connection with . . . prosecuting the case." Fed. R. Crim. P. 16(a)(2) (emphasis added); see also Fed. R. Civ. 26(b)(3)(A). Correspondence between prosecutors and defense attorneys is simply not an "internal" matter that is subject to a work product protection. + +Correspondence with an adversary also waives any work-product coverage. "The privilege derived from the work-product doctrine is not absolute. Like other qualified privileges, it may be waived." United States v. Nobles, 422 U.S. 225, 239 (1975). "Disclosure to an adversary waives the work product protection as to items actually disclosed, even where disclosure occurs in settlement." In re Chrysler Motors Corp. Overnight Evaluation Program Litigation, 860 F.2d 844, 846 (8th Cir. 1988). Thus, "[c]ourts will imply waiver when a party + +In Jane Doe v. Epstein, doc. #462, Case No. 9:08-CV-80119-ICAM (Feb. 4, 2010) (denying defense objection to Request for Production #10), the Court ordered Epstein to produce "all correspondence between you and your attorneys and state or federal law enforcement or prosecutors." It now appears to the victims that, in clear contravention of this Court's discovery orders, Epstein's attorneys secretly withheld significant correspondence involving plea discussions by several of Epstein's attorneys, including Lillian Sanchez, Jay Lefkowitz, and Ken Starr. If this is true, as part of any privilege log they file, the defense attorneys should explain why they secretly and improperly withheld this information. + +claiming the protection has voluntarily disclosed work product to a party not covered by the work-product doctrine." United States v. Ary, 518 F.3d 775, 783 (10th Cir. 2008). + +Perhaps recognizing the difficulty inherent in its position under these well-recognized general principles, the Government claims that the court cases have been "inconsistent" on whether communications during plea bargaining waive work product privilege. Gov't Resp. at 8. This is simply untrue, as a review of the relevant cases quickly demonstrates. + +The Government concedes that there is circuit court authority that defendants' disclosure of work product materials to the government during plea bargaining waives all work product protection. The Government acknowledges, for example, that Westinghouse Electric Corp. v. Republic of the Philippines, 951 F.2d 1414 (3d Cir. 1991), explicitly adopts this position. That case concluded that Westinghouse's disclosure of work product materials to the Justice Department during an investigation "waived the work-product doctrine as against all other adversaries." Id. at 1429. This holding makes sense, because it is hard to understand how a litigant can claim confidentiality in materials it has otherwise disclosed. + +The Government claims, however, that this common sense conclusion has been rejected by the First Circuit, which (according to the Government) has "held that a company may maintain even its . . . work-product privilege in materials that it discloses to the U.S. Attorney's Office during pre-indictment presentations and ongoing plea negotiations." Gov't Resp. at 8 (citing In re Keeper of the Records (Grand Jury Subpoena Addressed to XYZ Corp.), 348 F.3d 16, 27-28 (1st Cir. 2003)). But the case the Government cites stands for no such broad proposition. Rather, that case involved a situation where for two years the Government had been demanding that XYZ Corporation should waive its privileges and produce various documents + +relevant to a government investigation; the company "steadfastly had refused." Id. at 26. The company ultimately proffered some of the documents that the Government had been seeking. But the company's counsel voluntarily produced those documents under a "clear and explicit" reservation of all privileges. Id. at 27. And the reservation was "accepted by the government's consistent course of conduct," id. at 28, which included treating the documents as protected. Thus, in that case, there was simply no conduct from which a waiver could be inferred, as the Government had agreed through its course of conduct that the protection existed. Here, of course, there is not such course of conduct and, in any event, the victims have never "accepted" that the correspondence is protected. + +Moreover, in an effort to show the Courts of Appeals are inconsistent, the Government pretends to have universally surveyed caselaw with its citations to just these two allegedly "inconsistent" cases. In fact, the clear bulk of circuit authority has clearly and straightforwardly rejected arguments that the U.S. Attorney's Office advances here (and has frequently done so at the request of the Government). See, e.g., In re Qwest Communications, Inc., 450 F.3d 1179, 1192-1201 (10th Cir. 2006) (company's disclosure of documents to the SEC during criminal investigation waived work product protections); Grace United Methodist Church v. City of Cheyenne, 451 F.3d 643, 668 (10th Cir. 2005) ("any work product objection was waived by [party] via production" of the documents in question); In re Columbia/HCA Healthcare Corp. Billing Practices Litigation, 293 F.3d 289, 302 (6th Cir. 2002) (attorney client/work product privilege was "never designed to protect conversations between a client and the Government i.e., an adverse party — rather, it pertains only to conversations between the client and his or her attorney. . . purpose [of attorney-client privilege] is to encourage full and frank communication + +between attorneys and their clients and thereby promote broader public interests in the observance of law and administration of justice. Nowhere amongst these reasons [for protection] is the ability to `talk candidly with the Government.'"); United States v. MIT., 129 F.3d 681, 687 (1st Cir. 1997) ("the prevailing rule that disclosure to an adversary, real or potential, forfeits work product protection"); In re Steinhardt Partners, L.P., 9 F.3d 230, 235 (2nd Cir. 1993) ("voluntary disclosure of work product to an adversary waives the privilege as to other parties"); In re Chrysler Motors Overnight Evaluation Litigation, 860 F.2d 844, 846-47 (8h 1988) (defendant company's disclosure of computer tape to class counsel during settlement negotiated waived work product when tape sought by government as part of criminal case); In re Sealed Case, 676 F.2d 793, 824-25 (D.C. Cir. 1982) (production of documents during settlement discussions with the SEC waived work product protection as to grand jury). + +For all these reasons, the Court should reject the Government's claim that its correspondence with Epstein's attorneys during plea negotiations somehow is confidential work product immune from discovery. + +## CONCLUSION + +For all the foregoing reasons, if the Court allows the defense attorneys to intervene in this case, the Court should rule (1) that Rule 410 does not prevent discovery of plea negotiation correspondence; (2) there is no basis for inventing a new "common law" privilege preventing discovery of the correspondence; and (3) the correspondence is not confidential "work product" of the Government and is discoverable by the victims in this case. + +DATED: October 10. 2011 + +Respectfully Submitted, + +s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS FISTOS & LEHRMAN, P.L. + +Fort Lauderdale, Florida 33301 + +and + +Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah + +Salt Lake City, UT 84112 + +Attorneys for Jane Doe #1 and Jane Doe #2 + +## CERTIFICATE OF SERVICE + +The foregoing document was served on October 10, 2011, on the following using the + +Court's CM/ECF system: + +[REDACTED] + +Assistant U.S. Attorneys + +[REDACTED] + +West Palm Beach, FL 33401 + +[REDACTED] + +Attorneys for the Government + +Roy Black, Esq. + +Jackie Perczek, Esq. + +Black, Srebnick, Kornspan & Stumpf, P.A. + +[REDACTED] + +Miami, FL 33131 + +[REDACTED] \ No newline at end of file diff --git a/marker2/ds9/EFTA00205728/EFTA00205728.metadata.json b/marker2/ds9/EFTA00205728/EFTA00205728.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b0d7a6f9fa7d8848cc9ee684d2d5eafcef2f32d6 --- /dev/null +++ b/marker2/ds9/EFTA00205728/EFTA00205728.metadata.json @@ -0,0 +1,1418 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205728.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 27, + "chars": 49783, + "elapsed_seconds": 6.09, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF FLORIDA", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 199.512, + 100.44 + ], + [ + 412.1432800292969, + 100.44 + ], + [ + 412.1432800292969, + 127.353515625 + ], + [ + 199.512, + 127.353515625 + ] + ] + }, + { + "title": "JANE DOE #1 AND JANE DOE #2'S RESPONSE TO SUPPLEMENTAL BRIEFING IN \nSUPPORT OF MOTION TO INTERVENE OF ROY BLACK. 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"llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205728" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205755/EFTA00205755.md b/marker2/ds9/EFTA00205755/EFTA00205755.md new file mode 100644 index 0000000000000000000000000000000000000000..9e6729137848ea241c19f4117ffbda8d0ae787ad --- /dev/null +++ b/marker2/ds9/EFTA00205755/EFTA00205755.md @@ -0,0 +1,15 @@ +Subject: Non-Prosecution Agreement re Epstein Case + +Date: Wed, 12 Oct 2011 22:05:43 +0000 + +Importance: Normal + +Attachments: Fully\_executed\_NPA.pdf + +Sony to inundate you. I now understand a bit better whapecial Counsel to the U.S. Attorney, who is also working on the victims' suit) wants to discuss. He wants to discuss how the Non-Prosecution Agreement may limit your ability to prosecute some of Epstein's crimes. + +I have attached a copy of the Non-Prosecution Agreement for you to review, so you will know what we are talking about. If you could give us 15-25 minutes tomorrow, it would be most appreciated. Ed is free between 9:00 and 2:30. + +<> + +![](_page_0_Picture_7.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00205755/EFTA00205755.metadata.json b/marker2/ds9/EFTA00205755/EFTA00205755.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..728ca78598d557869ac3e343548e690d16b64262 --- /dev/null +++ b/marker2/ds9/EFTA00205755/EFTA00205755.metadata.json @@ -0,0 +1,60 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205755.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 703, + "elapsed_seconds": 0.51, + "image_assets": [ + "_page_0_Picture_7.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 22 + ], + [ + "Line", + 12 + ], + [ + "Text", + 7 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205755" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205755/_page_0_Picture_7.jpeg b/marker2/ds9/EFTA00205755/_page_0_Picture_7.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..e950c528fcf828668cf75ca2e24d6444ba8fce4d --- /dev/null +++ b/marker2/ds9/EFTA00205755/_page_0_Picture_7.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:d7bfa106a4a187d179019f59de39c4b96fd93d1ed78842dc99843235bd57c79e +size 8719 diff --git a/marker2/ds9/EFTA00205756/EFTA00205756.md b/marker2/ds9/EFTA00205756/EFTA00205756.md new file mode 100644 index 0000000000000000000000000000000000000000..f47b4b00a3c0b2c96aee3ad28bb84c72975c1ab0 --- /dev/null +++ b/marker2/ds9/EFTA00205756/EFTA00205756.md @@ -0,0 +1,7 @@ +Subject: Question from Roy Black + +Date: Fri, 02 Sep 2011 02:12:09 +0000 + +Importance: Normal + +Hi Dexter — I guess one of us should respond to the question about Epstein intervening. What are your thoughts? \ No newline at end of file diff --git a/marker2/ds9/EFTA00205756/EFTA00205756.metadata.json b/marker2/ds9/EFTA00205756/EFTA00205756.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e3fc7aa64c1f63b1a4e92edf7b92828eb3237d7f --- /dev/null +++ b/marker2/ds9/EFTA00205756/EFTA00205756.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205756.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 204, + "elapsed_seconds": 0.34, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 9 + ], + [ + "Text", + 5 + ], + [ + "Line", + 5 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205756" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205757/EFTA00205757.md b/marker2/ds9/EFTA00205757/EFTA00205757.md new file mode 100644 index 0000000000000000000000000000000000000000..86e53e0a85f7f7aae5bd963179aa4169b3242796 --- /dev/null +++ b/marker2/ds9/EFTA00205757/EFTA00205757.md @@ -0,0 +1,22 @@ +![](_page_0_Picture_62.jpeg) + +**Subject:** Doe [REDACTED] USAO + +**Date:** Wed, 31 Aug 2011 16:28:18 +0000 + +**Importance:** Normal + +**Inline- +Images:** ATT00001 + +[REDACTED] + +We are filing a motion seeking limited intervention by Jeffrey Epstein to protect disclosure & use of the plea negotiations. Do you object to Mr. Epstein's limited intervention? Please let me know. Thanks, + +Jackie Perczek, Esq. + +![](_page_0_Picture_69.jpeg) + +\*\*\*\*\* + +The information in this email transmission is privileged and confidential. If you are not the intended recipient, nor the employee or agent responsible for delivering it to the intended recipient, you are hereby notified that any dissemination or copying of this transmission (including any attachments) is strictly prohibited. If you have received this email in error, please notify the sender by email reply. Thank you. \ No newline at end of file diff --git a/marker2/ds9/EFTA00205757/EFTA00205757.metadata.json b/marker2/ds9/EFTA00205757/EFTA00205757.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e3f321e591bfca7f78e1c0eb938c552844da40af --- /dev/null +++ b/marker2/ds9/EFTA00205757/EFTA00205757.metadata.json @@ -0,0 +1,61 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205757.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 867, + "elapsed_seconds": 3.66, + "image_assets": [ + "_page_0_Picture_62.jpeg", + "_page_0_Picture_69.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 32 + ], + [ + "Text", + 21 + ], + [ + "Line", + 16 + ], + [ + "PageFooter", + 2 + ], + [ + "Picture", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205757" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205757/_page_0_Picture_62.jpeg b/marker2/ds9/EFTA00205757/_page_0_Picture_62.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..f604520d102cfcc3b8191b64b1138690addc5e80 --- /dev/null +++ b/marker2/ds9/EFTA00205757/_page_0_Picture_62.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:dd0a00846697d1f424ad6e7b2949562aa879ac08e39aa22e1ca414cc3d4dcd08 +size 7713 diff --git a/marker2/ds9/EFTA00205757/_page_0_Picture_69.jpeg b/marker2/ds9/EFTA00205757/_page_0_Picture_69.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..f4dbf63a56493a8d90f16dccfc7112c2575a0b1e --- /dev/null +++ b/marker2/ds9/EFTA00205757/_page_0_Picture_69.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:da09efdc5ab94c8a4e4082afaca7240e4d380fd1973157d5c94c45baca2504b5 +size 4963 diff --git a/marker2/ds9/EFTA00205758/EFTA00205758.md b/marker2/ds9/EFTA00205758/EFTA00205758.md new file mode 100644 index 0000000000000000000000000000000000000000..634c291a2b8d0b366b0155bd9e3fba9b87cf1a19 --- /dev/null +++ b/marker2/ds9/EFTA00205758/EFTA00205758.md @@ -0,0 +1,15 @@ +To: "'brad@pathtojustice.com"' , "12Black@RoyBlack.com". + +Subject: Jane Does I United States + +Date: Fri, 16 Sep 2011 12:28:35 +0000 + +Importance: Normal + +Dear Brad and Roy: + +I was in Bogota for 10 days where my phone didn't work and I had very limited access to email so I have a lot of catching up to do. Do you have any objection to a ten day extension of time to respond to Mr Epstein's motion? + +Thank you + +sannomporrs \ No newline at end of file diff --git a/marker2/ds9/EFTA00205758/EFTA00205758.metadata.json b/marker2/ds9/EFTA00205758/EFTA00205758.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..4cfe196a1134c4cc718d2bba54a0bf54a4d641ce --- /dev/null +++ b/marker2/ds9/EFTA00205758/EFTA00205758.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205758.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 466, + "elapsed_seconds": 0.49, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 23 + ], + [ + "Line", + 12 + ], + [ + "Text", + 9 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205758" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205759/EFTA00205759.md b/marker2/ds9/EFTA00205759/EFTA00205759.md new file mode 100644 index 0000000000000000000000000000000000000000..8ac2339b564322b2fd8a03d2841b443140ffa517 --- /dev/null +++ b/marker2/ds9/EFTA00205759/EFTA00205759.md @@ -0,0 +1,27 @@ +To:' + +Subject: Re: Jane Does United States + +Date: Fri, 16 Sep 2011 14:33:31 +0000 + +Importance: Normal + +Of course not. Talk to you soon. + +From: + +To: Brad Edwards + +To: + +Subject: Jane Does I United States + +Sent: Sep 16, 2011 8:28 AM + +Dear Brad and Roy: + +I was in Bogota for 10 days where my phone didn't work and I had very limited access to email so I have a lot of catching up to do. Do you have any objection to a ten day extension of time to respond to Mr Epstein's motion? + +Thank you + +Sent via BlackBerry by AT&T \ No newline at end of file diff --git a/marker2/ds9/EFTA00205759/EFTA00205759.metadata.json b/marker2/ds9/EFTA00205759/EFTA00205759.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..897fb97b9c2fbd568b0452acdfcff819244dbb43 --- /dev/null +++ b/marker2/ds9/EFTA00205759/EFTA00205759.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205759.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 514, + "elapsed_seconds": 0.76, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 33 + ], + [ + "Text", + 17 + ], + [ + "Line", + 17 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205759" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205760/EFTA00205760.md b/marker2/ds9/EFTA00205760/EFTA00205760.md new file mode 100644 index 0000000000000000000000000000000000000000..ce3a8ce46f986ccb67fd61684e85795db8cc0439 --- /dev/null +++ b/marker2/ds9/EFTA00205760/EFTA00205760.md @@ -0,0 +1,15 @@ +To: ' " < (USAFLS)" < >, + +Subject: Re: Jane Does I United States + +Date: Fri, 16 Sep 2011 14:21:41 +0000 + +Importance Normal + +I have no objection. + +>>> ' Dear Brad and Roy: (USAFLS)" < > 9/16/2011 8:28 AM >>> + +I was in Bogota for 10 days where my phone didn't work and I had very limited access to email so I have a lot of catching up to do. Do you have any objection to a ten day extension of time to respond to Mr Epstein's motion? + +Thank , AUSA \ No newline at end of file diff --git a/marker2/ds9/EFTA00205760/EFTA00205760.metadata.json b/marker2/ds9/EFTA00205760/EFTA00205760.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..a1bd57b81e71f73f76aa14b54214ea26c7823096 --- /dev/null +++ b/marker2/ds9/EFTA00205760/EFTA00205760.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205760.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 445, + "elapsed_seconds": 0.48, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 31 + ], + [ + "Line", + 16 + ], + [ + "Text", + 9 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205760" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205761/EFTA00205761.md b/marker2/ds9/EFTA00205761/EFTA00205761.md new file mode 100644 index 0000000000000000000000000000000000000000..8aa178db36520ccffd544f397d83d1251962a7d5 --- /dev/null +++ b/marker2/ds9/EFTA00205761/EFTA00205761.md @@ -0,0 +1,69 @@ +![](_page_0_Picture_77.jpeg) + +**Subject:** RE: Re: + +**Date:** Mon, 26 Sep 2011 20:02:17 +0000 + +**Importance:** Normal + +--- + +Nobody knows. At the very first hearing -- 3 years ago -- the judge said the most he could do is order us outside to "confer." + +![](_page_0_Picture_82.jpeg) + +----- Original Message ----- + +Sent: Monday, September 26, 2011 3:56 PM + +Subject: Re: + +What if the court disagrees and says we violated cvra - what's the remedy? A declaratory judgment? He can't set the np aside and he definitely can't get money. + +----- Original Message ----- + +Sent: Mon Sep 26 15:54:03 2011 + +Subject: RE: + +Setting aside the non-pros and prosecuting him as though the Non-pros had never been signed. + +![](_page_0_Picture_91.jpeg) + +----- Original Message ----- + +Subject: Re: + +Suggest what thing? + +----- Original Message ----- + +No. He already served his sentence in state court and performed all his other obligations under the Non-Pros (including paying damages to 30-some girls). I argued it would be a Due Process violation to even suggest such a thing. + +![](_page_1_Picture_49.jpeg) + +-----Original Message----- + +![](_page_1_Picture_51.jpeg) + +Subject: Re: + +Have we conceded that a showing that we violated the CVRA would justify reopening/setting aside the nonpros? + +![](_page_1_Picture_54.jpeg) + +Sent: Mon Sep 26 15:23:17 2011 + +Subject: RE: + +Ideally to set aside the Non-Prosecution Agreement with Epstein and then to somehow convince us (probably through public pressure via the press) to prosecute him. + +![](_page_1_Picture_58.jpeg) + +![](_page_1_Picture_59.jpeg) + +Sent: Monday, September 26, 2011 2:22 PM + +![](_page_1_Picture_61.jpeg) + +What is the relief jane does want in the cvra case? \ No newline at end of file diff --git a/marker2/ds9/EFTA00205761/EFTA00205761.metadata.json b/marker2/ds9/EFTA00205761/EFTA00205761.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..356c86f9f375e3350f81f1f1f9e8e9d19d500df1 --- 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b/marker2/ds9/EFTA00205763/EFTA00205763.md @@ -0,0 +1,90 @@ +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson + +JANE DOES #1 AND #2, Petitioners, + +v. UNITED STATES OF AMERICA, Respondent. + +### UNITED STATES' RESPONSE TO SUPPLEMENTAL BRIEFING IN SUPPORT OF MOTION TO INTERVENE OF ROY BLACK, MARTIN WEINBERG, AND JAY LEFKOWITZ ]DE94] + +The United States of America, by and through the undersigned Assistant United States Attorney, hereby files this Response to the Supplemental Briefing of Attorneys Roy Black, Martin Weinberg, and Jay Lefkowitz (DE94). The Court asked the United States to address the Intervenor Attorneys' argument that special concerns or rules should apply to the disclosure and use of documents prepared and exchanged during plea negotiations between the Intervenors (on behalf of Jeffrey Epstein) and the U.S. Attorney's Office. The Intervenor Attorneys seek to preclude the unsealing of certain documents already filed with the Court as well as the use of their contents, and the discovery and use of additional plea negotiation documents and information. + +For the reasons set forth herein, the United States agrees that the Petitioners are attempting to use plea negotiations "against" Jeffrey Epstein, in violation of the Federal Rules of Evidence, and that the work product privilege is not automatically waived by disclosure in the context of confidential plea negotiations. Thus, the Court must determine, on a document-by-document basis, whether a document contains attorney work produce and, if so, whether that work product privilege has been waived. The United States further agrees that, in light of the Supreme Court's guidance on the Sixth Amendment Right to Counsel, the protections provided to civil mediation and arbitration proceedings should extend to confidential plea negotiations where a non-party seeks to use statements made during those negotiations against either party. + +## BACKGROUND + +The Court is very familiar with this matter, having handled the civil suits filed against Jeffrey Epstein pursuant to the Non-Prosecution Agreement-and this actions filed by Jane Does #1 and #2 against the United States. For purposes of this Supplemental Briefing, the relevant facts are that, through the civil litigation between the Jane Does and Jeffrey Epstein, the Jane Does obtained portions of correspondence and draft agreements between counsel for Jeffrey Epstein and counsel for the United States that were exchanged during the course of confidential a plea negotiations. To the knowledge of the government, the Jane Does have only received the portions of the correspondence written by government attorneys — all of the writings of Mr. Epstein's attorneys, excepts for a few short portions by Jack Goldberger — have been redacted. The Intervenor Attorneys ask that the Court order that the Jane Does cannot use the unredacted portions and deny their motion to use those documents in support of their claims. a The Intervenor Attorneys further ask that the Jane Does be barred from delving further into the confidential plea negotiations. + +At the hearing on August 12, 2011, the Court heard oral argument from Attorney Black, who suggested that the ban on discovering and using plea negotiations was broader than what is simply stated in Rule 410 of the Federal Rules of Evidence and Rule 11 of the Federal Rules of Criminal Procedure. The Court ordered supplemental briefing, and the Intervenor Attorneys have raised a number of arguments in their supplemental briefing: (I) that the plea negotiations may not be used against Mr. Epstein pursuant to Fed. R. Evid. 410 and Fed. R. Crim. P. 11(0; (2) that because the Jane Does are seeking inadmissible evidence, they bear a burden of showing a proper basis for discovery; (3) that the plea negotiations are irrelevant because the Jane Does are not entitled to invalidate the Non-Prosecution Agreement; (4) that the documents and information should be privileged under a common law plea negotiations privilege. In addition, in its initial briefing and at oral argument, the Intervenors argued that the communications were governed by the attorney work-product privilege. + +# ARGUMENT + +### A. The Petitioners Appear to Be Seeking to Use the Plea Negotiation Documents Against Jeffrey Epstein; However, This Argument Is Premature. + +With regard to the Intervenors' first argument, the United States agrees that the Jane Does have made clear that their ultimate goal is to have the Non-Prosecution Agreement set aside and to have Jeffrey Epstein prosecuted. Thus, although the United States is the named Respondent, the Petitioner have made clear that their true target is Jeffrey Epstein: "The victims very specifically advised Epstein more than one year ago that they would be filing U.S. Attorney correspondence in this case in an effort to invalidate his non-prosecutionagreement." (Pets.' Resp. to Epstein Mot'n for Limited Intervention, DE96 at 1.) As such, the Intervenors correctly note that "any statement made in the course of plea discussions with an attorney for the prosecuting authority [the U.S. Attorney's Office] which do not result in a plea of guilty" cannot be used against Jeffrey Epstein. Fed. R. Evid. 410(4). + +On today's date, September 26, 2011, the Court granted in part the Petitioners' Motion seeking a finding of violations of the Crime Victims' Rights Act ("CVRA"), but deferred ruling on the merits pending completion of discovery and denied the Petitioners' Motion to Have Their Facts Accepted as True. ( See DE99 at 13-14.) + +Accordingly, it is premature to speculate as to how the Petitioners will try to "use" the information currently within their possession. The United States suggests, for the reasons set forth below, that the parties enter into a Protective Order governing the use and filing of such material until such time as the matter is ripe. + +The Intervenors' second argument also is premature. In it, they argue that because they anticipate that the Jane Does will seek the discovery of inadmissible plea negotiations, the Court should made some sort of ruling requiring the Jane Does to make a showing of a proper basis for the discovery. As noted above, today the Court issued an Order wherein it allowed the Petitioners limited discovery via document requests and requests for admissions from the U.S. Attorney's Office. (DE99 at 11.) Rather than impose a preliminary restriction, the United States recommends that the Court require Petitioners to serve a copy of all discovery requests on the Intervenors so that they may interpose any objections and have those objections ruled upon prior to the United States serving any of its responses. + +# C. The Attorney Work-Product Privilege Applies to These Communications. F3 + +In a federal criminal case, the parties are prohibited from obtaining via discovery "reports, memoranda, or other internal government documents made by an attorney for the government or other government agent in connection with investigation or prosecuting the case," and "reports, memoranda, or other documents made by the defendant, or the defendant's attorney or agent, during the case's investigation or defense[.]" Fed. R. Crim. P. 16(a)(2), (b)(2)(A). In a federal civil case, the parties are prohibited from obtaining via discovery documents and tangible things that were prepared in preparation for litigation (including previous litigation), especially "mental impressions, conclusions, opinions, or legal theories of a party's attorney or other representative concerning the litigation." Fed. R. Civ. P. 26(b)(3)(B). + +1. + +s the motion to intervene, Movant Epstein and his counsel must expect to be subject to discovery at least as to his claims of privilege, on which he bears the burden of proof. + +Respectfully submitted, + +WIFREDO A. FERRER + +UNITED STATES ATTORNEY + +![](_page_2_Picture_9.jpeg) + +[Redacted] + +[Redacted] +[Redacted] with the +[Redacted] to receive + +Clerk +notice + +Brad Edwards, Esq., + +1 [Redacted] C + +2 [Redacted] + +H [Redacted] + +Paul G. Cassell + +[Redacted] + +[Redacted] + +[Redacted] + +Attorneys for Jane Doe # 1 and Jane Doe # 2 + +Roy Black, Esq. + +Jackie Perczek, Esq. + +[Redacted] + +![](_page_4_Picture_0.jpeg) + +![](_page_4_Picture_1.jpeg) + +Attorneys for Intervenors Jeffrey Epstein, Roy Black, Martin Weinberg, and Jay Lefkowitz + +fine United States uses the term "confidential" plea negotiations as a term of art. By definition, all plea negotiations are confidential and, pursuant to Rule II, are not to be made part of the Court record until a final agreement is reached and a guilty plea is entered. + +Pursuant to S.D. Fla. Local Rule 5.4(c), this would require that DE52 be destroyed or returned to counsel for the Jane Does and that DE63 and DE64 be destroyed or returned to counsel for the United States and that DE48 remain in the Court file only in its redacted form. + +F3The Intervenors also argue that the Court should find that the documents and information are irrelevant because the Petitioners are not entitled to invalidate the Non-Prosecution Agreement. In the Court's Order of September 26, 2011, granting in part the Petitioners' Motion for finding violations of the CVRA, the Court did not address the United States' argument that there is no remedy available for the Petitioners due in part to their failure to seek a prompt resolution of the case. However, in light of the Court's Order, it would seem that this issue is better resolved in a Motion for Reconsideration or on appeal of that ruling rather than in this Supplemental Briefing. 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I argued it would be a Due Process violation to even suggest such a thing. + +![](_page_0_Picture_139.jpeg) + +-----Original Message ----- + +**From:** [REDACTED] + +**Sent:** [REDACTED] + +**To:** [REDACTED] + +**Subject:** Re: + +Have we conceded that a showing that we violated the CVRA would justify reopening/setting aside the nonpros? + +**From:** [REDACTED] + +Ideally to set aside the Non-Prosecution Agreement with Epstein and then to somehow convince us (probably through public pressure via the press) to prosecute him. + +[REDACTED] + +----- Original Message ----- + +From: [REDACTED] + +Sent: [REDACTED] + +To: [REDACTED] + +Subject: + +What is the relief jane does want in the cvra case? \ No newline at end of file diff --git a/marker2/ds9/EFTA00205768/EFTA00205768.metadata.json b/marker2/ds9/EFTA00205768/EFTA00205768.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..df962ea24d889bc613b1d5d9a0044bc5a7bb7efb --- /dev/null +++ b/marker2/ds9/EFTA00205768/EFTA00205768.metadata.json @@ -0,0 +1,91 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205768.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1411, + "elapsed_seconds": 77.69, + "image_assets": [ + "_page_0_Picture_126.jpeg", + "_page_0_Picture_139.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 59 + ], + [ + "Text", + 58 + ], + [ + "Line", + 29 + ], + [ + "PageFooter", + 2 + ], + [ + "Picture", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 14 + ], + [ + "Span", + 13 + ], + [ + "Line", + 7 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205768" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205768/_page_0_Picture_126.jpeg b/marker2/ds9/EFTA00205768/_page_0_Picture_126.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..32fb61cf2f1bbba9af3333c0d915310e3c118724 --- /dev/null +++ b/marker2/ds9/EFTA00205768/_page_0_Picture_126.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:147f3e09f870bb470498b078aeea5d76ba29e4a7f8413a296f44155379c784e8 +size 4262 diff --git a/marker2/ds9/EFTA00205768/_page_0_Picture_139.jpeg b/marker2/ds9/EFTA00205768/_page_0_Picture_139.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..51aa93b5d88aa53262cd5332efec52b849a2bc54 --- /dev/null +++ b/marker2/ds9/EFTA00205768/_page_0_Picture_139.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:06eacaaca3eb806c759ce5b8f908b76f8836c438bcdc2d6e507e3be7e9ccf35a +size 3897 diff --git a/marker2/ds9/EFTA00205770/EFTA00205770.md b/marker2/ds9/EFTA00205770/EFTA00205770.md new file mode 100644 index 0000000000000000000000000000000000000000..7d830690a567c6703a92c3c775f644c9ed3fc67f --- /dev/null +++ b/marker2/ds9/EFTA00205770/EFTA00205770.md @@ -0,0 +1,736 @@ +## 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA + +3 JANE DOE, ) Case No. ) 08-80736-CIV-MARRA 4 Petitioner, ) ) 5) ) 6 UNITED STATES OF AMERICA,) ) 7 Respondent. ) West Palm Beach, Florida ) August 14, 2008 8 ) + +## 10 TRANSCRIPT OF HEARING + +11 BEFORE THE HONORABLE KENNETH A. MARRA 12 U.S. DISTRICT JUDGE + +14 Appearances: 15 FOR THE PETITIONER Bradley J. Edwards, ESQ., and Paul G. Cassell, ESQ. + +17 FOR THE RESPONDENT + +19 Reporter Stephen W. Franklin, RMR, CRR, CPE (561)514-3768 Official Court Reporter 20 701 Clematis Street, Suite 417 West Palm Beach, Florida 33401 + +1 (Call to the order of the Court.) + +2 THE COURT: Good afternoon. + +3 VOICES: Good afternoon, Your Honor. + +4 THE COURT: All right. This is the case of In Re: 5 Jane Does 1 and 2, case number 08-80736-C/V-MARRA. + +6 May I have counsel state appearances, please, and 7 if you can please try and speak up so we can hear you. + +8 MR. EDWARDS: Okay. Brad Edwards, on behalf of 9 Jane Doe 1 and 2. + +10 MR. CASSELL: Paul Cassell, along with Mr. Edwards. + +11 THE COURT: Good afternoon. + +12 : Good afternoon, Your Honor. For the 13 United States Government, Dexter Lee, Assistant U.S. 14 Attorney, and Marie + +15 THE COURT: All right. Good afternoon. + +16 Mr. -- everyone, we're having trouble hearing you, 17 so if you can try and speak up, and also if you could 18 identify yourself before you begin speaking so the reporter 19 can accurately indicate on the record who is speaking. / 20 appreciate that. + +21 / scheduled this for a status conference in order 22 to determine whether I'm going to need additional -- as far 23 as the parties were concerned, whether either of the parties 24 thought that I needed additional information in order to 25 proceed with the pending motion by the Plaintiffs or whether + +1 we have a complete record based upon what's already been 2 submitted, and I wasn't quite sure where we were on that 3 since we last met. + +4 So if I can hear from Mr. Edwards or Mr. Cassell 5 first what the Plaintiffs' position as far as where we stand 6 on the record in terms of whether I need additional facts, 7 evidence, or there's going to be a stipulation submitted to B me upon which I can rely. + +9 MR. EDWARDS: Sure. + +10 Your Honor, this is Brad Edwards. + +11 / believe that you do have a sufficient record, in 12 that / don't think that -- I think that we're in agreement 13 that additional evidence does not need to be taken in the 14 case for Your Honor to make a ruling. We have actually met 15 with the U.S. Attorney, and we've had meaningful discussions 16 in an attempt to resolve our issues. I think the only issue, 17 we can probably agree to this right now, is that the victims 18 are unable at this point in time to go any further with 19 requesting a remedy from the Court without the full and 20 complete plea agreement being produced to us from the U.S. 21 Government, and the U.S. Government's hands are tied in that 22 there's a confidentiality agreement within that plea 23 agreement that prohibits them from turning that over. + +24 So at this point in time, we would be asking Your 25 Honor to enter an order compelling them to turn over that + +1 2 agreement, and at that point in time I think we can meet again and probably resolve our disputes amongst ourselves. + +3 4 5 6 7 THE COURT: All right. So do I understand that you're modifying your claim for relief at this point and only seeking me to compel the Government to produce the plea agreement, or are you -- or is this a -- a preliminary step, after which you're then going to evaluate whether you want me to do something further? + +9 10 11 12 13 14 MR. EDWARDS: I think it's the latter, Your Honor. /t is, and it will likely always be, our position that the victims' rights are violated. However, because of the legal consequences of invalidating the current agreement, it is likely not in my clients' best interest to ask for the relief that we initially asked for. + +15 16 17 18 19 20 21 So in order to effectively evaluate the situation and ask for the appropriate relief, we would just be asking Your Honor at this point in time to allow us to see the full entire plea agreement that is purportedly drafted to protect my victims. That only seems fair to know, you know, what the plea agreement says, especially in light of the fact that Mr. Epstein knows what the plea agreement says. + +22 23 24 25 relief, whether THE COURT: All you will evaluate to either dismiss some additional relief? right. And then if I grant that the agreement and then decide your case or go forward and ask for 1 MR. EDWARDS: That's correct, Your Honor. + +2 THE COURT: /s it your plan or is there any kind 3 of -- been any kind of discussion between you and the 4 Government as to what you -- if I grant the relief of 5 requiring the Government to at least present you with the 6 agreement and let you view it, has there been any discussion 7 about you keeping it confidential and not letting it go any 8 further than your clients and using it for your 9 decision-making purposes, or do you wish to have it released 10 to you, and you would be able to use it however you wished? + +11 MR. EDWARDS: Well, Your Honor, we would prefer 12 that it be produced to us and not have to keep it 13 confidential. I think that that creates an undue hardship on 14 us. However, if it was Your Honor's order that we do 15 maintain some confidentiality of the agreement, we would 16 certainly abide by it. + +17 The reason we want it is not so that it's 18 disseminated everywhere; however, there is a public interest 19 in viewing what happens in the court process, and this is 20 just part of it. There's no reason that it should be sealed 21 or kept confidential. Seems to be an overwhelming reason 22 to -- to make it public. However, that's not our intention. 23 Our intention is just to view it, represent my clients and 24 then evaluate it and ask the Court for the appropriate relief 25 after we've seen it. + +1 THE COURT: All right. And, again, although I hear 2 you saying you think that it shouldn't be kept confidential 3 because there's some public interest in it, but if you had it 4 to use for whatever, to represent your client either in 5 advising your clients whether to go forward with this case or 6 not, or I guess to use it in connection with any other 7 litigation that you might want to initiate on behalf of your 8 clients where that agreement might have some relevance, 9 what's the interest in using -- having the ability to 10 disclose it beyond those purposes? + +11 MR. EDWARDS: Well, certainly if -- if the 12 agreement was designed to protect these victims in a criminal 13 as well as a civil context, and we are going to be filing 14 civil cases against Mr. Epstein, and this agreement, 15 undoubtedly it will play a big role in the amount of 16 protection the victims have been allotted, as well as the 17 course of action in the civil cases. It seems inevitable 18 that it's going to become, you know, more public at that 19 point in time, and I think that's in the very near future. + +20 At this point in time, it's not intention to make 21 it public, but I think that inevitably happens as soon as 22 civil litigation begins, and this is at the heart of it, 23 + +24 THE COURT: Well, civil litigation has already 25 begun, hasn't it? + +1 MR. EDWARDS: Right. + +2 THE COURT: Okay. All right. + +3 MR. EDWARDS: At least for some other parties, with 4 other attorneys and other things, so . . . + +5 THE COURT: Well, you filed a case yesterday, 6 didn't you? + +7 MR. EDWARDS: We filed one of them. It is not on 8 behalf of one of the Jane Does that /'m representing in this 9 action. + +10 THE COURT: Okay. All right. + +11 MR. EDWARDS: Just so that we're clear. + +12 THE COURT: I haven't seen the name, so I didn't 13 know who it was on behalf of. + +14 All right. Let me hear from or + +15 Ms. + +16 I understand that you're under a confidentiality 17 agreement, and / understand that you feel restricted in what 18 you can unilaterally do, but I've already entered some 19 rulings in this case that have made portions of that 20 agreement public. Is there any reason to keep the rest of 21 the agreement confidential, other than you're obligated by 22 the agreement and don't want to be in a position where you've 23 unilaterally violated it absent a court order? + +24 : Yes, Your Honor. This is I + +25 Good afternoon. + +1 Your Honor, we do feel bound by the confidentiality 2 provision such that we could not voluntarily disclose this 3 non-prosecution agreement without court order compelling us 4 to do so. + +5 The provision in the non-prosecution agreement 6 required us to notify Mr. Epstein and his attorneys of any 7 attempts to have this document disclosed in a public forum, B and we have done so. They have expressed their desire that 9 if this document is to be disclosed to the Petitioners in 10 this case, that it be done pursuant to a protective order 11 which would preclude the victims from disseminating it 12 publicly. + +13 We believe that is appropriate in this action. It 14 would allow them access to the document, which they claim 15 they have a need to have, and that's fine. They can review 16 it and determine where they wish to go. We believe there's 17 no public interest in having this disseminated. + +18 Now, should there be subsequent litigation between 19 Mr. Edwards' clients and Mr. Epstein, and the subject matter 20 of this agreement should arise, then Mr. Epstein and 21 Mr. Edwards will be in a position to litigate that in 22 whatever forum it is, rather than having that issue disposed 23 of where they're not present to voice their objections. + +24 So we would ask the Court to, if it compels us to 25 disclose it, to do so under a protective order which would + +1 provide for no public dissemination. + +2 THE COURT: All right. + +3 : Your Honor this is Marie + +4 Just to add onto what was saying, one of 5 our concerns is that there are names of individuals in the 6 order who are not currently -- + +7 THE COURT: Ms. , I'm having trouble B hearing you. I apologize. + +9 MS. : I'm sorry. + +10 Your Honor, one of our concerns is that the 11 agreement contains names of individuals who are not 12 currently -- haven't pled guilty or haven't -- do not have 13 certain obligations. And / think that there may be a Rule 14 6(e) issue if the agreement is made public or available to 15 the press, et cetera. + +16 THE COURT: Okay. So, I'm sorry, you say there are 17 names of other individuals that do what? + +18 MS. : They were other individuals who are 19 the subject of these -- who are the subject of the 20 Government's investigation but who are not necessarily known 21 to the public in the sense that Mr. Epstein entered the 22 guilty plea and the public is aware of that, but they may not 23 know about these other individuals who haven't been indicted, 24 and therefore I think they have a bit of a privacy interest 25 here. + +1 THE COURT: Okay. But they're not parties to the 2 agreement. + +3 MS. : No. + +4 THE COURT: Okay. Other than the fact that the 5 Government bound itself in the agreement not to disclose it, 6 and you require a court order to have it disclosed, what 7 would be the public interest, or what would be the 8 justification for denying disclosure of the agreement at 9 least to purported victims of Mr. Epstein's conduct? Why 10 shouldn't the victims who the Government, as I understand it, 11 provided notice of their rights under the Act that they had 12 the status of victims, why shouldn't they have the 13 opportunity to see that agreement? + +14 MS. : Your Honor, I guess I will respond. + +15 I was prepared to -- I need to highlight an issue 16 for the Court. I was prepared to argue today that we had 17 provided the victims with the portion of the agreement that 18 is relevant to them. + +19 Last night and this morning, in conversations with 20 Mr. Epstein's attorneys, they have said for the first time 21 that they do not believe that one portion of the agreement is 22 binding, and that is the portion that has been disclosed to 23 the victims. So I can no longer say that they have the 24 portion that is relevant to them. + +25 THE COURT: I'm sorry, I didn't quite follow that, + +1 Ms. . + +2 You've had discussions with Mr. Epstein's counsel 3 as to what? + +4 MS. : Your Honor, in preparation for 5 today's hearing, I was -- I had been working to confirm with 6 Mr. Epstein's attorney that the agreement that I have 7 described in my declaration is the one that they are 8 performing under. Last night and this morning for the first 9 time, I was told that they believe that a portion of the 10 agreement that is described in my declaration and that was 11 disclosed to the victims does not bind them. So as of this 12 point, the victims have not received at least what 13 Mr. Epstein claims is the portion relevant to them. + +14 THE COURT: Okay. Your understanding is that 15 Mr. Epstein's taking the position that the portions of the 16 agreement that have already been disclosed are not -- is not 17 binding on Mr. Epstein? + +18 MS. : Yes. + +19 : Your Honor, this is Dexter Lee. If I 20 may? + +21 The agreement initially negotiated was executed in 22 September of 2007. That's part one, I will call it. + +23 In October, there was an addendum to the executed 24 agreement which occurred the month before. There was some 25 more discussions, and there was a letter that was submitted + +1 to Mr. Epstein's attorneys by the United States Attorney in 2 December. That's part three, I will call it. + +3 There is now a dispute between the Government and 4 Mr. Epstein's attorneys about whether certain portions after 5 the original agreement are effective and binding. I just 6 need to make the Court aware of that and also Mr. Edwards and 7 Judge Cassell. + +8 MR. EDWARDS: This is the first time + +9 This is Brad Edwards speaking. + +10 This is the first time we're hearing any of this. 11 This is obviously even further evidence that the victims were 12 unaware of the plea agreement that was being worked out. + +13 But, nonetheless, I don't think that it changes our 14 position, in that we believe we're entitled to not only the 15 plea agreement, but all of the addenda that have been 16 attached to that plea agreement and have become part of that 17 plea agreement, just so that what we're asking for is clear. + +18 : Your Honor, this is Dexter Lee. + +19 We are prepared to give all three hopefully, in our 20 view, pursuant to a protective order preventing public 21 disclosure, but we just want the Court and the Petitioners' 22 counsel to know that there is a dispute ongoing right now 23 about which portions are effective and which are not. And we 24 can discuss that with them at the conclusion of the hearing. + +25 THE COURT: All right. But again, as far as my + +1 earlier question, even though there's a dispute now 2 apparently between Mr. Epstein and the Government as to what 3 portions of the agreement are or are not binding, does the 4 Government have any reason why the victims should not have 5 the benefit of seeing these -- the agreement, whether, you 6 know, it's going to be held binding down the road or not, 7 other than you agreed in a confidentiality order not to disclose it? But beyond that, is there any justification 9 that the Government can provide to me as to why the victims, 10 people who have been identified by the Government as victims 11 of Mr. Epstein, should not have the benefit of seeing this 12 plea agreement, or non-prosecution agreement, whatever you 13 want to term it? + +14 : Your Honor, this is Dexter Lee. When you 15 refer to victims, do you mean victims beyond the three that 16 are parties to the instant litigation? + +17 THE COURT: I mean -- yes, I'm talking about anyone 18 who the Government may have disclosed as a -- as a -- or sent 19 notice to based upon your understanding of who might have 20 been a potential or an alleged victim of Mr. Epstein's 21 conduct, whether they're part of this lawsuit or not. + +22 : Well, if the Court is asking whether we 23 could expand the protective order such that it would permit 24 disclosure to those other victims identified that have 25 received notification already, I believe that would be + +1 appropriate. + +2 THE COURT: Okay. But I guess my real question is 3 do you have any reason that you could advance why they should 4 not get it? + +5 Let's just limit ourselves to the victims who are 6 the Jane Does in this case before we go beyond that. Is 7 there any reason that the Government can advance why the two B Jane Does 1 and 2 in this case should not have the 9 opportunity to view the plea agreement, or the deferral 10 agreement or the addenda to it? Can anyone justify not 11 letting them see it? + +12 : Your Honor, this iS Dexter Lee. + +13 No, we cannot. + +14 THE COURT: Okay. All right. Now, Mr. Edwards. + +15 MR. EDWARDS: Yes. + +16 THE COURT: Is there any reason why I shouldn't, 17 assuming I'm going to allow or require the Government to 18 produce the agreement and the addenda to your clients in this 19 case -- and we'll talk about other victims in a minute -- is 20 there any reason why, at least initially, it shouldn't be 21 subject to a protective order so that in the case, for 22 example, that you filed yesterday on behalf of an alleged 23 victim under a Jane Doe, where you specifically reference 24 this agreement in your -- in one the counts, that it 25 shouldn't remain subject to a protective order at least until + +1 Mr. Epstein has the opportunity to litigate whether or not it 2 should be disclosed beyond -- beyond your clients or other 3 victims? + +4 MR. EDWARDS: At this point, Your Honor, I think 5 that that would probably be fair. + +6 My only real concern is that if there's an order 7 out there where anybody can access on PACER and it says, B "okay, at this point I'm ordering the Government to disclose 9 this plea agreement," I just want to make sure if anybody 10 else feels entitled to that agreement, whether it's other 11 victims, or counsel, or what have you, that they be required 12 to request it from the Government or these attorneys rather 13 than try to subpoena or request it from my office, knowing 14 that / have access to this confidential agreement. + +15 Other than that, no, I don't have any other reasons 16 why that's not a reasonable order. + +17 THE COURT: All right. And let's assume I think it 18 should be available to any person that the Government has 19 identified as an alleged victim of Mr. Epstein's conduct, and 20 they've sent notice of their rights under the statute as a 21 victim to this -- these individuals, and I permit disclose to 22 your clients, or anyone else who fits into the category of 23 victim as described by the Government, and require -- you 24 know, again, impose a protective order that it shouldn't go 25 to anyone beyond that until such time as, in a pending + +1 lawsuit, I conclude that the protective order should be 2 lifted after Mr. Epstein has an opportunity to be heard on 3 that issue, is there anything else that you would need at 4 this point? + +5 MR. EDWARDS: No, Your Honor. + +6 This is Brad Edwards. + +7 At this point in time that's all we're requesting. + +8 THE COURT: And or Ms. , if I 9 conclude that anyone that you've identified as a victim and 10 notified as a victim of their rights with respect to the 11 investigation of Mr. Epstein is entitled to view the 12 agreements, subject to a protective order until such other 13 time that / say it should be released beyond that, do you -- 14 is there any reason why I shouldn't make it available to all 15 of the people who have been identified by you as a victim? + +16 : This is Dexter Lee, Your Honor. + +17 The answer is no, there's no problem, with the 18 exception of the grand jury issue that my colleague, 19 Ms. , mentioned earlier. I may have to defer to her 20 right now on that issue to see if that would preclude what 21 the Court is asking. + +22 THE COURT: All right. Hold on one second. + +23 (Brief pause in proceedings.) + +24 THE COURT: Mr. Edwards, is there any reason why 25 you would need to see the names of others that the Government + +1 may have been investigating that might appear -- whose names 2 might appear in these agreements? /s there any interest that 3 you would have in that or need to see that information? + +4 MR. EDWARDS: Well, the primary interest would be 5 that those are obviously important witnesses for any case 6 that my clients have against Mr. Epstein, witnesses that 7 Mr. Epstein is clearly aware of, since he has access to the 8 complete full agreement, and it seems inherently unfair that 9 he would have access to the names -- to a witness list that 10 my clients would not be privy to. + +11 THE COURT: Well, why wouldn't you be able to get 12 those through discovery in the civil litigation? + +13 MR. EDWARDS: And that may be an appropriate time 14 to get it. But that would be my primary objection for not 15 getting the names of the victims, whether now or eventually. + +16 THE COURT: No, as I understand it, this is not the 17 names of other victims, this is the names of other 18 individuals that the Government may have been investigating 19 in connection with their investigation of Mr. Epstein, and 20 they're concerned about grand jury secrecy and information 21 that may have been brought before the grand jury that should 22 not be made public at this point, as I understood the 23 Government's position. + +24 Is that correct, Ms. + +25 MS. : Yes, Your Honor. + +1 MR. EDWARDS: Well, Your Honor, as I understand 2 this -- and correct me if I'm wrong, anybody -- this 3 non-prosecution agreement provides for a dismissal or 4 immunity for other individuals, and I think these are the 5 individuals that we are talking about. But all of that is 6 inextricably intertwined within this agreement, and it is 7 this agreement in its total form that is supposed to protect 6 the victims. I think that the victims have a right to know 9 of these other individuals, who my clients were also familiar 10 with during the course of this conduct, and how it protects 11 them in this case. And I don't see why they should, once 12 again, get an incomplete version of this. Because these are 13 characters that are very intertwined with the -- the -- with 14 Mr. Epstein's conduct. This is not completely and wholly 15 indifferent or irrelevant conduct for some other people. 16 This is all part of the same conduct, and I think that's 17 probably necessary for us to evaluate the effect of this 18 agreement and whether or not we're going to continue to 19 pursue this case. + +20 THE COURT: All right. So you're assuming that the 21 agreement also provides that the Government will not 22 prosecute these other individuals? That's what your 23 assumption is? + +24 MR. EDWARDS: Yes, Your Honor. + +25 THE COURT: Do you have any information to -- upon + +1 which you make that conclusion, or is that just an 2 assumption? + +3 MR. EDWARDS: That is all just, you know, the 4 discussions that we've had with various individuals, law 5 enforcement, clients, things like that. And putting it 6 together, that's what we believe is a portion of this 7 agreement. /f /'m wrong about that, one of the U.S. Attorneys on the phone can probably correct me. But that's 9 my belief. + +10 THE COURT: All right. Well, assume they're just 11 mentioned in the agreement in some way. And I'm not sure how 12 or why they would be mentioned. But assume they're mentioned 13 in the agreement, but there's no agreement by the Government 14 not to prosecute them. Is there any reason for you to have 15 their names if it's other than for the purpose of finding out 16 the extent to which the Government has agreed not to 17 prosecute Mr. Epstein and other individuals? + +18 MR. EDWARDS: That's a tough question for me to 19 answer without knowing in what context those individuals are 20 listed. However, I just renew my previous argument that / do 21 believe they're intertwined, and I think that, once again, if 22 we get a version of this plea agreement without the portions 23 that pertain to these other individuals, then we could 24 possibly be in the same position where we are not sure as to 25 the full extent of the protection allowed under this + +1 agreement. That would be -- without knowing how they're 2 mentioned, I can't voice any other objection to not getting 3 those portions but I could certainly foresee where, you know, 4 we're not going to get out of it what we're asking. + +5 THE COURT: All right. Well, again, I didn't 6 understand the Government to want to redact the entire 7 provisions that relate to these individuals. I understood B that they just wanted to redact their names. + +9 Am I correct, Ms. + +10 MS. : Yes. + +11 THE COURT: Okay. So if you were given the 12 agreement with these names redacted but you saw the context 13 in which they were listed, and then, after seeing the 14 agreement and the context in which their names were 15 mentioned, if it presented a problem to you that they were 16 being withheld, couldn't you then just, you know, file 17 another motion for disclosure of the names after you've had 18 an opportunity to, you know, evaluate whether or not there's 19 any real need for you to get these names? + +20 MR. EDWARDS: Okay. We could do that at that time, 21 Your Honor. + +22 THE COURT: All right. Anything else that anybody 23 wants to add to what -- our discussion? + +24 MR. EDWARDS: One more thing, Your Honor. This is 25 Brad Edwards. + +1 Same topic. My clients are currently in a position 2 where they may be speaking to local law enforcement regarding 3 certain issues pertaining to this case, and if we are unable 4 to have access to the other named people in this agreement, 5 it may put them at a disadvantage in terms of whether or not 6 it would be in their benefit to speak with other law 7 enforcement about this case. I mean, certainly if there's 8 individuals who have been given immunity in this agreement, 9 then it would only be to the disadvantage of my clients to 10 continue to try to pursue criminal charges. + +11 So in that regard, that would be my only objection 12 to not having the names of these other individuals. + +13 THE COURT: All right. Well, again, you're 14 assuming that there's some kind of immunity or deferral of 15 prosecution -- + +16 MR. EDWARDS: That's correct. + +17 THE COURT: -- given to people other than 18 Mr. Epstein, correct? + +19 MR. EDWARDS: That's correct. + +20 THE COURT: Okay. And that's something that would 21 be clear once you got the agreement and you read it, and if 22 the names were -- you know, if that was apparent in the 23 agreement, then you could come back and ask me to require the 24 disclosure of the names. + +25 MR. EDWARDS: Okay. That sounds fair. + +1 THE COURT: All right. or Ms. 2 did you have anything else you wanted to add? + +3 MS. : Well, Your Honor, I guess I will 4 just tell the Court this. It does indeed contain language 5 related to that issue. So I don't know if you want to make 6 Mr. Edwards jump through that hurdle or if you want to make 7 that decision now. + +8 THE COURT: All right. So you're telling me that 9 there is some language in the agreements that does obligate 10 the Government to not prosecute individuals other than 11 Mr. Epstein? + +12 MS. : Correct. + +13 THE COURT: All right. So if that's true, why 14 should the victims not know who those people are? + +15 MS. : Your Honor, I guess my concern 16 really relates to disclosure. And if your protective 17 order -- or I don't know if you need a written protective 18 order or an ore tenus order, limit Mr. Edwards to disclosing 19 it only to his clients and to his co-counsel, then I don't 20 think that we would have a basis to object. + +21 THE COURT: Again, with the right for them to come 22 back and ask for the ability to disclose it beyond that 23 limited group at a later time after Mr. Epstein has an 24 opportunity to be heard? + +25 MS. : Right. + +1 THE COURT: Again, Mr. Edwards, do you have any 2 problem with that procedure, you know, you're permitted to 3 disclose -- the names of these individuals who are also 4 getting the benefit of a non-prosecution agreement would be 5 disclosed to you under the terms of the protective order 6 without prejudice to you being able to, in any litigation 7 that ensues, seeking to disclose it beyond the limited group? + +8 MR. EDWARDS: No, Your Honor, that's fine. + +9 THE COURT: All right. Well, then I'm going to 10 order the Government to produce the agreement and any addenda 11 to Mr. Epstein -- Mr. Edwards in this case, and it would be 12 available also to any other individuals who have been 13 identified by the United States as victims in connection with 14 the investigation of Mr. Epstein, subject to a protective 15 order. Which, I'm going to ask the parties to try and work 16 on the language of a protective order to submit to me that 17 would prohibit disclosure to anyone other than Mr. -- to the 18 victim, or victims' counsel, without prejudice to the victims 19 seeking the ability to disclose it beyond that limited group 20 after Mr. Epstein has an opportunity to be heard on further 21 disclosure. + +22 MR. EDWARDS: Okay. Thank you, Your Honor. + +23 : This is Dexter Lee. + +24 Very well, Your Honor. We appreciate your time. + +25 THE COURT: All right. So is there any questions + +1 about it? Is there anything unclear about what I'm ordering? + +2 And I'm also -- okay. And the names of the -- 3 there will be no redaction in the agreements, but any victim 4 has to -- who gets notice of this has to agree to be bound by 5 the protective order until further order of the Court. + +6 MS. : Your Honor, this is Marie 7 + +8 Just to be clear, we are not under an obligation to 9 advise the victims of this, but if the victim asks for a copy 10 of the document, this is the procedure that we'll follow? + +11 THE COURT: Well, I'm not going to tell you whether 12 you have any obligation under the Act to disclose this or 13 not. I don't want to get into that. I don't know that you 14 do, but I don't want to say that you don't. So if you have 15 an independent obligation to disclose this to victims under 16 the Act, then -- then I'm not telling you not to do it. + +17 MS. : Okay. But your order isn't 18 ordering us to do it. We will have to make our evaluation. + +19 THE COURT: I'm only ordering it to be available to 20 victims, and the -- and then you have to decide whether 21 you're obligated under the Act to disclose it to anyone else 22 who falls into that category. + +23 MS. : Okay. Thank you, Your Honor. + +24 THE COURT: All right. Thank you. + +25 VOICES: Thank you, Your Honor. + +1 THE COURT: Have a good day. + +2 (Proceedings concluded.) + +3 \* \* \* \* \* + +## 4 CERTIFICATE + +5 I, Stephen W. Franklin, Registered Merit Reporter, and 6 Certified Realtime Reporter, certify that the foregoing is a 7 correct transcript from the record of proceedings in the 8 above-entitled matter. + +9 Dated this 20th day of AUGUST, 2008. + +10 + +11 + +Stephen W. Franklin, RMR, CRR + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +|

A

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ability (3) 6:9 22:22 23:19
able (3) 5:10 17:11 23:6
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access (6) 8:14 15:7,14 17:7,9 21:4
accurately (1) 2:19
Act (4) 10:11 24:12,16,21
action (3) 6:17 7:9 8:13
add (3) 9:4 20:23 22:2
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Ann (1) 1:17
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asked (1) 4:14
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Assistant (1) 2:13
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attorneys (7) 7:4 8:6 10:20 12:1,4 15:12 19:8
August (2) 17:25,9
AUSA (2) 1:17,17
available (5) 9:14 15:18 16:14 23:12 24:19
aware (3) 9:22 12:6 17:7

|

C

C (1) 1:17
call (3) 2:1 11:22 12:2
case (19) 1:3 2:4,5 3:14 4:24 6:5 7:5,19 8:10 14:6
14:8,19,21 17:5 18:11,19 21:3,7 23:11
cases (2) 6:14,17
Cassell (5) 1:15 2:10,10 3:4 12:7
category (2) 15:22 24:22
certain (3) 9:13 12:4 21:3
certainly (4) 5:16 6:11 20:3 21:7

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D

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day (2) 25:1,9
December (1) 12:2
decide (2) 4:23 24:20
decision (1) 22:7
decision-making (1) 5:9
declaration (2) 11:7,10
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Dexter (9) 1:17 2:13 7:24 11:19 12:18 13:14 14:12
16:16 23:23
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disclose (14) 6:10 8:2,25 10:5 13:8 15:8,21 22:22
23:3,7,19 24:12,15,21
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23:5
disclosing (1) 22:18
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23:17,21
discovery (1) 17:12
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dissemination (1) 9:1

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E

earlier (2) 13:1 16:19
Edwards (44) 1:15 2:8,8,10 3:4,9,10 4:9 5:1,11
6:11 7:1,3,7,11 8:19,21 12:6,8,9 14:14,15 15:4
16:5,6,24 17:4,13 18:1,24 19:3,18 20:20,24,25
21:16,19,25 22:6,18 23:1,8,11,22
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either (3) 2:23 4:24 6:4
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Epstein (23) 4:21 6:14 8:6,19,20 9:21 11:13,17
13:2,11 15:1 16:2,11 17:6,7,19 19:17 21:18
22:11,23 23:11,14,20
Epstein's (10) 10:9,20 11:2,6,15 12:1,4 13:20
15:19 18:14
especially (1) 4:20
ESQ (2) 1:15,15
et (1) 9:15
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evidence (3) 3:7,13 12:11
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extent (2) 19:16,25

F

fact (2) 4:20 10:4
facts (1) 3:6
fair (3) 4:19 15:5 21:25
falls (1) 24:22
familiar (1) 18:9
far (3) 2:22 3:5 12:25
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file (1) 20:16
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fits (1) 15:22
Florida (3) 1:1,7,20
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foregoing (1) 25:6
foresee (1) 20:3
form (1) 18:7
forum (2) 8:7,22
forward (2) 4:24 6:5
Franklin (3) 1:19 25:5,11
full (4) 3:19 4:17 17:8 19:25
further (6) 3:18 4:8 5:8 12:11 23:20 24:5
future (1) 6:19

G

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go (7) 3:18 4:24 5:7 6:5 8:16 14:6 15:24
going (12) 2:22 3:7 4:7 6:13,18 13:6 14:17 18:18
20:4 23:9,15 24:11
good (7) 2:2,3,11,12,15 7:25 25:1
Government (27) 2:13 3:21 4:5 5:4,5 10:5,10 12:3
13:2,4,9,10,18 14:7,17 15:8,12,18,23 16:25
17:18 18:21 19:13,16 20:6 22:10 23:10
Government's (3) 3:21 9:20 17:23
grand (3) 16:18 17:20,21
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group (3) 22:23 23:7,19
guess (5) 6:6 10:14 14:2 22:3,15
guilty (2) 9:12,22

H

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happens (2) 5:19 6:21
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hear (4) 2:7 3:4 6:1 7:14
heard (3) 16:2 22:24 23:20
hearing (6) 1:10 2:16 9:8 11:5 12:10,24
heart (1) 6:22
held (1) 13:6

|

I

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important (1) 17:5
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23:3,12
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issue (8) 3:16 8:22 9:14 10:15 16:3,18,20 22:5
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J

J (1) 1:15
Jame (7) 1:3 2:5,9 7:8 14:6,8,23
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K

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KENNETH (1) 1:11
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kind (3) 5:2,3 21:14
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L

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Lee (22) 1:17 2:12,13 7:14,24,24 9:4 11:19,19
12:18,18 13:14,14,22 14:12,12 16:8,16,16 22:1
23:23,23
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let's (2) 14:5 15:17
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list (1) 17:9
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litigate (2) 8:21 15:1
litigation (7) 6:7,22,24 8:18 13:16 17:12 23:6
local (1) 21:2
longer (1) 10:23

M

maintain (1) 5:15
Marie (4) 1:17 2:14 9:3 24:6
MARRA (1) 1:11
matter (2) 8:19 25:8
mean (3) 13:15,17 21:7
meaningful (1) 3:15
meet (1) 4:1
mentioned (6) 16:19 19:11,12,12 20:2,15

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Marra, +pursuant to Notice, taken before Victoria Aiello, +Court Reporter, pages 1-32. + +For the Plaintiff: Bradley Edwards, Esquire + +For the Defendant: Dexter Lee [REDACTED] + +(Call toOrder of the Court). + +THE COURT: Good morning. Please be seated. + +This is the case of In Re: Jane Doe, Case Number 08-80736-Civ-Marra. May I have counsel state their appearances, please? + +MR. LEE: Good morning, Your Honor. May it please the Court, for the United States of America, we have Maria , Assistant United States Attorney and Dexter Lee, Assistant United States Attorney. And we have seated in the front row FBI Special Agent Becker Kendall and Jason Richards. Thank you, Your Honor. + +MR. EDWARDS: Good morning, Your Honor. Brad Edwards on behalf of the petitioners. Petitioners are also in the courtroom today. This petition is styled on her behalf. + +THE COURT: Good morning. All right. We're here on the petitioner's motion to enforce her rights as a victim under 18 USC 3771. I have received the petition, the government's response and the victim's reply, which was filed, I guess, this morning. So, You want to proceed, counsel?. + +MR. EDWARDS: Yes, Your Honor. You prefer me at the podium? + +1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 MR. EDWARDS: Your Honor, as a factual background, Mr. Epstein is a billionaire that sexually abused and molested dozens and dozens of girls between the ages of 13 and 17 years old. And through cooperating victims, that evidence can be proven. Because of his deviant appetite for young girls, combined with his extraordinary wealth and power, he may just be the most dangerous sexual predator in U.S. history. This petitioner is one of the victims and she is in attendance today. Another one of Mr. Epstein's victims is also in attendance today. She would be able to provide evidence that she provided-- that Mr. Epstein paid her to provide him over 50 girls for the purposes of him to sexually abuse. Therefore, the undercurrents of the petition are clear. The plea bargain that was worked out for Mr. Epstein in light of the offenses that he committed is clearly unfair to the point that if anybody looks at the information, it is unconscionable. + +21 22 23 24 THE COURT: Well, I mean, is that for me? That's not my role. That's the prosecutor's role to apply, would it not? I can't force them to bring criminal charges. What do I have to do with that. + +THE COURT: That may be your opinion, that may be your client's opinion, but I presume that the government is aware that that's your client's opinion. How does that change anything? + +MR. EDWARDS: That's my problem. I'm not sure that the government is aware that is petitioner's opinion and that's why we're here today, just to enforce the victim's rights under 18 USC 3771, Crime Victims Rights Act, and all we are asking is to order that the plea agreement that has been negotiated in this case-- + +THE COURT: How do you know there is a plea agreement? The plea agreement is with the State of Florida, wasn't it? + +MR. EDWARDS: There was a state charge with one victim that I'm aware of. And the plea agreement as to that one victim was 18 months in the county jail. But along with that, the Palm Beach County Sheriff investigating this case was getting no action out of the local authorities and sent this to the FBI. + +THE COURT: It was actually the Palm Beach-- Town of Palm Beach Police, not the Sheriff's Office. + +1 2 why the FBI got involved because Michael Feeter wrote a scathing letter to the State Attorney about + +3 4 Mr. Epstein receiving preferencial treatment by local authorities. + +5 6 Before the FBI took the case, they went behind the victim's back, and this is our motion, + +7 8 without the victim's input and allowing her the right to meaningfully confer with the government, + +9 which is a right that she can assert at this time. + +10 11 They worked out a plea deal where if Mr. Epstein would plead to this other charge regarding another + +12 13 14 victim in the state court case, they would agree to not prosecute him for all of the federal charges of what they were aware of in federal court.. + +15 16 THE COURT: So that's already apparently taken place, correct? + +17 18 19 20 MR. EDWARDS: I don't know if it has taken place. I'm not sure exactly what stage it is in. I know it is supposed to be attached at some point in time to a state court plea. + +21 22 THE COURT: Hasn't he already plead guilty, though? + +23 24 25 MR. EDWARDS: If he did plead guilty, it is my understanding and belief that the agreement with the federal government and with the U.S. Attorney's 1 2 3 Office wasn't signed on that day. So it is still my belief, I could be wrong, but that that agreement hasn't been completed as of this time. + +4 5 THE COURT: So let's assume it hasn't been completed. + +6 7 MR. EDWARDS: Okay. Then petitioner would like the right to confer with-- + +8 9 10 11 12 13 THE COURT: You can go in the conference room. We've got the FBI agents, you've got the assigned prosecuting attorney. You have got a conference room. You've got your client. Go and talk. Confer. And then it is up government to decide what to do, correct? + +14 15 16 17 MR. EDWARDS: In a way, Your Honor, that's very similar to what happened in In Re: Dean and PB case where there is a plea agreement negotiated and then the victim gets the right to confer. + +18 19 THE COURT: It's already negotiated. What am I supposed to do? + +20 21 22 MR. EDWARDS: Order that the agreement that was negotiated is invalid and it is illegal as it did not pertain to the rights of the victim. + +23 24 25 THE COURT: I can order you into the conference room. Then the government can do what it chooses. It can agree to prosecute or it can agree + +1 2 3 4 5 6 7 8 9 10 11 to going forward with the agreement it had already reached and after consulting your client and in taking into consideration your client's views, decide to go forward anyway. I can't make them prosecute him. I can't-- All I can do is, at best, say confer with the victim, consider the victim's input before you make a decision or reconsider the decision you already made in view of the victim's input, if it is possible for you to do that. So if I invalidate the agreement, what's the best you can get? The right to confer? + +12 MR. EDWARDS: Exactly. That is all we can. + +13 14 15 THE COURT: So why can't you go into the conference room now, take as much time as you feel you need and confer? + +16 17 18 19 MR. EDWARDS: Judge, at this time I'd like to move ore tenus to add the victim that's in the courtroom to this conference with the U.S. Attorney's Office. + +20 21 THE COURT: So is that Jane Doe 2 for purposes of this? + +22 MR. EDWARDS: Exactly, Your Honor. + +23 24 THE COURT: All right. Let me hear from the government then. + +please the Court. Let me update the Court on the + +status of + +various matters. The agreement to defer prosecution + +to the State of Florida was signed and completed by + +December of 2007. Mr. Epstein's attorneys saught a + +higher review within the Department of Justice and + +it took a number of months for that to come to + +fruition. When it came to fruition, he ended up + +pleading guilty on June 30, 2008 to two charges in + +state court, and he was sentenced to a term of + +incarceration of 18 months, with another 12 months + +of community control after the completion of his + +sentence, and he is currently incarcerated as we + +speak. + +We have two arguments, Your Honor. First, + +insofar as the right that they claim under + +3771(a) (5), their right to confer in the case, we + +respectfully submit that there was no case in + +federal court and, indeed, none was contemplated if + +the plea agreement was to be successfully completed, + +since it contemplated the State of Florida sentence + +on the criminal charges. So as long as certain + +conditions were met and certain federal interests + +were vindicated, the federal government was + +Insofar as the best effort, Your Honor, we have cited the Attorney General's guidelines. The guidelines do say that you should normally advise victims of plea negotiations and the terms of the plea, but they recognize that there are times when they may not be appropriate or could cause some harm or prejudice, and they set out six factors which are to be considered, non-exhaustive factors. + +We have advised, in the declaration of + +that when the subject of having Mr. + +Epstein concede that he would be convicted of an enumerated offense for purposes of a cause of action under 18 USC 2255, there was a rather strenuous objection from Mr. Epstein's counsel that the federal government was inducing some effort to either fabricate claims, enhance claims or embellish claims and if this agreement ultimately could not be consumated, then we'd have a federal prosecution on our hands, and we did not want to be in a positin of creating additional impeachment material. + +I can't say that the stand by Mr. Edwards that the arguments of inducement in a subsequent civil action can be made by any criminal victim, that is true. It is another thing for that inducement to have come before the prosecution + +10 11 claim or seek enforcement of his or her rights under the statute before a case is filed? What does that + +12 refer to? + +13 14 MR. LEE: Your Honor, we believe that's a venue provision essentially telling an individual if + +15 16 there is no exigent case, there is no case of United States versus So And So, then you seek to enforce + +17 18 your rights, then you can go in and do so in the did court where the offense occurred. This is not + +19 20 saying, necessarily, that rights exist, but if you believe they exist, here is the place where you're + +21 22 going to have to lodge it, and the Court will have to decide. + +23 24 Now, there are certain of the eight rights accorded in 3771(a) that could come up before any + +arguing about the credibility and veracity of the individual. + +That was a considerably strong point, in + +essence, in not discussing those terms with the + +victims as might ordinarily be done if those + +considerations did not exist. + +So, first, Your Honor, we believe that + +3771(a)(5) does not apply. + +THE COURT: Well, what about the language in the statute that suggests that a victim can bring a + +believes that the perpetrator of the crime is going to try to 10 11 harm them or threatened them or intimidated them into not testifying or cooperating with the government and, of course, no indictment has been returned. If an individual went to the government and believed that the individual had not acted appropriately, they can go to the district court and say I need to have my rights under 3771(a)(1) enforced because those people are threatening me, and the government hasn't done enough. That would be a situation. + +12 13 14 15 But we're talking really here about (a) (5), which is the right to consult in the case and we respectfully submit that there is not case until a charge has been filed. + +16 17 18 THE COURT: So, what about the circuit case that was actually pending case had to do with a plea agreement in a pending case? + +19 20 21 22 23 24 25 MR. LEE: Yes. The distinction between the Dean case and the instant case, Your Honor, is this. In Dean, they had negotiated with BP Petroleum for a plea and it was always contemplated that there was going to be a federal prosecution. The distinction in this case was that there was already a pending state prosecution and the + +1 2 3 4 5 6 7 8 9 10 11 objective for both sides was to keep it in state court and the federal government's objective was to ensure that there were sufficient safeguards in the state court proceedings and concessions made by Mr. Epstein so that federal interests, particularly a cause of action for damages for the victims of the sexual exploitation could be preserved. So that's the key distinction because there was no federal case, there was no federal criminal charge contemplate so long as the agreement could be reached. + +12 13 THE COURT: All right. So they want me to invalidate your non-prosecution agreement. + +14 15 16 17 18 19 20 21 22 23 24 25 MR. LEE: Your Honor, we respectfully submit that 3771 does not grant authority of this Court to do so. In the Dean case, for instance, Your Honor, there was a plea agreement that was entered into and district court, of course, entertained a plea agreement and exercised its judicial discretion in terms of whether to accept it or not. The victims were encouraged to go to district court and say, you know, we didn't hear about this. We should have, and we object to it for the following reasons. The district court take that into account. There is no plea agreement before this Court. There will be no + +1 2 3 plea proceedings in this court. That was all done in state court several weeks ago. So that's another basis for distinguishing Dean. + +4 5 THE COURT: All right. So is there any point in conferring with these victims? + +6 7 8 9 MR. LEE: Your Honor, I will always confer, sit down with Jane Doe 1 and 2, with the two agents and Ms. . We'll be happy to sit down with them. + +10 11 12 13 14 15 THE COURT: But it wouldn't make any difference in terms of the outcome. Would maybe give them the benefit of your explanation of why you did what you did and why you came to the conclusion you did, but it is not going to change your decision in any way. + +16 17 18 MR. LEE: If it is going to change, it would have to be done at a level higher than mine, Your Honor. + +19 20 21 22 23 24 THE COURT: What was-- I didn't understand your statement earlier that Mr. Epstein wanted some kind of review of higher authority within the Department in terms of whether or not the federal government was going to insist on preserving any civil claims. + +consumated by the parties in December of 2007. Mr. Epstein's attorneys wanted a further review of the agreement higher up within the Department of Justice and they exercised their ability to do that. + +THE COURT: Meaning? Again, I'm trying to understand. He wasn't happy with the agreement that he had signed? + +MR. LEE: Basically, yes. And was trying to maintain that the agreement should be set aside or more favorable terms. + +THE COURT: Now, in terms of -- You don't dispute that Jane Doe 1 and 2-- First of all, do you have an objection to Jane Doe 2 being added as a petitioner in this case? + +MR. LEE: No, I don't. + +THE COURT: I'll grant that request. + +You don't dispute that they're victims within the meaning of the Act. + +MR. LEE: It depends to which -- There is one Jane Doe-- Well, there is one individual who is one of Mr. Edwards' clients who we do not believe to been a victim. If these are SN and CW, then we have no objection and I can discuss-- If I may have a moment, Your Honor. + +1 corrected. We have no objection. + +2 THE COURT: Okay. + +3 MR. LEE: We agree they're victims. + +4 5 6 7 8 9 10 11 12 13 14 THE COURT: Now, what is your position, then, regarding the right of a victim of a crime that is potentially subject to federal prosecution to be, to have input with the prosecutor, your office, before a resolution or decision not to prosecute is made? Do you say that there is no right to confer under those circumstances because there is no "case pending" so any decision not to prosecute, there is no right to confer but that right to confer only is triggered once there is an indictment or an information filed? + +15 16 17 18 19 20 21 MR. LEE: That is correct, Your Honor. The Attorney General guidelines which were published in May of 2005 provide that the rights in 3771(a)(1 through 8) accrue when a charge is filed in federal court. Now, that my change after the Dean decision. It is under consideration. But that's the government's position. + +22 23 THE COURT: All right. And so -- Are you saying all of the rights-- + +24 25 MR. LEE: Your Honor, some of the rights clearly will only pertain after a charge has been + +filed. The one that pertains to notice of public hearing, public proceedings, though, can't apply until there are public proceedings to be had. + +Of course, these guidelines are a floor and not a ceiling. They're to be applied with common sense. If somebody-- If charges of assault were being investigated and somebody would come in and say the perpetrator whom you're investigating is getting ready to indict has been threatening me, following me, and I need help because he or she is going to do something bad to me and try to take care of me before I can testify in the grand jury, this person would not be turned away because a charge hasn't been filed yet. Those guidelines would be applied with common sense. + +But specifically insofar as a (a) (5), which is the right to consult with the attorney for the government in the case, that would not accrue until there is a days. And, in our view, a case doesn't come into being until charges are filed. + +THE COURT: And are there any reported decisions that you are aware of where any court has found a right to confer before charges are filed? + +1 THE COURT: All right. Thank you. + +2 MR. LEE: Thank you, Your Honor. + +3 THE COURT: Counsel? + +4 5 6 7 8 9 MR. EDWARDS: I would just like to address that Dean decision. They're asking you that you just simply ignore it because the decision clearly was a decision made because as it is a direct result of a plea deal being worked out prior to the victims being able to speak. + +10 11 THE COURT: But there was a pending case, though, correct? + +12 MR. EDWARDS: As I understand the decision-- + +13 14 15 16 17 18 19 THE COURT: As I understand the plea deal, it was negotiated prior to charges being filed. Then there was a filed case and then the court had the ability to accept the plea or not. And at that point, you would have the ability to entertain or assert an objection because you weren't consulted about the plea. + +20 21 22 23 24 25 So there was a proceeding or case in which you can assert a right to confer. How do you do that before a case is filed? How do you enforce the government or force the government to consult about not filing a case? Every case they have to consult with the victim before they decide not to prosecute? + +MR. EDWARDS: No, there are limitations. I + +think in my reply I refer to the case of U.S. I. Rubin where they discussed that very scenario stating there at least has to be criminal charges contemplate by the government before these rights kick in. The rights under (d)(3) and (a)(5), the right to confer and the Dean case clearly states clearly rights under the CBRA apply before prosecution is under way. Logically, this includes the CBRA establishments of a victim's reasonable right to confer with the attorney for the government. And, that's read in the plain reading of the statutes as well. + +This first case in interpreting it, I think it's pretty clear the distinction they're making between BP and this case. Is it a distinction withoug a real difference in that the court is saying you have this right before the case is filed which is exactly what we are saying. And the result in that case was they filed the case, later let him plea out to some sweet deal. And in this case, what we have is they avoid that by deciding not to file. Either way, you deprive the victim of their right before making that decision. + +10 11 12 13 14 15 16 17 18 Dean, as it states, the victims do have rights when there is an impact and the eventual sent is substantially less. Whereas here, their input is received after the parties have reached a tentative deal. Well, the government just stated the deal was reached back in October of 2007. However, attached to their response is a letter to my client petitioner, dated January 10, 2008, after the time then counsel just put on the record that the deal was already finalized and it starts, the opening paragraph talks about whether they wanted the victims to have the right to confer. It says, this case is currently under investigation. This is January 2008. This case has been a lengthy process and we request your continued patience while we conduct a thorough investigation. Sounds like the exact opposite of, we want you to come in and confer and let us know what you really feel about this. + +19 20 21 22 23 24 25 That is our biggest problem with what has happened here, is that she just wasn't given a voice and if somebody would have heard her, we believe there would have been a different outcome. To go back into a room right now and talk, after there has already been a plea negotiated without Your Honor ordering that in this case the plea deal needs to be 1 vacated, it is illegal and give her her rights. + +2 THE COURT: Well, would you agree or not that Mr. + +3 Epstein plead guilty to the state charges + +4 probably at least, in part, in reliance upon the + +5 fact that he had an agreement with the federal + +6 government they weren't going to prosecute? Would + +7 you concede that or would would present evidence to + +8 that effect? + +9 MR. EDWARDS: Of course we would. Yes, of + +10 course. Sure. + +11 THE COURT: So you agree that Mr. Epstein is + +12 now sitting in the Palm Beach County Jail a + +13 convicted felon serving 18 months of imprisonment, + +14 at least in material part, because he relied upon + +15 the government's non-prosecution agreement? + +16 MR. EDWARDS: Yes. I agree that he is sitting + +17 there because he is guilty and maybe he took the + +18 plea rather than going to trial and being found + +19 guilty later in part because of this non-prosecution + +20 agreement that was worked out behind the other + +21 victims' backs. I would agree with that. + +22 THE COURT: So he accepted the State's deal + +23 in part because he knew he had an agreement from the + +24 federal government that they weren't going to + +MR. EDWARDS: I presume. I speculate that is true. + +THE COURT: So you want me now, then, to set aside the government's agreement with him because there was no conferring, yet he has already accepted a plea agreement and is sitting in custody, in part, in reliance on that agreement. I mean, I can undo the agreement in your theory, but how do I-- Mr. Epstein, in a sense, would then be adversely affected by my actions when he acted in reliance upon the agreement. How does that work? + +MR. EDWARDS: Certainly, we're only asking you to vacate the agreement. I understand and your point is well taken. And I believe that at that point in time his rights may kick in and say, wait, I was relying on this other deal so I wouldn't be prosecuted for these hundreds of other girls that I molested; that I plead guilty over here to the one girl that I will admit to molesting. So maybe I can get to withdraw my plea. But the last thing he wants to do because if he ends up going to trial, I'll be in prison for the rest of his life like any other person who ever did this crime would be. He could have that argument, I guess, but still wouldn't really work well for him. + +THE COURT: All right. So you still think I should set aside the agreement, require the government to confer? + +MR. EDWARDS: Work out a plea negotiation commensorate with the crimes that he committed and that are favorable after they confer with the victims. And it is within their discretion. Of course, they can decide on their own that, hey, I think that the agreement was fair after they have talked with the victims. That could happen. I don't know if a reasonable person that would do that, but it could happen. + +THE COURT: Apparently, you are not suggesting that that these person are not reasonable. + +MR. EDWARDS: I'm suggesting they haven't conferred with the victims and that if they took into consideration what these two in the courtroom have to say, I don't think that we'd be in this same position right now. + +THE COURT: They have never spoken to your client about what happened to them? + +MR. EDWARDS: They have spoken to them about what happened. Maybe not about what the girls wanted to happen as a result of this case, which is + +part of conferring to decide that these girls wanted money on their own, which is basically what this-- this non-prosecution agreement entails that has language that he'll agree to liability in a civil case. That's not what these girls-- They want justice. They want him in prison now more than ever. The reason they stated they kept this agreement from the girls and they basically conceded we didn't tell the girls about this agreement, well, the reason is because they would have objected and they wouldn't have been able to sign off on this and the victims would have had a voice, and we'd still been going through litigation. The exact problem they tried to prevent, at least in their terms which was the impeachment of these girls at a later trial, is still available to anybody once the civil suits are filed anyway. + +They have three arguments. One, we didn't have to talk to them. Two, we did talk to them sort of. And if you don't buy that, the reason we didn't talk to them, we were trying to prevent them from being impeached later. None of them trump the victims' rights to confer prior to plea negotiations. That's why, Your Honor, we would ask this Court to enter an order vacating that previous + +10 THE COURT: Now, having learned today, I guess, that the agreement was signed when, in October? + +11 MR. EDWARDS: October 2007, I heard. + +12 13 14 15 16 17 18 THE COURT: About eight or nine months ago, is there any need to rush to a decision in this matter? The decision has already been made. You filed this, I think, on the presumption that the agreement was about to take place and you wanted to be able to confer beforehand and you weren't sure what was going on. + +19 20 21 22 23 24 MR. EDWARDS: Precisely, Your Honor. And I'm holding the letters that are exhibits that they were writing to my client during the year of 2008 telling her how lengthy of a process this was going to be and be patient. So, right, I was completely in the dark about when this agreement was signed. + +plea agreement as illegal, ask them to confer with the victims once again or for the first time and work out a negotiated plea to that accord. + +THE COURT: Well, all you can ask them to do is confer. I can't ask them to do anything beyond that. I mean, it is up to them to negotiate. + +MR. EDWARDS: I wouldn't quarrel with that. + +agreement has already been consumated, and you want me to set it aside, as opposed to something that's about to occur, would you agree that-- and I have done this very quickly because of the petition and your allegation that something was about to happen. I'm not blaming you. + +MR. EDWARDS: I was mistaken. + +THE COURT: I'm not blaming you for doing that. In view of what you know now, is there any need to treat this as an emergency that has to be decided by tomorrow? + +MR. EDWARDS: I can't think of any reason in light of what we just heard. + +THE COURT: Mr. Lee, do you have anything else you wanted to add? Does either side think I need to take evidence about anything? If I do, since this is not an emergency anymore, I can probably find a more convenient time to do that. I don't have the time today to take evidence. But if you do believe that I should take evidence on this issue. + +MR. EDWARDS: It may be best if I conferred with the U.S. Attorney's Office on that and we can make a decision whether it is necessary or whether Your Honor deemed it was necessary for you to make a 10 11 12 13 14 government's is as to what actions were taken. And I don't know if I have enough information, based on Ms. affidavit or I need additional information. And because it is not an emergency, I don't have to do something quickly, we can play it be ear and make this into a more complete record for the court of appeals. + +15 16 17 18 19 20 21 MR. EDWARDS: If there is a time where it is necessary to take evidence, Your Honor is correct in stating that it is not an emergency and it doesn't need to happen today. And, I will confer with the government on this and if evidence needs to be taken, it be taken at a later date. It doesn't seem like there will be any prejudice to any party. + +22 23 THE COURT: Mr. Lee, do you have any thoughts? You want to consult with Mr. Edwards? + +24 25 MR. LEE: There may be a couple of factual matters that I need to chat with petitioner's + +decision. + +THE COURT: I want to know what your respective positions are because it may be something + +in terms of having a complete record, and this is going to be an issue that's it going to go to the Eleventh Circuit, may be better to have a complete record as to what your position is and the + +1 2 3 4 5 6 counsel on. If we can reach agreement on those as to what was communicated to CW and what time, if they don't dispute that, then we don't think it will be necessary to have an evidentiary hearing. But if we can agree, fine or maybe we can't. We'll talk about it. + +7 8 9 10 11 THE COURT: All right. So why don't you let me know if you think an evidentiary hearing is necessary. If there are additional stipulations you want to enter into or supplement what has already been presented, you can do that. + +12 13 14 15 16 17 18 19 Now, the other issue I want to take up, though, is the government filed its response to the petition under seal. And so I want to know why. What is in there that at this point needs to be under seal? Is there anything in there that's confidential, privileged, anything that's different from what you hve said here in open court that requires that to be sealed? + +20 21 22 23 24 25 MR. LEE: Well, Your Honor, on our motion to seal was based on two reasons. One that dealt with individuals or minors at the time that the offense occurred. So we were attempting to protect the privacy of those individuals. And also it dealt with negotiations with Mr. Epstein which were in the 1 2 3 nature of plea negotiations, which we treat as confidential. Normally, they're not aired out in open court. So those were our two reasons. + +4 5 6 THE COURT: All right. But I guess the letters you attached only related to Mr. Edwards' client. + +7 MR. LEE: Three of them, yes, Your Honor. + +8 9 10 THE COURT: Are you prepared, Mr. Edwards, to waive any issues regarding the release of those documents that relate to your clients? + +11 12 13 MR. EDWARDS: Judge, I think it would be appropriate to redact the names of the clients as they have done. + +14 15 THE COURT: I don't think the names are in there. + +16 17 18 19 MR. EDWARDS: I think they're redacted. They're blacked out. I have no problem with releasing those documents. I'm not sure that's part of the deal. But if it is-- + +20 MR. LEE: It is. + +21 MR. EDWARDS: Okay. I'll waive. + +22 23 24 THE COURT: You really don't have any objection to those letters that were sent to them being released to the public? + +THE COURT: Then what is there about the plea agreement or the negotiations that is in the response that we really haven't already kind of-- + +MR. LEE: Your Honor, there was a confidentiality agreement in the deferral of prosecution to the State of Florida. So we were trying to maintain the confidentiality of the negotiations that occurred since we had discussions during those negotiations as one of the reasons why we decided not to tell all of the individuals what was going on. + +THE COURT: But is that still necessary, that confidentiality or is that kind of moot at this point? + +MR. LEE: Well, we would like it sealed. Admittedly, what happened today in open court has probably weakened our argument. I don't dispute that. + +THE COURT: In your opinion, anything in particular, any paragraph in the response or in Ms. affidavit that you think is particularly troublesome that should remain under seal? + +> MR. LEE: May I have a moment, Your Honor? THE COURT: Yes. + +10 THE COURT: But hasn't the fact that this provision was part of the agreement again been aired? Is there any secret to it anymore? + +11 12 13 14 MR. LEE: The actual text of it has not been aired. The existence of it has been heard but the actual text has not and we believe it should still remain confidential. + +15 16 THE COURT: Okay. Any other argument on that issue? + +17 MR. LEE: No, Your Honor. Thank you. + +18 19 THE COURT: Ms. wants to speak to you. + +20 21 22 23 24 25 MR. LEE: Your Honor, one item that I'd like to bring to the Court's attention. We had advised Mr. Epstein and his attorneys that if we were to dislose some of the agreement, we would give them advance notice and ability to lodge an objection. We would like an opportunity to do that. + +of this in the notification letters that were dispatched to individuals which were attached to Ms. + +declaration, there is a citation to a clause in the agreement that was reached regarding the damages remedy under 18 USC 2255 that was subject to the constitutionality agreement, we believe that should still remain confidential. + +THE COURT: All right. But you're not disclosing. It would be by my order that it would be disclosed. + +MR. LEE: Yes, Your Honor. And we just would like to register that we believe it should remain confidential. + +THE COURT: All right. + +MR. EDWARDS: Your Honor, I don't see any authority for keeping that under seal. + +THE COURT: I agree. The fact that there is this preserved right on behalf of the victims to pursue a civil action is already a matter of public record; the exact text of the clause-- I don't see that disclosing the text of the clause when the fact that the clause exists is already a matter of public record. It is not harmful in any way to Mr. Epstein or the government and the letters to the victim that the victim can disclose those letters, they're not under any confidentiality obligation or restriction and they're free to disclose it themselves if they choose to. So I don't see that there is any real public necessity to keep the response sealed in view of what we discussed already on the record and the victim's ability to disclose those provisions of their own choosing, if they wish. So, in view of + +the public policy that matters filed in court proceedings should be open to the public and sealing should only occur in circumstances that justife the need to restrict public access, I'm going to deny the motion to seal the response and allow that to be viewed. + +All right. So I'll let both of you confer about whether there is a need for any additional evidence to be presented. Let me know one way or the other. If there is, we'll schedule a hearing. If there isn't and you want to submit some additional stipulated information, do that, and then I'll take care of this in due course. + +MR. EDWARDS: Thank you, Your Honor. + +THE COURT: All right. + +MR. LEE: Thank you, Your Honor. + +MS. : Thank you, Your Honor. + +THE COURT: You're welcome. + +(Proceedings concluded.) + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +I hereby certify that the foregoing is true + +and correct to the best of my ability. + +![]()Victoria Aiello, Court Reporter \ No newline at end of file diff --git a/marker2/ds9/EFTA00205797/EFTA00205797.metadata.json b/marker2/ds9/EFTA00205797/EFTA00205797.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..a638c4b17e05d4ff9fdbe59f82d11ee38a976df0 --- /dev/null +++ b/marker2/ds9/EFTA00205797/EFTA00205797.metadata.json @@ -0,0 +1,1174 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205797.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + 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48, 52), Plaintiffs' Motion to Have Their Facts Accepted Because of the Government's Failure to Contest Any of the Facts (DE 49), Plaintiffs' Motion for Order Directing the U.S. Attorney's Office Not to Withhold Relevant Evidence (DE 50), and Motion to Intervene or in the Alternative for a Sua Sponte Rule 11 Order (DE 79).1 All motions are fully briefed and ripe for review, and the Court has heard oral arguments on all motions. The Court has carefully considered the briefing and the parties' arguments and is otherwise fully advised in the premises. + +The Court is awaiting supplemental briefing on the Motion to Intervene of Roy Black, Martin Weinberg, and Jay Lefkowitz (DE 56) and will rule on that motion after it is fully briefed. Also, because the proposed interveners seek intervention to request a protective order against disclosure of certain correspondences at issue in Plaintiffs' Motion to Use Correspondence to Prove Violations of the Crime Victims' Rights Act and to Have Their Unredacted Pleadings Unsealed (DE 51), the Court will defer ruling on the latter motion until the intervention motion is ripe for review. + +# Background' + +Plaintiffs Jane Doe #1 and Jane Doe #2 are alleged victims of federal sex crimes committed by Jeffrey Epstein in Palm Beach County. Between 2001 and 2007, Epstein sexually abused multiple underage girls at his Palm Beach mansion, including Plaintiffs. In 2006, the Federal Bureau of Investigation ("FBI") opened an investigation into allegations that Epstein was inducing underage girls to engage in sexual acts. The case was eventually presented to the United States Attorney's Office for the Southern District of Florida, which accepted it for investigation. The Palm Beach County State Attorney's Office was also investigating similar allegations against Epstein. Plaintiffs allege that the FBI and U.S. Attorney's Office's investigation developed a strong case for a federal prosecution against Epstein based on "overwhelming" evidence. + +In June 2007, the FBI delivered to Jane Doe #1 a standard victim-notification letter, which explained that the case against Epstein was "under investigation" and notified Jane Doe #1 of her rights under the Crime Victims' Rights Act ("CVRA"). In August 2007, Jane Doe #2 received a similar notification letter. + +In September 2007, Epstein and the U.S. Attorney's Office began plea discussions. The negotiations led to an agreement under which Epstein would plead guilty to two state felony offenses for solicitation of prostitution and procurement of minors for prostitution and the U.S. + +This background discussion is based on the allegations in Plaintiffs' Petition for Enforcement of Crime Victims' Rights Act (DE I) and the Statement of Material Facts in Plaintiffs' Motion for Finding of Violation of the Crime Victims' Rights Act (DEs 48, 52). These allegations are not yet supported by evidence and the Court relies on them here solely to provide the context for the threshold legal issues addressed in this order. As discussed below, further factual development is necessary to resolve the additional issues raised in Plaintiffs' motions. + +Attorney's Office would agree not to prosecute Epstein for federal offenses. On September 24, 2007, Epstein and the U.S. Attorney's Office executed a Non-Prosecution Agreement ("NPA") under these terms. + +Plaintiffs contend that the U.S. Attorney's Office did not confer with them regarding the plea discussions and, in fact, intentionally kept secret the negotiations and the NPA. From September 24, 2007, the day on which the NPA was executed, through June 2008, the U.S. Attorney's Office did not notify either Plaintiff of the existence of the NPA. + +During this period, Plaintiffs communicated multiple times with the FBI and U.S. Attorney's Office, but neither Plaintiff was informed of the NPA. On January 10, 2008, the FBI sent letters to Plaintiffs advising them that "[t]his case is currently under investigation," but failing to disclose the existence of the NPA. On January 32, 2008, Jane Doe #1 met with FBI agents and attorneys from the U.S. Attorney's Office to discuss her abuse by Epstein. The government did not disclose the existence of the NPA. In mid-June 2008, Plaintiffs' counsel contacted the Assistant United States Attorney ("AUSA") handling their case to discuss the status of the investigation. The AUSA did not disclose the existence of the NPA. On June 27, 2008, the U.S. Attorney's Office notified Plaintiffs' counsel that Epstein was scheduled to plead guilty in state court on June 30, 2008. The U.S. Attorney's Office did not disclose the existence of the NPA nor the relationship between Epstein's state plea and the U.S. Attorney's Office's agreement to forgo federal charges. On July 3, 2008, Plaintiffs' counsel sent a letter to the U.S. Attorney's Office stating Jane Doe #1's desire that it bring federal charges against Epstein. + +On July 7, 2008, Jane Doe #1 filed a petition in this Court to enforce her rights under the CVRA! Jane Doe #1 alleged that she believed plea discussions were under way between Epstein and the U.S. Attorney's Office, and that the government, by failing to notify her of this development, had violated her rights under the CVRA. The United States responded to the petition on July 9, 2008, arguing that (1) a federal indictment had never been returned against Epstein and therefore the CVRA did not attach, and (2) nevertheless, the U.S. Attorney's Office had used its best efforts to comply with the CVRA. The government's response also disclosed that the U.S. Attorney's Office had entered into the NPA with Epstein. + +On July 11, 2008, this Court held a hearing on Jane Doe #1's petition, at which Jane Doe #2 was added as a plaintiff. At the hearing, Plaintiffs explained that their petition did not present an emergency and that therefore an immediate resolution was not necessary. On August 14, 2008, the Court held a status conference and ordered the United States to turn over the NPA to all identified victims, including Plaintiffs, and further ordered the parties to work out the terms of a protective order governing the NPA's disclosure. + +This action was relatively inactive for the next year and one-half while Plaintiffs litigated civil actions against Epstein. After those cases settled, Plaintiffs attempted to resolve their CVRA dispute with the U.S. Attorney's Office. On March 18, 2011, after the parties' settlement efforts failed, Plaintiffs filed a series of motions, which the Court now addresses in turn, along with Motion to Intervene. + +&#x27;Jane Doe #2 joined this action after Jane Doe #1 filed the initial Petition for Enforcement of Crime Victims' Rights Act. + +# I. Motion for Finding of Violations of the Crime Victims' Rights Act + +The CVRA was designed to protect victims' rights and ensure them involvement in the criminal justice process. United Stalest Moussaoui, 483 F.3d 220, 234 (4ih Cir. 2007); Kenna,. U.S. Dist. Court, 435 F.3d 1011, 1016 (9th Cir. 2006) ("The [CVRA] was enacted to make crime victims full participants in the criminal justice system."). The statute enumerates the following eight rights: + +- (1) The right to be reasonably protected from the accused. +- (2) The right to reasonable, accurate, and timely notice of any public court proceeding, or any parole proceeding, involving the crime or of any release or escape of the accused. +- (3) The right not to be excluded from any such public court proceeding, unless the court, after receiving clear and convincing evidence, determines that testimony by the victim would be materially altered if the victim heard other testimony at that proceeding. +- (4) The right to be reasonably heard at any public proceeding in the district court involving release, plea, sentencing, or any parole proceeding. +- (5) The reasonable right to confer with the attorney for the Government in the case. +- (6) The right to full and timely restitution as provided in law. +- (7) The right to proceedings free from unreasonable delay. +- (8) The right to be treated with fairness and with respect for the victim's dignity and privacy. + +18 U.S.C. § 3771(a). + +If a prosecution is underway, the CVRA grants victims standing to vindicate their rights in the ongoing criminal action. 18 U.S.C. § 3771(d)(3). If, however, a prosecution is not underway, the victims may initiate a new action under the CVRA in the district court of the + +district where the crime occurred.' Id. The statute also tasks the district courts and the prosecutors with the responsibility of protecting these rights. See 18 U.S.C. § 3771(b)(1) ("[T]he court shall ensure that the crime victim is afforded the rights described in subsection (a)."); § 3771(c)(1) ("Officers and employees of the Department of Justice . . . shall make their best efforts to see that crime victims are notified of, and accorded, the rights described in subsection (a)."). + +Here, Plaintiffs first argue that as a matter of law the CVRA's protections attach before a formal charge is filed against the criminal defendant. Accordingly, Plaintiffs contend that the CVRA applied here and that the U.S. Attorney's Office violated their CVRA rights; namely, their rights to confer, to be treated with fairness, and to accurate and timely notice of court proceedings. Based on these violations, Plaintiffs request that this Court set a briefing schedule and hearing on the appropriate remedy, which according to Plaintiffs is to invalidate the nonprosecution agreement. + +The United States argues that as a matter of law the CVRA does not apply before formal charges are filed, i.e., before an indictment or similar charging document, and therefore does not apply here because formal charges were never filed against Epstein. The United States further argues that even if the CVRA applied here, the U.S. Attorney's Office complied with its requirements. + +The Court first addresses the threshold issue whether the CVRA attaches before the government brings formal charges against the defendant The Court holds that it does because the + +Here, because no criminal case was pending, Plaintiffs filed their petition as a new matter in this judicial district, which the Clerk of Court docketed as a civil action. + +statutory language clearly contemplates pre-charge proceedings. For instance, subsections (a)(2) and (a)(3) provide rights that attach to "any public court proceeding ... involving the crime." Similarly, subsection (b) requires courts to ensure CVRA rights in "any court proceeding involving an offense against a crime victim." Court proceedings involving the crime are not limited to post-complaint or post-indictment proceedings, but can also include initial appearances and bond hearings, both of which can take place before a formal charge. By way of example, under Rule 5(a)(1)(A) of the Federal Rules of Criminal Procedure, upon arrest the defendant must be taken before a magistrate judge "without unnecessary delay" for an initial appearance. If the arrest takes place on a weekday, "without unnecessary delay" will typically require that the initial appearance occur the following morning, which will often be within twenty-four hours of arrest. See United States,. Mendoza, 473 F.2d 697, 702 (56 Cir. 1973) (holding that the government satisfied Rule 5's "without unnecessary delay" requirement by bringing the defendant before the magistrate judge on the first weekday morning following the arrest). By contrast, Rule 5(b) requires that where the defendant is arrested without a warrant, the government must file the complaint "promptly." The Supreme Court has interpreted "promptly" under Rule 5(b) as generally requiring that the complaint be filed within forty-eight hours of arrest. Cnty. Of Riverside.. McLaughlin, 500 U.S. 44, 56-57 (1991). It is therefore possible that where the defendant is arrested on a weekday without a warrant, the initial appearance—which may also involve the detention or bond hearing under Rule 5(d)(3)—will take place before the government files the criminal complaint. + +Subsection (cX1) requires that "Officers and employees of the Department of Justice and other departments and agencies of the United States engaged in the detection, investigation, or + +prosecution of crime shall make their best efforts to see that crime victims are notified of, and accorded, the rights in subsection (a)." (Emphasis added). Subsection (c)(I)'s requirement that officials engaged in "detection [or] investigation" afford victims the rights enumerated in subsection (a) surely contemplates pre-charge application of the CVRA. + +Subsection (d)(3) explains that the CVRA's enumerated rights "shall be asserted in the district court in which a defendant is being prosecuted for the crime or, if no prosecution is underway, in the district court in the district in which the crime occurred." (Emphasis added). If the CVRA's rights may be enforced before a prosecution is underway, then, to avoid a strained reading of the statute, those rights must attach before a complaint or indictment formally charges the defendant with the crime. + +This interpretation is consistent with other federal decisions that have addressed the scope of the CVRA. For instance, in In re Dean, 527 F.3d 391 (5\* Cir. 2008), the court held that subsection (a)(5)'s "right to confer" applied before any prosecution is underway. Id. at 394. Specifically, the court explained: + +The district court acknowledged that "there are clearly rights under the CVRA that apply before any prosecution is underway." Logically, this includes the CVRA's establishment of victims' reasonable right to confer with the attorney for the Government." At least in the posture of this case (and we do not speculate on the applicability to other situations), the government should have fashioned a reasonable way to inform the victims of the likelihood of criminal charges and to ascertain the victims' views on the possible details of a plea bargain. + +Id. at 394 (internal citation and quotation marks omitted). Federal district courts have reached similar conclusions. See, e.g., United States'. Rubin, 558 F. Supp. 2d 411, 417 n.5 (E.D.N.Y. 2008) (discussing victims' "ability to seek pre-prosecution relief' under the CVRA); United States.. Okun, No. 08-132, 2009 WL 790042, at '2 (E.D. Va. Mar. 24, 2009) ("[T]he Fifth + +Circuit has noted that victims acquire rights under the CVRA even before prosecution. This view is supported by the statutory language, which gives the victims rights before the accepting of plea agreements and, therefore, before adjudication of guilt."); United States" BP Prods N. Am. Inc., No. 07-434, 2008 WL 501321, at \*11 (S.D. Tex. Feb. 21, 2008) ("There are clearly rights under the CVRA that apply before any prosecution is underway."), mandamus denied in part, In re Dean 527 F.3d 391 (5ih Cir. 2008). + +The United States argues that because the CVRA accords rights related to "any court proceeding," 18 U.S.C. §§ 3771(b)(1), (d)(3), and "in the case," § 3771(b)(5), the CVRA applies only after formal charges are filed. The Court finds this argument unavailing. First, as discussed above, "court proceedings" can occur before formal charges are filed. Similarly, subsection (a)(5)'s reference to the right to confer with "the attorney for the Government in the case," is not limited to post-charge proceedings, as the United States is represented by attorneys in each criminal case at, for example, initial appearances and bond hearings.' Last, the government's interpretation ignores the additional language throughout the statute that clearly contemplates pre-charge protections, such as subsection (c)(1)'s mandate that U.S. agencies involved at the "detection" and "investigation" stage use their best efforts to accord victims their enumerated rights under the CVRA and subsection (d)(3)'s provision that victims may vindicate their CVRA + +For this reason, the Court respectfully disagrees with the interpretation adopted in In re Petersen, No. 10-298, 2010 WL 5108692 (N.D. Ind. Dec. 8, 2010), upon which the United States relies. See id. at \*2 (holding that a "victim's 'right to be treated with fairness and with respect for [his or her] dignity and privacy' may apply before any prosecution is underway and isn't necessarily tied to a `court proceeding' or `case,'" but concluding that "the right 'to confer with the attorney for the Government in the case' ... arise[s] only after charges have been brought against a defendant and a case has been opened"). But see In re Dean, 527 F.3d at 394 (holding that under subsection (a)(5), "the government should have fashioned a reasonable way to inform the victims of the likelihood of criminal charges"). + +rights even if "no prosecution is underway." See United States.. DBB, Inc., 180 F.3d 1277, 1281 (11ih Cir. 1999) ("[W]e read the statute to give full effect to each of its provisions. We do not look at one word or term in isolation, but instead we look to the entire statutory context.") (citation omitted). + +The Court also rejects the United States' argument that pre-charge CVRA rights could impair prosecutorial discretion and decision-making. Any encroachment into the prosecutors' discretion is expressly limited by the CVRA itself, which provides: "Nothing in this chapter shall be construed to impair the prosecutorial discretion of the Attorney General or any officer under his direction." 18 U.S.C. § 3771(d)(6). As the court explained in Rubin, "there is absolutely no suggestion in the statutory language that victims have a right independent of the government to prosecute a crime, set strategy, or object to or appeal pretrial or in limine orders .... In short, the CVRA, for the most part, gives victims a voice, not a veto." 558 F. Supp. at 418; see also BP Prods N. Am., 2008 WL 501321, at \*15 ("Even under an expansive approach, the reasonable right to confer on a proposed plea agreement and the government's obligation to provide notice of that right is subject to the limit that the CVRA not impair prosecutorial discretion."). Thus, to the extent that the victims' pre-charge CVRA rights impinge upon prosecutorial discretion, under the plain language of the statute those rights must yield. + +Having determined that as a matter of law the CVRA can apply before formal charges are filed, the Court must address whether the particular rights asserted here attached and, if so, whether the U.S. Attorney's Office violated those rights. However, the Court lacks a factual record to support such findings and must therefore defer ruling on these two issues pending the limited discovery discussed below. + +# II. Motion to Have Their Facts Accepted Because of the Government's Failure to Contest Any of the Facts + +For the reasons stated on the record at the August 12, 2011 hearing on this motion, the Court will deny Plaintiffs' request to have their facts accepted as true. + +# III. Motion for Order Directing the U.S. Attorney's Office Not to Withhold Relevant Evidence + +Plaintiffs request an order from the Court "directing the U.S. Attorney's Office not to suppress material evidence relevant to this case." (DE 50 at 1). Specifically, Plaintiffs seek all information and material known to the government that may be favorable to the victims regarding possible violations of their rights under the CVRA. The United States opposes the motion, arguing that neither the CVRA nor the Federal Rules of Civil Procedure impose a duty upon the U.S. Attorney's Office to provide evidence to Plaintiffs here. + +At the August 12, 2011 hearing on this motion, the United States agreed that this Court, under its inherent authority to manage this case, could impose discovery obligations on each party. Because the Court finds that some factual development is necessary to resolve the remaining issues in this case, it will permit Plaintiffs the opportunity to conduct limited discovery in the form of document requests and requests for admissions from the U.S. Attorney's Office. Either party may request additional discovery if necessary. + +Because the Court will allow this limited factual development, it is unnecessary to decide here whether the CVRA or the Federal Rules of Civil Procedure provide discovery rights in this context. The Court therefore reserves ruling on Plaintiffs' motion. + +#### Iv. 11 Order Motion to Intervene or in the Alternative for a Sua Sponte Rule + +ut.t C. scut beeks leave to intervene as a party-in-interest under Rule 24(b) of the Federal Rules of Civil Procedure. Reinhart seeks to intervene to file a motion for sanctions based on allegedly "unfounded factual and legal accusations made about Movant in Plaintiffs' Motion for Finding of Violations of the Crime Victims' Rights Act." (DE 79 at 1). In that motion, Plaintiffs alleged that Reinhart, a former Assistant U.S. Attorney, "joined Epstein's payroll shortly after important decisions were made limiting Epstein's criminal liability" and improperly represented Epstein victims in follow-on civil suits. (DE 48 at 22). Plaintiffs contend that such conduct "give[s], at least, the improper appearance that Reinhart may have attempted to curry [favor] with Epstein and then reap his reward through favorable employment." (DE 48 at 23). Reinhart takes great offense to these accusation—which he contends are false, irrelevant to the CVRA claims, and gratuitous—and seeks intervention to rebut these allegations and move for sanctions. + +Under Rule 24(b) of the Federal Rules of Civil Procedure, "the court may permit anyone to intervene who ... has a claim or defense that shares with the main action a common question of law or fact." It is "wholly discretionary with the court whether to allow intervention under Rule 24(b) and even though there is a common question of law or fact, or the requirements of Rule 24(b) are otherwise satisfied, the court may refuse to allow intervention." In re Bayshore Ford Trucks Sales, Inc., 471 F.3d 1233, 1246 (11th 2006). The Court will denyrequest to intervene. + +First, the Court finds that claim does not share a common question of law or fact with the CVRA action. Reinhart claims that two paragraphs of Plaintiffs' forty-page motion make groundless and bad-faith accusations against his integrity and character. However, the veracity of Plaintiffs' two paragraphs—i.e., whether4WMIumt used his position at the U.S. Attorney's Office to ingratiate himself with Epstein and advance his career in private practice—involves no common questions with the Plaintiffs' claims that the U.S. Attorney's Office violated their CVRA rights through the process in which it entered into the NPA with Epstein. Indeed, motion argues that the allegations against him are "irrelevant" and that Plaintiffs "do[] not make any effort to connect these allegations to the relief [they] seek[]." (DE 79 at 2). + +Second, even if these accusations shared common questions with Plaintiffs' CVRA claims, the Court would exercise its discretion and deny intervention. The Court cannot permit anyone slighted by allegations in court pleadings to intervene and conduct mini-trials to vindicate their reputation. Absent some other concrete interest in these proceedings, the Court does not believe that the allegations here are sufficiently harmful to justify permissive intervention. Reinhart has publicly aired his opposition to and denial of Plaintiffs' contentions, both on this docket and in open court, and the Court finds that further proceedings on this issue are unwarranted. For the same reason, the Court declines to conduct a sua sponte Rule 11 inquiry. + +# Conclusion + +For the foregoing reasons, it is hereby ORDERED AND ADJUDGED that Plaintiffs' Motion for Finding of Violations of the Crime Victims' Rights Act (DEs 48, 52) is GRANTED IN PART. The Court concludes that the CVRA can apply before formal charges are filed. The Court defers ruling on the merits of Plaintiffs' CVRA claims until the parties complete the discovery ordered herein. + +It is further ORDERED AND ADJUDGED that Plaintiffs' Motion to Have Their Facts Accepted (DE 49) is DENIED. + +The Court reserves ruling Plaintiffs' Motion for Order Directing the U.S. Attorney's Office Not to Withhold Relevant Evidence (DE 50) pending the discovery ordered herein. + +It is further ORDERED AND ADJUDGED that Motion to Intervene or in the Alternative for a Sua Sponte Rule 11 Order (DE 79) is DENIED. + +DONE AND ORDERED in Chambers at West Palm Beach, Palm Beach County, Florida this 26ih day of September, 2011. + +> KENNETH A. 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+++ b/marker2/ds9/EFTA00205844/EFTA00205844.md @@ -0,0 +1,136 @@ +# UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA + +CASE NO. 08-80736-CIV-MARRA/JOHNSON + +JANE DOES #1 AND #2, + +Plaintiffs, + +vs. + +UNITED STATES, + +Defendant. + +/ + +#### ORDER + +THIS CAUSE is before the Court upon Plaintiffs' Motion for Finding of Violations of the Crime Victims' Rights Act (DEs 48, 52), Plaintiffs' Motion to Have Their Facts Accepted Because of the Government's Failure to Contest Any of the Facts (DE 49), Plaintiffs' Motion for Order Directing the U.S. Attorney's Office Not to Withhold Relevant Evidence (DE 50), and Bruce E. Reinhart's Motion to Intervene or in the Alternative for a Sua Sponte Rule 11 Order (DE 79).1 All motions are fully briefed and ripe for review, and the Court has heard oral arguments on all motions. The Court has carefully considered the briefing and the parties' arguments and is otherwise fully advised in the premises. + +The Court is awaiting supplemental briefing on the Motion to Intervene of Roy Black, Martin Weinberg, and Jay Lefkowitz (DE 56) and will rule on that motion after it is fully briefed. Also, because the proposed interveners seek intervention to request a protective order against disclosure of certain correspondences at issue in Plaintiffs' Motion to Use Correspondence to Prove Violations of the Crime Victims' Rights Act and to Have Their Unredacted Pleadings Unsealed (DE 51), the Court will defer ruling on the latter motion until the intervention motion is ripe for review. + +### Background' + +Plaintiffs Jane Doe #1 and Jane Doe #2 are alleged victims of federal sex crimes committed by Jeffrey Epstein in Palm Beach County. Between 2001 and 2007, Epstein sexually abused multiple underage girls at his Palm Beach mansion, including Plaintiffs. In 2006, the Federal Bureau of Investigation ("FBI") opened an investigation into allegations that Epstein was inducing underage girls to engage in sexual acts. The case was eventually presented to the United States Attorney's Office for the Southern District of Florida, which accepted it for investigation. The Palm Beach County State Attorney's Office was also investigating similar allegations against Epstein. Plaintiffs allege that the FBI and U.S. Attorney's Office's investigation developed a strong case for a federal prosecution against Epstein based on "overwhelming" evidence. + +In June 2007, the FBI delivered to Jane Doe #1 a standard victim-notification letter, which explained that the case against Epstein was "under investigation" and notified Jane Doe #1 of her rights under the Crime Victims' Rights Act ("CVRA"). In August 2007, Jane Doe #2 received a similar notification letter. + +In September 2007, Epstein and the U.S. Attorney's Office began plea discussions. The negotiations led to an agreement under which Epstein would plead guilty to two state felony offenses for solicitation of prostitution and procurement of minors for prostitution and the U.S. + +This background discussion is based on the allegations in Plaintiffs' Petition for Enforcement of Crime Victims' Rights Act (DE I) and the Statement of Material Facts in Plaintiffs' Motion for Finding of Violation of the Crime Victims' Rights Act (DEs 48, 52). These allegations are not yet supported by evidence and the Court relies on them here solely to provide the context for the threshold legal issues addressed in this order. As discussed below, further factual development is necessary to resolve the additional issues raised in Plaintiffs' motions. + +Attorney's Office would agree not to prosecute Epstein for federal offenses. On September 24, 2007, Epstein and the U.S. Attorney's Office executed a Non-Prosecution Agreement ("NPA") under these terms. + +Plaintiffs contend that the U.S. Attorney's Office did not confer with them regarding the plea discussions and, in fact, intentionally kept secret the negotiations and the NPA. From September 24, 2007, the day on which the NPA was executed, through June 2008, the U.S. Attorney's Office did not notify either Plaintiff of the existence of the NPA. + +During this period, Plaintiffs communicated multiple times with the FBI and U.S. Attorney's Office, but neither Plaintiff was informed of the NPA. On January 10, 2008, the FBI sent letters to Plaintiffs advising them that "[t]his case is currently under investigation," but failing to disclose the existence of the NPA. On January 32, 2008, Jane Doe #1 met with FBI agents and attorneys from the U.S. Attorney's Office to discuss her abuse by Epstein. The government did not disclose the existence of the NPA. In mid-June 2008, Plaintiffs' counsel contacted the Assistant United States Attorney ("AUSA") handling their case to discuss the status of the investigation. The AUSA did not disclose the existence of the NPA. On June 27, 2008, the U.S. Attorney's Office notified Plaintiffs' counsel that Epstein was scheduled to plead guilty in state court on June 30, 2008. The U.S. Attorney's Office did not disclose the existence of the NPA nor the relationship between Epstein's state plea and the U.S. Attorney's Office's agreement to forgo federal charges. On July 3, 2008, Plaintiffs' counsel sent a letter to the U.S. Attorney's Office stating Jane Doe #1's desire that it bring federal charges against Epstein. + +On July 7, 2008, Jane Doe #1 filed a petition in this Court to enforce her rights under the CVRA! Jane Doe #1 alleged that she believed plea discussions were under way between Epstein and the U.S. Attorney's Office, and that the government, by failing to notify her of this development, had violated her rights under the CVRA. The United States responded to the petition on July 9, 2008, arguing that (1) a federal indictment had never been returned against Epstein and therefore the CVRA did not attach, and (2) nevertheless, the U.S. Attorney's Office had used its best efforts to comply with the CVRA. The government's response also disclosed that the U.S. Attorney's Office had entered into the NPA with Epstein. + +On July 11, 2008, this Court held a hearing on Jane Doe #1's petition, at which Jane Doe #2 was added as a plaintiff. At the hearing, Plaintiffs explained that their petition did not present an emergency and that therefore an immediate resolution was not necessary. On August 14, 2008, the Court held a status conference and ordered the United States to turn over the NPA to all identified victims, including Plaintiffs, and further ordered the parties to work out the terms of a protective order governing the NPA's disclosure. + +This action was relatively inactive for the next year and one-half while Plaintiffs litigated civil actions against Epstein. After those cases settled, Plaintiffs attempted to resolve their CVRA dispute with the U.S. Attorney's Office. On March 18, 2011, after the parties' settlement efforts failed, Plaintiffs filed a series of motions, which the Court now addresses in turn, along with Bruce E. Reinhart's Motion to Intervene. + +&#x27;Jane Doe #2 joined this action after Jane Doe # I filed the initial Petition for Enforcement of Crime Victims' Rights Act. + +# I. Motion for Finding of Violations of the Crime Victims' Rights Act + +The CVRA was designed to protect victims' rights and ensure them involvement in the criminal justice process. United States v. Moussaoui, 483 F.3d 220, 234 (4ih Cir. 2007); Kenna v. U.S. Dist. Court, 435 F.3d 1011, 1016 (9th Cir. 2006) ("The [CVRAJ was enacted to make crime victims full participants in the criminal justice system."). The statute enumerates the following eight rights: + +- (1) The right to be reasonably protected from the accused. +- (2) The right to reasonable, accurate, and timely notice of any public court proceeding, or any parole proceeding, involving the crime or of any release or escape of the accused. +- (3) The right not to be excluded from any such public court proceeding, unless the court, after receiving clear and convincing evidence, determines that testimony by the victim would be materially altered if the victim heard other testimony at that proceeding. +- (4) The right to be reasonably heard at any public proceeding in the district court involving release, plea, sentencing, or any parole proceeding. +- (5) The reasonable right to confer with the attorney for the Government in the case. +- (6) The right to full and timely restitution as provided in law. +- (7) The right to proceedings free from unreasonable delay. +- (8) The right to be treated with fairness and with respect for the victim's dignity and privacy. + +18 U.S.C. § 3771(a). + +If a prosecution is underway, the CVRA grants victims standing to vindicate their rights in the ongoing criminal action. 18 U.S.C. § 3771(d)(3). If, however, a prosecution is not underway, the victims may initiate a new action under the CVRA in the district court of the + +district where the crime occurred.' Id. The statute also tasks the district courts and the prosecutors with the responsibility of protecting these rights. See 18 U.S.C. § 3771(b)(1) ("[T]he court shall ensure that the crime victim is afforded the rights described in subsection (a)."); § 3771(c)(1) ("Officers and employees of the Department of Justice . . . shall make their best efforts to see that crime victims are notified of, and accorded, the rights described in subsection (a)."). + +Here, Plaintiffs first argue that as a matter of law the CVRA's protections attach before a formal charge is filed against the criminal defendant. Accordingly, Plaintiffs contend that the CVRA applied here and that the U.S. Attorney's Office violated their CVRA rights; namely, their rights to confer, to be treated with fairness, and to accurate and timely notice of court proceedings. Based on these violations, Plaintiffs request that this Court set a briefing schedule and hearing on the appropriate remedy, which according to Plaintiffs is to invalidate the nonprosecution agreement. + +The United States argues that as a matter of law the CVRA does not apply before formal charges are filed, i.e., before an indictment or similar charging document, and therefore does not apply here because formal charges were never filed against Epstein. The United States further argues that even if the CVRA applied here, the U.S. Attorney's Office complied with its requirements. + +The Court first addresses the threshold issue whether the CVRA attaches before the government brings formal charges against the defendant The Court holds that it does because the + +Here, because no criminal case was pending, Plaintiffs filed their petition as a new matter in this judicial district, which the Clerk of Court docketed as a civil action. + +statutory language clearly contemplates pre-charge proceedings. For instance, subsections (a)(2) and (a)(3) provide rights that attach to "any public court proceeding ... involving the crime." Similarly, subsection (b) requires courts to ensure CVRA rights in "any court proceeding involving an offense against a crime victim." Court proceedings involving the crime are not limited to post-complaint or post-indictment proceedings, but can also include initial appearances and bond hearings, both of which can take place before a formal charge. By way of example, under Rule 5(a)(1)(A) of the Federal Rules of Criminal Procedure, upon arrest the defendant must be taken before a magistrate judge "without unnecessary delay" for an initial appearance. If the arrest takes place on a weekday, "without unnecessary delay" will typically require that the initial appearance occur the following morning, which will often be within twenty-four hours of arrest. See United States v. Mendoza, 473 F.2d 697, 702 (56 Cir. 1973) (holding that the government satisfied Rule 5's "without unnecessary delay" requirement by bringing the defendant before the magistrate judge on the first weekday morning following the arrest). By contrast, Rule 5(b) requires that where the defendant is arrested without a warrant, the government must file the complaint "promptly." The Supreme Court has interpreted "promptly" under Rule 5(b) as generally requiring that the complaint be filed within forty-eight hours of arrest. Cnty. Of Riverside v. McLaughlin, 500 U.S. 44, 56-57 (1991). It is therefore possible that where the defendant is arrested on a weekday without a warrant, the initial appearance—which may also involve the detention or bond hearing under Rule 5(d)(3)—will take place before the government files the criminal complaint. + +Subsection (cX1) requires that "Officers and employees of the Department of Justice and other departments and agencies of the United States engaged in the detection, investigation, or + +prosecution of crime shall make their best efforts to see that crime victims are notified of, and accorded, the rights in subsection (a)." (Emphasis added). Subsection (c)(I)'s requirement that officials engaged in "detection [or] investigation" afford victims the rights enumerated in subsection (a) surely contemplates pre-charge application of the CVRA. + +Subsection (d)(3) explains that the CVRA's enumerated rights "shall be asserted in the district court in which a defendant is being prosecuted for the crime or, if no prosecution is underway, in the district court in the district in which the crime occurred." (Emphasis added). If the CVRA's rights may be enforced before a prosecution is underway, then, to avoid a strained reading of the statute, those rights must attach before a complaint or indictment formally charges the defendant with the crime. + +This interpretation is consistent with other federal decisions that have addressed the scope of the CVRA. For instance, in In re Dean, 527 F.3d 391 (5\* Cir. 2008), the court held that subsection (a)(5)'s "right to confer" applied before any prosecution is underway. Id. at 394. Specifically, the court explained: + +The district court acknowledged that "there are clearly rights under the CVRA that apply before any prosecution is underway." Logically, this includes the CVRA's establishment of victims' reasonable right to confer with the attorney for the Government." At least in the posture of this case (and we do not speculate on the applicability to other situations), the government should have fashioned a reasonable way to inform the victims of the likelihood of criminal charges and to ascertain the victims' views on the possible details of a plea bargain. + +Id. at 394 (internal citation and quotation marks omitted). Federal district courts have reached similar conclusions. See, e.g., United States v. Rubin, 558 F. Supp. 2d 411, 417 n.5 (E.D.N.Y. 2008) (discussing victims' "ability to seek pre-prosecution relief' under the CVRA); United States v. Okun, No. 08-132, 2009 WL 790042, at '2 (E.D. Va. Mar. 24, 2009) ("[T]he Fifth + +Circuit has noted that victims acquire rights under the CVRA even before prosecution. This view is supported by the statutory language, which gives the victims rights before the accepting of plea agreements and, therefore, before adjudication of guilt."); United States v. BP Prods N. Am. Inc., No. 07-434, 2008 WL 501321, at \*11 (S.D. Tex. Feb. 21, 2008) ("There are clearly rights under the CVRA that apply before any prosecution is underway."), mandamus denied in part, In re Dean 527 F.3d 391 (5ih Cir. 2008). + +The United States argues that because the CVRA accords rights related to "any court proceeding," 18 U.S.C. §§ 3771(b)(1), (d)(3), and "in the case," § 3771(b)(5), the CVRA applies only after formal charges are filed. The Court finds this argument unavailing. First, as discussed above, "court proceedings" can occur before formal charges are filed. Similarly, subsection (a)(5)'s reference to the right to confer with "the attorney for the Government in the case," is not limited to post-charge proceedings, as the United States is represented by attorneys in each criminal case at, for example, initial appearances and bond hearings.' Last, the government's interpretation ignores the additional language throughout the statute that clearly contemplates pre-charge protections, such as subsection (c)(1)'s mandate that U.S. agencies involved at the "detection" and "investigation" stage use their best efforts to accord victims their enumerated rights under the CVRA and subsection (d)(3)'s provision that victims may vindicate their CVRA + +For this reason, the Court respectfully disagrees with the interpretation adopted in In re Petersen, No. 10-298, 2010 WL 5108692 (N.D. Ind. Dec. 8, 2010), upon which the United States relies. See id. at \*2 (holding that a "victim's `right to be treated with fairness and with respect for [his or her] dignity and privacy' may apply before any prosecution is underway and isn't necessarily tied to a `court proceeding' or `case,'" but concluding that "the right 'to confer with the attorney for the Government in the case' ... arise[s] only after charges have been brought against a defendant and a case has been opened"). But see In re Dean, 527 F.3d at 394 (holding that under subsection (a)(5), "the government should have fashioned a reasonable way to inform the victims of the likelihood of criminal charges"). + +rights even if "no prosecution is underway." See United States v. DBB, Inc., 180 F.3d 1277, 1281 (11ih Cir. 1999) ("[W]e read the statute to give full effect to each of its provisions. We do not look at one word or term in isolation, but instead we look to the entire statutory context.") (citation omitted). + +The Court also rejects the United States' argument that pre-charge CVRA rights could impair prosecutorial discretion and decision-making. Any encroachment into the prosecutors' discretion is expressly limited by the CVRA itself, which provides: "Nothing in this chapter shall be construed to impair the prosecutorial discretion of the Attorney General or any officer under his direction." 18 U.S.C. § 3771(d)(6). As the court explained in Rubin, "there is absolutely no suggestion in the statutory language that victims have a right independent of the government to prosecute a crime, set strategy, or object to or appeal pretrial or in limine orders .... In short, the CVRA, for the most part, gives victims a voice, not a veto." 558 F. Supp. at 418; see also BP Prods N. Am., 2008 WL 501321, at \*15 ("Even under an expansive approach, the reasonable right to confer on a proposed plea agreement and the government's obligation to provide notice of that right is subject to the limit that the CVRA not impair prosecutorial discretion."). Thus, to the extent that the victims' pre-charge CVRA rights impinge upon prosecutorial discretion, under the plain language of the statute those rights must yield. + +Having determined that as a matter of law the CVRA can apply before formal charges are filed, the Court must address whether the particular rights asserted here attached and, if so, whether the U.S. Attorney's Office violated those rights. However, the Court lacks a factual record to support such findings and must therefore defer ruling on these two issues pending the limited discovery discussed below. + +# II. Motion to Have Their Facts Accepted Because of the Government's Failure to Contest Any of the Facts + +For the reasons stated on the record at the August 12, 2011 hearing on this motion, the Court will deny Plaintiffs' request to have their facts accepted as true. + +### III. Motion for Order Directing the U.S. Attorney's Office Not to Withhold Relevant Evidence + +Plaintiffs request an order from the Court "directing the U.S. Attorney's Office not to suppress material evidence relevant to this case." (DE 50 at 1). Specifically, Plaintiffs seek all information and material known to the government that may be favorable to the victims regarding possible violations of their rights under the CVRA. The United States opposes the motion, arguing that neither the CVRA nor the Federal Rules of Civil Procedure impose a duty upon the U.S. Attorney's Office to provide evidence to Plaintiffs here. + +At the August 12, 2011 hearing on this motion, the United States agreed that this Court, under its inherent authority to manage this case, could impose discovery obligations on each party. Because the Court finds that some factual development is necessary to resolve the remaining issues in this case, it will permit Plaintiffs the opportunity to conduct limited discovery in the form of document requests and requests for admissions from the U.S. Attorney's Office. Either party may request additional discovery if necessary. + +Because the Court will allow this limited factual development, it is unnecessary to decide here whether the CVRA or the Federal Rules of Civil Procedure provide discovery rights in this context. The Court therefore reserves ruling on Plaintiffs' motion. + +### IV. Bruce E. Reinhart's Motion to Intervene or in the Alternative for a Sua Sponte Rule 11 Order + +Bruce E. Reinhart seeks leave to intervene as a party-in-interest under Rule 24(b) of the Federal Rules of Civil Procedure. Reinhart seeks to intervene to file a motion for sanctions based on allegedly "unfounded factual and legal accusations made about Movant in Plaintiffs' Motion for Finding of Violations of the Crime Victims' Rights Act." (DE 79 at 1). In that motion, Plaintiffs alleged that Reinhart, a former Assistant U.S. Attorney, "joined Epstein's payroll shortly after important decisions were made limiting Epstein's criminal liability" and improperly represented Epstein victims in follow-on civil suits. (DE 48 at 22). Plaintiffs contend that such conduct "give[s], at least, the improper appearance that Reinhart may have attempted to curry [favor] with Epstein and then reap his reward through favorable employment." (DE 48 at 23). Reinhart takes great offense to these accusation—which he contends are false, irrelevant to the CVRA claims, and gratuitous—and seeks intervention to rebut these allegations and move for sanctions. + +Under Rule 24(b) of the Federal Rules of Civil Procedure, "the court may permit anyone to intervene who ... has a claim or defense that shares with the main action a common question of law or fact." It is "wholly discretionary with the court whether to allow intervention under Rule 24(b) and even though there is a common question of law or fact, or the requirements of Rule 24(b) are otherwise satisfied, the court may refuse to allow intervention." In re Bayshore Ford Trucks Sales, Inc., 471 F.3d 1233, 1246 (11th 2006). The Court will deny Reinhart's request to intervene. + +First, the Court finds that Reinhart's claim does not share a common question of law or fact with the CVRA action. Reinhart claims that two paragraphs of Plaintiffs' forty-page motion make groundless and bad-faith accusations against his integrity and character. However, the veracity of Plaintiffs' two paragraphs—i.e., whether Reinhart used his position at the U.S. Attorney's Office to ingratiate himself with Epstein and advance his career in private practice—involves no common questions with the Plaintiffs' claims that the U.S. Attorney's Office violated their CVRA rights through the process in which it entered into the NPA with Epstein. Indeed, Reinhart's motion argues that the allegations against him are "irrelevant" and that Plaintiffs "do[] not make any effort to connect these allegations to the relief [they] seek[]." (DE 79 at 2). + +Second, even if these accusations shared common questions with Plaintiffs' CVRA claims, the Court would exercise its discretion and deny intervention. The Court cannot permit anyone slighted by allegations in court pleadings to intervene and conduct mini-trials to vindicate their reputation. Absent some other concrete interest in these proceedings, the Court does not believe that the allegations here are sufficiently harmful to justify permissive intervention. Reinhart has publicly aired his opposition to and denial of Plaintiffs' contentions, both on this docket and in open court, and the Court finds that further proceedings on this issue are unwarranted. For the same reason, the Court declines to conduct a sua sponte Rule 11 inquiry. + +### Conclusion + +For the foregoing reasons, it is hereby ORDERED AND ADJUDGED that Plaintiffs' Motion for Finding of Violations of the Crime Victims' Rights Act (DEs 48, 52) is GRANTED IN PART. The Court concludes that the CVRA can apply before formal charges are filed. The + +Court defers ruling on the merits of Plaintiffs' CVRA claims until the parties complete the discovery ordered herein. + +It is further ORDERED AND ADJUDGED that Plaintiffs' Motion to Have Their Facts Accepted (DE 49) is DENIED. + +The Court reserves ruling Plaintiffs' Motion for Order Directing the U.S. Attorney's Office Not to Withhold Relevant Evidence (DE 50) pending the discovery ordered herein. + +It is further ORDERED AND ADJUDGED that Bruce E. Reinhart's Motion to Intervene or in the Alternative for a Sua Sponte Rule 11 Order (DE 79) is DENIED. + +DONE AND ORDERED in Chambers at West Palm Beach, Palm Beach County, Florida this 26ih day of September, 2011. + +> rZ ge KENNETH A. 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Sep 2011 19:03:55 +0000 + +**Importance:** Normal + +--- + +**This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended.** + +**\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\*** Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +**Notice of Electronic Filing** + +The following transaction was entered on 9/19/2011 at 3:03 PM EDT and filed on 9/19/2011 + +**Case Name:** Doe █ United States of America + +**Case Number:** [9:08-cv-80736-KAM](#) + +**Filer:** + +**Document Number:** [97](#) + +**Docket Text:** + +**ORDER granting [95] Motion for Extension of Time to File Response/Reply to [93] MOTION to Intervene For Limited Intervention by Jeffrey Epstein. Signed by Judge Kenneth A. Marra on 9/19/2011. (ir)** + +**9:08-cv-80736-KAM Notice has been electronically mailed to:** + +![](_page_0_Picture_148.jpeg) + +Bradley James Edwards + +Bruce Reinhart + +Dexter Lee dexter + +Jacqueline Perczek + +Jay C. Howell jay + +![](_page_0_Picture_156.jpeg) + +![](_page_1_Picture_1.jpeg) + +9:08-cv-80736-1CAM Notice has not been delivered electronically to those listed below and will be provided by other means. 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+size 11332 diff --git a/marker2/ds9/EFTA00205858/_page_1_Picture_1.jpeg b/marker2/ds9/EFTA00205858/_page_1_Picture_1.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..547233ead1267a8c57e3bcf6dfbf3b78500dbf0a --- /dev/null +++ b/marker2/ds9/EFTA00205858/_page_1_Picture_1.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:9a51dd590f07147769d7b3e4f3924da361d08788efa94b06a2b548ace5456ace +size 2439 diff --git a/marker2/ds9/EFTA00205860/EFTA00205860.md b/marker2/ds9/EFTA00205860/EFTA00205860.md new file mode 100644 index 0000000000000000000000000000000000000000..dfc8fb939eb37cdb108bfbc7562a5670d5978283 --- /dev/null +++ b/marker2/ds9/EFTA00205860/EFTA00205860.md @@ -0,0 +1,19 @@ +From: (USAFLS)" alMIN> + +To: ala> + +Subject: Jane Does v. United States, 08-80736-CIV-Marra/Johnson + +Date: Fri, 16 Sep 2011 18:41:37 +0000 + +Importance: Normal + +Attachments: Proposed\_Order on\_Motn\_for\_Extension\_of Time.wpd + +<> Good afternoon -- Attached please find the proposed Order on the Unopposed Motion for Extension of Time. + +Thank you. + +Assistant U.S. Attorney + +Fax \ No newline at end of file diff --git a/marker2/ds9/EFTA00205860/EFTA00205860.metadata.json b/marker2/ds9/EFTA00205860/EFTA00205860.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1be0b562cc6738616147bcd4bf35cc971d236c60 --- /dev/null +++ b/marker2/ds9/EFTA00205860/EFTA00205860.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205860.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 426, + "elapsed_seconds": 0.72, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 28 + ], + [ + "Text", + 15 + ], + [ + "Line", + 14 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205860" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205861/EFTA00205861.md b/marker2/ds9/EFTA00205861/EFTA00205861.md new file mode 100644 index 0000000000000000000000000000000000000000..112518ff725e4c8cbaa10e507f5c148f4e9970ac --- /dev/null +++ b/marker2/ds9/EFTA00205861/EFTA00205861.md @@ -0,0 +1,45 @@ +To: + +Subject: Re: Jane Does v United States + +Date: Fri, 16 Sep 2011 14:36:23 +0000 + +Importance: Normal + +Thanks. I will call ou late this afternoon. I am in training until 2:00 + +USA + +--- Original Message + +From: Brad Edwards + +Sen + +To: + +Subject: Re: Jane Does v United States + +Of course not. Talk to you soon. + +-----Ori inal Messa e + +From: + +To: Brad Edwards + +To: + +Subject: Jane Does v United States + +Sent: Sep 16, 2011 8:28 AM + +Dear Brad and Roy: + +I was in Bogota for 10 days where my phone didn't work and I had very limited access to email so I have a lot of catching up to do. Do you have any objection to a ten day extension of time to respond to Mr Epstein's motion? + +Thank ou + +USA + +Sent via BlackBerry by AT&T \ No newline at end of file diff --git a/marker2/ds9/EFTA00205861/EFTA00205861.metadata.json b/marker2/ds9/EFTA00205861/EFTA00205861.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..c55a532ce529b56cec64371e2caaf8109c16c5ec --- /dev/null +++ b/marker2/ds9/EFTA00205861/EFTA00205861.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205861.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 712, + "elapsed_seconds": 1.07, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 52 + ], + [ + "Line", + 26 + ], + [ + "Text", + 24 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205861" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205862/EFTA00205862.md b/marker2/ds9/EFTA00205862/EFTA00205862.md new file mode 100644 index 0000000000000000000000000000000000000000..ef76e49faa1fec075b565e44b03b31d564f47ffd --- /dev/null +++ b/marker2/ds9/EFTA00205862/EFTA00205862.md @@ -0,0 +1,23 @@ +From: To: Cc: + +Subject: Rh.. hpstun + +Date: Fri, 07 Oct 2011 18:22:15 +0000 + +Importance: Normal + +Thanks Doug. I am also including with some of the legal issues we ace. Thanks. to the U.S. Attorney, on this e-mail given his familiarity + +From: Molloy, Douglas (USAFLM) + +Sent: Frida October 07 2011 2:20 PM + +C + +I am the AUSA from the MDFL assigned to the Epstein matter. In that regard ,-and I have arranged for a meeting in West Palm Beach for a full debriefing on all issues. I would like to include in that meeting, which we have set for October 27, 2011. + +Regards, + +Assistant U.S. Attorney + +Fort Myers Division, MDFL \ No newline at end of file diff --git a/marker2/ds9/EFTA00205862/EFTA00205862.metadata.json b/marker2/ds9/EFTA00205862/EFTA00205862.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..9af380d5a4330a2f27847bb97c663a5a756920a7 --- /dev/null +++ b/marker2/ds9/EFTA00205862/EFTA00205862.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205862.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 616, + "elapsed_seconds": 0.73, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 37 + ], + [ + "Line", + 19 + ], + [ + "Text", + 15 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205862" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205863/EFTA00205863.md b/marker2/ds9/EFTA00205863/EFTA00205863.md new file mode 100644 index 0000000000000000000000000000000000000000..be93f7c60e76762157cfeaab6e0b44d6c4a8fe31 --- /dev/null +++ b/marker2/ds9/EFTA00205863/EFTA00205863.md @@ -0,0 +1,51 @@ +**To:** "[REDACTED]. (USAFLS)" <[REDACTED]> + +**Subject:** Re: Epstein/Doe [REDACTED]. USAO + +**Date:** Thu, 29 Sep 2011 15:17:06 +0000 + +**Importance** +: Normal + +--- + +Thanks, and no problem. I was in Bogota too for 8 days visiting my family last week. + +>>> + +**From:** "[REDACTED]. (USAFLS)" <[REDACTED]> +**To:** "[REDACTED]" <[REDACTED]> +**CC:** "[REDACTED] (USAFLS)" <[REDACTED]> +**Date:** 9/29/2011 11:15 AM +**Subject:** Re: Epstein/Doe [REDACTED]. USAO + +Dear Jackie, + +Of course. Thank you for being so accommodating with my previous requests. + +[REDACTED], AUSA + +--- + +**From:** Jackie Perczek [mailto:[REDACTED]] +**Sent:** Thursday, September 29, 2011 11:08 AM +**To:** [REDACTED]. (USAFLS) +**Subject:** Epstein/Doe [REDACTED]. USAO + +Hi [REDACTED], + +I would like to ask Judge Marra until October 14 to file replies re: Epstein's motion to intervene. I ran this by Paul Cassell who has no objection. Can I file the motion as unopposed and tell the Judge that the govt does not object either? + +Thanks, + +Jackie + +Jackie Perczek, Esq. + +[REDACTED] + +[www.royblack.com](http://www.royblack.com) + +\*\*\*\*\* + +The information in this email transmission is privileged and confidential. If you are not the intended recipient, nor the employee or agent responsible for delivering it to the intended recipient, you are hereby notified that any dissemination or copying of this transmission (including any attachments) is strictly prohibited. If you have received this email in error, please notify the sender by email reply. Thank you. \ No newline at end of file diff --git a/marker2/ds9/EFTA00205863/EFTA00205863.metadata.json b/marker2/ds9/EFTA00205863/EFTA00205863.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..321c863513f9248b9b8cb9cbfa2239e6a9ae0664 --- /dev/null +++ b/marker2/ds9/EFTA00205863/EFTA00205863.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205863.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1536, + "elapsed_seconds": 6.79, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 76 + ], + [ + "Text", + 49 + ], + [ + "Line", + 35 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205863" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205864/EFTA00205864.md b/marker2/ds9/EFTA00205864/EFTA00205864.md new file mode 100644 index 0000000000000000000000000000000000000000..668379da70968b27a5c136c8586de845d43534b0 --- /dev/null +++ b/marker2/ds9/EFTA00205864/EFTA00205864.md @@ -0,0 +1,38 @@ +**To:** "[REDACTED], [REDACTED] [REDACTED]. (USAFLS)" <[REDACTED]> + +**Subject:** Epstein/Doe [REDACTED]. USAO + +**Date:** Thu, 29 Sep 2011 15:08:15 +0000 + +**Importance:** Normal + +**Inline- +Images:** ATT00001 + +Hi [REDACTED], + +I would like to ask Judge Marra until October 14 to file replies re: Epstein's motion to intervene. I ran this by Paul Cassell who has no objection. Can I file the motion as unopposed and tell the Judge that the govt does not object either? + +Thanks, + +Jackie + +Jackie Perczek, Esq. + +![](_page_0_Picture_126.jpeg) + +201 South Biscayne Boulevard + +Suite 1300 + +Miami, Florida 33131 + +O: [REDACTED] + +Fax: [REDACTED] + +[www.royblack.com](http://www.royblack.com) + +\*\*\*\*\* + +The information in this email transmission is privileged and confidential. If you are not the intended recipient, nor the employee or agent responsible for delivering it to the intended recipient, you are hereby notified that any dissemination or copying of this transmission (including any attachments) is strictly prohibited. If you have received this email in error, please notify the sender by email reply. Thank you. \ No newline at end of file diff --git a/marker2/ds9/EFTA00205864/EFTA00205864.metadata.json b/marker2/ds9/EFTA00205864/EFTA00205864.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..55bb7c6d39559f55bacd93f451e39a4e55475075 --- /dev/null +++ b/marker2/ds9/EFTA00205864/EFTA00205864.metadata.json @@ -0,0 +1,60 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205864.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1112, + "elapsed_seconds": 5.34, + "image_assets": [ + "_page_0_Picture_126.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 62 + ], + [ + "Text", + 39 + ], + [ + "Line", + 31 + ], + [ + "Picture", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205864" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205864/_page_0_Picture_126.jpeg b/marker2/ds9/EFTA00205864/_page_0_Picture_126.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..6a88eae2eecd1bb1c1764b0d763b6e80d3caa338 --- /dev/null +++ b/marker2/ds9/EFTA00205864/_page_0_Picture_126.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:80a459602765e2862197c884587cbc07931ee38d0dd742c6d30b248abd719ff8 +size 5382 diff --git a/marker2/ds9/EFTA00205865/EFTA00205865.md b/marker2/ds9/EFTA00205865/EFTA00205865.md new file mode 100644 index 0000000000000000000000000000000000000000..9662c1a39c5d9fd1c0df0ecf117e671321547235 --- /dev/null +++ b/marker2/ds9/EFTA00205865/EFTA00205865.md @@ -0,0 +1,37 @@ +![](_page_0_Picture_86.jpeg) + +**Subject:** Re: Epstein/Doe [REDACTED]. USAO +**Date:** Thu, 29 Sep 2011 15:14:40 +0000 + +**Importance:** Normal + +**Inline- +Images:** ATT00001 + +Of course. Thank you for being so accommodating with my previous requests. + +![](_page_0_Picture_91.jpeg) + +--- + +**From:** Jackie Perczek [mailto:JPerczek@royblack.com] + +**Sent:** Thursday, September 29, 2011 11:08 AM + +![](_page_0_Picture_94.jpeg) + +**Subject:** Epstein/Doe [REDACTED]. USAO + +Hi Marie, + +I would like to ask Judge Marra until October 14 to file replies re: Epstein's motion to intervene. I ran this by Paul Cassell who has no objection. Can I file the motion as unopposed and tell the Judge that the govt does not object either? + +Thanks, + +Jackie + +Jackie Perczek, Esq. + +![](_page_0_Picture_101.jpeg) + +The information in this email transmission is privileged and confidential. If you are not the intended recipient, nor the employee or agent responsible for delivering it to the intended recipient, you are hereby notified that any dissemination or copying of this transmission (including any attachments) is strictly prohibited. If you have received this email in error, please notify the sender by email reply. 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This will give us some context for our discussion on Wednesday. + +Assistant U.S. Attorney + +500 S. Australian Ave, Suite 400 + +West Palm Beach, FL 33401 + +Fax + +From: Maria Kelljchian [mailto:maria@pathtojustice.com] + +Sent: Monday, October 03, 2011 2:06 PM + +To: Villafana, Ann Marie C. (USAFLS); Lee, Dexter (USAFLS);126lack@royblack.com' + +Cc: 'Paul Cassell'; brad@pathtojustice.com + +Subject: Jane Doe #1 and Jane Doe #2 vs. US + +Attached please find: + +JANE DOE #1 AND JANE DOE #2'S FIRST REQUEST FOR PRODUCTION TO THE GOVERNMENT REGARDING INFORMATION RELEVANT TO THEIR PENDING ACTION CONCERN THE CRIME VICTIMS RIGHTS ACT + +Copy has also been sent via US Mail today. + +Maria W. Kelljchian + +Florida Registered Paralegal + +Farmer, Jaffe, Weissing, + +Edwards, Fistos & Lehrman, P.L. + +Fort Lauderdale, Florida 33301 + +fax maria@pathtojustice.com + +![](_page_0_Picture_29.jpeg) + +f Become our fan on Facebook \ No newline at end of file diff --git a/marker2/ds9/EFTA00205866/EFTA00205866.metadata.json b/marker2/ds9/EFTA00205866/EFTA00205866.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d6fb7f1156ba1b1e73ddcb93c3333bf7fe3e9acf --- /dev/null +++ b/marker2/ds9/EFTA00205866/EFTA00205866.metadata.json @@ -0,0 +1,60 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205866.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1200, + "elapsed_seconds": 1.29, + "image_assets": [ + "_page_0_Picture_29.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 68 + ], + [ + "Line", + 31 + ], + [ + "Text", + 30 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205866" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205866/_page_0_Picture_29.jpeg b/marker2/ds9/EFTA00205866/_page_0_Picture_29.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..5d57aced9396015f848058ad9182d650416b9476 --- /dev/null +++ b/marker2/ds9/EFTA00205866/_page_0_Picture_29.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:793bedd89a4d71fe1f78502ddfb33283b4f3e6b3055a293840849e7355f3ee6b +size 1618 diff --git a/marker2/ds9/EFTA00205867/EFTA00205867.md b/marker2/ds9/EFTA00205867/EFTA00205867.md new file mode 100644 index 0000000000000000000000000000000000000000..967be7c2329834e719c648c20d71da3e61fc355f --- /dev/null +++ b/marker2/ds9/EFTA00205867/EFTA00205867.md @@ -0,0 +1,229 @@ +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA + +Case No. 08-80736-Civ + +JANE DOE #1 and JANE DOE #2, + +Plaintiffs + +v. + +UNITED STATES, + +Defendants + +### JANE DOE #1 AND JANE DOE #2'S FIRST REQUEST FOR PRODUCTION TO THE GOVERNMENT REGARDING INFORMATION RELEVANT TO THEIR PENDING ACTION CONCERN THE CRIME VICTIMS RIGHTS ACT + +COME NOW Jane Doe #1 and Jane Doe #2 ("the victims"), by and through undersigned counsel, and request the defendant United States (hereinafter "the Government") to produce the original or best copy of the items listed herein below for inspection and/or copying, pursuant to the Court's Order (DE #99) directing discovery in this case. + +## BACKGROUND + +As the Government will recall, the victims have asked the Government to stipulate to undisputed facts in this case. The Government has declined. Accordingly, the victims filed their Motion for Finding of Violations of the Crime Victims' Rights Act and Request for a Hearing on Appropriate Remedies (DE 48) (the victims' "summary judgment motion") along with a Motion to Have Their Facts Accepted Because of the Government's Failure to Contest Any of the Facts (DE 49). + +On September 26, 2011, the Court denied the victims' motion to have their facts accepted (DE 99 at 11). At the same time, however, the Court has ordered discovery to develop the factual record concerning the summary judgment motion (DE 99 at 11). The Court reserved ruling on the victims' motion for an order directing the Government not to suppress relevant evidence (DE 99 at 11). + +On September 28, 2011, the victims requested that the Government voluntarily provide documents concerning this case. The Government declined to provide even a single document. Accordingly, the victims now seek the following information relevant to their pending summary judgment motion. + +# DISCOVERY REOUESTED + +The numbered discovery requests below should all be construed in light of the definitions of terms provided at the end of the requests. + +I. In the victims' currently-pending summary judgment motion, the victims contend that the Government conducted an extensive criminal investigation into Jeffrey Epstein's sexual exploitation of young girls, including Jane Doe #1 and Jane Doe #2 between 2001 and 2008. The victims also contend that the FBI and other federal agencies established that Epstein operated a large criminal enterprise that used paid employees and underlings to repeatedly find and bring minor girls to him. In deferring ruling on the victims' summary judgment motion, the Court noted that the victims had alleged that the FBI and the U.S. Attorney's Office's "investigation developed a strong case for a federal prosecution against Epstein based on 'overwhelming' evidence." DE 99 at 2. The Court, however, also noted that this was an allegation that needed "further factual development." DE 99 at 2 n.2. Please provide all documents, correspondence, and other information that supports these victims' allegations, including: + +- (a) the FBI case file on the Epstein case; +- (b) all documents, correspondence, witness statements, FBI 302s, and other similar information, that the Government collected as part of its case against and/or investigation of Epstein, including any information provided to Epstein or receive from Epstein as part of "discovery" or exchange of information concerning the case; +- (c) all documents, correspondence, witness statements, and other similar information that the Government received from any federal, state, local, or other law enforcement agency regarding sex offenses committed against children by Jeffrey Epstein; +- (d) the 82-page prosecution memorandum (a/k/a "pros memo") outlining numerous federal sexual offenses committed by Epstein (and any attachments to that memorandum) and the 53-page draft indictment for numerous federal + +offenses that the Government developed in this case and any similar successor or predecessor document; and + +- (e) Any other prosecution memorandum regarding Jeffrey Epstein (and any documents attached to that memorandum) and all draft federal indictments that were prepared regarding Epstein. Please also provide all documents, correspondence, and other information regarding these prosecution memoranda and the draft federal indictments. + +2. Throughout their pending summary judgment motion, the victims contend that they received only limited notifications from the Government (and, in particular, the U.S. Attorney's Office acting through FBI agents) about the plea negotiations that occurred with Jeffrey Epstein and the non-prosecution agreement that was ultimately reached. Please provide all documents, correspondence and other information regarding victim notifications in this case, including (but not limited to): + +- a) All crime victims notifications (and draft notifications) sent to Jane Doe #1 and Jane Doe #2 and the other identified victims of Epstein's offenses; +- b) All correspondence, documents, and other information regarding negotiations between the Government and Epstein's defense attorneys concerning the extent and nature of notifications to be made to Epstein's victims; +- c) All correspondence, documents, and other information regarding discussions between the Government, the FBI, the Palm Beach Police Department, the Palm Beach County State Attorney's Office, and Epstein's defense attorneys concerning the extent and nature of notifications to be made to Epstein's victims; +- d) All correspondence, documents, and other information regarding "marching orders" that were given to FBI agents regarding the information that they could provide to the victims about the negotiations and the non-prosecution agreement; +- e) All correspondence, documents, and other information regarding information that could be given to attorneys for the victims about the non-prosecution agreement, including information about what could be told to Brad Edwards (counsel for Jane Doe #1 and Jane Doe #2) about the non-prosecution agreement; 0 All correspondence, documents, and other information regarding Epstein's awareness that his victims (including Jane Doe #1 and Jane Doe #2) would not be notified of the non-prosecution agreement (and its ultimate presentation in court) or given a chance to confer regarding the plea negotiations he was conducting with the Government. + +3. The victims allege in their pending summary judgment motion that the Government negotiated a non-prosecution agreement with Epstein and that among the subjects covered in that non-prosecution agreement was a confidentiality provision that precluded disclosing the agreement to them and to other victims. Please provide all draft plea agreements (both state and federal) and non-prosecution agreements prepared either by attorneys for the Government or by attorneys for Epstein, as well as any correspondence, documents or other information pertaining to these agreements and to any confidentiality provision in these agreements. Please indicate that date on which each of these proposed agreements was drafted and by whom. + +4. The victims allege in their pending summary judgment motion that the Government was interested in finding a place to conclude any plea agreement that would effectively keep Epstein's victims (most of whom resided in or about West Palm Beach) from learning what was happening through the press. Please provide all correspondence, documents, and other information pertaining to negotiations between the Government and Jeffrey Epstein concerning the court and/or location in which Jeffrey Epstein would enter any guilty plea (including in particular any negotiations concerning concluding the plea in Miami or other location outside of West Palm Beach). + +5. The victims allege in their pending summary judgment motion that part of the plea negotiations with Epstein involved Epstein's efforts to make sure that the victims would be represented in civil cases against Epstein by someone who was not an experienced personal injury lawyer. Please provide all correspondence, documents, and other information pertaining to negotiations between the Government and Jeffrey Epstein regarding any legal representation of the victims in civil cases against Epstein, including any negotiations about what kinds of representation should be provided in a plea agreement or non-prosecution agreement. + +6. The victims allege in their pending summary judgment that the Government wanted the non-prosecution agreement with Epstein concealed from public view because of the intense public criticism that would have resulted had the agreement been disclosed and/or the possibility that victims would have objected in court and convicted the judge not to accept the agreement. Please provide all correspondence, documents, and other information concerning the Government's and/or Epstein awareness or discussion of this possible public criticism and/or victim objections. + +7. The victims allege in their pending summary judgment motion that the Government was aware that it potentially had obligations under the CVRA to notify the victims about the nonprosecution agreement and any related state court plea agreement. Please provide all correspondence, documents, and other information regarding the Government's awareness of its potential CVRA obligations in this case and regarding any discussions between the Government and Epstein concerning these CVRA obligations in this case. This should include any objections raised by Epstein to any notification of the victims (including Jane Doe #1 and Jane Doe #2) and any Government response to these objections. This should also include any correspondence and information about whether the CVRA applied to the victims. + +8. The victims allege in their pending summary judgment motion that, after Epstein signed the non-prosecution agreement, his performance was delayed while he used his significant social and political connections to lobby the Justice Department to obtain a more favorable plea deal (including lobbying components of the Justice Department in Washington, D.C., including the Child Exploitation Obscenity Section). Please provide all correspondence, documents, and other information regarding Epstein's lobbying efforts to persuade the Government to give him a more favorable plea arrangement and/or non-prosecution agreement, including efforts by former President Bill Clinton, Andrew Albert Christian Edward (a/k/a Prince Andrew, Duke of York), Harvard Law Professor Alan Dershowitz, Ken Starr, Lillian Sanchez, Jay Lefkowitz, and Roy Black on his behalf. + +9. On January 10, 2008, Jane Doe #1 and Jane Doe #2 received letters from the FBI advising them that "this case is currently under investigation." Please provide all documents, correspondence, and other information relating to those representations being made by the FBI to Jane Doe #1 and Jane Doe #2, including all information about whether the FBI was aware of the non-prosecution agreement at that time and about whether Epstein was aware of the notifications being made to the victims. + +10. In their pending summary judgment motion, the victims have alleged that the FBI was led to believe that their investigation of Epstein was going to produce a federal criminal prosecution and that the FBI was also misled by the U.S. Attorney's office about the status of the case. Please provide all documents, correspondence, and other information relating to these allegations, including: + +- a) All documents, correspondence, and other information relating to discussions between the U.S. Attorney's Office and the FBI concerning the status of the investigation and the plea discussions with Epstein, as well as what kind of charges would appropriately be filed against Epstein; +- b) All documents, correspondence, and other information relating to the U.S. Attorney's Office's representations to the FBI and any other state or local law enforcement agency about how this case was being handled; and +- c) All documents, correspondence, and other information relating to whether the FBI would support the position of the U.S. Attorney's Office that it has not violated the rights of Epstein's victims in this case. + +11. In their pending summary judgment motion, the victims have alleged that they had various meetings with Government prosecutors and/or agents (including FBI agents). Related to these meetings, they also allege that in mid-June 2008, their attorney (Bradley J. Edwards) discussed with an AUSA involved in the case the need for filing federal charges and that the AUSA asked the attorney to send a letter about why such charges should be filed without disclosing the existence of a previously-signed non-prosecution agreement. The victims further allege that on about July 3, 2008, their attorney sent a letter urging the filing of federal charges against Epstein. Please provide all documents, correspondence, and other information regarding these meetings with the victims and their legal counsel, including meetings with the victims on October 26, 2007, and January 31, 2008, and the contact with their legal counsel in mid-June 2008. Please also provide all documents, correspondence, and other information related to contacts between the Government and the National Crime Victim's Law Institute (NCVLI) concerning possible legal representation or other assistance to the victims by NCVLI. + +12. In their pending summary judgment motion, the victims allege that in mid-June 2008, their attorney (Bradley J. Edwards) discussed with an AUSA involved in the case the need for filing federal charges and that the AUSA asked the attorney to send a letter about why such charges should be filed without disclosing the existence of the non-prosecution agreement. The victims further allege that on about July 3, 2008, their attorney sent a letter urging the filing of federal charges against Epstein. Please provide all documents, correspondence, and other information regarding these contacts, including e-mails and correspondence generated as a result of the attorney's inquiry and any action that was taken in response to the letter that he sent. + +13. In their pending summary judgment motion, the victims allege that on or about June 27, 2008, the Government learned that Epstein would be entering his plea to state charges on about June 30, 2008. Please provide all documents, correspondence, and information regarding: + +- a) How the Government Office learned that the plea was going to be entered; +- b) How the Government notified victims about the entry of the guilty plea; and +- c) The contents of the notifications given to the victims about the entry of the guilty, including whether the victims were informed about the non-prosecution agreement and about whether the entry of this plea would preclude prosecution of crimes Epstein had committed against them. + +14. In their pending summary judgment motion, the victims have alleged that the Government and Epstein worked together to keep the existence of the non-prosecution agreement secret, including declining comment about the existence of such an agreement when asked about it when his guilty plea in state court became public knowledge. Please provide all documents, correspondence, and information about the Government's and Epstein's efforts to keep the existence of the non-prosecution agreement secret, including all e-mails and correspondence about "declining comment" or similar devices to keep the non-prosecution agreement secret. + +15. In their pending summary judgment motion, the victims allege that at all materials times, it would have been practical and feasible for the Government to have kept the victims informed about the discussions concerning the non-prosecution agreement. The victims further allege that on about July 9, 2008, the U.S. Attorney's Office provided notice to Jane Doe #1 of some of the terms of the agreement between it and Jeffrey Epstein. The victims also received a "corrected" notification letter on about September 3, 2008. Please provide all documents, correspondence, and other information about these notifications, including: + +- a) any information about whether these notifications should or should not include some mention of the non-prosecution agreement; +- b) any information about the contents of these notifications; +- c) any communications between the Government and Epstein's counsel regarding what the notifications should contain, including any communication on or about July 9, 2008, objecting to parts of the draft; +- d) Any communications between the Government and Epstein's counsel about which parts of the non-prosecution agreement were operative (including whether Part 3 was operative); +- e) Any communications between the Government and Epstein's counsel regarding the September 3, 2008, corrected notification letter; and 0 any documents, correspondence, and other information regarding the practicality and feasibility of providing notice to the victims of the existence of the agreement, which shall include any correspondence related to meeting with the victims or notifying them in any way of the non-prosecution agreement. + +16. In their pending summary judgment motion, the victims allege that one of the senior prosecutors in the U.S. Attorney's Office joined Epstein's payroll shortly after important decisions were made limiting Epstein's criminal liability — and improperly represented people close to Epstein. In light of this fact, the peculiar nature of the non-prosecution agreement + +reached in this case, and other information in the possession of the victims, it is also possible that other improper relationships exist between Government agents and Epstein. Please provide any documents, correspondence, and other information regarding the possibility of any improper relationship, including: + +- a) Attorney involvement in and/or awareness of any aspect of the Government's criminal investigation and/or possible prosecution/non-prosecution of Epstein. +- b) Attorney involvement in and/or awareness of the Government's interest in an witness, subject, or tar et of the E stein investigation, inch, Ghislaine Maxwell, Lesley Groff, , Louella Ruboyo, Larry Morrison, Larry Visoki, David Rogers, William Hammond, and Robert Roxburgh; +- c) All documents, correspondence, and other information reflecting telephone calls (includin telephone logs and telephone billing statements) made by or received by from Jeffrey Epstein, the Florida Science Foundation, Jack Goldberger, Alan Dersowitz, Roy Black, Ken Starr, Lillian Sanchez, and any other person involved with the criminal defense of Jeffrey Epstein, including telephone calls to and from Jack Goldberger and the Florida Science Foundation; +- d) All documents, correspondence, and other information including, for example, emails) that were sent to, copied to, or sent by in which the word "Epstein," ' "Ruboyo," "Morrison," "Visoki," "Rogers," "Hammond," Roxburgh," " "Florida Science Foundation," "Starr," "Black," "Goldberger," "Jeffrey," "Australian," "Lewis," "Sanchez," "358 El Brillo Way" appears and which are connected to or related to Jeffrey Epstein, Jack Goldberger, or the Jeffrey Epstein investigation or prosecution; +- e) All documents, correspondence, and other information (including for example emails) of a similar nature that indicate that my other Government prosecutor has represented (or discussed representing) a person or entity related to Jeffrey Epstein or has received business or funds from a person or entity related to Jeffrey Epstein; +- f) All documents, correspondence, and other information that indicate or suggest that tqy Government prosecutor or investigator (including state and local prosecutor or investigator) has had any form of business, social, personal, or other relationship with Jeffrey Epstein or a person or entity related to Jeffrey Epstein; and +- g) All documents, correspondence, and other information that indicate or suggest that pfly Government prosecutor or investigator (including state and local prosecutor or investigator) would receive anything of value, directly or indirectly from Jeffrey Epstein or a person or entity related to Jeffrey Epstein (including any charitable contributions to be made by Epstein to any entity). + +17. In December 2010, the victims sent a letter to the U.S. Attorney's Office for the Southern District of Florida, requesting that the Office investigate whether "improper influences" were brought to bear during the negotiations involving the possible prosecution (and ultimately the non-prosecution) of Jeffrey Epstein. That letter led to a reference of the matter to the Office of Professional Responsibility (OPR) in the Justice Department in Washington, D.C., which began some kind of an inquiry/investigation. Please provide: + +- a) All documents, correspondence, and other information collected by the Office of Professional Responsibility (OPR) and any other component of the Justice Department (including the FBI) in response to the victims' letter; +- b) All documents, correspondence, witness statements, and other information collected as part of OPR's inquiry/investigation; +- c) All documents, correspondence, witness statements and other information collected as part of any criminal inquiry/investigation that was initiated as a result of that letter, including any inquiry/investigation into criminal conflict of interest violations (such as 18 U.S.C. § 205 and § 207) +- d) All documents, correspondence, witness statements, and other information collected by any federal investigative agency that was triggered by OPR's inquiry/investigation, including any FBI inquiry/investigation regarding any improper influences or criminal or ethical violations that may have been committed by government attorneys during the handling of the Epstein investigation and/or prosecution; +- e) Any documents corres ondence, and other information regarding the accuracy or inaccuracy of sworn statements (found in DE 79-1 at p. 31) that he "did not participate in any way in the Office's investigation of Epstein;" that he "was not involved in any of the Office's decisionmaking with regard to the Epstein matter;" and that he "never learned any confidential, non-public information about the Epstein matter;" +- f) Any documents, correspondence, or other information regarding the circumstances that lead OPR to send a letter to the victims on May 6, 2011, indicating that they would not provide any further assistance to the victims in connection with their allegations that improper influences were brought to bear on the Epstein case; +- g) Any document, correspondence, e-mail, memoranda, or other information prepared by OPR, the FBI, or other Justice Department Component as a result of or following up on the victims' December 2010 letter concerning the Epstein case; and +- h) Any documents, correspondence, or other information that OPR has collected or obtained regarding the Epstein investigation and/or prosecution. + +18. At a couple points during the prosecution of this action, including in approximately December 2010 and most recently after the August 2011 hearing, the Justice Department in Washington, D.C., discussed or determined that the U.S. Attorney's Office for the Southern District of Florida (USAO SDFL) was "conflicted out", or may be conflicted out, of handling various issues related to the Epstein case because it suffered from a conflict of interest. The Justice Department accordingly sent various issues related to the Epstein case (and, on information and belief, issues related to Jane Doe #1 and Jane Doe #2) to the Department of Justice and to a United States Attorney's Office in another District. Please provide all documents, correspondence, and other information regarding the potential conflicts of interest that the Justice Department discussed or determined existed for the USAO SDFL, as well as any referral that was made to Main Justice or to any other District, including any documents that + +were transmitted to any other District regarding the conflict and regarding what was to be investigated. + +19. In March 2011, former U.S. Attorney Alexander Acosta sent a three-page letter to the news media in which he claimed that when Government attorneys began investigating Epstein, Epstein launched "a yearlong assault on the prosecution and the prosecutors." Shortly thereafter, Jeffrey Epstein's defense attorney Roy Black sent a responsive letter to Alexander Acost's letter to the news media in which he claimed that he did not pry into the personal lives of prosecutors but merely pointed out misconduct and over-reaching by certain people involved in the Epstein investigation. Please provide all documents, correspondence and other information that supports or contradicts Acosta's allegations in his letter, including any information that the Justice Department received from Epstein attacking the prosecutors and investigators working on the case. Please also provides all documents, correspondence, information about misconduct and over-reaching that was provided by Black and that the Government found that supported or contradicted such allegations. + +20. In their pending summary judgment motion, the victims have alleged that Epstein's guilty plea to state charges was intended to be the consummation of a non-prosecution agreement that barred prosecution of federal offenses committed against them. They have further alleged that Epstein entered such a guilty plea on or about June 30, 2008. Please provide all documents, correspondence, and other information between the Government and state and local prosecutors and police agencies (including The Palm Beach Police Department and Palm Beach State Attorney's Office) regarding the Epstein investigation and ultimate Epstein plea. + +21. In their pending summary judgment motion, the victims have alleged that correspondence in the possession of the Government will support their claims. Please provide all documents, correspondence, and other information between Government attorneys/officials (including both federal and state prosecutors) and attorneys for Jeffrey Epstein (or non-attorney acting on Epstein's behalf) relating to (I) negotiations involving the possible prosecution (and ultimately the non-prosecution) by federal or state agencies for sex offenses, including sex offenses committed against Jane Doe #1 and Jane Doe #2, (2) Epstein's entry of state guilty pleas for related sex offenses; (3) a non-prosecution agreement entered into between Epstein and the Government that barred his prosecution for offenses committed against Jane Doe #1 and Jane Doe #2; (4) the fulfillment of Epstein's and/or the Government's obligations under the nonprosecution agreement and/or the state guilty pleas Epstein entered; (5) any work release or other conditional release of Epstein from confinement; (6) any designation of Epstein as a sex offender or restrictions on him contacting victims of his offenses (including Jane Doe #1 and Jane Doe #2); and (7) any termination of supervision or parole of Epstein. This information should include unredacted e-mails, letters, and correspondence of any type between government prosecutors workin on the case includin but not limited to federal •rosecutors Alexander Acosta Jeffre + +and state prosecutors Dahlia Weiss, Lana Belolovek, and others involved in the Epstein investigation) and defense attorneys representing Epstein (including, but not limited to, Roy Black, Jay Lefkowitz, Jack Goldberger, Martin Weinberg, Gerald Lefcourt, Michael Tien, Guy Lewis, Lilly Ann Sanchez, Ken Starr, Alan Dershowitz) and agents acting in support of Epstein (including, but not limited to former President Bill Clinton and Andrew Albert Christian Edward + +(a/k/a Prince Andrew, Duke of York). This should also include letters of recommendation or similar communications submitted to any Government official vouching for or providing support for Jeffrey Epstein. + +22. As you know, throughout their pending summary judgment motion, the victims have alleged that they were not properly notified of plea negotiations with Jeffrey Epstein and were denied their right to confer by the Government and that instead the Government gave Epstein generous concessions through the plea negotiations. Please provide any documents, correspondence and other information that reflects or discusses any consideration of any type that Epstein had previously provided or offered to provide to the Government (or any individual within the Government, in either his official or private capacity) or any person previously employed by the Government and involved in the Epstein investigation or prosecution. The documents, correspondence, and other information should include any information discussing: + +- (a) Any donation or offer to donate, directly or indirectly, either funds, services, or any other valuable consideration to any person or entity; +- (b) Any offer to assist, directly or indirectly, any person to obtain employment, business opportunities, business clients, real estate, office properties; +- (c) Any offer to assist the Government or law enforcement agencies in the investigation or prosecution of any federal or state criminal offense; +- (d) Any consideration that Epstein had provided to Government or law enforcement agencies in the past; and +- (e) Any other consideration of any type that Epstein offered to provide or had provided in the past that could provide a basis for the Government extending Epstein a more generous or lenient plea bargain or non-prosecution agreement than would be received by any other similarly situated child abuse suspect. + +23. The Crime Victims' Rights Act, 18 U.S.C. § 3771(c)(1), requires the Government to use its "best efforts" to protect the rights of crime victims. Please provide all documents, correspondence, and other information that will assist Jane Doe #1 and Jane Doe #2 in protecting their rights under the CVRA, including all documents, correspondence, and other information that the Government previously identified as being helpful to the victims but refused to provide based on its legal interpretation (now rejected by the Court) that the CVRA did not apply to this case because no indictment was filed. + +24. In the course of its investigation of Epstein and negotiations with Epstein, the Government (i.e., federal investigators and prosecutors) shared documents, correspondence, and information with other persons outside the federal government, including state and local prosecuting and law enforcement agencies, prosecuting and law enforcement agencies in other countries, Epstein's legal counsel, legal counsel for crime victims, and other entities. Please provide all documents, correspondence, and other information that the Government shared with any entity or person outside the federal government, including all correspondence (including emails) with those entities or persons. + +25. After the victims had made extensive efforts to try and reach a stipulated set of facts in this case, in March 2011 the Government refused to negotiate about such facts. Accordingly, at that time the victims filed various motions to obtain evidence in this case and, at the same time, the victims voluntarily made all initial disclosures on their part that are required by Federal Rule of Civil Procedure 26(a)(1). Please provide all initial disclosures required by the Federal Rules of Civil Procedure, including all disclosures required by Rule 26(a)(1). + +# DEFINITIONS + +For the purpose of construing the foregoing discvery requests, the following terms are defined: + +The term "documents" means and includes, without limitation, all writings of any kind, including the originals and all non-identical copies or drafts, whether different from the original by reason of any notation made on such copy or draft or otherwise including, without limitation, correspondence, memoranda, notes, diaries, statistics, letters, e-mails, electronic computer files, telegrams, minutes, contracts, reports, studies, checks, statements, receipts, returns, summaries, pamphlets, books, prospectuses, interoffice communications, offers, notations of any sort of conversation, telephone calls, meetings or other communications, bulletins, printed matter, computer print-outs, teletypes, facsimiles, invoices, work sheets and all drafts, alterations, modifications, changes, and amendments of any of the foregoing, graphic or aural writs, records or representations of any kind including, without limitation, photographs, charts, graphs, microfiche, microfilm, videotape, recordings, motion pictures; and electronic, mechanical or electric records or representations of any kind including, without limitation, tapes, cassettes and disc recordings, and writings and printed material of every kind. + +The term "correspondence" means any tangible object that conveys information or memorializes information that was conveyed in tangible or oral form including, but not limited to, writings, letters, memoranda, reports, notes, e-mails, telephone logs, telephone billing information, telephone recordings, and interoffice communications. + +The term "Epstein's victims" means any person that the Government identified as a possible victim of a sex offense committed by Jeffrey Epstein, including Jane Doe #1, Jane Doe #2, all victims identified in attachment to the non-prosecution agreement entered into by Epstein, and another person that the Government investigated as a possible victim of Epstein's sex offenses. + +The term "Government" means the federal government, including all employees of and components of the United States Department of Justice (such as, the Office of the Attorney General, the Office of the Deputy Attorney General, the Criminal Divisions, the Office of Professional Responsibility, the Child Exploitation and Obscenity Section, the U.S. Attorney's Offices for the Southern District and Middle District of Florida, and the Federal Bureau of Investigation) and other federal government agencies with law enforcement responsibilities related to the Epstein case (such as the Internal Revenue Service). This request for production seeks all documents, correspondence, and other information held by all of these entities, including all employees of and components of the Justice Department that worked on or were in any way involved the Epstein investigation and/or that possess information relevant to the victims' claims. + +The term "including" means containing within the request, but not limiting the request. + +The term "witness statement" means any document or other recording in any form (including oral form) reflecting, recording, or otherwise memorializing a statement made or information conveyed by a potential witness, including for example FBI 302's. The term includes information collected by any law enforcement, prosecuting or government agency, including all federal, state, and local law enforcement agencies located in Washington, D.C., or Florida. + +### NO GRAND JURY TRANSCRIPTS SOUGHT + +If any of the foregoing requests cover grand jury transcripts, do not provide the grand jury transcript. If any of the foregoing requests include documents that quote directly from a grand jury transcript, please redact that particular quotation. + +# PRIVILEGE LOG + +If you believe that any document, correspondence, or other information requested in this request is subject to a privilege and if you intend to assert that privilege, please provide a "privilege log" consistent with Local Rule 26.1(g), including a description a document that is consistent with Local Rule 26.1(g)(3)(B). Your privilege log should include the type of document, general subject matter of the document, date of the document, and author and addressee of the document or correspondence. + +## REDUCING UNDUE BURDEN + +If you believe that complying with any of the foregoing requests would be unduly burdensome, please contact victims counsel — Bradley J. Edwards — to discuss ways to reduce any such burden. + +DATED: October 3, 2011 + +Respectfully Submitted, + +s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS FISTOS & LEHRMAN, P.L. + +Fort Lauderdale, Florida 33301 Telephone Facsimile Florida Bar No.: E-mail: + +and + +Paul G. Cassell + +Pro Hac Vice + +S.J. Quinney College of Law at the + +Universit of Utah + +Salt Lake Cit 84112 + +Telephone: + +Facsimile: + +E-Mail: + +Attorneys for Jane Doe #1 and Jane Doe #2 + +# CERTIFICATE OF SERVICE + +The foregoing document was served on October 3, 2011, on the following via US Mail and E-Mail Transmission: + +Assistant U.S. Attorneys 500 S. Australian Ave., Suite 400 West Palm Beach, FL 33401 + +Fax: + +E-mail: + +E-mail: + +Attorneys for the Government + +Roy Black, Esq. + +Jackie Perczek, Esq. + +Black Srebnick Koms an & Stumpf, P.A. + +Miami, FL 33131 + +Attorneys for Proposed Intervenors Roy Black et al. + +Respectfully Submitted, + +S/ Bradley J. Edwards + +Bradley J. 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0000000000000000000000000000000000000000..a9be69c5b18eda8777a43b84d55c9906e4ec5b9e --- /dev/null +++ b/marker2/ds9/EFTA00205880/EFTA00205880.md @@ -0,0 +1,106 @@ +**To:** [REDACTED] + +**Subject:** Re: FORMAL NOTICE of Office-wide Recusal of Southern District of Florida (GCO File No. REC-11-4159) + +**Date:** Mon, 03 Oct 2011 16:02:25 +0000 + +**Importance:** Normal + +--- + +Nope. [REDACTED] is the [REDACTED] in MDFL. I'll reach out to him in the next day or so. + +--- + +**From:** [REDACTED] + +**Sent:** Monday, October 03, 2011 12:00 PM + +**To:** [REDACTED] + +**Subject:** FW: FORMAL NOTICE of Office-wide Recusal of Southern District of Florida (GCO File No. REC-11-4159) + +Hi [REDACTED] – Did you ever get the name of a line AUSA? I just let a message on [REDACTED] secretary's voicemail, but wondered whether you had heard anything. + +[REDACTED] +Assistant U.S. Attorney + +--- + +**From:** [REDACTED] + +**Sent:** Wednesday, August 24, 2011 7:28 PM + +**To:** [REDACTED] + +**Subject:** FW: FORMAL NOTICE of Office-wide Recusal of Southern District of Florida (GCO File No. REC-11-4159) + +FYI. + +--- + +**From:** [REDACTED] + +**Sent:** Wednesday, August 24, 2011 3:32 PM + +**To:** [REDACTED] + +**Cc:** [REDACTED] + +**Subject:** FORMAL NOTICE of Office-wide Recusal of Southern District of Florida (GCO File No. REC-11-4159) + +**MEMORANDUM FOR:** + +Wifredo A. Ferrer + +First Assistant United States Attorney + +Southern District of Florida + +Robert E. O'Neill + +United States Attorney + +Middle District of Florida + +First Assistance United States Attorney + +Middle District of Florida + +## THROUGH: + +General Counsel + +Executive Office for United States Attorneys + +## FROM: + +Assistant General Counsel + +Executive Office for United States Attorneys + +RE: Office-Wide Recusal of Southern District of Florida from the Investigation + +and Potential Prosecution of Mr. Jeffery Epstein (GCO File No. REC-11-4159) + +THIS IS FORMAL NOTICE that David Margolis, Associate Deputy Attorney General (ADAG), approved the office-wide recusal of the United States Attorney's Office for the Southern District of Florida (SDFL) from all matters, to include the investigation and potential prosecution, relating to Jeffrey Epstein's alleged sexual activities with minor females. The ADAG authorized this recusal in accordance with United States Attorney's Manual (USAM) 3-2.170 and United States Attorney's Procedures (OM) 3-2.170.001 based upon existing conflicts of interest or the appearance of conflicts of interest pertaining to the matter. + +ADAG Margolis has assigned this matter to the United States Attorney's Office for the Middle District of Florida and, pursuant to 28 U.S.C.' 515(4 has directed and authorized United States Attorney Robert E. O'Neill to conduct any kind of legal proceeding, civil or criminal, including grand jury proceedings and proceedings before committing magistrate judges, which the United States Attorney for the Southern District of Florida is authorized by law to conduct regarding this matter. See USAP 3-2.170.001(6)(C).(2)(b). + +Each office should communicate directly with each other concerning the investigations related to this matter in accordance with the procedures outlined in AP 1-2 1 70.001(6mon)(3i. The oint of contact for the Middle District of Florida is Criminal Chief who can be contacted a The point of contact for the Southern District of Florida is First Assistant United States Attorney who can be reached at + +All Assistant United States Attorneys subsequently assigned to this matter must be appointed as Special Attorneys in order to appear on behalf of the government in the Southern District of Florida. See USAM 3- 2.300 and USAP 3-2.170.001(1C)(21(b). 6 Please contact Nicole West, EOUSA Personnel Staff, Policy and Special Programs Division, a o obtain the appointments. + +In accordance with USAP 3-2.170.001(6)1CX2n)(3), any Special Attorney assigned the matter or case should sign any pleadings or documents using the signature block of the Middle District of Florida, with the addition of the Attorney General's name preceding that of the United States Attorney. + +lila; any questions relating to this recusal matter, please contact Assistant General Counsel eneral Counsel's Office, EOUSA, at Thank you. + +Thank you, + +Assistant General Counsel + +General Counsel's Office + +Executive Office for United States Attorneys + +![](_page_2_Picture_7.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00205880/EFTA00205880.metadata.json b/marker2/ds9/EFTA00205880/EFTA00205880.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..dfba3baacef9546645f40e7fd9d341b647543613 --- /dev/null +++ b/marker2/ds9/EFTA00205880/EFTA00205880.metadata.json @@ -0,0 +1,198 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205880.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 4188, + "elapsed_seconds": 5.67, + "image_assets": [ + "_page_2_Picture_7.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "MEMORANDUM FOR:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 668.25 + ], + [ + 161.568, + 668.25 + ], + [ + 161.568, + 681.21 + ], + [ + 30.6, + 681.21 + ] + ] + }, + { + "title": "THROUGH:", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 30.6, + 280.26 + ], + [ + 103.70439147949219, + 280.26 + ], + [ + 103.70439147949219, + 296.4735412597656 + ], + [ + 30.6, + 296.4735412597656 + ] + ] + }, + { + "title": "FROM:", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 30.6, + 356.4 + ], + [ + 77.87467956542969, + 356.4 + ], + [ + 77.87467956542969, + 372.6035461425781 + ], + [ + 30.6, + 372.6035461425781 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 48 + ], + [ + "Text", + 46 + ], + [ + "Line", + 24 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 79 + ], + [ + "Line", + 32 + ], + [ + "Text", + 16 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 36 + ], + [ + "Line", + 14 + ], + [ + "Text", + 7 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205880" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205880/_page_2_Picture_7.jpeg b/marker2/ds9/EFTA00205880/_page_2_Picture_7.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..2861ebef644377bfb675a49f665564c6000dcb3c --- /dev/null +++ b/marker2/ds9/EFTA00205880/_page_2_Picture_7.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:fc359151e3241ba4fcd140cd1c2d4a2d76b1c204f009445db9bed25969f57107 +size 6904 diff --git a/marker2/ds9/EFTA00205883/EFTA00205883.md b/marker2/ds9/EFTA00205883/EFTA00205883.md new file mode 100644 index 0000000000000000000000000000000000000000..2da1f6c9d701139b512f1c0f502caa7907b19951 --- /dev/null +++ b/marker2/ds9/EFTA00205883/EFTA00205883.md @@ -0,0 +1,43 @@ +[REDACTED] +[REDACTED] +[REDACTED] + +**Cc:** 'Paul Cassell' <[REDACTED]> + +<[REDACTED]> + +**Subject:** Jane Doe #1 and Jane Doe #2 vs. US + +**Date:** Mon, 03 Oct 2011 18:05:49 +0000 + +**Importance:** Normal + +**Attachments:** Plaintiffs\_1st\_RFP\_to\_US\_ATTY.pdf + +**Inline-Images:** image001.jpg + +--- + +Attached please find: + +JANE DOE #1 AND JANE DOE #2'S FIRST REQUEST FOR PRODUCTION TO THE GOVERNMENT REGARDING INFORMATION RELEVANT TO THEIR PENDING ACTION CONCERN THE CRIME VICTIMS RIGHTS ACT + +Copy has also been sent via US Mail today. + +**Maria W. Kelljchian** + +Florida Registered Paralegal + +**Farmer, Jaffe, Weissing,** + +**Edwards, Fistos & Lehrman, P.L.** + +425 North Andrews Avenue, Suite 2 + +Fort Lauderdale, Florida 33301 + +![](_page_0_Picture_95.jpeg) + +![](_page_0_Picture_96.jpeg) + +**Become our fan on Facebook** \ No newline at end of file diff --git a/marker2/ds9/EFTA00205883/EFTA00205883.metadata.json b/marker2/ds9/EFTA00205883/EFTA00205883.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1547a6b074193a52050ab616173f452dbae1e42a --- /dev/null +++ b/marker2/ds9/EFTA00205883/EFTA00205883.metadata.json @@ -0,0 +1,61 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205883.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 816, + "elapsed_seconds": 4.44, + "image_assets": [ + "_page_0_Picture_95.jpeg", + "_page_0_Picture_96.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 41 + ], + [ + "Text", + 33 + ], + [ + "Line", + 20 + ], + [ + "Picture", + 3 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205883" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205883/_page_0_Picture_95.jpeg b/marker2/ds9/EFTA00205883/_page_0_Picture_95.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..f26309042f29fdce029ea171f0d8c1c654a0598f --- /dev/null +++ b/marker2/ds9/EFTA00205883/_page_0_Picture_95.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:7eef713772d381fd7cf23966ffaa5639cd114bf25d9f70e01c6dc6d486235b23 +size 2872 diff --git a/marker2/ds9/EFTA00205883/_page_0_Picture_96.jpeg b/marker2/ds9/EFTA00205883/_page_0_Picture_96.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..bd621376bffda578a0e22ab131363e891f3f0d40 --- /dev/null +++ b/marker2/ds9/EFTA00205883/_page_0_Picture_96.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:867f80a1e35debe23f794032f8f9f890296c343bf6381c7e9c3c31a2d2aeae88 +size 1544 diff --git a/marker2/ds9/EFTA00205884/EFTA00205884.md b/marker2/ds9/EFTA00205884/EFTA00205884.md new file mode 100644 index 0000000000000000000000000000000000000000..2066b1f97dc93a18634a07241fa6429226130f08 --- /dev/null +++ b/marker2/ds9/EFTA00205884/EFTA00205884.md @@ -0,0 +1,205 @@ +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA + +Case No. 08-80736-Civ-Marra/Johnson + +JANE DOE #1 and JANE DOE #2, + +Plaintiffs + +v. + +UNITED STATES, + +Defendants + +### JANE DOE #1 AND JANE DOE #2'S FIRST REQUEST FOR PRODUCTION TO THE GOVERNMENT REGARDING INFORMATION RELEVANT TO THEIR PENDING ACTION CONCERN THE CRIME VICTIMS RIGHTS ACT + +COME NOW Jane Doe #1 and Jane Doe #2 ("the victims"), by and through undersigned counsel, and request the defendant United States (hereinafter "the Government") to produce the original or best copy of the items listed herein below for inspection and/or copying, pursuant to the Court's Order (DE #99) directing discovery in this case. + +## BACKGROUND + +As the Government will recall, the victims have asked the Government to stipulate to undisputed facts in this case. The Government has declined. Accordingly, the victims filed their Motion for Finding of Violations of the Crime Victims' Rights Act and Request for a Hearing on Appropriate Remedies (DE 48) (the victims' "summary judgment motion") along with a Motion to Have Their Facts Accepted Because of the Government's Failure to Contest Any of the Facts (DE 49). + +On September 26, 2011, the Court denied the victims' motion to have their facts accepted (DE 99 at 11). At the same time, however, the Court has ordered discovery to develop the factual record concerning the summary judgment motion (DE 99 at 11). The Court reserved ruling on the victims' motion for an order directing the Government not to suppress relevant evidence (DE 99 at 11). + +On September 28, 2011, the victims requested that the Government voluntarily provide documents concerning this case. The Government declined to provide even a single document. Accordingly, the victims now seek the following information relevant to their pending summary judgment motion. + +## DISCOVERY REOUESTED + +The numbered discovery requests below should all be construed in light of the definitions of terms provided at the end of the requests. + +I. In the victims' currently-pending summary judgment motion, the victims contend that the Government conducted an extensive criminal investigation into Jeffrey Epstein's sexual exploitation of young girls, including Jane Doe #1 and Jane Doe #2 between 2001 and 2008. The victims also contend that the FBI and other federal agencies established that Epstein operated a large criminal enterprise that used paid employees and underlings to repeatedly find and bring minor girls to him. In deferring ruling on the victims' summary judgment motion, the Court noted that the victims had alleged that the FBI and the U.S. Attorney's Office's "investigation developed a strong case for a federal prosecution against Epstein based on 'overwhelming' evidence." DE 99 at 2. The Court, however, also noted that this was an allegation that needed "further factual development." DE 99 at 2 n.2. Please provide all documents, correspondence, and other information that supports these victims' allegations, including: + +- (a) the FBI case file on the Epstein case; +- (b) all documents, correspondence, witness statements, FBI 302s, and other similar information, that the Government collected as part of its case against and/or investigation of Epstein, including any information provided to Epstein or receive from Epstein as part of "discovery" or exchange of information concerning the case; +- (c) all documents, correspondence, witness statements, and other similar information that the Government received from any federal, state, local, or other law enforcement agency regarding sex offenses committed against children by Jeffrey Epstein; +- (d) the 82-page prosecution memorandum (a/k/a "pros memo") outlining numerous federal sexual offenses committed by Epstein (and any attachments to that memorandum) and the 53-page draft indictment for numerous federal + +offenses that the Government developed in this case and any similar successor or predecessor document; and + +- (e) Any other prosecution memorandum regarding Jeffrey Epstein (and any documents attached to that memorandum) and all draft federal indictments that were prepared regarding Epstein. Please also provide all documents, correspondence, and other information regarding these prosecution memoranda and the draft federal indictments. + +2. Throughout their pending summary judgment motion, the victims contend that they received only limited notifications from the Government (and, in particular, the U.S. Attorney's Office acting through FBI agents) about the plea negotiations that occurred with Jeffrey Epstein and the non-prosecution agreement that was ultimately reached. Please provide all documents, correspondence and other information regarding victim notifications in this case, including (but not limited to): + +- a) All crime victims notifications (and draft notifications) sent to Jane Doe #1 and Jane Doe #2 and the other identified victims of Epstein's offenses; +- b) All correspondence, documents, and other information regarding negotiations between the Government and Epstein's defense attorneys concerning the extent and nature of notifications to be made to Epstein's victims; +- c) All correspondence, documents, and other information regarding discussions between the Government, the FBI, the Palm Beach Police Department, the Palm Beach County State Attorney's Office, and Epstein's defense attorneys concerning the extent and nature of notifications to be made to Epstein's victims; +- d) All correspondence, documents, and other information regarding "marching orders" that were given to FBI agents regarding the information that they could provide to the victims about the negotiations and the non-prosecution agreement; +- e) All correspondence, documents, and other information regarding information that could be given to attorneys for the victims about the non-prosecution agreement, including information about what could be told to Brad Edwards (counsel for Jane Doe #1 and Jane Doe #2) about the non-prosecution agreement; 0 All correspondence, documents, and other information regarding Epstein's awareness that his victims (including Jane Doe #1 and Jane Doe #2) would not be notified of the non-prosecution agreement (and its ultimate presentation in court) or given a chance to confer regarding the plea negotiations he was conducting with the Government. + +3. The victims allege in their pending summary judgment motion that the Government negotiated a non-prosecution agreement with Epstein and that among the subjects covered in that non-prosecution agreement was a confidentiality provision that precluded disclosing the agreement to them and to other victims. Please provide all draft plea agreements (both state and federal) and non-prosecution agreements prepared either by attorneys for the Government or by attorneys for Epstein, as well as any correspondence, documents or other information pertaining to these agreements and to any confidentiality provision in these agreements. Please indicate that date on which each of these proposed agreements was drafted and by whom. + +4. The victims allege in their pending summary judgment motion that the Government was interested in finding a place to conclude any plea agreement that would effectively keep Epstein's victims (most of whom resided in or about West Palm Beach) from learning what was happening through the press. Please provide all correspondence, documents, and other information pertaining to negotiations between the Government and Jeffrey Epstein concerning the court and/or location in which Jeffrey Epstein would enter any guilty plea (including in particular any negotiations concerning concluding the plea in Miami or other location outside of West Palm Beach). + +5. The victims allege in their pending summary judgment motion that part of the plea negotiations with Epstein involved Epstein's efforts to make sure that the victims would be represented in civil cases against Epstein by someone who was not an experienced personal injury lawyer. Please provide all correspondence, documents, and other information pertaining to negotiations between the Government and Jeffrey Epstein regarding any legal representation of the victims in civil cases against Epstein, including any negotiations about what kinds of representation should be provided in a plea agreement or non-prosecution agreement. + +6. The victims allege in their pending summary judgment that the Government wanted the non-prosecution agreement with Epstein concealed from public view because of the intense public criticism that would have resulted had the agreement been disclosed and/or the possibility that victims would have objected in court and convicted the judge not to accept the agreement. Please provide all correspondence, documents, and other information concerning the Government's and/or Epstein awareness or discussion of this possible public criticism and/or victim objections. + +7. The victims allege in their pending summary judgment motion that the Government was aware that it potentially had obligations under the CVRA to notify the victims about the nonprosecution agreement and any related state court plea agreement. Please provide all correspondence, documents, and other information regarding the Government's awareness of its potential CVRA obligations in this case and regarding any discussions between the Government and Epstein concerning these CVRA obligations in this case. This should include any objections raised by Epstein to any notification of the victims (including Jane Doe #1 and Jane Doe #2) and any Government response to these objections. This should also include any correspondence and information about whether the CVRA applied to the victims. + +8. The victims allege in their pending summary judgment motion that, after Epstein signed the non-prosecution agreement, his performance was delayed while he used his significant social and political connections to lobby the Justice Department to obtain a more favorable plea deal (including lobbying components of the Justice Department in Washington, D.C., including the Child Exploitation Obscenity Section). Please provide all correspondence, documents, and other information regarding Epstein's lobbying efforts to persuade the Government to give him a more favorable plea arrangement and/or non-prosecution agreement, including efforts by former President Bill Clinton, Andrew Albert Christian Edward (a/k/a Prince Andrew, Duke of York), Harvard Law Professor Alan Dershowitz, Ken Starr, Lillian Sanchez, Jay Lefkowitz, and Roy Black on his behalf. + +9. On January 10, 2008, Jane Doe #1 and Jane Doe #2 received letters from the FBI advising them that "this case is currently under investigation." Please provide all documents, correspondence, and other information relating to those representations being made by the FBI to Jane Doe #1 and Jane Doe #2, including all information about whether the FBI was aware of the non-prosecution agreement at that time and about whether Epstein was aware of the notifications being made to the victims. + +10. In their pending summary judgment motion, the victims have alleged that the FBI was led to believe that their investigation of Epstein was going to produce a federal criminal prosecution and that the FBI was also misled by the U.S. Attorney's office about the status of the case. Please provide all documents, correspondence, and other information relating to these allegations, including: + +- a) All documents, correspondence, and other information relating to discussions between the U.S. Attorney's Office and the FBI concerning the status of the investigation and the plea discussions with Epstein, as well as what kind of charges would appropriately be filed against Epstein; +- b) All documents, correspondence, and other information relating to the U.S. Attorney's Office's representations to the FBI and any other state or local law enforcement agency about how this case was being handled; and +- c) All documents, correspondence, and other information relating to whether the FBI would support the position of the U.S. Attorney's Office that it has not violated the rights of Epstein's victims in this case. + +11. In their pending summary judgment motion, the victims have alleged that they had various meetings with Government prosecutors and/or agents (including FBI agents). Related to these meetings, they also allege that in mid-June 2008, their attorney (Bradley J. Edwards) discussed with an AUSA involved in the case the need for filing federal charges and that the AUSA asked the attorney to send a letter about why such charges should be filed without disclosing the existence of a previously-signed non-prosecution agreement. The victims further allege that on about July 3, 2008, their attorney sent a letter urging the filing of federal charges against Epstein. Please provide all documents, correspondence, and other information regarding these meetings with the victims and their legal counsel, including meetings with the victims on October 26, 2007, and January 31, 2008, and the contact with their legal counsel in mid-June 2008. Please also provide all documents, correspondence, and other information related to contacts between the Government and the National Crime Victim's Law Institute (NCVLI) concerning possible legal representation or other assistance to the victims by NCVLI. + +12. In their pending summary judgment motion, the victims allege that in mid-June 2008, their attorney (Bradley J. Edwards) discussed with an AUSA involved in the case the need for filing federal charges and that the AUSA asked the attorney to send a letter about why such charges should be filed without disclosing the existence of the non-prosecution agreement. The victims further allege that on about July 3, 2008, their attorney sent a letter urging the filing of federal charges against Epstein. Please provide all documents, correspondence, and other information regarding these contacts, including e-mails and correspondence generated as a result of the attorney's inquiry and any action that was taken in response to the letter that he sent. + +13. In their pending summary judgment motion, the victims allege that on or about June 27, 2008, the Government learned that Epstein would be entering his plea to state charges on about June 30, 2008. Please provide all documents, correspondence, and information regarding: + +- a) How the Government Office learned that the plea was going to be entered; +- b) How the Government notified victims about the entry of the guilty plea; and +- c) The contents of the notifications given to the victims about the entry of the guilty, including whether the victims were informed about the non-prosecution agreement and about whether the entry of this plea would preclude prosecution of crimes Epstein had committed against them. + +14. In their pending summary judgment motion, the victims have alleged that the Government and Epstein worked together to keep the existence of the non-prosecution agreement secret, including declining comment about the existence of such an agreement when asked about it when his guilty plea in state court became public knowledge. Please provide all documents, correspondence, and information about the Government's and Epstein's efforts to keep the existence of the non-prosecution agreement secret, including all e-mails and correspondence about "declining comment" or similar devices to keep the non-prosecution agreement secret. + +15. In their pending summary judgment motion, the victims allege that at all materials times, it would have been practical and feasible for the Government to have kept the victims informed about the discussions concerning the non-prosecution agreement. The victims further allege that on about July 9, 2008, the U.S. Attorney's Office provided notice to Jane Doe #1 of some of the terms of the agreement between it and Jeffrey Epstein. The victims also received a "corrected" notification letter on about September 3, 2008. Please provide all documents, correspondence, and other information about these notifications, including: + +- a) any information about whether these notifications should or should not include some mention of the non-prosecution agreement; +- b) any information about the contents of these notifications; +- c) any communications between the Government and Epstein's counsel regarding what the notifications should contain, including any communication on or about July 9, 2008, objecting to parts of the draft; +- d) Any communications between the Government and Epstein's counsel about which parts of the non-prosecution agreement were operative (including whether Part 3 was operative); +- e) Any communications between the Government and Epstein's counsel regarding the September 3, 2008, corrected notification letter; and 0 any documents, correspondence, and other information regarding the practicality and feasibility of providing notice to the victims of the existence of the agreement, which shall include any correspondence related to meeting with the victims or notifying them in any way of the non-prosecution agreement. + +16. In their pending summary judgment motion, the victims allege that one of the senior prosecutors in the U.S. Attorney's Office joined Epstein's payroll shortly after important decisions were made limiting Epstein's criminal liability — and improperly represented people close to Epstein. In light of this fact, the peculiar nature of the non-prosecution agreement + +reached in this case, and other information in the possession of the victims, it is also possible that other improper relationships exist between Government agents and Epstein. Please provide any documents, correspondence, and other information regarding the possibility of any improper relationship, including: + +- a) Attorney Bruce Reinhart's involvement in and/or awareness of any aspect of the Government's criminal investigation and/or possible prosecution/non-prosecution of Epstein; +- b) Attorney Bruce Reinhart's involvement in and/or awareness of the Government's interest in any witness, subject, or target of the Epstein investigation, includin j Maxwell, Larry Morrison, Larry Visoki, David Rogers, William Hammond, and Robert Roxburgh; +- c) All documents, correspondence, and other information reflecting telephone calls (including telephone logs and telephone billing statements) made by or received by Reinhart from Jeffrey Epstein, the Florida Science Foundation, Jack Goldberger, Alan Dersowitz, Roy Black, Ken Starr, Lillian Sanchez, and any other person involved with the criminal defense of Jeffrey Epstein, including telephone calls to and from Jack Goldberger and the Florida Science Foundation; +- d) All documents, correspondence, and other information (including, for example, emails) that were sent to, co ied to, or sent by Reinhart in which the word "Epstein," " "Morrison," "Visoki," "Rogers," "Hammond," Roxburgh," " "Florida Science Foundation," "Starr," "Black," "Goldberger," "Jeffrey," "Australian," "Lewis," "Sanchez," "358 El Brillo Way" appears and which are connected to or related to Jeffrey Epstein, Jack Goldberger, or the Jeffrey Epstein investigation or prosecution; +- e) All documents, correspondence, and other information (including for example emails) of a similar nature that indicate that my other Government prosecutor has represented (or discussed representing) a person or entity related to Jeffrey Epstein or has received business or funds from a person or entity related to Jeffrey Epstein; +- f) All documents, correspondence, and other information that indicate or suggest that tqy Government prosecutor or investigator (including state and local prosecutor or investigator) has had any form of business, social, personal, or other relationship with Jeffrey Epstein or a person or entity related to Jeffrey Epstein; and +- g) All documents, correspondence, and other information that indicate or suggest that pfly Government prosecutor or investigator (including state and local prosecutor or investigator) would receive anything of value, directly or indirectly from Jeffrey Epstein or a person or entity related to Jeffrey Epstein (including any charitable contributions to be made by Epstein to any entity). + +17. In December 2010, the victims sent a letter to the U.S. Attorney's Office for the Southern District of Florida, requesting that the Office investigate whether "improper influences" were brought to bear during the negotiations involving the possible prosecution (and ultimately the non-prosecution) of Jeffrey Epstein. That letter led to a reference of the matter to the Office of Professional Responsibility (OPR) in the Justice Department in Washington, D.C., which began some kind of an inquiry/investigation. Please provide: + +- a) All documents, correspondence, and other information collected by the Office of Professional Responsibility (OPR) and any other component of the Justice Department (including the FBI) in response to the victims' letter; +- b) All documents, correspondence, witness statements, and other information collected as part of OPR's inquiry/investigation; +- c) All documents, correspondence, witness statements and other information collected as part of any criminal inquiry/investigation that was initiated as a result of that letter, including any inquiry/investigation into criminal conflict of interest violations (such as 18 U.S.C. § 205 and § 207) +- d) All documents, correspondence, witness statements, and other information collected by any federal investigative agency that was triggered by OPR's inquiry/investigation, including any FBI inquiry/investigation regarding any improper influences or criminal or ethical violations that may have been committed by government attorneys during the handling of the Epstein investigation and/or prosecution; +- e) Any documents, correspondence, and other information regarding the accuracy or inaccuracy of Bruce Reinhart's sworn statements (found in DE 79-1 at p. 31) that he "did not participate in any way in the Office's investigation of Epstein;" that he "was not involved in any of the Office's decisionmaking with regard to the Epstein matter;" and that he "never learned any confidential, non-public information about the Epstein matter;" +- f) Any documents, correspondence, or other information regarding the circumstances that lead OPR to send a letter to the victims on May 6, 2011, indicating that they would not provide any further assistance to the victims in connection with their allegations that improper influences were brought to bear on the Epstein case; +- g) Any document, correspondence, e-mail, memoranda, or other information prepared by OPR, the FBI, or other Justice Department Component as a result of or following up on the victims' December 2010 letter concerning the Epstein case; and +- h) Any documents, correspondence, or other information that OPR has collected or obtained regarding the Epstein investigation and/or prosecution. + +18. At a couple points during the prosecution of this action, including in approximately December 2010 and most recently after the August 2011 hearing, the Justice Department in Washington, D.C., discussed or determined that the U.S. Attorney's Office for the Southern District of Florida (USAO SDFL) was "conflicted out", or may be conflicted out, of handling various issues related to the Epstein case because it suffered from a conflict of interest. The Justice Department accordingly sent various issues related to the Epstein case (and, on information and belief, issues related to Jane Doe #1 and Jane Doe #2) to the Department of Justice and to a United States Attorney's Office in another District. Please provide all documents, correspondence, and other information regarding the potential conflicts of interest that the Justice Department discussed or determined existed for the USAO SDFL, as well as any referral that was made to Main Justice or to any other District, including any documents that + +were transmitted to any other District regarding the conflict and regarding what was to be investigated. + +19. In March 2011, former U.S. Attorney Alexander Acosta sent a three-page letter to the news media in which he claimed that when Government attorneys began investigating Epstein, Epstein launched "a yearlong assault on the prosecution and the prosecutors." Shortly thereafter, Jeffrey Epstein's defense attorney Roy Black sent a responsive letter to Alexander Acost's letter to the news media in which he claimed that he did not pry into the personal lives of prosecutors but merely pointed out misconduct and over-reaching by certain people involved in the Epstein investigation. Please provide all documents, correspondence and other information that supports or contradicts Acosta's allegations in his letter, including any information that the Justice Department received from Epstein attacking the prosecutors and investigators working on the case. Please also provides all documents, correspondence, information about misconduct and over-reaching that was provided by Black and that the Government found that supported or contradicted such allegations. + +20. In their pending summary judgment motion, the victims have alleged that Epstein's guilty plea to state charges was intended to be the consummation of a non-prosecution agreement that barred prosecution of federal offenses committed against them. They have further alleged that Epstein entered such a guilty plea on or about June 30, 2008. Please provide all documents, correspondence, and other information between the Government and state and local prosecutors and police agencies (including The Palm Beach Police Department and Palm Beach State Attorney's Office) regarding the Epstein investigation and ultimate Epstein plea. + +21. In their pending summary judgment motion, the victims have alleged that correspondence in the possession of the Government will support their claims. Please provide all documents, correspondence, and other information between Government attorneys/officials (including both federal and state prosecutors) and attorneys for Jeffrey Epstein (or non-attorney acting on Epstein's behalf) relating to (I) negotiations involving the possible prosecution (and ultimately the non-prosecution) by federal or state agencies for sex offenses, including sex offenses committed against Jane Doe #1 and Jane Doe #2, (2) Epstein's entry of state guilty pleas for related sex offenses; (3) a non-prosecution agreement entered into between Epstein and the Government that barred his prosecution for offenses committed against Jane Doe #1 and Jane Doe #2; (4) the fulfillment of Epstein's and/or the Government's obligations under the nonprosecution agreement and/or the state guilty pleas Epstein entered; (5) any work release or other conditional release of Epstein from confinement; (6) any designation of Epstein as a sex offender or restrictions on him contacting victims of his offenses (including Jane Doe #1 and Jane Doe #2); and (7) any termination of supervision or parole of Epstein. This information should include unredacted e-mails, letters, and correspondence of any type between government prosecutors working on the case (including, but not limited to, federal prosecutors Alexander Acosta, MI + +Inennn IEAn11 ..... Anl Pt all,. I inn inn A An RA ^Inn If, linfe.. 1 twin/. I nn nn,1 4ln inn VAR nig n•-I and state prosecutors Dahlia Weiss, Lana Belolovek, and others involved in the Epstein investigation) and defense attorneys representing Epstein (including, but not limited to, Roy Black, Jay Lefkowitz, Jack Goldberger, Martin Weinberg, Gerald Lefcourt, Michael Tien, Guy Lewis, Lilly Ann Sanchez, Ken Starr, Alan Dershowitz) and agents acting in support of Epstein (including, but not limited to former President Bill Clinton and Andrew Albert Christian Edward + +(a/k/a Prince Andrew, Duke of York). This should also include letters of recommendation or similar communications submitted to any Government official vouching for or providing support for Jeffrey Epstein. + +22. As you know, throughout their pending summary judgment motion, the victims have alleged that they were not properly notified of plea negotiations with Jeffrey Epstein and were denied their right to confer by the Government and that instead the Government gave Epstein generous concessions through the plea negotiations. Please provide any documents, correspondence and other information that reflects or discusses any consideration of any type that Epstein had previously provided or offered to provide to the Government (or any individual within the Government, in either his official or private capacity) or any person previously employed by the Government and involved in the Epstein investigation or prosecution. The documents, correspondence, and other information should include any information discussing: + +- (a) Any donation or offer to donate, directly or indirectly, either funds, services, or any other valuable consideration to any person or entity; +- (b) Any offer to assist, directly or indirectly, any person to obtain employment, business opportunities, business clients, real estate, office properties; +- (c) Any offer to assist the Government or law enforcement agencies in the investigation or prosecution of any federal or state criminal offense; +- (d) Any consideration that Epstein had provided to Government or law enforcement agencies in the past; and +- (e) Any other consideration of any type that Epstein offered to provide or had provided in the past that could provide a basis for the Government extending Epstein a more generous or lenient plea bargain or non-prosecution agreement than would be received by any other similarly situated child abuse suspect. + +23. The Crime Victims' Rights Act, 18 U.S.C. § 3771(c)(1), requires the Government to use its "best efforts" to protect the rights of crime victims. Please provide all documents, correspondence, and other information that will assist Jane Doe #1 and Jane Doe #2 in protecting their rights under the CVRA, including all documents, correspondence, and other information that the Government previously identified as being helpful to the victims but refused to provide based on its legal interpretation (now rejected by the Court) that the CVRA did not apply to this case because no indictment was filed. + +24. In the course of its investigation of Epstein and negotiations with Epstein, the Government (i.e., federal investigators and prosecutors) shared documents, correspondence, and information with other persons outside the federal government, including state and local prosecuting and law enforcement agencies, prosecuting and law enforcement agencies in other countries, Epstein's legal counsel, legal counsel for crime victims, and other entities. Please provide all documents, correspondence, and other information that the Government shared with any entity or person outside the federal government, including all correspondence (including emails) with those entities or persons. + +25. After the victims had made extensive efforts to try and reach a stipulated set of facts in this case, in March 2011 the Government refused to negotiate about such facts. Accordingly, at that time the victims filed various motions to obtain evidence in this case and, at the same time, the victims voluntarily made all initial disclosures on their part that are required by Federal Rule of Civil Procedure 26(a)(1). Please provide all initial disclosures required by the Federal Rules of Civil Procedure, including all disclosures required by Rule 26(a)(1). + +# DEFINITIONS + +For the purpose of construing the foregoing discvery requests, the following terms are defined: + +The term "documents" means and includes, without limitation, all writings of any kind, including the originals and all non-identical copies or drafts, whether different from the original by reason of any notation made on such copy or draft or otherwise including, without limitation, correspondence, memoranda, notes, diaries, statistics, letters, e-mails, electronic computer files, telegrams, minutes, contracts, reports, studies, checks, statements, receipts, returns, summaries, pamphlets, books, prospectuses, interoffice communications, offers, notations of any sort of conversation, telephone calls, meetings or other communications, bulletins, printed matter, computer print-outs, teletypes, facsimiles, invoices, work sheets and all drafts, alterations, modifications, changes, and amendments of any of the foregoing, graphic or aural writs, records or representations of any kind including, without limitation, photographs, charts, graphs, microfiche, microfilm, videotape, recordings, motion pictures; and electronic, mechanical or electric records or representations of any kind including, without limitation, tapes, cassettes and disc recordings, and writings and printed material of every kind. + +The term "correspondence" means any tangible object that conveys information or memorializes information that was conveyed in tangible or oral form including, but not limited to, writings, letters, memoranda, reports, notes, e-mails, telephone logs, telephone billing information, telephone recordings, and interoffice communications. + +The term "Epstein's victims" means any person that the Government identified as a possible victim of a sex offense committed by Jeffrey Epstein, including Jane Doe #1, Jane Doe #2, all victims identified in attachment to the non-prosecution agreement entered into by Epstein, and another person that the Government investigated as a possible victim of Epstein's sex offenses. + +The term "Government" means the federal government, including all employees of and components of the United States Department of Justice (such as, the Office of the Attorney General, the Office of the Deputy Attorney General, the Criminal Divisions, the Office of Professional Responsibility, the Child Exploitation and Obscenity Section, the U.S. Attorney's Offices for the Southern District and Middle District of Florida, and the Federal Bureau of Investigation) and other federal government agencies with law enforcement responsibilities related to the Epstein case (such as the Internal Revenue Service). This request for production seeks all documents, correspondence, and other information held by all of these entities, including all employees of and components of the Justice Department that worked on or were in any way involved the Epstein investigation and/or that possess information relevant to the victims' claims. + +The term "including" means containing within the request, but not limiting the request. + +The term "witness statement" means any document or other recording in any form (including oral form) reflecting, recording, or otherwise memorializing a statement made or information conveyed by a potential witness, including for example FBI 302's. The term includes information collected by any law enforcement, prosecuting or government agency, including all federal, state, and local law enforcement agencies located in Washington, D.C., or Florida. + +### NO GRAND JURY TRANSCRIPTS SOUGHT + +If any of the foregoing requests cover grand jury transcripts, do not provide the grand jury transcript. If any of the foregoing requests include documents that quote directly from a grand jury transcript, please redact that particular quotation. + +## PRIVILEGE LOG + +If you believe that any document, correspondence, or other information requested in this request is subject to a privilege and if you intend to assert that privilege, please provide a "privilege log" consistent with Local Rule 26.1(g), including a description a document that is consistent with Local Rule 26.1(g)(3)(B). Your privilege log should include the type of document, general subject matter of the document, date of the document, and author and addressee of the document or correspondence. + +### REDUCING UNDUE BURDEN + +If you believe that complying with any of the foregoing requests would be unduly burdensome, please contact victims counsel — Bradley J. Edwards — to discuss ways to reduce any such burden. + +DATED: October 3, 2011 + +Respectfully Submitted, + +s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 + +![](_page_11_Picture_11.jpeg) + +and + +Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake Cit UT 84112 + +![](_page_12_Picture_2.jpeg) + +Attorneys for Jane Doe #1 and Jane Doe #2 + +## CERTIFICATE OF SERVICE + +The foregoing document was served on October 3, 2011, on the following via US Mail and E-Mail Transmission: + +Dexter Lee A. Marie Villafafia Assistant U.S. Attorneys 500 S. Australian Ave., Suite 400 West Palm Beach, FL 33401 + +![](_page_12_Picture_7.jpeg) + +Attorneys for the Government + +Roy Black, Esq. Jackie Perczek, Esq. Black, Srebnick, Komspan & Stumpf, P.A. 201 South Biscayne Boulevard Suite 1300 Miami FL 33131 + +![](_page_12_Picture_10.jpeg) + +Attorneys for Proposed Intervenors Roy Black et al. + +Respectfully Submitted, + +S/ Bradley J. Edwards + +Bradley J. 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United States of America Reply to Response to Motion + +**Date:** Fri, 14 Oct 2011 22:41:20 +0000 + +**Importance:** Normal + +--- + +**This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended.** + +**\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\*** Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +**Notice of Electronic Filing** + +The following transaction was entered by Perczek, Jacqueline on 10/14/2011 at 6:41 PM EDT and filed on 10/14/2011 + +**Case Name:** Doe v. United States of America + +**Case Number:** [9:08-cv-80736-KAM](#) + +**Filer:** Jeffrey Epstein + +**Document Number:** [108](#) + +**Docket Text:** + +**REPLY to Response to Motion re [93] MOTION to Intervene For Limited Intervention filed by Jeffrey Epstein. (Perczek, Jacqueline)** + +**9:08-cv-80736-KAM Notice has been electronically mailed to:** + +[REDACTED] [REDACTED], [REDACTED] + +Bradley James Edwards [REDACTED], [REDACTED] + +Bruce Reinhart [REDACTED], [REDACTED] + +[REDACTED] [REDACTED], [REDACTED], [REDACTED] + +Jacqueline Perczek [REDACTED], [REDACTED] + +Jay C. Howell [REDACTED] + +Roy Eric Black + +9:08-cv-80736-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at + +The following document(s) are associated with this transaction: + +Document description:Main Document + +Original filenamem/a + +Electronic document Stamp: + +[STAMP dcecfStamp\_11 1105629215 [Date=10/14/2011] [FileNumber=9348321- 0] [53cc70f2e009db090ed6f296adc0cf4e2efIc254868996ade249647708782cb68a c912811 aace7066303d831eaad347b8007e561582940b4ae007acc22655a64]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00205897/EFTA00205897.metadata.json b/marker2/ds9/EFTA00205897/EFTA00205897.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..35c8e6461a3d93bbb84d373d1954383932c99903 --- /dev/null +++ b/marker2/ds9/EFTA00205897/EFTA00205897.metadata.json @@ -0,0 +1,135 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205897.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2276, + "elapsed_seconds": 7.46, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 31.212, + 324.0 + ], + [ + 181.76399999999998, + 324.0 + ], + [ + 181.76399999999998, + 337.77 + ], + [ + 31.212, + 337.77 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 31.212, + 451.9800000000001 + ], + [ + 99.144, + 451.9800000000001 + ], + [ + 99.144, + 464.12999999999994 + ], + [ + 31.212, + 464.12999999999994 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 77 + ], + [ + "Text", + 46 + ], + [ + "Line", + 36 + ], + [ + "SectionHeader", + 4 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 23 + ], + [ + "Line", + 12 + ], + [ + "Text", + 8 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205897" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205899/EFTA00205899.md b/marker2/ds9/EFTA00205899/EFTA00205899.md new file mode 100644 index 0000000000000000000000000000000000000000..ef116928022d6f4bc682d480b22a6bd6e3a39eeb --- /dev/null +++ b/marker2/ds9/EFTA00205899/EFTA00205899.md @@ -0,0 +1,37 @@ +To: (USAFLS)" < + +Subject: Doe I. USAO + +Date: Fri, 14 Oct 2011 20:48:01 +0000 + +Importance: Normal + +Inline- + +ATT00001 Images: + +Hi + +In a little while, I will be filing Epstein's omnibus reply in support of his motion to intervene. It is one pleading, that replies to your response and to Cassell's response. It was better and more efficient to do one pleading. It will be 19 pages. Do you oppose a motion to file an overlong pleading? Cassell says he opposes anything longer than 15 pages. + +Also, my reply to Cassell's response to the supplemental briefing filed by the would-be intervenor lawyers is due early next week. I will be filing a motion for an extension until October 31. Cassell has no objection. Can I say the govt has no objection either? + +Thanks, + +Jackie Perczek, Esq. + +![](_page_0_Picture_12.jpeg) + +201 South Biscayne Boulevard + +Suite 1300 + +Miami, Florida 33131 + +O: (305) 371-6421 + +Fax: (305) 358-2006 + +www.royblack.com + +The information in this email transmission is privileged and confidential. If you are not the intended recipient, nor the employee or agent responsible for delivering it to the intended recipient, you are hereby notified that any dissemination or copying of this transmission (including any attachments) is strictly prohibited. If you have received this email in error, please notify the sender by email reply. 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USAO + +**Date:** Sat, 15 Oct 2011 01:01:08 +0000 + +**Importance:** Normal + +**Inline- +Images:** ATT00001 + +--- + +Hi Jackie: I am so sorry. I just received this. I was traveling today. Of course, no objection. + +![](_page_0_Picture_102.jpeg) + +--- + +**From:** Jackie Perczek [mailto:JPerczek@royblack.com] + +**Sent:** Friday, October 14, 2011 04:48 PM + +![](_page_0_Picture_105.jpeg) + +**Subject:** Doe [. USAO + +![](_page_0_Picture_107.jpeg) + +In a little while, I will be filing Epstein's omnibus reply in support of his motion to intervene. It is one pleading, that replies to your response and to Cassell's response. It was better and more efficient to do one pleading. It will be 19 pages. Do you oppose a motion to file an overlong pleading? Cassell says he opposes anything longer than 15 pages. + +Also, my reply to Cassell's response to the supplemental briefing filed by the would-be intervenor lawyers is due early next week. I will be filing a motion for an extension until October 31. Cassell has no objection. Can I say the govt has no objection either? + +Thanks, + +Jackie Perczek, Esq. + +![](_page_0_Picture_112.jpeg) + +\*\*\*\*\* + +The information in this email transmission is privileged and confidential. If you are not the intended recipient, nor the employee or agent responsible for delivering it to the intended recipient, you are hereby notified that any dissemination or copying of this transmission (including any attachments) is strictly prohibited. If you have received this email in error, please notify the sender by email reply. 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Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered by Perczek, Jacqueline on 10/14/2011 at 7:06 PM EDT and filed on 10/14/2011 + +Case Name: Doe I United States of America + +Case Number: 9:08-cv-80736-KAM + +Filer: Jeffrey Epstein + +Document Number: 109 + +## Docket Text: + +MOTION for Leave to File Excess Pages in Omnibus Reply In Support of Motion For Limited Intervention by Jeffrey Epstein. (Perczek, Jacqueline) + +9:08-cv-80736-KAM Notice has been electronically mailed to: + +![](_page_0_Picture_18.jpeg) + +Bradley James Edwards brad@pathtojustice.com, ecf®pathtojustice.com + +Bruce Reinhart ecf@brucereinhartlaw.com, asabater@brucereinhartlaw.com + +Dexter Lee dexter.lee@usdoj.gov, andrea.neumann2®usdoj.gov, USAFLS-HQDKT@usdoj.gov + +Jacqueline Perczek pleading@royblack.com, JackieP@Toyblack.com + +Jay C. Howell jaygayhowell.com + +Jay P. Lefkowitz lefkowitz@kirkland.com + +Roy Eric Black pleading®royblack.com + +9:08-cv-80736-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. 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All motions are fully briefed and ripe for review, and the Court has heard oral arguments on all motions. The Court has carefully considered the briefing and the parties' arguments and is otherwise fully advised in the premises. + +&#x27; The Court is awaiting supplemental briefing on the Motion to Intervene of Roy Black, Martin Weinberg, and Jay Lefkowitz (DE 56) and will rule on that motion after it is fully briefed. Also, because the proposed interveners seek intervention to request a protective order against disclosure of certain correspondences at issue in Plaintiffs' Motion to Use Correspondence to Prove Violations of the Crime Victims' Rights Act and to Have Their Unredacted Pleadings Unsealed (DE 51), the Court will defer ruling on the latter motion until the intervention motion is ripe for review. + +# Background' + +Plaintiffs Jane Doe #1 and Jane Doe #2 are alleged victims of federal sex crimes committed by Jeffrey Epstein in Palm Beach County. Between 2001 and 2007, Epstein sexually abused multiple underage girls at his Palm Beach mansion, including Plaintiffs. In 2006, the Federal Bureau of Investigation ("FBI") opened an investigation into allegations that Epstein was inducing underage girls to engage in sexual acts. The case was eventually presented to the United States Attorney's Office for the Southern District of Florida, which accepted it for investigation. The Palm Beach County State Attorney's Office was also investigating similar allegations against Epstein. Plaintiffs allege that the FBI and U.S. Attorney's Office's investigation developed a strong case for a federal prosecution against Epstein based on "overwhelming" evidence. + +In June 2007, the FBI delivered to Jane Doe #1 a standard victim-notification letter, which explained that the case against Epstein was "under investigation" and notified Jane Doe #1 of her rights under the Crime Victims' Rights Act ("CVRA"). In August 2007, Jane Doe #2 received a similar notification letter. + +In September 2007, Epstein and the U.S. Attorney's Office began plea discussions. The negotiations led to an agreement under which Epstein would plead guilty to two state felony offenses for solicitation of prostitution and procurement of minors for prostitution and the U.S. + +This background discussion is based on the allegations in Plaintiffs' Petition for Enforcement of Crime Victims' Rights Act (DE I) and the Statement of Material Facts in Plaintiffs' Motion for Finding of Violation of the Crime Victims' Rights Act (DEs 48, 52). These allegations are not yet supported by evidence and the Court relies on them here solely to provide the context for the threshold legal issues addressed in this order. As discussed below, further factual development is necessary to resolve the additional issues raised in Plaintiffs' motions. + +Attorney's Office would agree not to prosecute Epstein for federal offenses. On September 24, 2007, Epstein and the U.S. Attorney's Office executed a Non-Prosecution Agreement ("NPA") under these terms. + +Plaintiffs contend that the U.S. Attorney's Office did not confer with them regarding the plea discussions and, in fact, intentionally kept secret the negotiations and the NPA. From September 24, 2007, the day on which the NPA was executed, through June 2008, the U.S. Attorney's Office did not notify either Plaintiff of the existence of the NPA. + +During this period, Plaintiffs communicated multiple times with the FBI and U.S. Attorney's Office, but neither Plaintiff was informed of the NPA. On January 10, 2008, the FBI sent letters to Plaintiffs advising them that "[t]his case is currently under investigation," but failing to disclose the existence of the NPA. On January 32, 2008, Jane Doe #1 met with FBI agents and attorneys from the U.S. Attorney's Office to discuss her abuse by Epstein. The government did not disclose the existence of the NPA. In mid-June 2008, Plaintiffs' counsel contacted the Assistant United States Attorney ("AUSA") handling their case to discuss the status of the investigation. The AUSA did not disclose the existence of the NPA. On June 27, 2008, the U.S. Attorney's Office notified Plaintiffs' counsel that Epstein was scheduled to plead guilty in state court on June 30, 2008. The U.S. Attorney's Office did not disclose the existence of the NPA nor the relationship between Epstein's state plea and the U.S. Attorney's Office's agreement to forgo federal charges. On July 3, 2008, Plaintiffs' counsel sent a letter to the U.S. Attorney's Office stating Jane Doe #1's desire that it bring federal charges against Epstein. + +On July 7, 2008, Jane Doe #1 filed a petition in this Court to enforce her rights under the CVRA! Jane Doe #1 alleged that she believed plea discussions were under way between Epstein and the U.S. Attorney's Office, and that the government, by failing to notify her of this development, had violated her rights under the CVRA. The United States responded to the petition on July 9, 2008, arguing that (1) a federal indictment had never been returned against Epstein and therefore the CVRA did not attach, and (2) nevertheless, the U.S. Attorney's Office had used its best efforts to comply with the CVRA. The government's response also disclosed that the U.S. Attorney's Office had entered into the NPA with Epstein. + +On July 11, 2008, this Court held a hearing on Jane Doe #1's petition, at which Jane Doe #2 was added as a plaintiff. At the hearing, Plaintiffs explained that their petition did not present an emergency and that therefore an immediate resolution was not necessary. On August 14, 2008, the Court held a status conference and ordered the United States to turn over the NPA to all identified victims, including Plaintiffs, and further ordered the parties to work out the terms of a protective order governing the NPA's disclosure. + +This action was relatively inactive for the next year and one-half while Plaintiffs litigated civil actions against Epstein. After those cases settled, Plaintiffs attempted to resolve their CVRA dispute with the U.S. Attorney's Office. On March 18, 2011, after the parties' settlement efforts failed, Plaintiffs filed a series of motions, which the Court now addresses in turn, along with Motion to Intervene. + +&#x27;Jane Doe #2 joined this action after Jane Doe # I filed the initial Petition for Enforcement of Crime Victims' Rights Act.

I. Motion for Finding of Violations of the Crime Victims' Rights Act

The CVRA was designed to protect victims' rights and ensure them involvement in the criminal justice process. United Stalest Moussaoui, 483 F.3d 220, 234 (4ih Cir. 2007); Kenna,. U.S. Dist. Court, 435 F.3d 1011, 1016 (9th Cir. 2006) ("The [CVRA] was enacted to make crime victims full participants in the criminal justice system."). The statute enumerates the following eight rights:

  • (1) The right to be reasonably protected from the accused.
  • (2) The right to reasonable, accurate, and timely notice of any public court proceeding, or any parole proceeding, involving the crime or of any release or escape of the accused.
  • (3) The right not to be excluded from any such public court proceeding, unless the court, after receiving clear and convincing evidence, determines that testimony by the victim would be materially altered if the victim heard other testimony at that proceeding.
  • (4) The right to be reasonably heard at any public proceeding in the district court involving release, plea, sentencing, or any parole proceeding.
  • (5) The reasonable right to confer with the attorney for the Government in the case.
  • (6) The right to full and timely restitution as provided in law.
  • (7) The right to proceedings free from unreasonable delay.
  • (8) The right to be treated with fairness and with respect for the victim's dignity and privacy.

18 U.S.C. § 3771(a).

If a prosecution is underway, the CVRA grants victims standing to vindicate their rights in the ongoing criminal action. 18 U.S.C. § 3771(d)(3). If, however, a prosecution is not underway, the victims may initiate a new action under the CVRA in the district court of the

district where the crime occurred.' Id. The statute also tasks the district courts and the prosecutors with the responsibility of protecting these rights. See 18 U.S.C. § 3771(b)(1) ("[T]he court shall ensure that the crime victim is afforded the rights described in subsection (a)."); § 3771(c)(1) ("Officers and employees of the Department of Justice . . . shall make their best efforts to see that crime victims are notified of, and accorded, the rights described in subsection (a).").

Here, Plaintiffs first argue that as a matter of law the CVRA's protections attach before a formal charge is filed against the criminal defendant. Accordingly, Plaintiffs contend that the CVRA applied here and that the U.S. Attorney's Office violated their CVRA rights; namely, their rights to confer, to be treated with fairness, and to accurate and timely notice of court proceedings. Based on these violations, Plaintiffs request that this Court set a briefing schedule and hearing on the appropriate remedy, which according to Plaintiffs is to invalidate the nonprosecution agreement.

The United States argues that as a matter of law the CVRA does not apply before formal charges are filed, i.e., before an indictment or similar charging document, and therefore does not apply here because formal charges were never filed against Epstein. The United States further argues that even if the CVRA applied here, the U.S. Attorney's Office complied with its requirements.

The Court first addresses the threshold issue whether the CVRA attaches before the government brings formal charges against the defendant The Court holds that it does because the

Here, because no criminal case was pending, Plaintiffs filed their petition as a new matter in this judicial district, which the Clerk of Court docketed as a civil action.

statutory language clearly contemplates pre-charge proceedings. For instance, subsections (a)(2) and (a)(3) provide rights that attach to "any public court proceeding ... involving the crime." Similarly, subsection (b) requires courts to ensure CVRA rights in "any court proceeding involving an offense against a crime victim." Court proceedings involving the crime are not limited to post-complaint or post-indictment proceedings, but can also include initial appearances and bond hearings, both of which can take place before a formal charge. By way of example, under Rule 5(a)(1)(A) of the Federal Rules of Criminal Procedure, upon arrest the defendant must be taken before a magistrate judge "without unnecessary delay" for an initial appearance. If the arrest takes place on a weekday, "without unnecessary delay" will typically require that the initial appearance occur the following morning, which will often be within twenty-four hours of arrest. See United States,. Mendoza, 473 F.2d 697, 702 (56 Cir. 1973) (holding that the government satisfied Rule 5's "without unnecessary delay" requirement by bringing the defendant before the magistrate judge on the first weekday morning following the arrest). By contrast, Rule 5(b) requires that where the defendant is arrested without a warrant, the government must file the complaint "promptly." The Supreme Court has interpreted "promptly" under Rule 5(b) as generally requiring that the complaint be filed within forty-eight hours of arrest. Cnty. Of Riverside.. McLaughlin, 500 U.S. 44, 56-57 (1991). It is therefore possible that where the defendant is arrested on a weekday without a warrant, the initial appearance—which may also involve the detention or bond hearing under Rule 5(d)(3)—will take place before the government files the criminal complaint.

Subsection (cX1) requires that "Officers and employees of the Department of Justice and other departments and agencies of the United States engaged in the detection, investigation, or

prosecution of crime shall make their best efforts to see that crime victims are notified of, and accorded, the rights in subsection (a)." (Emphasis added). Subsection (c)(I)'s requirement that officials engaged in "detection [or] investigation" afford victims the rights enumerated in subsection (a) surely contemplates pre-charge application of the CVRA.

Subsection (d)(3) explains that the CVRA's enumerated rights "shall be asserted in the district court in which a defendant is being prosecuted for the crime or, if no prosecution is underway, in the district court in the district in which the crime occurred." (Emphasis added). If the CVRA's rights may be enforced before a prosecution is underway, then, to avoid a strained reading of the statute, those rights must attach before a complaint or indictment formally charges the defendant with the crime.

This interpretation is consistent with other federal decisions that have addressed the scope of the CVRA. For instance, in In re Dean, 527 F.3d 391 (5\* Cir. 2008), the court held that subsection (a)(5)'s "right to confer" applied before any prosecution is underway. Id. at 394. Specifically, the court explained:

The district court acknowledged that "there are clearly rights under the CVRA that apply before any prosecution is underway." Logically, this includes the CVRA's establishment of victims' reasonable right to confer with the attorney for the Government." At least in the posture of this case (and we do not speculate on the applicability to other situations), the government should have fashioned a reasonable way to inform the victims of the likelihood of criminal charges and to ascertain the victims' views on the possible details of a plea bargain.

Id. at 394 (internal citation and quotation marks omitted). Federal district courts have reached similar conclusions. See, e.g., United States'. Rubin, 558 F. Supp. 2d 411, 417 n.5 (E.D.N.Y. 2008) (discussing victims' "ability to seek pre-prosecution relief' under the CVRA); United States.. Okun, No. 08-132, 2009 WL 790042, at '2 (E.D. Va. Mar. 24, 2009) ("[T]he Fifth

Circuit has noted that victims acquire rights under the CVRA even before prosecution. This view is supported by the statutory language, which gives the victims rights before the accepting of plea agreements and, therefore, before adjudication of guilt."); United States" BP Prods N. Am. Inc., No. 07-434, 2008 WL 501321, at \*11 (S.D. Tex. Feb. 21, 2008) ("There are clearly rights under the CVRA that apply before any prosecution is underway."), mandamus denied in part, In re Dean 527 F.3d 391 (5ih Cir. 2008).

The United States argues that because the CVRA accords rights related to "any court proceeding," 18 U.S.C. §§ 3771(b)(1), (d)(3), and "in the case," § 3771(b)(5), the CVRA applies only after formal charges are filed. The Court finds this argument unavailing. First, as discussed above, "court proceedings" can occur before formal charges are filed. Similarly, subsection (a)(5)'s reference to the right to confer with "the attorney for the Government in the case," is not limited to post-charge proceedings, as the United States is represented by attorneys in each criminal case at, for example, initial appearances and bond hearings.' Last, the government's interpretation ignores the additional language throughout the statute that clearly contemplates pre-charge protections, such as subsection (c)(1)'s mandate that U.S. agencies involved at the "detection" and "investigation" stage use their best efforts to accord victims their enumerated rights under the CVRA and subsection (d)(3)'s provision that victims may vindicate their CVRA

For this reason, the Court respectfully disagrees with the interpretation adopted in In re Petersen, No. 10-298, 2010 WL 5108692 (N.D. Ind. Dec. 8, 2010), upon which the United States relies. See id. at \*2 (holding that a "victim's 'right to be treated with fairness and with respect for [his or her] dignity and privacy' may apply before any prosecution is underway and isn't necessarily tied to a `court proceeding' or `case,'" but concluding that "the right 'to confer with the attorney for the Government in the case' ... arise[s] only after charges have been brought against a defendant and a case has been opened"). But see In re Dean, 527 F.3d at 394 (holding that under subsection (a)(5), "the government should have fashioned a reasonable way to inform the victims of the likelihood of criminal charges").

rights even if "no prosecution is underway." See United States.. DBB, Inc., 180 F.3d 1277, 1281 (11ih Cir. 1999) ("[W]e read the statute to give full effect to each of its provisions. We do not look at one word or term in isolation, but instead we look to the entire statutory context.") (citation omitted).

The Court also rejects the United States' argument that pre-charge CVRA rights could impair prosecutorial discretion and decision-making. Any encroachment into the prosecutors' discretion is expressly limited by the CVRA itself, which provides: "Nothing in this chapter shall be construed to impair the prosecutorial discretion of the Attorney General or any officer under his direction." 18 U.S.C. § 3771(d)(6). As the court explained in Rubin, "there is absolutely no suggestion in the statutory language that victims have a right independent of the government to prosecute a crime, set strategy, or object to or appeal pretrial or in limine orders .... In short, the CVRA, for the most part, gives victims a voice, not a veto." 558 F. Supp. at 418; see also BP Prods N. Am., 2008 WL 501321, at \*15 ("Even under an expansive approach, the reasonable right to confer on a proposed plea agreement and the government's obligation to provide notice of that right is subject to the limit that the CVRA not impair prosecutorial discretion."). Thus, to the extent that the victims' pre-charge CVRA rights impinge upon prosecutorial discretion, under the plain language of the statute those rights must yield.

Having determined that as a matter of law the CVRA can apply before formal charges are filed, the Court must address whether the particular rights asserted here attached and, if so, whether the U.S. Attorney's Office violated those rights. However, the Court lacks a factual record to support such findings and must therefore defer ruling on these two issues pending the limited discovery discussed below.

II. Motion to Have Their Facts Accepted Because of the Government's Failure to Contest Any of the Facts

For the reasons stated on the record at the August 12, 2011 hearing on this motion, the Court will deny Plaintiffs' request to have their facts accepted as true.

III. Motion for Order Directing the U.S. Attorney's Office Not to Withhold Relevant Evidence

Plaintiffs request an order from the Court "directing the U.S. Attorney's Office not to suppress material evidence relevant to this case." (DE 50 at 1). Specifically, Plaintiffs seek all information and material known to the government that may be favorable to the victims regarding possible violations of their rights under the CVRA. The United States opposes the motion, arguing that neither the CVRA nor the Federal Rules of Civil Procedure impose a duty upon the U.S. Attorney's Office to provide evidence to Plaintiffs here.

At the August 12, 2011 hearing on this motion, the United States agreed that this Court, under its inherent authority to manage this case, could impose discovery obligations on each party. Because the Court finds that some factual development is necessary to resolve the remaining issues in this case, it will permit Plaintiffs the opportunity to conduct limited discovery in the form of document requests and requests for admissions from the U.S. Attorney's Office. Either party may request additional discovery if necessary.

Because the Court will allow this limited factual development, it is unnecessary to decide here whether the CVRA or the Federal Rules of Civil Procedure provide discovery rights in this context. The Court therefore reserves ruling on Plaintiffs' motion.

IN'. 11 Order Motion to Intervene or in the Alternative for a Sua Sponte Rule

seeks leave to intervene as a party-in-interest under Rule 24(b) of the Federal Rules of Civil Procedure. Reinhart seeks to intervene to file a motion for sanctions based on allegedly "unfounded factual and legal accusations made about Movant in Plaintiffs' Motion for Finding of Violations of the Crime Victims' Rights Act." (DE 79 at 1). In that motion, Plaintiffs alleged that Reinhart, a former Assistant U.S. Attorney, "joined Epstein's payroll shortly after important decisions were made limiting Epstein's criminal liability" and improperly represented Epstein victims in follow-on civil suits. (DE 48 at 22). Plaintiffs contend that such conduct "give[s], at least, the improper appearance that Reinhart may have attempted to curry [favor] with Epstein and then reap his reward through favorable employment." (DE 48 at 23). Reinhart takes great offense to these accusation—which he contends are false, irrelevant to the CVRA claims, and gratuitous—and seeks intervention to rebut these allegations and move for sanctions.

Under Rule 24(b) of the Federal Rules of Civil Procedure, "the court may permit anyone to intervene who ... has a claim or defense that shares with the main action a common question of law or fact." It is "wholly discretionary with the court whether to allow intervention under Rule 24(b) and even though there is a common question of law or fact, or the requirements of Rule 24(b) are otherwise satisfied, the court may refuse to allow intervention." In re Bayshore Ford Trucks Sales, Inc., 471 F.3d 1233, 1246 (11th 2006). The Court will deny request to intervene.

First, the Court finds that claim does not share a common question of law or fact with the CVRA action. maims that two paragraphs of Plaintiffs' forty-page motion make groundless and bad-faith accusations against his integrity and character. However, the veracity of Plaintiffs' two paragraphs—i.e., whether Reinhart used his position at the U.S. Attorney's Office to ingratiate himself with Epstein and advance his career in private practice—involves no common questions with the Plaintiffs' claims that the U.S. Attorney's Office violated their CVRA rights through the process in which it entered into the NPA with Epstein. Indeed, motion argues that the allegations against him are "irrelevant" and that Plaintiffs "do[] not make any effort to connect these allegations to the relief [they] seek[]." (DE 79 at 2).

Second, even if these accusations shared common questions with Plaintiffs' CVRA claims, the Court would exercise its discretion and deny intervention. The Court cannot permit anyone slighted by allegations in court pleadings to intervene and conduct mini-trials to vindicate their reputation. Absent some other concrete interest in these proceedings, the Court does not believe that the allegations here are sufficiently harmful to justify permissive intervention. Reinhart has publicly aired his opposition to and denial of Plaintiffs' contentions, both on this docket and in open court, and the Court finds that further proceedings on this issue are unwarranted. For the same reason, the Court declines to conduct a sua sponte Rule 11 inquiry.

Conclusion

For the foregoing reasons, it is hereby ORDERED AND ADJUDGED that Plaintiffs' Motion for Finding of Violations of the Crime Victims' Rights Act (DEs 48, 52) is GRANTED IN PART. The Court concludes that the CVRA can apply before formal charges are filed. The

Court defers ruling on the merits of Plaintiffs' CVRA claims until the parties complete the discovery ordered herein.

It is further ORDERED AND ADJUDGED that Plaintiffs' Motion to Have Their Facts Accepted (DE 49) is DENIED.

The Court reserves ruling Plaintiffs' Motion for Order Directing the U.S. Attorney's Office Not to Withhold Relevant Evidence (DE 50) pending the discovery ordered herein.

It is further ORDERED AND ADJUDGED that Bruce E. Motion to Intervene or in the Alternative for a Sua Sponte Rule 11 Order (DE 79) is DENIED.

DONE AND ORDERED in Chambers at West Palm Beach, Palm Beach County, Florida this 26ih day of September, 2011.

rZ se KENNETH A. MARRA United States District Judge

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b/marker2/ds9/EFTA00205917/EFTA00205917.md @@ -0,0 +1,223 @@ +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA + +Case No. 08-80736-Civ-Marra/Johnson + +JANE DOE #1 and JANE DOE #2, + +Plaintiffs + +I + +UNITED STATES, + +Defendants + +### JANE DOE #1 AND JANE DOE #2'S FIRST REQUEST FOR PRODUCTION TO THE GOVERNMENT REGARDING INFORMATION RELEVANT TO THEIR PENDING ACTION CONCERN THE CRIME VICTIMS RIGHTS ACT + +COME NOW Jane Doe #1 and Jane Doe #2 ("the victims"), by and through undersigned counsel, and request the defendant United States (hereinafter "the Government") to produce the original or best copy of the items listed herein below for inspection and/or copying, pursuant to the Court's Order (DE #99) directing discovery in this case. + +## BACKGROUND + +As the Government will recall, the victims have asked the Government to stipulate to undisputed facts in this case. The Government has declined. Accordingly, the victims filed their Motion for Finding of Violations of the Crime Victims' Rights Act and Request for a Hearing on Appropriate Remedies (DE 48) (the victims' "summary judgment motion") along with a Motion to Have Their Facts Accepted Because of the Government's Failure to Contest Any of the Facts (DE 49). + +On September 26, 2011, the Court denied the victims' motion to have their facts accepted (DE 99 at 11). At the same time, however, the Court has ordered discovery to develop the factual record concerning the summary judgment motion (DE 99 at 11). The Court reserved ruling on the victims' motion for an order directing the Government not to suppress relevant evidence (DE 99 at 11). + +On September 28, 2011, the victims requested that the Government voluntarily provide documents concerning this case. The Government declined to provide even a single document. Accordingly, the victims now seek the following information relevant to their pending summary judgment motion. + +## DISCOVERY REOUESTED + +The numbered discovery requests below should all be construed in light of the definitions of terms provided at the end of the requests. + +I. In the victims' currently-pending summary judgment motion, the victims contend that the Government conducted an extensive criminal investigation into Jeffrey Epstein's sexual exploitation of young girls, including Jane Doe #1 and Jane Doe #2 between 2001 and 2008. The victims also contend that the FBI and other federal agencies established that Epstein operated a large criminal enterprise that used paid employees and underlings to repeatedly find and bring minor girls to him. In deferring ruling on the victims' summary judgment motion, the Court noted that the victims had alleged that the FBI and the U.S. Attorney's Office's "investigation developed a strong case for a federal prosecution against Epstein based on 'overwhelming' evidence." DE 99 at 2. The Court, however, also noted that this was an allegation that needed "further factual development." DE 99 at 2 n.2. Please provide all documents, correspondence, and other information that supports these victims' allegations, including: + +- (a) the FBI case file on the Epstein case; +- (b) all documents, correspondence, witness statements, FBI 302s, and other similar information, that the Government collected as part of its case against and/or investigation of Epstein, including any information provided to Epstein or receive from Epstein as part of "discovery" or exchange of information concerning the case; +- (c) all documents, correspondence, witness statements, and other similar information that the Government received from any federal, state, local, or other law enforcement agency regarding sex offenses committed against children by Jeffrey Epstein; +- (d) the 82-page prosecution memorandum (a/k/a "pros memo") outlining numerous federal sexual offenses committed by Epstein (and any attachments to that memorandum) and the 53-page draft indictment for numerous federal + +offenses that the Government developed in this case and any similar successor or predecessor document; and + +- (e) Any other prosecution memorandum regarding Jeffrey Epstein (and any documents attached to that memorandum) and all draft federal indictments that were prepared regarding Epstein. Please also provide all documents, correspondence, and other information regarding these prosecution memoranda and the draft federal indictments. + +2. Throughout their pending summary judgment motion, the victims contend that they received only limited notifications from the Government (and, in particular, the U.S. Attorney's Office acting through FBI agents) about the plea negotiations that occurred with Jeffrey Epstein and the non-prosecution agreement that was ultimately reached. Please provide all documents, correspondence and other information regarding victim notifications in this case, including (but not limited to): + +- a) All crime victims notifications (and draft notifications) sent to Jane Doe #1 and Jane Doe #2 and the other identified victims of Epstein's offenses; +- b) All correspondence, documents, and other information regarding negotiations between the Government and Epstein's defense attorneys concerning the extent and nature of notifications to be made to Epstein's victims; +- c) All correspondence, documents, and other information regarding discussions between the Government, the FBI, the Palm Beach Police Department, the Palm Beach County State Attorney's Office, and Epstein's defense attorneys concerning the extent and nature of notifications to be made to Epstein's victims; +- d) All correspondence, documents, and other information regarding "marching orders" that were given to FBI agents regarding the information that they could provide to the victims about the negotiations and the non-prosecution agreement; +- e) All correspondence, documents, and other information regarding information that could be given to attorneys for the victims about the non-prosecution agreement, including information about what could be told to Brad Edwards (counsel for Jane Doe #1 and Jane Doe #2) about the non-prosecution agreement; 0 All correspondence, documents, and other information regarding Epstein's awareness that his victims (including Jane Doe #1 and Jane Doe #2) would not be notified of the non-prosecution agreement (and its ultimate presentation in court) or given a chance to confer regarding the plea negotiations he was conducting with the Government. + +3. The victims allege in their pending summary judgment motion that the Government negotiated a non-prosecution agreement with Epstein and that among the subjects covered in that non-prosecution agreement was a confidentiality provision that precluded disclosing the agreement to them and to other victims. Please provide all draft plea agreements (both state and federal) and non-prosecution agreements prepared either by attorneys for the Government or by attorneys for Epstein, as well as any correspondence, documents or other information pertaining to these agreements and to any confidentiality provision in these agreements. Please indicate that date on which each of these proposed agreements was drafted and by whom. + +4. The victims allege in their pending summary judgment motion that the Government was interested in finding a place to conclude any plea agreement that would effectively keep Epstein's victims (most of whom resided in or about West Palm Beach) from learning what was happening through the press. Please provide all correspondence, documents, and other information pertaining to negotiations between the Government and Jeffrey Epstein concerning the court and/or location in which Jeffrey Epstein would enter any guilty plea (including in particular any negotiations concerning concluding the plea in Miami or other location outside of West Palm Beach). + +5. The victims allege in their pending summary judgment motion that part of the plea negotiations with Epstein involved Epstein's efforts to make sure that the victims would be represented in civil cases against Epstein by someone who was not an experienced personal injury lawyer. Please provide all correspondence, documents, and other information pertaining to negotiations between the Government and Jeffrey Epstein regarding any legal representation of the victims in civil cases against Epstein, including any negotiations about what kinds of representation should be provided in a plea agreement or non-prosecution agreement. + +6. The victims allege in their pending summary judgment that the Government wanted the non-prosecution agreement with Epstein concealed from public view because of the intense public criticism that would have resulted had the agreement been disclosed and/or the possibility that victims would have objected in court and convicted the judge not to accept the agreement. Please provide all correspondence, documents, and other information concerning the Government's and/or Epstein awareness or discussion of this possible public criticism and/or victim objections. + +7. The victims allege in their pending summary judgment motion that the Government was aware that it potentially had obligations under the CVRA to notify the victims about the nonprosecution agreement and any related state court plea agreement. Please provide all correspondence, documents, and other information regarding the Government's awareness of its potential CVRA obligations in this case and regarding any discussions between the Government and Epstein concerning these CVRA obligations in this case. This should include any objections raised by Epstein to any notification of the victims (including Jane Doe #1 and Jane Doe #2) and any Government response to these objections. This should also include any correspondence and information about whether the CVRA applied to the victims. + +8. The victims allege in their pending summary judgment motion that, after Epstein signed the non-prosecution agreement, his performance was delayed while he used his significant social and political connections to lobby the Justice Department to obtain a more favorable plea deal (including lobbying components of the Justice Department in Washington, D.C., including the Child Exploitation Obscenity Section). Please provide all correspondence, documents, and other information regarding Epstein's lobbying efforts to persuade the Government to give him a more favorable plea arrangement and/or non-prosecution agreement, including efforts by former President Bill Clinton, Andrew Albert Christian Edward (a/k/a Prince Andrew, Duke of York), Harvard Law Professor Alan Dershowitz, Ken Starr, Lillian Sanchez, Jay Lefkowitz, and Roy Black on his behalf. + +9. On January 10, 2008, Jane Doe #1 and Jane Doe #2 received letters from the FBI advising them that "this case is currently under investigation." Please provide all documents, correspondence, and other information relating to those representations being made by the FBI to Jane Doe #1 and Jane Doe #2, including all information about whether the FBI was aware of the non-prosecution agreement at that time and about whether Epstein was aware of the notifications being made to the victims. + +10. In their pending summary judgment motion, the victims have alleged that the FBI was led to believe that their investigation of Epstein was going to produce a federal criminal prosecution and that the FBI was also misled by the U.S. Attorney's office about the status of the case. Please provide all documents, correspondence, and other information relating to these allegations, including: + +- a) All documents, correspondence, and other information relating to discussions between the U.S. Attorney's Office and the FBI concerning the status of the investigation and the plea discussions with Epstein, as well as what kind of charges would appropriately be filed against Epstein; +- b) All documents, correspondence, and other information relating to the U.S. Attorney's Office's representations to the FBI and any other state or local law enforcement agency about how this case was being handled; and +- c) All documents, correspondence, and other information relating to whether the FBI would support the position of the U.S. Attorney's Office that it has not violated the rights of Epstein's victims in this case. + +11. In their pending summary judgment motion, the victims have alleged that they had various meetings with Government prosecutors and/or agents (including FBI agents). Related to these meetings, they also allege that in mid-June 2008, their attorney (Bradley J. Edwards) discussed with an AUSA involved in the case the need for filing federal charges and that the AUSA asked the attorney to send a letter about why such charges should be filed without disclosing the existence of a previously-signed non-prosecution agreement. The victims further allege that on about July 3, 2008, their attorney sent a letter urging the filing of federal charges against Epstein. Please provide all documents, correspondence, and other information regarding these meetings with the victims and their legal counsel, including meetings with the victims on October 26, 2007, and January 31, 2008, and the contact with their legal counsel in mid-June 2008. Please also provide all documents, correspondence, and other information related to contacts between the Government and the National Crime Victim's Law Institute (NCVLI) concerning possible legal representation or other assistance to the victims by NCVLI. + +12. In their pending summary judgment motion, the victims allege that in mid-June 2008, their attorney (Bradley J. Edwards) discussed with an AUSA involved in the case the need for filing federal charges and that the AUSA asked the attorney to send a letter about why such charges should be filed without disclosing the existence of the non-prosecution agreement. The victims further allege that on about July 3, 2008, their attorney sent a letter urging the filing of federal charges against Epstein. Please provide all documents, correspondence, and other information regarding these contacts, including e-mails and correspondence generated as a result of the attorney's inquiry and any action that was taken in response to the letter that he sent. + +13. In their pending summary judgment motion, the victims allege that on or about June 27, 2008, the Government learned that Epstein would be entering his plea to state charges on about June 30, 2008. Please provide all documents, correspondence, and information regarding: + +- a) How the Government Office learned that the plea was going to be entered; +- b) How the Government notified victims about the entry of the guilty plea; and +- c) The contents of the notifications given to the victims about the entry of the guilty, including whether the victims were informed about the non-prosecution agreement and about whether the entry of this plea would preclude prosecution of crimes Epstein had committed against them. + +14. In their pending summary judgment motion, the victims have alleged that the Government and Epstein worked together to keep the existence of the non-prosecution agreement secret, including declining comment about the existence of such an agreement when asked about it when his guilty plea in state court became public knowledge. Please provide all documents, correspondence, and information about the Government's and Epstein's efforts to keep the existence of the non-prosecution agreement secret, including all e-mails and correspondence about "declining comment" or similar devices to keep the non-prosecution agreement secret. + +15. In their pending summary judgment motion, the victims allege that at all materials times, it would have been practical and feasible for the Government to have kept the victims informed about the discussions concerning the non-prosecution agreement. The victims further allege that on about July 9, 2008, the U.S. Attorney's Office provided notice to Jane Doe #1 of some of the terms of the agreement between it and Jeffrey Epstein. The victims also received a "corrected" notification letter on about September 3, 2008. Please provide all documents, correspondence, and other information about these notifications, including: + +- a) any information about whether these notifications should or should not include some mention of the non-prosecution agreement; +- b) any information about the contents of these notifications; +- c) any communications between the Government and Epstein's counsel regarding what the notifications should contain, including any communication on or about July 9, 2008, objecting to parts of the draft; +- d) Any communications between the Government and Epstein's counsel about which parts of the non-prosecution agreement were operative (including whether Part 3 was operative); +- e) Any communications between the Government and Epstein's counsel regarding the September 3, 2008, corrected notification letter; and 0 any documents, correspondence, and other information regarding the practicality and feasibility of providing notice to the victims of the existence of the agreement, which shall include any correspondence related to meeting with the victims or notifying them in any way of the non-prosecution agreement. + +16. In their pending summary judgment motion, the victims allege that one of the senior prosecutors in the U.S. Attorney's Office joined Epstein's payroll shortly after important decisions were made limiting Epstein's criminal liability — and improperly represented people close to Epstein. In light of this fact, the peculiar nature of the non-prosecution agreement + +reached in this case, and other information in the possession of the victims, it is also possible that other improper relationships exist between Government agents and Epstein. Please provide any documents, correspondence, and other information regarding the possibility of any improper relationship, including: + +- a) Attorney volvement in and/or awareness of any aspect of the Governor n norm tigation and/or possible prosecution/non-prosecution of Epstein; +- b) Attorneys involvement in and/or awareness of the Government's interest in any witness, subject, or target of the Epstein investigation, including , Ghislaine Maxwell, Simbiniime, Lesley Groff, disim uella Ruboyo, Larry Morrison, Larry Visoki, David Rogers, William Hammond, and Robert Roxburgh; +- c) All documents, correspondence, and other information reflecting telephone calls (including telephone logs and telephone billing statements) made by or received by Reinhart from Jeffrey Epstein, the Florida Science Foundation, Jack Goldberger, Alan Dersowitz, Roy Black, Ken Starr, Lillian Sanchez, and any other person involved with the criminal defense of Jeffrey Epstein, including telephone calls to and from Jack Goldberger and the Florida Science Foundation; +- d) All documents, correspondence, and other information (including, for example, emails) that were sent to, copied to, or sent by Reinhart in which the word "Epstein," °KA., "Ruboyo," "Morrison," "Visoki," "Rogers," "Hammond," Roxburgh," sleet/Pa, " "Florida Science Foundation," "Starr," "Black," "Goldberger," "Jeffrey," "Australian," "Lewis," "Sanchez," "358 El Brillo Way" appears and which are connected to or related to Jeffrey Epstein, Jack Goldberger, or the Jeffrey Epstein investigation or prosecution; +- e) All documents, correspondence, and other information (including for example emails) of a similar nature that indicate that my other Government prosecutor has represented (or discussed representing) a person or entity related to Jeffrey Epstein or has received business or funds from a person or entity related to Jeffrey Epstein; +- f) All documents, correspondence, and other information that indicate or suggest that tqy Government prosecutor or investigator (including state and local prosecutor or investigator) has had any form of business, social, personal, or other relationship with Jeffrey Epstein or a person or entity related to Jeffrey Epstein; and +- g) All documents, correspondence, and other information that indicate or suggest that pfly Government prosecutor or investigator (including state and local prosecutor or investigator) would receive anything of value, directly or indirectly from Jeffrey Epstein or a person or entity related to Jeffrey Epstein (including any charitable contributions to be made by Epstein to any entity). + +17. In December 2010, the victims sent a letter to the U.S. Attorney's Office for the Southern District of Florida, requesting that the Office investigate whether "improper influences" were brought to bear during the negotiations involving the possible prosecution (and ultimately the non-prosecution) of Jeffrey Epstein. That letter led to a reference of the matter to the Office of Professional Responsibility (OPR) in the Justice Department in Washington, D.C., which began some kind of an inquiry/investigation. Please provide: + +- a) All documents, correspondence, and other information collected by the Office of Professional Responsibility (OPR) and any other component of the Justice Department (including the FBI) in response to the victims' letter; +- b) All documents, correspondence, witness statements, and other information collected as part of OPR's inquiry/investigation; +- c) All documents, correspondence, witness statements and other information collected as part of any criminal inquiry/investigation that was initiated as a result of that letter, including any inquiry/investigation into criminal conflict of interest violations (such as 18 U.S.C. § 205 and § 207) +- d) All documents, correspondence, witness statements, and other information collected by any federal investigative agency that was triggered by OPR's inquiry/investigation, including any FBI inquiry/investigation regarding any improper influences or criminal or ethical violations that may have been committed by government attorneys during the handling of the Epstein investigation and/or prosecution; +- e) Any documents, correspondence, and other information regarding the accuracy or inaccuracy of Bruce Reinhart's sworn statements (found in DE 79-1 at p. 31) that he "did not participate in any way in the Office's investigation of Epstein;" that he "was not involved in any of the Office's decisionmaking with regard to the Epstein matter;" and that he "never learned any confidential, non-public information about the Epstein matter;" +- f) Any documents, correspondence, or other information regarding the circumstances that lead OPR to send a letter to the victims on May 6, 2011, indicating that they would not provide any further assistance to the victims in connection with their allegations that improper influences were brought to bear on the Epstein case; +- g) Any document, correspondence, e-mail, memoranda, or other information prepared by OPR, the FBI, or other Justice Department Component as a result of or following up on the victims' December 2010 letter concerning the Epstein case; and +- h) Any documents, correspondence, or other information that OPR has collected or obtained regarding the Epstein investigation and/or prosecution. + +18. At a couple points during the prosecution of this action, including in approximately December 2010 and most recently after the August 2011 hearing, the Justice Department in Washington, D.C., discussed or determined that the U.S. Attorney's Office for the Southern District of Florida (USAO SDFL) was "conflicted out", or may be conflicted out, of handling various issues related to the Epstein case because it suffered from a conflict of interest. The Justice Department accordingly sent various issues related to the Epstein case (and, on information and belief, issues related to Jane Doe #1 and Jane Doe #2) to the Department of Justice and to a United States Attorney's Office in another District. Please provide all documents, correspondence, and other information regarding the potential conflicts of interest that the Justice Department discussed or determined existed for the USAO SDFL, as well as any referral that was made to Main Justice or to any other District, including any documents that + +were transmitted to any other District regarding the conflict and regarding what was to be investigated. + +19. In March 2011, former U.S. Attorney Alexander Acosta sent a three-page letter to the news media in which he claimed that when Government attorneys began investigating Epstein, Epstein launched "a yearlong assault on the prosecution and the prosecutors." Shortly thereafter, Jeffrey Epstein's defense attorney Roy Black sent a responsive letter to Alexander Acost's letter to the news media in which he claimed that he did not pry into the personal lives of prosecutors but merely pointed out misconduct and over-reaching by certain people involved in the Epstein investigation. Please provide all documents, correspondence and other information that supports or contradicts Acosta's allegations in his letter, including any information that the Justice Department received from Epstein attacking the prosecutors and investigators working on the case. Please also provides all documents, correspondence, information about misconduct and over-reaching that was provided by Black and that the Government found that supported or contradicted such allegations. + +20. In their pending summary judgment motion, the victims have alleged that Epstein's guilty plea to state charges was intended to be the consummation of a non-prosecution agreement that barred prosecution of federal offenses committed against them. They have further alleged that Epstein entered such a guilty plea on or about June 30, 2008. Please provide all documents, correspondence, and other information between the Government and state and local prosecutors and police agencies (including The Palm Beach Police Department and Palm Beach State Attorney's Office) regarding the Epstein investigation and ultimate Epstein plea. + +21. In their pending summary judgment motion, the victims have alleged that correspondence in the possession of the Government will support their claims. Please provide all documents, correspondence, and other information between Government attorneys/officials (including both federal and state prosecutors) and attorneys for Jeffrey Epstein (or non-attorney acting on Epstein's behalf) relating to (I) negotiations involving the possible prosecution (and ultimately the non-prosecution) by federal or state agencies for sex offenses, including sex offenses committed against Jane Doe #1 and Jane Doe #2, (2) Epstein's entry of state guilty pleas for related sex offenses; (3) a non-prosecution agreement entered into between Epstein and the Government that barred his prosecution for offenses committed against Jane Doe #1 and Jane Doe #2; (4) the fulfillment of Epstein's and/or the Government's obligations under the nonprosecution agreement and/or the state guilty pleas Epstein entered; (5) any work release or other conditional release of Epstein from confinement; (6) any designation of Epstein as a sex offender or restrictions on him contacting victims of his offenses (including Jane Doe #1 and Jane Doe #2); and (7) any termination of supervision or parole of Epstein. This information should include unredacted e-mails, letters, and correspondence of any type between government prosecutors working on the case (including, but not limited to, federal prosecutors Alexander Acosta, Jeffrey H. Sloman, Matt Menchel, Andy Lourie, Ann Marie Villafana, Dexter Lee, and Bruce Reinhart and state prosecutors Dahlia Weiss, Lana Belolovek, and others involved in the Epstein investigation) and defense attorneys representing Epstein (including, but not limited to, Roy Black, Jay Lefkowitz, Jack Goldberger, Martin Weinberg, Gerald Lefcourt, Michael Tien, Guy Lewis, Lilly Ann Sanchez, Ken Starr, Alan Dershowitz) and agents acting in support of Epstein (including, but not limited to former President Bill Clinton and Andrew Albert Christian Edward + +(a/k/a Prince Andrew, Duke of York). This should also include letters of recommendation or similar communications submitted to any Government official vouching for or providing support for Jeffrey Epstein. + +22. As you know, throughout their pending summary judgment motion, the victims have alleged that they were not properly notified of plea negotiations with Jeffrey Epstein and were denied their right to confer by the Government and that instead the Government gave Epstein generous concessions through the plea negotiations. Please provide any documents, correspondence and other information that reflects or discusses any consideration of any type that Epstein had previously provided or offered to provide to the Government (or any individual within the Government, in either his official or private capacity) or any person previously employed by the Government and involved in the Epstein investigation or prosecution. The documents, correspondence, and other information should include any information discussing: + +- (a) Any donation or offer to donate, directly or indirectly, either funds, services, or any other valuable consideration to any person or entity; +- (b) Any offer to assist, directly or indirectly, any person to obtain employment, business opportunities, business clients, real estate, office properties; +- (c) Any offer to assist the Government or law enforcement agencies in the investigation or prosecution of any federal or state criminal offense; +- (d) Any consideration that Epstein had provided to Government or law enforcement agencies in the past; and +- (e) Any other consideration of any type that Epstein offered to provide or had provided in the past that could provide a basis for the Government extending Epstein a more generous or lenient plea bargain or non-prosecution agreement than would be received by any other similarly situated child abuse suspect. + +23. The Crime Victims' Rights Act, 18 U.S.C. § 3771(c)(1), requires the Government to use its "best efforts" to protect the rights of crime victims. Please provide all documents, correspondence, and other information that will assist Jane Doe #1 and Jane Doe #2 in protecting their rights under the CVRA, including all documents, correspondence, and other information that the Government previously identified as being helpful to the victims but refused to provide based on its legal interpretation (now rejected by the Court) that the CVRA did not apply to this case because no indictment was filed. + +24. In the course of its investigation of Epstein and negotiations with Epstein, the Government (i.e., federal investigators and prosecutors) shared documents, correspondence, and information with other persons outside the federal government, including state and local prosecuting and law enforcement agencies, prosecuting and law enforcement agencies in other countries, Epstein's legal counsel, legal counsel for crime victims, and other entities. Please provide all documents, correspondence, and other information that the Government shared with any entity or person outside the federal government, including all correspondence (including emails) with those entities or persons. + +25. After the victims had made extensive efforts to try and reach a stipulated set of facts in this case, in March 2011 the Government refused to negotiate about such facts. Accordingly, at that time the victims filed various motions to obtain evidence in this case and, at the same time, the victims voluntarily made all initial disclosures on their part that are required by Federal Rule of Civil Procedure 26(a)(1). Please provide all initial disclosures required by the Federal Rules of Civil Procedure, including all disclosures required by Rule 26(a)(1). + +# DEFINITIONS + +For the purpose of construing the foregoing discvery requests, the following terms are defined: + +The term "documents" means and includes, without limitation, all writings of any kind, including the originals and all non-identical copies or drafts, whether different from the original by reason of any notation made on such copy or draft or otherwise including, without limitation, correspondence, memoranda, notes, diaries, statistics, letters, e-mails, electronic computer files, telegrams, minutes, contracts, reports, studies, checks, statements, receipts, returns, summaries, pamphlets, books, prospectuses, interoffice communications, offers, notations of any sort of conversation, telephone calls, meetings or other communications, bulletins, printed matter, computer print-outs, teletypes, facsimiles, invoices, work sheets and all drafts, alterations, modifications, changes, and amendments of any of the foregoing, graphic or aural writs, records or representations of any kind including, without limitation, photographs, charts, graphs, microfiche, microfilm, videotape, recordings, motion pictures; and electronic, mechanical or electric records or representations of any kind including, without limitation, tapes, cassettes and disc recordings, and writings and printed material of every kind. + +The term "correspondence" means any tangible object that conveys information or memorializes information that was conveyed in tangible or oral form including, but not limited to, writings, letters, memoranda, reports, notes, e-mails, telephone logs, telephone billing information, telephone recordings, and interoffice communications. + +The term "Epstein's victims" means any person that the Government identified as a possible victim of a sex offense committed by Jeffrey Epstein, including Jane Doe #1, Jane Doe #2, all victims identified in attachment to the non-prosecution agreement entered into by Epstein, and another person that the Government investigated as a possible victim of Epstein's sex offenses. + +The term "Government" means the federal government, including all employees of and components of the United States Department of Justice (such as, the Office of the Attorney General, the Office of the Deputy Attorney General, the Criminal Divisions, the Office of Professional Responsibility, the Child Exploitation and Obscenity Section, the U.S. Attorney's Offices for the Southern District and Middle District of Florida, and the Federal Bureau of Investigation) and other federal government agencies with law enforcement responsibilities related to the Epstein case (such as the Internal Revenue Service). This request for production seeks all documents, correspondence, and other information held by all of these entities, including all employees of and components of the Justice Department that worked on or were in any way involved the Epstein investigation and/or that possess information relevant to the victims' claims. + +The term "including" means containing within the request, but not limiting the request. + +The term "witness statement" means any document or other recording in any form (including oral form) reflecting, recording, or otherwise memorializing a statement made or information conveyed by a potential witness, including for example FBI 302's. The term includes information collected by any law enforcement, prosecuting or government agency, including all federal, state, and local law enforcement agencies located in Washington, D.C., or Florida. + +#### NO GRAND JURY TRANSCRIPTS SOUGHT + +If any of the foregoing requests cover grand jury transcripts, do not provide the grand jury transcript. If any of the foregoing requests include documents that quote directly from a grand jury transcript, please redact that particular quotation. + +## PRIVILEGE LOG + +If you believe that any document, correspondence, or other information requested in this request is subject to a privilege and if you intend to assert that privilege, please provide a "privilege log" consistent with Local Rule 26.1(g), including a description a document that is consistent with Local Rule 26.1(g)(3)(B). Your privilege log should include the type of document, general subject matter of the document, date of the document, and author and addressee of the document or correspondence. + +### REDUCING UNDUE BURDEN + +If you believe that complying with any of the foregoing requests would be unduly burdensome, please contact victims counsel — Bradley J. Edwards — to discuss ways to reduce any such burden. + +DATED: October 3. 2011 + +Respectfully Submitted, + +s/ Bradley J. Edwards + +Bradley J. Edwards FARMER, JAFFE, WEISSING, + +![](_page_11_Picture_13.jpeg) + +*and* + +Paul G. Cassell +*Pro Hac Vice* + +SLOAN COLLEGE ST. LOUIS + +![](_page_12_Picture_87.jpeg) + +Attorneys for Jane Doe #1 and Jane Doe #2 + +### CERTIFICATE OF SERVICE + +The foregoing document was served on October 3, 2011, on the following via US Mail and E-Mail Transmission: + +Douter Lee + +A + +A + +5 + +V + +( + +F + +E + +E + +A + +Roy Black, Esq. +Jackie Perczek, Esq. + +![](_page_12_Picture_102.jpeg) + +Respectfully Submitted, + +*S/ Bradley J. Edwards* + +Bradley J. 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offices, are we? + +From: (USAFLS) + +Sent: Frida October 21, 2011 2:23 PM + +To: (USAFLS • (USAFLM 9\_ + +Cc: (USAFLS); (FBI); (FBI); (FBI); (FBI) + +Subject: RE: FORMAL NOTICE of Office-wide Recusal of Southern District of Florida (GCO File No. REC-11-4159) + +Hi everyone — I am back from court. Sony about that. MI I hope that your trial went well. + +On Monday, we will be meetin at the FBI Office in West Palm Beach with Supervisory Special Agent and case agents and Former case agent be available. also will + +The address for the FBI is telephone number is The office + +. There is plenty of parking. + +You said that you would arrive at 9:30, is that right? The agents and I need to get all of my boxes over to the FBI before you arrive, so I just need to reconfirm your arrival time. + +Assistant U.S. Attorne + +Fax + +(USAFLS) + +October 21, 2011 2:09 PM + +(USAFLM); . (USAFLS) + +(USAFLS) + +Subject: RE: FORMAL NOTICE of Office-wide Recusal of Southern District of Florida (GCO File No. REC-11-4159) + +I believe that you and will be meeting at the FBI's offices in West Palm Beach with the FBI agents who have been working on the matter so that they can all fill you in on the history and facts of the criminal investigation. Assuming that it fits within your travel timetable, I was also planning to drive up from Miami to + +meet with you and in the early afternoon to discuss how our office's continued handling of the Crime Victims' Rights Act litigation brought by two of Epstein's victims impacts upon the criminal investigation and vice versa. (Unfortunately, who has long been handling the CVRA litigation along with , and who is also our district's Ethics Officer and one of our Professional Responsibility Officers, will not be able to participate.) Will that plan work for you? + +Can you provide and me with directions to the location of the meeting in West Palm Beach? + +Thanks, + +From: (USAFLM) Sent: Frida October 21, 2011 1:55 PM To: (USAFLS) Subject: RE: FORMAL NOTICE of Office-wide Recusal of Southern District of Florida (GCO File No. REC-11-4159) + +Can you direct someone to give me directions for our meeting, and please let me know who all will be there. Thanks, + +From: (USAFLS) Sent: Frida October 21, 2011 11:44 AM To: (USAEO) Cc: USAFLS (USAFLS); (USAFLS); (USAFLS); (USAFLM) Subject: RE: FORMAL NOTICE of Office-wide Recusal of Southern District of Florida (GCO File No. REC-11-4159) + +I neglected to tell you in my previous email that we are scheduled to meet on Monday with AUSA of the MDFL, who has been assigned to the Epstein criminal matter by the MDFL, in furtherance of the transfer of the criminal matter to the MDFL. + +From: (USAFLS) Sent: Frida October 21, 2011 11:35 AM To: (USAEO) Cc: (USAFLS); (USAFLS); (USAFLS); (USAFLS) Subject: RE: FORMAL NOTICE of Office-wide Recusal of Southern District of Florida (GCO File No. REC-11-4159) + +In transferring the criminal matter involving Jeffrey Epstein to the MDFL, while retaining responsibility for the related CVRA litigation, our district has encountered a potential problem. The district court has ordered discovery in the CVRA litigation, and the Petitioners have served us with a discovery request. See attached files. The underlying criminal case file is thus pertinent to both the CVRA litigation handled by the SDFL and the criminal investigation that has been transferred to the MDFL. USAP 3-2.170.001, the pertinent USAP, does not appear to contemplate this bifurcated need for the criminal case file: + +Once the recusal has been approved and the matter or case assigned to either a new USAO or the Criminal or Civil Division, the United States Attorney of the recused USAO should take steps to ensure that the matter is closed and management, supervisory and reporting responsibilities, and all case files for the particular matter or case are transferred to the new USAO or the Criminal or Civil Division . This includes all administrative, ministerial, and financial litigation actions normally completed by the recused USAO, including input into LIONS and TALON. Thereafter, the recused USAO can only provide limited administrative support to the new USAO or the Criminal or Civil Division, such as furnishing copies of local rules, advising of local practice, assisting with scheduling, providing time before the grand jury, providing local information for grand jury and victim/ witness support services, or providing facilities for depositions. The recused USAO, however, should not make any decisions or take any substantive actions in the matter or case. The intent of this section is to make clear that once recusal of the matter or case has been approved by the ADAG and the matter or case has been transferred to a new USAO or the Criminal or Civil Division, the matter or case no longer belongs in any sense to the recused USAO. + +When a new USAO assumes responsibility for the recused case, it should process the case from the investigatory stage through and including any post-judgment actions, including any appellate work or actions required by the Financial Litigation Unit (FLU). The Special Attorney assigned the matter or case should sign any pleadings or documents using the signature block of the newly assigned USAO, with the addition of the Attorney General's name preceding that of the United States Attorney. Any administrative or ministerial support and any decisions should be provided by the Special Attorney's USAO and supervisory chain. In the event that the Special Attorney has substantive questions that the recused USAO is precluded from answering, the Special Attorney should contact EOUSA GCO for consultation and advice. + +When the Criminal Division or other litigating component assumes responsibility for the recused case, it should process the case from the investigatory stage through and including any judgment actions. When any post-judgment actions normally conducted by a USAO FLU become necessary, and the Criminal Division or other litigating component is unable to handle such actions, the Trial Attorney handling the matter should contact EOUSA GCO, which will assist the component in obtaining a USAO FLU section to conduct the post-judgment FLU actions. + +USAP 3-2.170.001(6)(C)(2)(b)(3). + +Can EOUSA provide any guidance on how we are expected to handle the transfer of the case file under these circumstances? Although we will be seeking to dismiss the CVRA proceedings and will seek relief from the discovery that was ordered, the district court is unlikely to look kindly upon a government position that we cannot respond to discovery because we transferred the case file to the MDFL after our office was recused from the criminal matter involving Jeffrey Epstein. And the criminal case file will clearly be needed to respond to the contemplated discovery in the CVRA litigation. + +Thanks for your help, + +From: (USAFLS) Sent: Monda Au ust 29, 2011 2:00 PM To: . (USAFLS); (USAFLS) Subject: Fw: FORMAL NOTICE of Office-wide Recusal of Southern District of Florida (GCO File No. REC-11-4159) + +Re: the Epstein question. + +From: (USAEO) Sent: Monday, August 29, 2011 01:57 PM To: (USAFLS) Subject: RE: FORMAL NOTICE of Office-wide Recusal of Southern District of Florida (GCO File No. REC-11-4159) + +Hello M=, + +Yes, that is correct. The investigations concerning Epstein, personally, are the matters your office is recused. + +The CVRA matters, while stemming from matters involving Epstein, are matters brought be other individuals and those matters may remain with your office. + +Please let me know if you would like to further discuss or if you have any questions, + +Thank you, + +General Counsel's Office + +Executive Office for United States Attorneys + +Phone: - New Phone Number + +Fax: - New Fax Number + +Email: + +From: (USAFLS) Sent: Monda Au ust 29, 2011 12:26 PM To: (USAEO) Subject: RE: FORMAL NOTICE of Office-wide Recusal of Southern District of Florida (GCO File No. REC-11-4159) + +I hope the storms and Irene haven't affected you too badly. I wanted to make sure I am correct that this recusal from any new criminal investigation into Epstein does not affect SDFL's handling of the CVRA civil case pending before Judge Marra. I believe that had discussed the potential for recusal in the CVRA matter with GC a while back and I am fairly certain that I discussed this with Jay earlier this year at the NAC. In both instances, the resolution was that our Office could and should handle the CVRA matter. I wanted to make sure that is still the case. Thanks + +(USAEO) + +August 24, 2011 3:32 PM + +(USAFLS); (USAFLM)a (USAFLSa(USAFLM) + +(ODAG) ()MD); (USAEO); (USAEO); (USAEO); (USAEO) + +Subject: FORMAL NOTICE of Office-wide Recusal of Southern District of Florida (GCO File No. REC-11-4159) + +## MEMORANDUM FOR: + +Wifredo A. Ferrer + +United States Attorney + +Southern District of Florida + +First Assistant United States Attorney + +Southern District of Florida + +Robert E. O'Neill + +United States Attorney + +Middle District of Florida + +First Assistance United States Attorney + +Middle District of Florida + +## THROUGH: + +General Counsel + +Executive Office for United States Attorneys + +FROM: + +THIS IS FORMAL NOTICE that David =I Associate Deputy Attorney General (ADAG), approved the office-wide recusal of the United States Attorney's Office for the Southern District of Florida (SDFL) from all matters, to include the investigation and potential prosecution, relating to Jeffrey Epstein's alleged sexual activities with minor females. The ADAG authorized this recusal in accordance with United States Attorney's Manual (USAM) 3-2.170 and United States Attorney's Procedures (USAP) 3-2.170.001 based upon existing conflicts of interest or the appearance of conflicts of interest pertaining to the matter. + +ADAG has assigned this matter to the United States Attorney's Office for the Middle District of Florida and, pursuant to 28 U.S.C.' 515(a), has directed and authorized United States Attorney Robert E. O'Neill to conduct any kind of legal proceeding, civil or criminal, including grand jury proceedings and proceedings before committing magistrate judges, which the United States Attorney for the Southern District of Florida is authorized by law to conduct regarding this matter. See USAP 3-2.170.001(6).(C)(2)(b). + +Each office should communicate directly with each other concerning the investigations related to this matter in accordance with the procedures outlined in USAP 3-2.170.001(6)(w)pm% The oint of contact for the Middle District of Florida is Criminal Chief who can be contacted at . The oint of contact for the Southern District of Florida is First Assistant United States Attorney who can be reached at + +All Assistant United States Attorneys subsequently assigned to this matter must be appointed as Special Attorneys in order to appear on behalf of the government in the Southern District of Florida. See USAM, 2.300 and USAP 3-2.170.001(6 C 2 b . Please contact , EOUSA Personnel Staff, Policy and Special Programs Division, at to obtain the appointments. + +In accordance with USAP 3-2.170.001(6).(cX2)(b)(3), any Special Attorney assigned the matter or case should sign any pleadings or documents using the signature block of the Middle District of Florida, with the addition of the Attorney General's name preceding that of the United States Attorney. + +If any questions relating to this recusal matter, lease contact General Counsel's Office, EOUSA, at . 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United States of America Notice (Other) + +Date: Mon, 17 Oct 2011 01:51:45 +0000 + +Importance: Normal + +**This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended.** + +**\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\*** Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +**Notice of Electronic Filing** + +The following transaction was entered by Perczek, Jacqueline on 10/16/2011 at 9:51 PM EDT and filed on 10/16/2011 + +Case Name: Doe [REDACTED] United States of America + +Case Number: [9:08-cv-80736-KAM](#) + +Filer: Jeffrey Epstein + +Document Number: [112](#) + +**Docket Text:** + +**NOTICE by Jeffrey Epstein re [109] MOTION for Leave to File Excess Pages in *Omnibus Reply In Support of Motion For Limited Intervention Notice of No Objection From Government* (Perczek, Jacqueline)** + +**9:08-cv-80736-KAM Notice has been electronically mailed to:** + +[REDACTED] + +Bradley James Edwards + +Bruce Reinhart ed + +Dexter Lee dexter.lee@ + +Jacqueline Perczek pleas + +Jay C. Howell + +Jay P. Lefkowitz + +Martin G. Weinb + +[REDACTED] + +Roy Eric Black + +9:08-cv-80736-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +The following document(s) are associated with this transaction: + +Document description:Main Document + +Original filenamem/a + +Electronic document Stamp: + +[STAMP dcecfStamp\_11 1105629215 [Date=10/16/2011] [FileNumber=9348726- 0] [60088e67O18d244cc087c69c80cb0f1d79f3416981be103c9d254978d402309e5 2c4bd72684e6778ded2327188d33ae9a7164967abfc6bab6840382d114c3c5]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00205936/EFTA00205936.metadata.json b/marker2/ds9/EFTA00205936/EFTA00205936.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b07248d6b910f9742bb02245cac06ac5c1af2fb9 --- /dev/null +++ b/marker2/ds9/EFTA00205936/EFTA00205936.metadata.json @@ -0,0 +1,135 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205936.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": 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Friday, July 22, 2011 4:40:50 PM (UTC-05:00) Eastern Time (US & Canada) + +was read on Friday, July 22, 2011 5:43:23 PM (UTC-05:00) Eastern Time (US & Canada). \ No newline at end of file diff --git a/marker2/ds9/EFTA00205939/EFTA00205939.metadata.json b/marker2/ds9/EFTA00205939/EFTA00205939.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..548d0e0dd0898d6d80f71778d65ca99b8fbc266b --- /dev/null +++ b/marker2/ds9/EFTA00205939/EFTA00205939.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205939.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 326, + "elapsed_seconds": 0.48, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + 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I will review the email and we can discuss tomorrow. + +--- Original Message --- + +From: + +Sent: Wednesday, July 20, 2011 05:15 PM + +Cc. A , , , ttlfhielifrSt ElrombeirBemjewpS(4404149III) + +Subject: FW: E-mail questions from Newsweek. + +Hi Alicia -- Here is the email from Newsweek. Please respond as the Office sees fit. + +Assistant U.S. Attorney 561-209-1047 + +-----Original Message---- + +From: Barrett, Wayne (mailto:Wayne.Barrett@newsweekdailybeast.com) + +Sent: Wednesday, July 20, 2011 4:58 PM + +To: + +Subject: + +Hi 1Phrlititheltt + +This is Jacob Albert, research assistant for Wayne Barrett, at Newsweek. I know you've said that you wouldn't comment on our questions, but I wanted to give you the chance to hear what we're asking before declining. If you'd rather speak by phone, on or off record, I'm + +1) The nonprosecution deal that you worked out specified that Epstein would do 30 months in jail? What's your understanding of why he did only 13 of the 18mo of his jail sentence, and why was he excused from the carrying out the remainder of his sentence? Who approved the sentence reduction, at state or federal level, and why? + +2) Do you have any knowledge of how Jeffrey Epstein was able to preserve personal and corporate tax benefits/exemption in the Virgin Islands, in 2009, which requires residency (183 days) that Epstein was unable to meet, as he was under house arrest during that period? Do you know whether VI residency requirements for tax benefits/exemptions are waived if you're in prison or under house arrest in another state? + +If you still have no comment, please let me know; the article running in Newsweek will state that your office wouldn't comment. + +Thanks, + +Jacob Albert + +Research Assitant for Wayne Barrett \ No newline at end of file diff --git a/marker2/ds9/EFTA00205940/EFTA00205940.metadata.json b/marker2/ds9/EFTA00205940/EFTA00205940.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e0ab29a56b196b4d589f134765c1f06578f18f45 --- /dev/null +++ b/marker2/ds9/EFTA00205940/EFTA00205940.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205940.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1846, + "elapsed_seconds": 1.2, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 69 + ], + [ + "Line", + 35 + ], + [ + "Text", + 29 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205940" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205941/EFTA00205941.md b/marker2/ds9/EFTA00205941/EFTA00205941.md new file mode 100644 index 0000000000000000000000000000000000000000..bde2024105aaf515dd422fe368a20b18c0af6fa7 --- /dev/null +++ b/marker2/ds9/EFTA00205941/EFTA00205941.md @@ -0,0 +1,25 @@ +Subject: FW: E-mail questions from Newsweek. + +Date: Wed, 20 Jul 2011 21:15:05 +0000 + +Importance: Normal + +Here is the email from Newsweek. Please respond as the Office sees fit. + +----Original Message--- + +From: Barrett, Wayne imailto:Wayne.Barrett@newsweekdailybeast.com) + +This is Jacob Albert, research assistant for Wayne Barrett, at Newsweek. I know you've said that you wouldn't comment on our questions, but I wanted to give you the chance to hear what we're asking before declining. If you'd rather speak by phone, on or off record, I'm + +1) The nonprosecution deal that you worked out specified that Epstein would do 30 months in jail? What's your understanding of why he did only 13 of the 18mo of his jail sentence, and why was he excused from the carrying out the remainder of his sentence? Who approved the sentence reduction, at state or federal level, and why? + +2) Do you have any knowledge of how Jeffrey Epstein was able to preserve personal and corporate tax benefits/exemption in the Virgin Islands, in 2009, which requires residency (183 days) that Epstein was unable to meet, as he was under house arrest during that period? Do you know whether VI residency requirements for tax benefits/exemptions are waived if you're in prison or under house arrest in another state? + +If you still have no comment, please let me know; the article running in Newsweek will state that your office wouldn't comment. + +Thanks, + +Jacob Albert + +Research Assitant for Wayne Barrett \ No newline at end of file diff --git a/marker2/ds9/EFTA00205941/EFTA00205941.metadata.json b/marker2/ds9/EFTA00205941/EFTA00205941.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..7de8c6908c80fe2046e6dc3009304d57252519fa --- /dev/null +++ b/marker2/ds9/EFTA00205941/EFTA00205941.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205941.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1474, + "elapsed_seconds": 0.74, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 39 + ], + [ + "Line", + 20 + ], + [ + "Text", + 15 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205941" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205942/EFTA00205942.md b/marker2/ds9/EFTA00205942/EFTA00205942.md new file mode 100644 index 0000000000000000000000000000000000000000..63f09c4e9a55c7cfe973439145c9bf9a90387519 --- /dev/null +++ b/marker2/ds9/EFTA00205942/EFTA00205942.md @@ -0,0 +1,15 @@ +Subject: Emailing: 20110721 Ltr to Black.wpd + +Date: Thu, 21 Jul 2011 18:05:07 +0000 + +Importance: Normal + +Attachments: 20110721 Ltr to\_Black.wpd + +«20110721 Ltr to Black.wpd>> Hi revised version. Any further thoughts before I send? recommended removing the reference to the Privacy Act. Here is the + +The message is ready to be sent with the following file or link attachments: + +20110721 atr to Black.wpd + +Note: To protect against computer viruses, e-mail programs may prevent sending or receiving certain types of file attachments. Check your e-mail security settings to determine how attachments are handled. \ No newline at end of file diff --git a/marker2/ds9/EFTA00205942/EFTA00205942.metadata.json b/marker2/ds9/EFTA00205942/EFTA00205942.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..05f08ef01741bcf38ab3b4bda402b1ec8810d72e --- /dev/null +++ b/marker2/ds9/EFTA00205942/EFTA00205942.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205942.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 608, + "elapsed_seconds": 0.69, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 24 + ], + [ + "Line", + 12 + ], + [ + "Text", + 8 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205942" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205943/EFTA00205943.md b/marker2/ds9/EFTA00205943/EFTA00205943.md new file mode 100644 index 0000000000000000000000000000000000000000..c2fb8f43c459c495526bd87abf374ac80093722e --- /dev/null +++ b/marker2/ds9/EFTA00205943/EFTA00205943.md @@ -0,0 +1,19 @@ +![](_page_0_Picture_1.jpeg) + +![](_page_0_Picture_2.jpeg) + +## DELIVERY BY ELECTRONIC MAIL + +Roy Black, Esq. Black Srebnick Komspan & Stumpf P.A. 201 S. Biscayne Blvd, Suite 1300 Miami, FL 33131 + +Re: Jeffrey Epstein + +Dear Mr. Black: + +On July 17, 2011, the Office received a written request from the District Attorney of the County of New York for a copy of the signed Non-Prosecution Agreement and the list of identified victims that was provided to Mr. Epstein pursuant to the Non-Prosecution Agreement. Pursuant to the District Attorney's request, the U.S. Attorney's Office intends to disclose these items to Assistant District Attorney, at 5:00 p.m. on Friday, July 22, 2011. Pursuant to the terms of the Non-Prosecution Agreement, the Office is hereby giving you notice of this intended disclosure. + +Sincerely, Wifredo A. Ferrer United States Attorney + +![](_page_0_Picture_9.jpeg) + +cc \ No newline at end of file diff --git a/marker2/ds9/EFTA00205943/EFTA00205943.metadata.json b/marker2/ds9/EFTA00205943/EFTA00205943.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..8a2cf2927c54e85d9d5f5c0f76e8762bcb711a55 --- /dev/null +++ b/marker2/ds9/EFTA00205943/EFTA00205943.metadata.json @@ -0,0 +1,94 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205943.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 886, + "elapsed_seconds": 0.6, + "image_assets": [ + "_page_0_Picture_1.jpeg", + "_page_0_Picture_2.jpeg", + "_page_0_Picture_9.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "DELIVERY BY ELECTRONIC MAIL", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 31.212, + 140.94 + ], + [ + 225.87718200683594, + 140.94 + ], + [ + 225.87718200683594, + 155.103515625 + ], + [ + 31.212, + 155.103515625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 42 + ], + [ + "Line", + 21 + ], + [ + "Text", + 6 + ], + [ + "Picture", + 3 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205943" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205943/_page_0_Picture_1.jpeg b/marker2/ds9/EFTA00205943/_page_0_Picture_1.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..d3fe459aef007d89f8d8238280ffaf9830a32752 --- /dev/null +++ b/marker2/ds9/EFTA00205943/_page_0_Picture_1.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:91d4bdf230c56c5390c7faaa9b74d085e438fd0aa71f7862d73cf4a2090f731a +size 3243 diff --git a/marker2/ds9/EFTA00205943/_page_0_Picture_2.jpeg b/marker2/ds9/EFTA00205943/_page_0_Picture_2.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..3679cc298f27f87be2814e9fcb94d4e41cf06984 --- /dev/null +++ b/marker2/ds9/EFTA00205943/_page_0_Picture_2.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:2e0158ecac479c566bf015fa0c7ea8d1cf727f80686cdc2b6143ad536f901bb0 +size 5265 diff --git a/marker2/ds9/EFTA00205943/_page_0_Picture_9.jpeg b/marker2/ds9/EFTA00205943/_page_0_Picture_9.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..47ac9c94c3cbcc2877fc987e83bebd3dbcb7e2c6 --- /dev/null +++ b/marker2/ds9/EFTA00205943/_page_0_Picture_9.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:8a66e24e1cd71a09bab02fee92c6c2554dd96290af0e492cb1c420a62326d216 +size 8868 diff --git a/marker2/ds9/EFTA00205944/EFTA00205944.md b/marker2/ds9/EFTA00205944/EFTA00205944.md new file mode 100644 index 0000000000000000000000000000000000000000..3ba19e819b17f1f401cdb39e4306d7758a09cc10 --- /dev/null +++ b/marker2/ds9/EFTA00205944/EFTA00205944.md @@ -0,0 +1,19 @@ +To: Roy BLACK + +Subject: Jeffrey Epstein + +Date: Wed, 27 Jul 2011 20:16:04 +0000 + +Importance: Normal + +Attachments: 20110728060949.pdf + +Dear Mr. Black: + +Attached please find a response to Mr. Weinberg's letter. 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Weinberg, Esq. 20 Park Plaza, Suite 1000 Boston, MA 02116 + +Re: Jeffrey Epstein + +Dear Mr. Weinberg: + +Thank you for your letter of July 22, 2011. In order to review and address the objections that you raised in that letter, the Office deferred making its planned disclosure to the District Attorney of the County of New York of the Non-Prosecution Agreement ("Agreement") and the list of identified victims that was provided to Mr. Epstein pursuant to the Agreement. Nonetheless, after completing a full review of your objections, the Office still intends to proceed with the planned disclosures. + +The Agreement requires the Office only to provide Mr. Epstein with notice prior to a disclosure of the Agreement "[i]f the United States receives a Freedom of Information Act request or any compulsory process"; the Agreement does not require Mr. Epstein's concurrence in any disclosure. Contrary to your suggestion, the Agreement (including paragraph 13) also does not make the Agreement itself "confidential." On the contrary, the Agreement expressly contemplates that disclosures of the Agreement may be made, and the Agreement further contemplates, contrary to your suggestion, that such disclosures of the Agreement may be made other than in response to "compulsory process." Here, moreover, the District Attorney of the County of New York, as a local law enforcement agency, has provided a legitimate request for disclosure of the requested information, as well as a promise to maintain the confidentiality of the information, particularly the names of the minor victims. + +Your objection pursuant to Federal Rule of Criminal Procedure 6(e) also does not impact the planned disclosures. The victim list itself is not grand jury material, and, thus, disclosure of that list to the District Attorney's Office will not violate Rule 6(e). + +If you wish to supply any additional authority (other than citation to Rule 6(e) and to paragraph 13 of the Agreement) for your claims that the Office cannot disclose the Agreement and + +MARTIN WEINBERG, ESQ. +JULY 27, 2011 +PAGE 2 OF 2 + +the victim list to the District Attorney of the County of New York, we would be willing to consider those authorities before making any disclosure, provided that any such authorities are furnished to us before 5:00 p.m. on July 29, 2011. Otherwise, seeing no obstacle to the previously-planned disclosures, the Office will be disclosing copies of both the Non-Prosecution Agreement and the list of identified victims that was provided to Mr. Epstein to the District Attorney of the County of New York at 5:00 p.m. on July 29, 2011. + +Sincerely, + +Wifredo A. Ferrer +United States Attorney + +![](_page_1_Picture_48.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00205945/EFTA00205945.metadata.json b/marker2/ds9/EFTA00205945/EFTA00205945.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..fddc52e3fec2269a6ae226ae1da683de33bc7aaa --- /dev/null +++ b/marker2/ds9/EFTA00205945/EFTA00205945.metadata.json @@ -0,0 +1,147 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205945.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2839, + "elapsed_seconds": 3.15, + "image_assets": [ + "_page_0_Picture_0.jpeg", + "_page_0_Picture_3.jpeg", + "_page_1_Picture_48.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "U.S. Department of Justice", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 165.24, + 49.41 + ], + [ + 308.7931213378906, + 49.41 + ], + [ + 308.7931213378906, + 64.60748291015625 + ], + [ + 165.24, + 64.60748291015625 + ] + ] + }, + { + "title": "DELIVERY BY FACSIMILE", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 73.44, + 230.84999999999997 + ], + [ + 223.78854370117188, + 230.84999999999997 + ], + [ + 223.78854370117188, + 246.86749267578125 + ], + [ + 73.44, + 246.86749267578125 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 63 + ], + [ + "Line", + 32 + ], + [ + "Text", + 8 + ], + [ + "Picture", + 2 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 26 + ], + [ + "Line", + 12 + ], + [ + "Text", + 9 + ], + [ + "PageFooter", + 2 + ], + [ + "Picture", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205945" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205945/_page_0_Picture_0.jpeg b/marker2/ds9/EFTA00205945/_page_0_Picture_0.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..3c57f26e999afcec0822a709f24a56f8905aa377 --- /dev/null +++ b/marker2/ds9/EFTA00205945/_page_0_Picture_0.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:ff99468b1ea1f32bd3cf373dd016d192a32e4af640d09f286f0f593b88036bcc +size 11705 diff --git a/marker2/ds9/EFTA00205945/_page_0_Picture_3.jpeg b/marker2/ds9/EFTA00205945/_page_0_Picture_3.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..443fb9f94a44e81dab3e85cb8cdf41bc40fbf31b --- /dev/null +++ b/marker2/ds9/EFTA00205945/_page_0_Picture_3.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:0d5f4dd0ecef21d193bd5065c130fc89abd2c28c510d55042ef373bbf8aa5af5 +size 8967 diff --git a/marker2/ds9/EFTA00205945/_page_1_Picture_48.jpeg b/marker2/ds9/EFTA00205945/_page_1_Picture_48.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..979f83a160371e00332648db7722b4f47e2ffaf6 --- /dev/null +++ b/marker2/ds9/EFTA00205945/_page_1_Picture_48.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:6fc85c16b11476b3274be04ed7392514797d0e0af63abe187498f17729166ba7 +size 14892 diff --git a/marker2/ds9/EFTA00205947/EFTA00205947.md b/marker2/ds9/EFTA00205947/EFTA00205947.md new file mode 100644 index 0000000000000000000000000000000000000000..3ac7ff6c75d20d09c8e579273ede81adb8cdcdcd --- /dev/null +++ b/marker2/ds9/EFTA00205947/EFTA00205947.md @@ -0,0 +1,15 @@ +From: (USAFLS)" < IMIM> + +To: (USAFLS)" < IIMIM> + +Subject: Memo re Epstein + +Date: Tue, 26 Jul 2011 13:14:45 +0000 + +Importance: Normal + +Hi Ben — Do you want me to summarize the basis for the conflict or the new leads or both? + +Assistant U.S. Attorney + +Fax \ No newline at end of file diff --git a/marker2/ds9/EFTA00205947/EFTA00205947.metadata.json b/marker2/ds9/EFTA00205947/EFTA00205947.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..17de822bb4b34932bbface3789042bfd2378dc02 --- /dev/null +++ b/marker2/ds9/EFTA00205947/EFTA00205947.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205947.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 253, + "elapsed_seconds": 0.61, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 21 + ], + [ + "Text", + 12 + ], + [ + "Line", + 9 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205947" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205948/EFTA00205948.md b/marker2/ds9/EFTA00205948/EFTA00205948.md new file mode 100644 index 0000000000000000000000000000000000000000..dfab2232e4dd365f92f73148b5b4a0d4743746be --- /dev/null +++ b/marker2/ds9/EFTA00205948/EFTA00205948.md @@ -0,0 +1,29 @@ +To + +Subject: Re: Jeffrey Epstein + +Date: Wed, 27 Jul 2011 20:19:15 +0000 + +Importance: Normal + +ThankM + +--Original Message + +From: + +To: Ro BLACK + +Cc: + +Sent: 7/27/2011 4:16:04 PM + +Subject: Jeffrey Epstein + +Dear Mr. Black: + +Attached please find a response to Mr. Weinberg's letter. A copy was sent to Mr. Weinberg by fax. + +Thank you. + +Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 \ No newline at end of file diff --git a/marker2/ds9/EFTA00205948/EFTA00205948.metadata.json b/marker2/ds9/EFTA00205948/EFTA00205948.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..925f4a3dfae91fc0d0984643f184a315fc912f03 --- /dev/null +++ b/marker2/ds9/EFTA00205948/EFTA00205948.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205948.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 411, + "elapsed_seconds": 0.74, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 37 + ], + [ + "Line", + 19 + ], + [ + "Text", + 16 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205948" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205949/EFTA00205949.md b/marker2/ds9/EFTA00205949/EFTA00205949.md new file mode 100644 index 0000000000000000000000000000000000000000..dd92de1632b6fd437bb2968fec1feab59ba4b514 --- /dev/null +++ b/marker2/ds9/EFTA00205949/EFTA00205949.md @@ -0,0 +1,17 @@ +To: + +Subject: ea :Press ontact rom ewswee c re e reyEpstein case + +Date: Wed, 20 Jul 2011 20:05:14 +0000 + +Importance: Normal + +Your message + +To: + +Subject: Press Contact rom Newsweek re Jeffrey Epstein case + +Sent: Wednesday, July 20, 2011 3:58:10 PM (UTC-05:00) Eastern Time (US & Canada) + +was read on Wednesday, July 20, 2011 4:04:45 PM (UTC-05:00) Eastern Time (US & Canada). \ No newline at end of file diff --git a/marker2/ds9/EFTA00205949/EFTA00205949.metadata.json b/marker2/ds9/EFTA00205949/EFTA00205949.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..90ad916f79b02fc4761fdcd32512b1708784533b --- /dev/null +++ b/marker2/ds9/EFTA00205949/EFTA00205949.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205949.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 374, + "elapsed_seconds": 0.54, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 21 + ], + [ + "Line", + 11 + ], + [ + "Text", + 10 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205949" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205950/EFTA00205950.md b/marker2/ds9/EFTA00205950/EFTA00205950.md new file mode 100644 index 0000000000000000000000000000000000000000..2e0efcbb6e674bdb5686e1e7343a0b64ee4b9799 --- /dev/null +++ b/marker2/ds9/EFTA00205950/EFTA00205950.md @@ -0,0 +1,25 @@ +From: To: Cc: (USAFLS)" (USAFLS)" USAFLS)" (USAFLS)" + +Subject: RE: Press Contact from Newsweek re Jeffrey Epstein case + +Date: Wed, 20 Jul 2011 20:05:14 +0000 + +Importance: Normal + +Ugh. Thanks. + +Hope you are well. + +From: (USAFLS) + +Sent: Wednesday, July 20, 2011 3:58 PM + +To: USAFLS) + +(USAFLS); (USAFLS); (USAF LS) Cc: (USAFLS); (USAFISIr (USAFLS); (USAFLS); + +Subject: Press Contact from Newsweek re Jeffrey Epstein case + +I . I just received a call from (sp?) from Newsweek wantin to ask me some questions "off the r:cord." I told him that I would ask you to return his call. His number is + +Assistant U.S. Attorney \ No newline at end of file diff --git a/marker2/ds9/EFTA00205950/EFTA00205950.metadata.json b/marker2/ds9/EFTA00205950/EFTA00205950.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f1ced6753dc46b63e710ceff167bc50c629456f8 --- /dev/null +++ b/marker2/ds9/EFTA00205950/EFTA00205950.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205950.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 611, + "elapsed_seconds": 0.98, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 47 + ], + [ + "Line", + 23 + ], + [ + "Text", + 16 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205950" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205951/EFTA00205951.md b/marker2/ds9/EFTA00205951/EFTA00205951.md new file mode 100644 index 0000000000000000000000000000000000000000..10c7bd01d6d707f96a8948dfb29e38e63e0e5b71 --- /dev/null +++ b/marker2/ds9/EFTA00205951/EFTA00205951.md @@ -0,0 +1,21 @@ +![](_page_0_Picture_50.jpeg) + +**Subject:** FOIA Request + +**Date:** Wed, 20 Jul 2011 01:30:21 +0000 + +**Importance:** Normal + +**Attachments:** 20110720113911.pdf; 20110719\_\_\_\_\_tr\_to\_Black.wpd + +--- + +Dear C[REDACTED] I received the attached letter from an Assistant District Attorney in New York regarding the investigation of Jeffrey Epstein. She is asking for two discrete items that she needs to prepare her response to an appeal of his sex offender registration status in New York, which is directly related to these items. I have prepared the attached letter to Mr. Epstein's counsel regarding Section 552. + +Can you review and give me your position? + +Thank you. + +<<20110720113911.pdf>> <<20110719\_\_\_\_\_tr to Black.wpd>> + +![](_page_0_Picture_59.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00205951/EFTA00205951.metadata.json b/marker2/ds9/EFTA00205951/EFTA00205951.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..a142529e5b019df63c491ca8d86f2e5428f7a0d0 --- /dev/null +++ b/marker2/ds9/EFTA00205951/EFTA00205951.metadata.json @@ -0,0 +1,61 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205951.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 761, + "elapsed_seconds": 3.16, + "image_assets": [ + "_page_0_Picture_50.jpeg", + "_page_0_Picture_59.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 28 + ], + [ + "Text", + 17 + ], + [ + "Line", + 12 + ], + [ + "PageFooter", + 2 + ], + [ + "Picture", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205951" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205951/_page_0_Picture_50.jpeg b/marker2/ds9/EFTA00205951/_page_0_Picture_50.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..ff92a8a4fa3a4119744c8929f3e9c51a9d11a08b --- /dev/null +++ b/marker2/ds9/EFTA00205951/_page_0_Picture_50.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:8383c68a8f4b199ecc198a6a098c949ad89ce1dcd9ff1af3b5f766f6769d743e +size 9472 diff --git a/marker2/ds9/EFTA00205951/_page_0_Picture_59.jpeg b/marker2/ds9/EFTA00205951/_page_0_Picture_59.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..98b4eca98584702429cde6eb534bfcf3e6f972ab --- /dev/null +++ b/marker2/ds9/EFTA00205951/_page_0_Picture_59.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:020585a79154fef61beb0bac67ce8d61b313860ef12b31320131a0ba2d895e8f +size 7731 diff --git a/marker2/ds9/EFTA00205952/EFTA00205952.md b/marker2/ds9/EFTA00205952/EFTA00205952.md new file mode 100644 index 0000000000000000000000000000000000000000..0f7cd13627558c3cf68abf036cdd4708093dba6e --- /dev/null +++ b/marker2/ds9/EFTA00205952/EFTA00205952.md @@ -0,0 +1,70 @@ +ONE HOGAN PLACE + +New York, N. Y. 10013 + +[REDACTED] + +![](_page_0_Picture_137.jpeg) + +CYRUS R. VANCE, JR. +DISTRICT ATTORNEY + +APPEALS BUREAU +FAX DOCUMENT COVERSHEET +FAX # [REDACTED] + +Date: July 17, 2011 + +To: [REDACTED] + +Fax: [REDACTED] + +From: [REDACTED] + +Tel #: ( ) 335- 9263 + +# of Pages 2 (includes cover sheet) + +| URGENT | ROUTINE | +|------------------------------------------------------------------------|-------------------------------------------------------------| +| Deliver Immediately | Discuss with Appropriate Person(s) | +| As Requested | For Your Approval | +| Review and Comment | Take Necessary Action | +| For Your Information | Reply Via FAX | +| File | Reply Via Messenger | +| Reply Directly | Progress Report | +| Investigate | Let's Discuss | +| Prepare Reply for Signature | | +| Other Action To Be Taken/Additional Comments: | | + +My transmittal sheet from Friday days it didn't go through at not time. If this is repeat, I'm apologize. + +Again, I approve your cooperation — + +[REDACTED] + +COUNTY OF NEW YORK + +ONE HOGAN PLACE + +Now \for N. V.10013 + +![](_page_1_Picture_8.jpeg) + +CYRUS R. VANCE, JR. + +Dirt= ATTCatiff + +Dear Ms. Villafalia, + +July 15, 2011 + +![](_page_1_Picture_12.jpeg) + +As we have discussed, I am currently working on the appeal brought by defendant Jeffrey Epstein in which he challenges his risk-offender designation under New York State's Sexual Offender Registration Act. + +The non-prosecution agreement between defendant and your Office would be of assistance to us In fashioning our response on appeal. I would appreciate it if you would send us a copy of that agreement, including the list of victims. + +Please let me know If you need any further information In order to make this material available. I appreciate your assistance, and courtesy, In this matter. + +![](_page_1_Picture_17.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00205952/EFTA00205952.metadata.json b/marker2/ds9/EFTA00205952/EFTA00205952.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..5eaa9967c96844e6ebb6afd9d66af77db2b803e4 --- /dev/null +++ b/marker2/ds9/EFTA00205952/EFTA00205952.metadata.json @@ -0,0 +1,191 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205952.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2797, + "elapsed_seconds": 5.61, + "image_assets": [ + "_page_0_Picture_137.jpeg", + "_page_1_Picture_8.jpeg", + "_page_1_Picture_12.jpeg", + "_page_1_Picture_17.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "DISTRICT ATTORNEY", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 252.14399999999998, + 21.87 + ], + [ + 376.992, + 21.87 + ], + [ + 376.992, + 34.019999999999996 + ], + [ + 252.14399999999998, + 34.019999999999996 + ] + ] + }, + { + "title": "APPEALS BUREAU FAX DOCUMENT COVERSHEET FAX # 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Pursuant to 5 U.S.C. § 552a(b) (7), the Office intends to disclose these items to Deborah L. Morse, Assistant District Attorney, at 5:00 p.m. on Thursday, July 21, 2011. Pursuant to the terms of the Non-Prosecution Agreement, the Office is hereby giving you notice of this intended disclosure. + +Sincerely, +Wifredo A. Ferrer +United States Attorney + +![](_page_0_Picture_66.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00205954/EFTA00205954.metadata.json b/marker2/ds9/EFTA00205954/EFTA00205954.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..43b28a0595e1eabfab6303922809d267b144b669 --- /dev/null +++ b/marker2/ds9/EFTA00205954/EFTA00205954.metadata.json @@ -0,0 +1,90 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205954.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 839, + "elapsed_seconds": 3.43, + "image_assets": [ + "_page_0_Picture_56.jpeg", + "_page_0_Picture_61.jpeg", + "_page_0_Picture_66.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "DELIVERY BY ELECTRONIC MAIL", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 31.212, + 141.75 + ], + [ + 224.60399999999998, + 141.75 + ], + [ + 224.60399999999998, + 153.89999999999998 + ], + [ + 31.212, + 153.89999999999998 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 31 + ], + [ + "Text", + 15 + ], + [ + "Line", + 15 + ], + [ + "Picture", + 3 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205954" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205954/_page_0_Picture_56.jpeg b/marker2/ds9/EFTA00205954/_page_0_Picture_56.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..16f1c3a97214d3743c6c08161dab70d81b7e8188 --- /dev/null +++ b/marker2/ds9/EFTA00205954/_page_0_Picture_56.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:183c015fe5e334773613920078f7bec4da6f698fe1c39bcda775b01e67c59c12 +size 8544 diff --git a/marker2/ds9/EFTA00205954/_page_0_Picture_61.jpeg b/marker2/ds9/EFTA00205954/_page_0_Picture_61.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..e77432d6b69eadb9e9032c3a45d98c92799b1b43 --- /dev/null +++ b/marker2/ds9/EFTA00205954/_page_0_Picture_61.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:b19f97a72efce0bfac5e0148ffaebd30990d213132211e1c1f30f27b49afeabe +size 3900 diff --git a/marker2/ds9/EFTA00205954/_page_0_Picture_66.jpeg b/marker2/ds9/EFTA00205954/_page_0_Picture_66.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..97f6104e3b20773a199b28b584d6c728c68f63cd --- /dev/null +++ b/marker2/ds9/EFTA00205954/_page_0_Picture_66.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:68e8eb0574099bf3ad7c308f7072d2dc4cef39a272f4987919d763988c433c67 +size 7295 diff --git a/marker2/ds9/EFTA00205955/EFTA00205955.md b/marker2/ds9/EFTA00205955/EFTA00205955.md new file mode 100644 index 0000000000000000000000000000000000000000..c358a9708edd6a4151dd06a5c5fba85371c7edff --- /dev/null +++ b/marker2/ds9/EFTA00205955/EFTA00205955.md @@ -0,0 +1,21 @@ +To: + +Date: Wed, 20 Jul 2011 20:58:08 +0000 + +Importance: Normal + +Hi + +This is Jacob Albert, research assistant for Wayne Barrett, at Newsweek. I know you've said that you wouldn't comment on our questions, but I wanted to give you the chance to hear what we're asking before declining. If you'd rather speak by phone, on or off record, I'm MI + +1) The nonprosecution deal that you worked out specified that Epstein would do 30 months in jail? What's your understanding of why he did only 13 of the 18mo of his jail sentence, and why was he excused from the carrying out the remainder of his sentence? Who approved the sentence reduction, at state or federal level, and why? + +2) Do you have any knowledge of how Jeffrey Epstein was able to preserve personal and corporate tax benefits/exemption in the Virgin Islands, in 2009, which requires residency (183 days) that Epstein was unable to meet, as he was under house arrest during that period? Do you know whether VI residency requirements for tax benefits/exemptions are waived if you're in prison or under house arrest in another state? + +If you still have no comment, please let me know; the article running in Newsweek will state that your office wouldn't comment. + +Thanks, + +Jacob Albert + +Research Assitant for Wayne Barrett \ No newline at end of file diff --git a/marker2/ds9/EFTA00205955/EFTA00205955.metadata.json b/marker2/ds9/EFTA00205955/EFTA00205955.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b5f1e99b3933fb2fd5c6e4a61e4ee45a74734db9 --- /dev/null +++ b/marker2/ds9/EFTA00205955/EFTA00205955.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205955.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1274, + "elapsed_seconds": 0.58, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 37 + ], + [ + "Line", + 19 + ], + [ + "Text", + 12 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205955" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205956/EFTA00205956.md b/marker2/ds9/EFTA00205956/EFTA00205956.md new file mode 100644 index 0000000000000000000000000000000000000000..c29e47329e576790016ed29fd31f80d19b4ae6ce --- /dev/null +++ b/marker2/ds9/EFTA00205956/EFTA00205956.md @@ -0,0 +1,19 @@ +From: Il /fi ala> + +To: (USAFLS)" alMIN> + +Subject: Read: RE: Potential Epstein recusal (criminal) + +Date: Tue, 19 Jul 2011 17:59:43 +0000 + +Importance: Normal + +Your message + +To: + +Subject: RE: Potential Epstein recusal (criminal) + +Sent: Tuesday, July 19, 2011 1:58:21 PM (UTC-05:00) Eastern Time (US & Canada) + +was read on Tuesday, July 19, 2011 1:59:43 PM (UTC-05:00) Eastern Time (US & Canada). \ No newline at end of file diff --git a/marker2/ds9/EFTA00205956/EFTA00205956.metadata.json b/marker2/ds9/EFTA00205956/EFTA00205956.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..0b880dbb7e5e07285c3a67b108cb3296efdd037c --- /dev/null +++ b/marker2/ds9/EFTA00205956/EFTA00205956.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205956.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 392, + "elapsed_seconds": 0.54, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 26 + ], + [ + "Line", + 11 + ], + [ + "Text", + 10 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205956" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205957/EFTA00205957.md b/marker2/ds9/EFTA00205957/EFTA00205957.md new file mode 100644 index 0000000000000000000000000000000000000000..b8515c0f4806c5755e1c2cf4fab34e563257b4cb --- /dev/null +++ b/marker2/ds9/EFTA00205957/EFTA00205957.md @@ -0,0 +1,25 @@ +From: To: + +Subject: RE: Potential Epstein recusal (criminal) + +Date: Tue, 19 Jul 2011 17:58:59 +0000 + +Importance: Normal + +I think letting Mike know is fine. Thanks. + +Sent: Tuesday, July 19, 2011 1:58 PM + +Subject: RE: Potential Epstein recusal (criminal) + +I have told the case agents and the group supervisor, don't know if it has gone any higher than that. Let me know if you want me to ask if he is chain of command. + +![](_page_0_Picture_8.jpeg) + +Sent: Tuesday, July 19, 2011 1:S6 PM + +Subject: Potential Epstein recusal (criminal) + +I spoke to at EOUSA/GC about our office seeking recusal from any new investigation into allegations against Epstein (-is no longer with GC). S agreed that we should seek recusal and asked that we submit something to him giving a brief history of the case and the basis for recusal. He doesn't need (or want) anything too detailed, but we should provide him with enough information to allow him to formulate the recusal request. can you draft something for us to send to him? Also, does the FBI know that we are seeking recusal? I don't want them to be blindsided. Thanks. + +Ben \ No newline at end of file diff --git a/marker2/ds9/EFTA00205957/EFTA00205957.metadata.json b/marker2/ds9/EFTA00205957/EFTA00205957.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..5d7680533ffa9546743a8fd1f2389848df77d5f5 --- /dev/null +++ b/marker2/ds9/EFTA00205957/EFTA00205957.metadata.json @@ -0,0 +1,60 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205957.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1108, + "elapsed_seconds": 0.66, + "image_assets": [ + "_page_0_Picture_8.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 39 + ], + [ + "Line", + 20 + ], + [ + "Text", + 12 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205957" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205957/_page_0_Picture_8.jpeg b/marker2/ds9/EFTA00205957/_page_0_Picture_8.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..5ac79c3119b2d1982e8f681e0d9cd52fe82e5352 --- /dev/null +++ b/marker2/ds9/EFTA00205957/_page_0_Picture_8.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:a60efe0caa583c5042f2eb9acd1227dbb7648d7f21c02a4a98edc9823b0bb13a +size 8785 diff --git a/marker2/ds9/EFTA00205958/EFTA00205958.md b/marker2/ds9/EFTA00205958/EFTA00205958.md new file mode 100644 index 0000000000000000000000000000000000000000..cb401b28cca934c9d31af4049d7a22a87172eaeb --- /dev/null +++ b/marker2/ds9/EFTA00205958/EFTA00205958.md @@ -0,0 +1,27 @@ +U.S. Department of Justice United States Attorney Southern District of Florida + +500 S. Australian Ave, Ste 400 + +West Palm Beach, FL 33401 + +Facsimile: (561) 820-8777 + +July 19, 2011 + +## DELIVERY BY ELECTRONIC MAIL + +Roy Black, Esq. Black Srebnick Komspan & Stumpf P.A. 201 S. Biscayne Blvd, Suite 1300 Miami, FL 33131 + +Re: Jeffrey Epstein + +Dear Mr. Black: + +On July 17, 2011, the Office received a written request from the District Attorney of the County of New York for a copy of the signed Non-Prosecution Agreement and the list of identified victims that was provided to Mr. Epstein pursuant to the Non-Prosecution Agreement. Pursuant to 5 U.S.C. § 552a(b) (7), the Office intends to disclose these items to Deborah L. Morse, Assistant District Attorney, at the close of business on Thursday, July 21, 2011. Pursuant to the terms of the Non-Prosecution Agreement, the Office is hereby giving you notice of this intended disclosure. + +Sincerely, Wifredo A. Ferrer United States Attorney + +By: + +cc: + +Deborah L. Morse, Assistant District Attorney, County of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00205958/EFTA00205958.metadata.json b/marker2/ds9/EFTA00205958/EFTA00205958.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..adb4d77f0de1ccaa4415639671cc28fa90ab9084 --- /dev/null +++ b/marker2/ds9/EFTA00205958/EFTA00205958.metadata.json @@ -0,0 +1,82 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205958.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1060, + "elapsed_seconds": 0.7, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "DELIVERY BY ELECTRONIC MAIL", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 31.212, + 140.94 + ], + 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recusal (criminal) + +Date: Tue, 19 Jul 2011 18:54:11 +0000 + +Importance: Normal + +Your message + +To: (USAFLS) + +Subject: RE: Potential Epstein recusal (criminal) + +Sent: Tuesday, July 19, 2011 1:58:21 PM (UTC-05:00) Eastern Time (US & Canada) + +was read on Tuesday, July 19, 2011 2:53:21 PM (UTC-05:00) Eastern Time (US & Canada). \ No newline at end of file diff --git a/marker2/ds9/EFTA00205959/EFTA00205959.metadata.json b/marker2/ds9/EFTA00205959/EFTA00205959.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..4a8e8fa54aab004213215fe3b377b55d0c05805c --- /dev/null +++ b/marker2/ds9/EFTA00205959/EFTA00205959.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205959.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 402, + "elapsed_seconds": 0.51, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 21 + ], + [ + "Line", + 11 + ], + [ + "Text", + 10 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205959" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205960/EFTA00205960.md b/marker2/ds9/EFTA00205960/EFTA00205960.md new file mode 100644 index 0000000000000000000000000000000000000000..78bef3f8c0f073c2708a6b1fa6922cfd02d6a84a --- /dev/null +++ b/marker2/ds9/EFTA00205960/EFTA00205960.md @@ -0,0 +1,13 @@ +Subject: Read: Memo regarding Conflict in Epstein Investigation + +Date: Tue, 26 Jul 2011 21:05:02 +0000 + +Importance: Normal + +Your message + +.jec.. n Epstein Investigation + +Sent: Tuesday, July 26, 2011 5:03:18 PM (UTC-05:00) Eastern Time (US & Canada) + +was read on Tuesday, July 26, 2011 5:05:02 PM (UTC-05:00) Eastern Time (US & Canada). \ No newline at end of file diff --git a/marker2/ds9/EFTA00205960/EFTA00205960.metadata.json b/marker2/ds9/EFTA00205960/EFTA00205960.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f76b3fb14318b3ad63e44d18254b5776ee7d3ba3 --- /dev/null +++ b/marker2/ds9/EFTA00205960/EFTA00205960.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205960.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 335, + "elapsed_seconds": 0.42, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 18 + ], + [ + "Line", + 8 + ], + [ + "Text", + 7 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205960" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205961/EFTA00205961.md b/marker2/ds9/EFTA00205961/EFTA00205961.md new file mode 100644 index 0000000000000000000000000000000000000000..a45c2ff9151c239c55d39bbe9aa7752ae633c414 --- /dev/null +++ b/marker2/ds9/EFTA00205961/EFTA00205961.md @@ -0,0 +1,23 @@ +To: + +Cc: + +Subject: Memo regarding Conflict in Epstein Investigation + +Date: Tue, 26 Jul 2011 21:03:18 +0000 + +Importance: Normal + +Attachments: Epstein\_Conflict\_Memo.pdf + +HiM— Here is the Memo you requested during our conference call. Please let me know if you want it in Word Perfect so you can cut and paste it into a letter to DC. + +Thank you. Sorry for the delay. + +«Epstein Conflict Memo.pdf>> + +Assistant U.S. Attorney + +500 S. Australian Ave, Suite 400 + +West Palm Beach, FL 33401 \ No newline at end of file diff --git a/marker2/ds9/EFTA00205961/EFTA00205961.metadata.json b/marker2/ds9/EFTA00205961/EFTA00205961.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..665f0d1380a3eb04ea877851ce579644fc7a3719 --- /dev/null +++ b/marker2/ds9/EFTA00205961/EFTA00205961.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205961.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 481, + "elapsed_seconds": 0.64, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 29 + ], + [ + "Line", + 15 + ], + [ + "Text", + 13 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205961" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205962/EFTA00205962.md b/marker2/ds9/EFTA00205962/EFTA00205962.md new file mode 100644 index 0000000000000000000000000000000000000000..15d3f97a4933761b45b80bf89fc300fc75829d18 --- /dev/null +++ b/marker2/ds9/EFTA00205962/EFTA00205962.md @@ -0,0 +1,13 @@ +Subject: Re: Memo re Epstein + +Date: Tue, 26 Jul 2011 13:17:59 +0000 + +Importance: Normal + +I think basis of the conflict is the main issue but maybe add a paragraph on the leads. Thanks. + +Sent: Tuesday, July 26, 2011 09:14 AM + +Subject: Memo re Epstein + +Hi Ben Do you want me to summarize the basis for the conflict or the new leads or both? \ No newline at end of file diff --git a/marker2/ds9/EFTA00205962/EFTA00205962.metadata.json b/marker2/ds9/EFTA00205962/EFTA00205962.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..843fa4407146215a6e5c787a55aa8b5fb3220060 --- /dev/null +++ b/marker2/ds9/EFTA00205962/EFTA00205962.metadata.json @@ -0,0 +1,50 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205962.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 338, + "elapsed_seconds": 0.42, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 17 + ], + [ + "Text", + 8 + ], + [ + "Line", + 8 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205962" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205963/EFTA00205963.md b/marker2/ds9/EFTA00205963/EFTA00205963.md new file mode 100644 index 0000000000000000000000000000000000000000..932116efa46594c405f8e67e5dadc0273544433c --- /dev/null +++ b/marker2/ds9/EFTA00205963/EFTA00205963.md @@ -0,0 +1,19 @@ +From: "S, (USAFLS)" <=1MINE> + +To: (USAFLS)" alMIN> + +Subject: Read: Memo regarding Conflict in Epstein Investigation + +Date: Tue, 26 Jul 2011 21:12:15 +0000 + +Importance: Normal + +Your message + +To: (USAFLS) + +Subject: Memo regarding Conflict in Epstein Investigation + +Sent: Tuesday, July 26, 2011 5:03:18 PM (UTC-05:00) Eastern Time (US & Canada) + +was read on Tuesday, July 26, 2011 5:12:00 PM (UTC-05:00) Eastern Time (US & Canada). \ No newline at end of file diff --git a/marker2/ds9/EFTA00205963/EFTA00205963.metadata.json b/marker2/ds9/EFTA00205963/EFTA00205963.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..c3f8fc18faa8c84c3b4007bcedaf32dfaad3ee8b --- /dev/null +++ b/marker2/ds9/EFTA00205963/EFTA00205963.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205963.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 428, + "elapsed_seconds": 0.51, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 21 + ], + [ + "Line", + 11 + ], + [ + "Text", + 10 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205963" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205964/EFTA00205964.md b/marker2/ds9/EFTA00205964/EFTA00205964.md new file mode 100644 index 0000000000000000000000000000000000000000..f5e10ff56d3ecda0d6c4de04bb335cea8930f7f1 --- /dev/null +++ b/marker2/ds9/EFTA00205964/EFTA00205964.md @@ -0,0 +1,67 @@ +SubjectDate + +Re: Jeffrey Epstein Investigation July 26, 2011 + +First Assistant U.S. Attorney + +### I. Introduction + +This memorandum summarizes the conflict of interest related to the investigation by the Federal Bureau of Investigation ("FBI") of additional crimes committed by Jeffrey Epstein ("Epstein"). The memo begins with a brief overview of the original investigation of Epstein, dubbed "Operation Leap Year"; summarizes the resolution of Operation Leap Year by the Southern District of Florida; and addresses the events following the resolution of Operation Leap Year, including the basis for the conflict. Lastly, the memo briefly addresses the additional crimes that the FBI wants to investigate. + +### II. "Operation Leapt" + +The investigation of Jeffrey Epstein initially was undertaken by the City of Palm Beach Police Department in response to a complaint received from the parents of a 14-year-old girl, from . Whenand another girl began fighting at school because the other girl accused f being a prostitute, one of the school pr. intervened. The principal searche purse and found \$300 cash. The principal asked here the money came from. initially claimed that she earned the money working at ' " which no one believed. hen claimed that she made the money selling drugs; no one believed that either. finally admitted that she had been paid \$300 to give a massage to a man on Palm Beach island. parents approached the Palm Beach Police Department ("PBPD") about pressing charges. + +PBPD began investi atin the recipient of the massage, Jeffrey Epstein, and and PBPD identified 27 girls who went to Epstein's house to perform "massage services" (not including one licensed massage therapist). The girls' ages ranged from 14 years' old to 23 years' old. Some girls saw Epstein only once and some saw him dozens of times. The "massage services" performed also varied. Some girls were fully clothed while they massaged Epstein; some wore only their underwear; and some were fully nude. During all of these massages, Epstein masturbated himself and he would and vibrator to more often, Epstein — either over their clothin and uated to , usually or on their bare skin. Epstein often used a a number of them. For the girls who saw him Epstein sometimes brought into the sexual activity. One of the girls described as Epstein's "sex slave". + +On October 18, 2005, PBPD obtained a search warrant with the assistance of the Palm Beach County State Attorney's Office ("PBSAO"). By this time, PBSAO had already been contacted by Epstein's cadre of lawyers. When PBPD arrived at Epstein's home two days later (10/20/05) to execute the search warrant, they found several items conspicuously missing. For example, computer monitors and keyboards were found, but the CPUs were gone. Ft Similarly, surveillance cameras were found, but they were disconnected and the videotapes were gone. Nonetheless, the search did recover some evidence of value, including message pads showing messages from many girls over a two year span. + +The messages show girls returning phone calls to confirm appointments to "work." Messages were taken by three of Epstein's "personal assistants." + +Photographs taken inside the home showed that the girls' descriptions of the layout of the home and master bedroom/bathroom area were accurate. PBPD also found massage tables and oils, the high school transcript of one of the girls, and sex toys. + +In sum, the PBPD investigation showed that girls from would be contacted by one of Epstein's assistants to make an appointment to "work." Up to three appointments each day would be made. The girls would travel to Epstein's home in Palm Beach where they would meet Epstein's chef and Epstein': An the kitchen. The assistant would escort the girls upstairs to the master bedroom/bathroom area and set up the massage table and massage oils. The girl sometimes was instructed to remove her clothing. The assistant would leave and Epstein would enter the room wearing a robe. He would remove the robe and lie face down and nude on the massage table. Epstein would then instruct the girl on what to do and would ask her to remove her clothing. After some time E stein would turn over so that he was lying face up. Epstein would masturbate himself and When Epstein climaxed, the massage was over, and the girl was instructed to get dressed and to go downstairs to the kitchen while Epstein showered. Epstein's assistant would be in the kitchen and the girl would be paid—usually \$200-and if it was a "new" girl, the assistant would ask for the girl's phone number to contact her in the future. Fz Girls were encouraged to find other girls to bring with them. If a girl brought another girl to perform a "massage," each girl would receive \$200. Each time a girl returned to the house, Epstein would pressure the girl to go further sexually, . Epstein would pay more for these acts — in the words of one girl, "the more you do, the more you make." + +The PBPD investigation consisted primarily of sworn taped statements from the girls. When PBPD began having problems with PBSAO, they approached the FBI. The investigation was formally presented to the FBI and to the U.S. Attorney's Office after PBSAO "presented" the case to a state grand jury and the state grand jury returned an indictment charging Epstein only with one felony count of solicitation of [adult] prostitution. + +After the matter was presented to the U.S. Attorney's Office and there was a determination that federal statutes had been violated, FBI, ICE, and the U.S. Attorney's Office opened files. The federal investigation focused on the interstate nexus required for all of the federal violations, so a number of grand jury subpoenas were issued for telephone records, flight manifests, and credit card records. The federal agents also re-interviewed some of the girls. The agents delved into Epstein's history and interviewed other girls and obtained records to corroborate the girls' stories. FBI also interviewed girls who came forward after the PBSAO indictment was reported in the papers and the additional girls identified through those interviews. + +The attempt to handle secretly the federal case was doomed from the start when the Chief of the Palm Beach Police Department gave a letter to each of the victims identified through his investigation telling them that, because of his disappointment in the way that the PBSAO had handled the case, the matter had been referred to the FBI. Almost immediately, Epstein's attorneys began calling to request a meeting with the U.S. Attorney's Office. When one attorney was unable to schedule a meeting, Epstein hired another attorney who called up the chain of command until someone agreed to a meeting. + +Between January and May 2007, an indictment package was prepared, charging Epstein and three of his personal assistants with a number of child exploitation offenses. The case agent made several appearances before the grand jury. Attorneys for Epstein made several presentations to the U.S. Attorney's Office to convince the Office not to prosecute, and made allegations of prosecutorial misconduct against the line Assistant and the First Assistant U.S. Attorney. Epstein also challenged the legal analysis behind the prosecution, both within the U.S. Attorney's Office (up to the U.S. Attorney) and to the Child Exploitation and Obscenity Section at the Justice Department. All of Epstein's challenges were considered and rejected. + +## The Resolution of "Operation Leap Year" + +On September 24, 2007, Epstein signed a Non-Prosecution Agreement wherein the U.S. Attorney's Office for the Southern District of Florida promised not to prosecute Epstein for the crimes that were the subject of the grand jury investigation if: (1) he pled guilty to two crimes in state court - + +the state felony prostitution charge and a state charge of procuring minors into prostitution, which would require Epstein to register as a sex offender; (2) he were sentenced to at least 18 months' imprisonment, and (3) he agreed to pay damages to the victims of his offenses. After signing this Agreement, Epstein and his counsel decided that they were dissatisfied with its terms, and again complained to the Justice Department, seeking review to the Deputy Assistant Attorney General and the Deputy Attorney General. + +After those attempts also failed, on June 30, 2008, Epstein entered his guilty plea in state court and began serving his sentence. + +#### IV. Post-Resolution Events + +A few days before the plea and sentencing (in state court those occur on the same day), the Assistant U.S. Attorney handling the matter contacted counsel for three of Epstein's identified victims and informed him of the upcoming court date, encouraging his clients to attend and be heard. They did not appear. On July 7, 2008, two of those victims filed suit against the United States in federal court claiming that their rights had been violated under the Crime Victims' Rights Act because they had not been consulted before the Office entered into the Non-Prosecution Agreement. (This will be referred to as the "CVRA Action.") + +After an initial flurry of activity, the Petitioners obtained a copy of the confidential Non-Prosecution Agreement, and the Court ordered that it be shared with all of the identified victims. After it was provided, the Petitioners and most of Epstein's victims focused on their civil suits against him. + +In 2009, the U.S. Attorney's Office in Fort Lauderdale initiated an investigation into a Pont scheme operated by Scott Rothstein through his law firm. As part of his Ponzi scheme, Rothstein told investors that his law firm represented several of Epstein's victims and that Epstein was willing to pay huge sums of money to avoid exposing his criminal activities. The attorney representing the victims in the CVRA Action, Brad Edwards ("Edwards"), worked at the Rothstein firm. Epstein sued Edwards, alleging that Edwards was part of the Ponzi scheme, and alleging that Edwards' attempts to subpoena some of Epstein's high-powered friends were done to increase the value of the Ponzi scheme, rather than for legitimate discovery purposes. + +In the summer of 2010, most of the civil suits against Epstein were settled, including the suits filed by the two victims in the CVRA Action. All of the settlements were confidential, so it is unknown how much each of the victims received. + +In September 2010, U.S. District Judge Kenneth Marra, who handled most of the civil cases and the CVRA Action, issued an Order closing the CVRA Action. Almost immediately thereafter, the Petitioners filed a Motion to Reopen, stating that they had obtained discovery through their civil suits against Epstein that showed that the U.S. Attorney's Office had violated their rights as victims. + +For several months, attempts were made to resolve the matter. In short, the victims have asked that the U.S. Attorney's Office disavow the Non-Prosecution Agreement, on the basis that the CVRA was violated, and bring charges against Epstein. Edwards has said that one of his clients repeatedly calls and asks him when Epstein is going to jail. One of the other attorneys on the case has suggested that emails he considers to be embarrassing to the Office will not be disclosed if we re-open our investigation of Epstein and prosecute him. + +Herein lies the conflict. If the U.S. Attorney's Office for the Southern District of Florida reinitiates a grand jury investigation of Jeffrey Epstein, it will be perceived — correctly or incorrectly — as having been done at the insistence of the victims in the CVRA Action. And Epstein will allege that any prosecution arising therefrom will have been undertaken in an effort to resolve the CVRA Action, not based upon the merits of the investigation itself. + +# V. The FBI's Current Investigation + +The main focus of the FBI's current investigation is a victim, , who refused to speak with agents during the "Operation Leap Year" investigation. Based upon her debriefing, Epstein engaged in several additional crimes, in the Southern District of Florida and, more importantly, in several other Districts, with and other minor females. Epstein transported in his private airplanes to engage in sexual activity with him. Epstein also "pimped" to several of his other important friends, and transported her to those sexual encounters. This activity was not part of the initial investi ation. + +also reported that, during the "Operation Leap Year" investigation, she was contacted by Epstein's investigators, lawyers, and Epstein himself, and offered payment to remain silent when contacted by the police. + +FBI agents are seeking grand jury subpoenas at this time to corroborate statement. They also are asking for permission to approach one of Epstein's "personal assistants," who was served with a target letter during the "Operation Leap Year" investigation, to give her a "de-target" letter and interview her. + +During a meeting, two of Epstein's attorneys, Gerald Lefcourt and Lilly Ann Sanchez, admitted that attorney Roy Black instructed Epstein to have the CPUs removed although they insisted that those instruction were given well in advance of the execution of the search warrant — not in response to a "leak." + +FzSometimes Epstein made the payment and asked for the phone number, sometimes it was the assistant. \ No newline at end of file diff --git a/marker2/ds9/EFTA00205964/EFTA00205964.metadata.json b/marker2/ds9/EFTA00205964/EFTA00205964.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..9d10bac670a0a4a5e2b2c2486a58713c7051573f --- /dev/null +++ b/marker2/ds9/EFTA00205964/EFTA00205964.metadata.json @@ -0,0 +1,299 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205964.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 4, + "chars": 13355, + "elapsed_seconds": 1.29, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Memorandum", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 31.823999999999998, + 34.019999999999996 + ], + [ + 140.12356567382812, + 34.019999999999996 + ], + [ + 140.12356567382812, + 53.78033447265625 + ], + [ + 31.823999999999998, + 53.78033447265625 + ] + ] + }, + { + "title": "I. 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Could you send it in WP? Thanks again. + +wane= memo regaraing concoct m Epstein investigation + +Hi Ben — Here is the Memo you requested during our conference call. Please let me know if you want it in Word Perfect so you can cut and paste it into a letter to DC. + +Thank you. Sony for the delay. + +« File: Epstein Conflict Memo.pdf » + +![](_page_0_Picture_8.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00205968/EFTA00205968.metadata.json b/marker2/ds9/EFTA00205968/EFTA00205968.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b3ebebc6add4c97973c8d6f6f4b1f9fed02dd9d7 --- /dev/null +++ b/marker2/ds9/EFTA00205968/EFTA00205968.metadata.json @@ -0,0 +1,60 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205968.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 488, + "elapsed_seconds": 0.51, + "image_assets": [ + "_page_0_Picture_8.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 20 + ], + [ + "Line", + 10 + ], + [ + "Text", + 8 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205968" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205968/_page_0_Picture_8.jpeg b/marker2/ds9/EFTA00205968/_page_0_Picture_8.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..9fdfc8c0bf5aea3394d1cbb672cad4f1a6787a37 --- /dev/null +++ b/marker2/ds9/EFTA00205968/_page_0_Picture_8.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:94a15be77714ffa9d4bc49ba9cd3bac2bfe7e4aa52d773d82a3a0cdb34eb8633 +size 8971 diff --git a/marker2/ds9/EFTA00205969/EFTA00205969.md b/marker2/ds9/EFTA00205969/EFTA00205969.md new file mode 100644 index 0000000000000000000000000000000000000000..2bcbdd25eec696de4888413b4979c87b796c126e --- /dev/null +++ b/marker2/ds9/EFTA00205969/EFTA00205969.md @@ -0,0 +1,19 @@ +From: " IIM> + +To:' + +Subject: Read: Memo regarding Conflict in Epstein Investigation + +Date: Tue, 26 Jul 2011 21:12:07 +0000 + +Importance: Normal + +Your message + +To: + +Subject: Memo regarding Conflict in Epstein Investigation + +Sent: Tuesday, July 26, 2011 5:03:18 PM (UTC-05:00) Eastern Time (US & Canada) + +was read on Tuesday, July 26, 2011 5:11:08 PM (UTC-05:00) Eastern Time (US & Canada). \ No newline at end of file diff --git a/marker2/ds9/EFTA00205969/EFTA00205969.metadata.json b/marker2/ds9/EFTA00205969/EFTA00205969.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..fd528ea5ba1cad82392211be1a07d9fd0b3260db --- /dev/null +++ b/marker2/ds9/EFTA00205969/EFTA00205969.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205969.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 387, + "elapsed_seconds": 0.51, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 23 + ], + [ + "Line", + 11 + ], + [ + "Text", + 10 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205969" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205970/EFTA00205970.md b/marker2/ds9/EFTA00205970/EFTA00205970.md new file mode 100644 index 0000000000000000000000000000000000000000..e2f67d8438d82a0de5d2f5765e49e322e3ae387d --- /dev/null +++ b/marker2/ds9/EFTA00205970/EFTA00205970.md @@ -0,0 +1,17 @@ +To: Amy Ederi MIII1MIIIIMI "KATHERINE W. EZELL" + +Subject: Epstein Hearing + +Date: Fri, 12 Aug 2011 22:42:23 +0000 + +Importance: Normal + +Hi everyone — I wanted to let you know that we left today's hearing with no decisions. If I were a betting person, I would bet that Judge Marra is going to allow the plaintiffs to seek discovery and that we will be having an evidentiary hearing a few months from now. + +On another note, I just heard that I received an interview for one of the magistrate positions. The interviews are going to occur on the 24th and 27th, so keep your fingers crossed on that note, too. + +I will keep you all posted. + +Thank you! + +![](_page_0_Picture_8.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00205970/EFTA00205970.metadata.json b/marker2/ds9/EFTA00205970/EFTA00205970.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..07a92e03596a9a8a30d9e7632d45404e9f127384 --- /dev/null +++ b/marker2/ds9/EFTA00205970/EFTA00205970.metadata.json @@ -0,0 +1,60 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205970.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 672, + "elapsed_seconds": 0.51, + "image_assets": [ + "_page_0_Picture_8.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 29 + ], + [ + "Line", + 13 + ], + [ + "Text", + 8 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205970" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205970/_page_0_Picture_8.jpeg b/marker2/ds9/EFTA00205970/_page_0_Picture_8.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..4954b194d28e2e783b6a7436bde275aa83ad864e --- /dev/null +++ b/marker2/ds9/EFTA00205970/_page_0_Picture_8.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:a79890507b1303fda32b130c0cb6accdcfc27db19919d2066b026d0219ecf9fe +size 10318 diff --git a/marker2/ds9/EFTA00205971/EFTA00205971.md b/marker2/ds9/EFTA00205971/EFTA00205971.md new file mode 100644 index 0000000000000000000000000000000000000000..89467a6128963462b5f772d09028c30c194ae051 --- /dev/null +++ b/marker2/ds9/EFTA00205971/EFTA00205971.md @@ -0,0 +1,37 @@ +Subject: RE: Epstein + +Date: Fri, 12 Aug 2011 22:13:37 +0000 + +Importance: Normal + +Good luck with the interview) + +I didn't realize you were still dealing with OPR. What a nightmare. + +Have you tried yoga? I find it really helps with stress and anxiety. + +Sent: Friday, August 12, 2011 5:52 PM + +Subject: RE: Epstein + +Thanks. I am really nervous. I got an interview for the magistrate position, but between this and the OPR thing, I am just a bundle of nerves. + +Sent: Frida Au ust 12 2011 5:41 PM + +Subject: RE: Epstein + +Thanks for letting me know. Have a good weekend, . + +Sent: Frida , Au ust 12, 2011 5:40 PM + +Subject: RE: Epstein + +Really hard to say. We won on some things, but Judge didn't like our argument re rights don't attach precharging. + +![](_page_1_Picture_0.jpeg) + +Sent: Frida Au.ust 12 2011 3:56 PM + +Subject: Epstein + +How did the Epstein hearing go? \ No newline at end of file diff --git a/marker2/ds9/EFTA00205971/EFTA00205971.metadata.json b/marker2/ds9/EFTA00205971/EFTA00205971.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..5d7583a19661c4867fb939c83afaf594f43978cf --- /dev/null +++ b/marker2/ds9/EFTA00205971/EFTA00205971.metadata.json @@ -0,0 +1,90 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205971.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 856, + "elapsed_seconds": 0.8, + "image_assets": [ + "_page_1_Picture_0.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 38 + ], + [ + "Line", + 18 + ], + [ + "Text", + 15 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 7 + ], + [ + "Text", + 4 + ], + [ + "Line", + 4 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205971" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205971/_page_1_Picture_0.jpeg b/marker2/ds9/EFTA00205971/_page_1_Picture_0.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..ed20a0477b89fec341a7abbe2af63f4d3353eacd --- /dev/null +++ b/marker2/ds9/EFTA00205971/_page_1_Picture_0.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:26c4f49c498be63c8ffdca9f69e9b56feea56ffb5d1d5018658bead7e9525006 +size 7143 diff --git a/marker2/ds9/EFTA00205973/EFTA00205973.md b/marker2/ds9/EFTA00205973/EFTA00205973.md new file mode 100644 index 0000000000000000000000000000000000000000..41cc6a0a53c2f6cf4ba1e42426129f12e9fa4b31 --- /dev/null +++ b/marker2/ds9/EFTA00205973/EFTA00205973.md @@ -0,0 +1,17 @@ +To: + +Subject: Read: Epstein Hearing + +Date: Fri, 12 Aug 2011 22:49:12 +0000 + +Importance: Normal + +Your message + +To: + +Subject: Epstein Hearing + +Sent: Friday, August 12, 2011 6:49:16 PM (UTC-05:00) Eastern Time (US & Canada) + +was read on Friday, August 12, 2011 6:49:12 PM (UTC-05:00) Eastern Time (US & Canada). \ No newline at end of file diff --git a/marker2/ds9/EFTA00205973/EFTA00205973.metadata.json b/marker2/ds9/EFTA00205973/EFTA00205973.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b577813f5a5f9ff694150f77579cf3ad32ef4c47 --- /dev/null +++ b/marker2/ds9/EFTA00205973/EFTA00205973.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205973.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 308, + "elapsed_seconds": 0.54, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 21 + ], + [ + "Line", + 11 + ], + [ + "Text", + 10 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205973" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205974/EFTA00205974.md b/marker2/ds9/EFTA00205974/EFTA00205974.md new file mode 100644 index 0000000000000000000000000000000000000000..f28c48e8d252d55d9f5f1c5d46022347ff2a0da7 --- /dev/null +++ b/marker2/ds9/EFTA00205974/EFTA00205974.md @@ -0,0 +1,150 @@ +To: ' (USAFLS)" <1 >, <2011®hp-s0-71- 2.usa.doj.gov>, at 2: <00.p.m.@hp-s0-71-2.usa.doj.gov>; + +Subject: RE: Jane Does 1 and 21 United States - Hearing on Friday, August 12, 2011, at 2:00 p.m. + +Date: Mon, 22 Aug 2011 20:29:36 +0000 + +Importance: Normal + +Call me when you get a chance to discuss. + +From: (USAFLS) + +Sent: Thursda Au ust 18, 2011 12:03 PM + +To: (USAFLS) + +Subject: FW: Jane Does 1 and 21 United States - Hearing on Friday, August 12, 2011, at 2:00 p.m. + +Hi — I am sorry to burden you. Can you scroll down to my email to on August 16th and then read up to the top? + +I am working on my OPR thing which I really have to give my full attention to, but I don't want to mess up the Jane Does case because I can't get to that quickly enough. Can you just give me your initial impressions? + +Assistant U.S. Attorney + +From: M, (USAFLS) + +Sent: Wednesda Au ust 17, 2011 3:05 PM + +To: (USAFLS) + +Cc: (USAFLS) + +Subject: RE: Jane Does 1 and 21 United States - Hearing on Friday, August 12, 2011, at 2:00 p.m. + +Yes. We would seek leave to file this supplemental brief, and attach the supplemental brief as an Exhibit for the Court, and our opposition, to review. Since this brief will be laden with practical examples of the burdens which would be placed on the government, in the event CVRA rights were found to attach prior to the filing of a formal charge, I believe you are in a much better position to list these examples. + +From: (USAFLS) + +Sent: Wednesday, August 17, 2011 3:00 PM + +To: IMISAFLS) + +Cc: (USAFLS) + +Subject: RE: Jane Does 1 and 21 United States - Hearing on Friday, August 12, 2011, at 2:00 p.m. + +Alright. Do you want to draft something or should I? I think it would be best to file the Motion for Leave to File Supplemental Briefing along with the actual supplemental briefing, don't you? + +I ;V\ + +From: M, (USAFLS) Sent: Wednesda , Au ust 17, 2011 2:50 PM To: . (USAFLS) Cc: (USAFLS) Subject: RE: Jane Does 1 and 21 United States - Hearing on Friday, August 12, 2011, at 2:00 p.m. + +I think it's a good idea to seek leave to submit additional briefing on the issue of impairing prosecutorial discretion if CVRA rights are found to attach prior to the filing of a formal charge. + +I would be careful with the waiver of sovereign immunity argument. Only Congress can waive the sovereign immunity of the United States, and it does so through enactment of statutes. If the government's filing of a formal criminal charge constitutes a waiver of sovereign immunity, that would only be so because a federal statute so provides. I am aware of none. Title 28, United States Code, section 1345, confers subject matter jurisdiction on the federal courts where the United States brings the civil action. This does not constitute a waiver of sovereign immunity to any counterclaim the defendant wants to file. Thus, submitting to the jurisdiction of the court, by filing a lawsuit as a plaintiff, does not open up the federal government to a counterclaim. I believe the same logic would apply in the criminal context. + +Also, actions for specific relief, e.g. injunctive relief, against U.S. Government officials have been allowed under the theory that the claim being made is that the federal government official acted beyond his or her statutory authority, e.g. ultra vires. Since the official is acting beyond his statutory authority, the official's actions are considered individual, and not sovereign actions. Larson I Domestic & Foreign Commerce Corp. 337 U.S. 682 (1949). Thus, the action is against the individual official, not the sovereign. + +As to why a formal charge is necessary before CVRA rights attach, it seems logical that the statute should allow the Attorney General and those acting on his behalf, to exercise unfettered prosecutorial discretion in terms of accepting a case for prosecution, who to charge, what to charge, and when to charge. We should be allowed to do all those things without having to consult with any victims of the offenses. However, once we have exercised our prosecutorial discretion, and formally charged someone, then it becomes less a restriction on our prosecutorial discretion to make us do things like consult, notify victims of hearings, and addressing the court when necessary. Once a case is charged, the government has far less discretion, since our actions are now governed by the Federal Rules of Criminal Procedure, caselaw, and rules of the federal courts. + +From: (USAFLS) Sent: Tuesda August 16, 2011 5:32 PM To: USAFLS) Cc: (USAFLS) Subject: RE: Jane Does 1 and 2 I. United States - Hearing on Friday, August 12, 2011, at 2:00 p.m. + +Hi and 1 have been bouncing some ideas around and wanted to share them with you before we shared them with the whole group. + +It seems that there were two points that were left hanging that were not completely answered during the argument. One was Judge Marra's repeated questions about "how would this really impact the + +government's discretion," alternatively phrased as, "couldn't you just have picked up the phone and called them?" The second was Cassell's claim that "the floodgates hadn't opened" since the decision in In re Dean. + +As to the first, I don't think that Judge Marra truly grasped the magnitude of what he was suggesting and certain examples would seem to bring the issue into clearer focus. For example, the position of the movants would require AUSAs (not agents, not victim-witness coordinators, not secretaries), to personally "consult" with every victim in advance of declining a case or deferring to a state prosecution. Imagine how burdensome this would be in cases like these: + +- A credit card "skimmer" case, where the defendant may have "skimmed" the credit card numbers of hundreds of victims. +- A child pornography case, where the defendant may have up to a million images of child pornography on his computer. +- A theft of mail case where the defendant may have stolen dozens or hundreds of pieces of mail. +- A white collar fraud case with a large number of victims. + +The court also should consider a situation, like the one here, where one of the "victims" is essentially in the defense camp. By consulting with him/her, especially in a case where we plan to defer to the State, we would be disclosing what could be a confidential investigation. + +The Court asked Cassell "how far back does it go?" The distinction between pre-charge and post-charge is the clearest line, and a line is necessary. It also is an appropriate line for two reasons. First, as I mentioned during the hearing, the United States has sovereign immunity from suit. We waive that immunity when we submit to the court's jurisdiction — via the filing of a criminal complaint or an indictment. Thus, drawing the line at the point of filing a charge is consistent with separation of powers principles. Second, prior to the filing of a public charge, there are constitutional due process principles (as incorporated in part in Rule 6(e)) governing the defendant's right not to be publicly accused of a crime without the opportunity to defend himself. By waiting until there is a public charge, there can be no claim of violation of grand jury secrecy. Also by waiting until there is a public charge, there can be no claim of the type of "conflict of interest" that has arisen in this case — where Epstein could manufacture a claim that we are investigating him due to pressure brought to bear by the victims' suit. + +As to the second point, Cassell's claim that the "floodgates hadn't opened," I beg to differ. I spent about 4 hours yesterday going through district court filings on Lexis Courtlink, and although I wasn't able to review each and every one, I did find several good examples: + +- Thibeaux I. Doherty, 08-CV-61848, S.D. Fla. (Judge Cohn). Plaintiff sued 2 U.S. District Judges, several AUSAs, the clerk of court, and 2 U.S. Magistrate Judges claiming that they committed the crime of obstruction of justice in connection with his 2255 Petition. The plaintiff asked for relief pursuant to 3771(d)(3). +- Piskanini Cameron, 11-CV-76 (W.D. Pa.) Plaintiff sued the Superintendent and Warden of the Prison along with the Pennsylvania Board of Probation and Parole. Plaintiff asked the court to order the USAO to "meet and confer with this crime victim to determine the procedure and need to initial Federal Criminal Prosecutions against petitioner's retaliators." +- Hentges I. State of Minnesota, et al., 10-CV-4081 (D. Minn.) Plaintiff sued State of Minnesota, Minnesota Attorney General, 2 Minnesota trial court judges, 1 Minnesota appellate judges, the child support enforcement unit officers in Colorado and Minnesota, and various County Attorneys. Plaintiff demanded immediate "federal protection, including restraining orders" and issuance of arrest warrants, and crime victim compensation. Plaintiff claimed that the defendants violated 18 USC 514 "Presentation of Fictitious Obligations" by forcing him to pay child support that he claimed he had + +Do you think it is worth asking Judge Marra for permission to file supplemental briefing addressing these two discrete issues? + +Assistant U.S. Attorne + +Fax + +From: M, (USAFLS) + +Sent: Tuesda Au ust 16, 2011 9:39 AM + +To: . (USAFLS); (USAFLS); (USAFLS); (USAFLS) + +Cc: .(USAFLS); (USAFLS) + +Subject: RE: Jane Does 1 and 2 I. United States - Hearing on Friday, August 12, 2011, at 2:00 p.m. + +Willy, + +The hearing last 2.5 hours. Judge Marra first heard from the proposed intervenors, Bruce Reinhart and Roy Black. Bruce seeks to intervene to move for sanctions against the victims' attorneys for making baseless allegations against Reinhart for purported violations of DOJ and Florida Bar rules. Black seeks to intervene to prevent the unsealing and use of Epstein's defense attorneys' work product, as referenced in the series of onesided e-mails provided to the victims' attorneys in the civil litigation against Epstein. Judge Marra gave Black and the government two weeks to submit additional briefing on the issue, with an opportunity for the victims to respond. Marra questioned how a matter could still be protected attorney work-product if it had been revealed to the government, the opposing side, in the Epstein criminal investigation. Black argued that criminal defense attorneys should be allowed to be candid and frank with prosecutors, free from any fear that their thoughts and impressions will be made public at some future time. + +The court denied the victims' motion to accept facts. Judge Marra said the victims had not denominated their motion as one for summary judgment, recognized that many of the alleged "facts" were opinions and conclusions, and said it was unfair to make the government stipulate or disagree with those "facts." The Court heard argument on the motion to compel the government to provide relevant information helpful to their case, and the motion for a finding that the CVRA had been violated. + +During our portion of the argument, I emphasized section 3771(d)(6)'s admonition that "inlothing in this chapter shall be construed to impair the prosecutorial discretion of the Attorney General or any officer under his direction." I suggested that, if the court was faced with two possible interpretations of a provision, and one would impair the A/G's prosecutorial discretion and one would not, the court was obligated to choose the one that would not. + +Judge Marra was skeptical that applying 3771(a)(5), the right to reasonably consult with the attorney for the government in the case, would really impair prosecutorial discretion. At one point, he stated that, if the government had consulted with the victims prior to entering into the non-prosecution agreement, while the victims may not have agreed with that course of action, there was nothing they could do. He asked how that would impair prosecutorial discretion. I argued that U.S. Attorney's Offices decline prosecutions frequently, and that construing 3771(a)(5) to apply prior to the filing of a formal charge, would require the government to consult with identified victims prior to declining a case for prosecution. Additionally, I expressed pessimism that victims would not try to seek court intervention in the event an unfavorable decision had been made by the U.S. Attorney's Office. + +The Court inquired about an evidentiary hearing. I told the Court that the government had asserted a 'best efforts" defense, and that the resolution of that issue would require an evidentiary hearing. On the issue of discovery, the Court asked me if it had the authority to permit discovery. I said yes, if the court believed discovery was necessary to resolve disputed factual issues in the case. + +I do not expect the court to rule until the round of briefing on the work-product issue is completed. I have included and on this e-mail. They both attended the hearing and I welcome any comments they might want to add. + +From: (USAFLS) Sent: Tuesda August 16, 2011 9:02 AM To: (USAFLS); (USAFLS); I., (USAFLS); Subject: RE: Jane Does 1 and 2 United States - Hearing on Friday, August 12, 2011, at 2:00 p.m. (USAFLS) + +What happened at the hearing? + +From: (USAFLS) Sent: Frida Au ust 12, 2011 9:16 AM To: USAFLS • (USAFLS); (USAFLS); (USAFLS • . USAFLS Cc: (USAFLS); (USAFLS); (USAFLS) Subject: RE: Jane Does 1 and 2 United States - Hearing on Friday, August 12, 2011, at 2:00 p.m. + +Good luck. Let me know what happens after the hearing. Sure to get press calls. + +From: (USAFLS) Sent: Frida Au ust 12, 2011 9:07 AM To: (USAFLS); M, (USAFLS); (USAFLS); (USAFLS)\_\_\_ Cc: I M (USAFLS); III (USAFLS); (USAFLS) Subject: Re: Jane Does 1 and 2 United States - Hearing on Friday, August 12, 2011, at 2:00 p.m. + +Best of luck, We're in good hands with you there. Thanks for all your hard work in this difficult matter. + +From: (USAFLS) Sent: Fricaugust 12, 2011 12:06 AM To: M, (USAFLS); (USAFLS); (USAFLS); - (USAFLSL\_\_ Cc: (USAFLS); IIII (USAFLS); (USAFLS) Subject: Re: Jane Does 1 and 2 United States - Hearing on Friday, August 12, 2011, at 2:00 p.m. + +I agree that we should go forward with our best efforts defense, at least at this point. + +Good luck tomorrow, Hopefully, the judge will realize that he never needs to get to the best efforts defense or to any evidentiary hearing. + +From: M, Sent: Thursda To: Cc: (USAFLS) Au ust 11, 2011 07:38 PM (USAFLS); (USAFLS); (USAFLS (USARS); -. USAFLS (USAFLS); (USAFLS) + +Colleagues, + +Judge Marra will be holding a hearing tomorrow, August 12, at 2:00 p.m., on the victims four (4) motions. In the court's order, he stated he would be asking for the parties' positions on whether an evidentiary hearing is necessary. For our part, on the legal issue of whether rights under the Crime Victims Rights Act attached prior to the filing of a formal charge, the government does not believe any evidentiary hearing is necessary. The only two facts which are relevant are not disputed by the victims: (1) no formal charge was ever filed against Epstein in the S.D.Fla.; and (2) Epstein entered pleas of guilty to state charges on June 30, 2008, in Palm Beach County Circuit Court. + +If the court were to find that CVRA rights did attach in the absence of a formal charge against Epstein, the government has asserted that it used its "best efforts" to comply with the CVRA. In October 2007, after the non-prosecution agreement was signed, FBI agents met with four victims and advised them of the agreement. There is a dispute over what was told to these individuals, and the reasons why notifications to other victims did not occur. The victims also claim that CVRA letters sent to them by the FBI in January 2008 and May 2008 were deceptive, since an agreement with Epstein had already been reached (although not fully approved by Main Justice). + +I believe an evidentiary hearing would be necessary for the government to present its "best efforts" defense. This would involve the government calling witnesses, including M, the FBI agents, and other current and former DOJ employees with relevant knowledge of our efforts to comply with the CVRA. + +We need to decide whether to maintain our best efforts defense, since it exposes us to an opportunity for the victims to probe what we did, and why we did it, and provide a platform for making us look bad. One consideration is whether our chances of prevailing, e.g. convincing the Court that we did use our best efforts, is sufficiently great to justify the effort and ordeal. + +I believe we should go forward with our best efforts defense. Our office did its best to ensure the victims were apprised of events in the matter involving Epstein, despite howls of protest coming from Epstein's attorneys. Our office had to walk a narrow path between perceived CVRA responsibilities, the incessant complaining from Epstein's legal camp, and preserving what might still have been a federal prosecution of Epstein had he gotten the agreement overturned at DOJ, or reneged on it completely. Giving up on the best efforts defense would be conceding too much. + +: We will call you tomorrow after the hearing, to let you know about what went on, and the press coverage. + +I will be leaving here at 9:00 a.m. and hope to be at the West Palm Beach office by 11:00 a.m. Thanks. \ No newline at end of file diff --git a/marker2/ds9/EFTA00205974/EFTA00205974.metadata.json b/marker2/ds9/EFTA00205974/EFTA00205974.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..8f81346ee367ae8c334dbd9639b45f8483554b1f --- /dev/null +++ b/marker2/ds9/EFTA00205974/EFTA00205974.metadata.json @@ -0,0 +1,212 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205974.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 6, + "chars": 17171, + "elapsed_seconds": 1.64, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 71 + ], + [ + "Line", + 35 + ], + [ + "Text", + 26 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 81 + ], + [ + "Line", + 39 + ], + [ + "Text", + 10 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 97 + ], + [ + "Line", + 49 + ], + [ + "ListItem", + 7 + ], + [ + "Text", + 5 + ], + [ + "ListGroup", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 3, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 84 + ], + [ + "Line", + 43 + ], + [ + "Text", + 18 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 4, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 99 + ], + [ + "Line", + 49 + ], + [ + "Text", + 12 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 5, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 67 + ], + [ + "Line", + 34 + ], + [ + "Text", + 10 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205974" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205980/EFTA00205980.md b/marker2/ds9/EFTA00205980/EFTA00205980.md new file mode 100644 index 0000000000000000000000000000000000000000..c96410410c79900afbbedc2f7c75dc234fc084d2 --- /dev/null +++ b/marker2/ds9/EFTA00205980/EFTA00205980.md @@ -0,0 +1,71 @@ +To: + +Subject: FW: FORMAL NOTICE of Office-wide Recusal of Southern District of Florida (GCO File No. REC-11-4159) + +Date: Wed, 24 Aug 2011 23:28:25 +0000 + +Importance: Normal + +FYI. + +From: + +Sent: Wednesday, August 24, 2011 3:32 PM + +To: Cc: + +Subject: FORMAL NOTICE of Office-wide Recusal of Southern District of Florida (GCO File No. REC-11-4159) + +## MEMORANDUM FOR: + +Wifredo A. Ferrer + +United States Attorney + +Southern District of Florida + +First Assistant United States Attorney + +Southern District of Florida + +Robert E. O'Neill + +United States Attorney + +Middle District of Florida + +First Assistance United States Attorney + +Middle District of Florida + +## THROUGH: + +Assistant General Counsel + +Executive Office for United States Attorneys + +RE: Office-Wide Recusal of Southern District of Florida from the Investigation + +and Potential Prosecution of Mr. Jeffery Epstein (GCO File No. REC-11-4159) + +THIS IS FORMAL NOTICE that David Margolis, Associate Deputy Attorney General (ADAG), approved the office-wide recusal of the United States Attorney's Office for the Southern District of Florida (SDFL) from all matters, to include the investigation and potential prosecution, relating to Jeffrey Epstein's alleged sexual activities with minor females. The ADAG authorized this recusal in accordance with United States Attorney's Manual (USAM) 3-2.170 and United States Attorney's Procedures (USAP) 3-2.170.001 based upon existing conflicts of interest or the appearance of conflicts of interest pertaining to the matter. + +ADAG Margolis has assigned this matter to the United States Attorney's Office for the Middle District of Florida and, pursuant to 28 U.S.C. ' 515(a)., has directed and authorized United States Attorney Robert E. O'Neill to conduct any kind of legal proceeding, civil or criminal, including grand jury proceedings and proceedings before committing magistrate judges, which the United States Attorney for the Southern District of Florida is authorized by law to conduct regarding this matter. See USAP 3-2.170.001(6).(C).(2)(b). + +Each office should communicate directly with each other concerning the investigations related to this matter in accordance with the procedures outlined in (mamma). T t for the Middle District of Florida is Criminal Chief who can be contacted a Thepoint of contact for the Southern District of Florida is irst ssistant United States Attorney who can be reached a + +All Assistant United States Attorneys subsequently assigned to this matter must be appointed as Special Attorneys in order to appear on behalf of the government in the Southern District of Florida. See USAM, 3- 2.300 and USAP 3-2.170.001(6)(C1(2)(b). Please contact Nicole West, EOUSA Personnel Staff, Policy and Special Programs Division, at to obtain the appointments. + +In accordance with USAP 3-2.170.001(6)1CX2M(3), any Special Attorney assigned the matter or case should sign any pleadings or documents using the signature block of the Middle District of Florida, with the addition of the Attorney General's name preceding that of the United States Attorney. + +iHa ltave any questions relating to this recusal matter, please contact Assistant General Counsel General Counsel's Office, EOUSA, at Thank you. + +Thank you, + +Assistant General Counsel + +General Counsel's Office + +Executive Office for United States Attorneys + +![](_page_2_Picture_0.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00205980/EFTA00205980.metadata.json b/marker2/ds9/EFTA00205980/EFTA00205980.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..67f74a0706871cf7775432dec816ed6e75888feb --- /dev/null +++ b/marker2/ds9/EFTA00205980/EFTA00205980.metadata.json @@ -0,0 +1,167 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205980.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 3351, + "elapsed_seconds": 1.39, + "image_assets": [ + "_page_2_Picture_0.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "MEMORANDUM FOR:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 328.05 + ], + [ + 164.14385986328125, + 328.05 + ], + [ + 164.14385986328125, + 344.1035461425781 + ], + [ + 30.6, + 344.1035461425781 + ] + ] + }, + { + "title": "THROUGH:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 685.26 + ], + [ + 103.70439147949219, + 685.26 + ], + [ + 103.70439147949219, + 701.4735412597656 + ], + [ + 30.6, + 701.4735412597656 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 55 + ], + [ + "Line", + 27 + ], + [ + "Text", + 22 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 83 + ], + [ + "Line", + 36 + ], + [ + "Text", + 15 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ], + [ + "Line", + 1 + ], + [ + "Span", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205980" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205980/_page_2_Picture_0.jpeg b/marker2/ds9/EFTA00205980/_page_2_Picture_0.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..b92bb0032958d49a3cbf7b821af9b58a0ea16ee9 --- /dev/null +++ b/marker2/ds9/EFTA00205980/_page_2_Picture_0.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:51409df33e65ad9380d905a3376e84686f0aa6109d8bd7074af503f918bd0372 +size 5948 diff --git a/marker2/ds9/EFTA00205983/EFTA00205983.md b/marker2/ds9/EFTA00205983/EFTA00205983.md new file mode 100644 index 0000000000000000000000000000000000000000..d553c25f19b3b12604f6cf2a56e1de1e448dabda --- /dev/null +++ b/marker2/ds9/EFTA00205983/EFTA00205983.md @@ -0,0 +1,23 @@ +From: "KATHERINE W. EZELL" -4 + +To: JOSEFSBERG" SAFLS " "ROBERT + +Subject: Re: Magistrate Interview + +Date: Wed, 24 Aug 2011 23:04:35 +0000 + +Importance: Normal + +That sounds so good, I think a hostile question answered well can be much more impressive and memorable than all friendly ones. We're behind you all the wayl Fingers crossed. Keep us posted! K Sent from my Blackberry. Please excuse any typos. Thank you. + +From: (USAFLS) [mailto. Sent: Wednesday, August 24, 2011 05:44 PM To: ROBERT I. JOSEFSBERG; KATHERINE W. EZELL; Amy Ederi < Subject: Magistrate Interview + +Hi Bob, Kathy, and Amy — I had my interview with the committee this afternoon, and it seemed to go pretty well (knock wood). Only one hostile question, and I think I answered the question satisfactorily. No questions about Epstein at all. + +Thank you so much for all of the well-wishes and good thoughts! + +They are finishing up the interviews on Saturday and everyone thinks we will have an answer on whom they are sending through to the District Judges on Saturday night or Sunday. + +Fingers crossed for a little while longer, please. + +00 \ No newline at end of file diff --git a/marker2/ds9/EFTA00205983/EFTA00205983.metadata.json b/marker2/ds9/EFTA00205983/EFTA00205983.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..26904367bc5c2d1051b52e92b3d9cbb79e7d9072 --- /dev/null +++ b/marker2/ds9/EFTA00205983/EFTA00205983.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205983.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1105, + "elapsed_seconds": 0.67, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 45 + ], + [ + "Line", + 23 + ], + [ + "Text", + 12 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205983" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205984/EFTA00205984.md b/marker2/ds9/EFTA00205984/EFTA00205984.md new file mode 100644 index 0000000000000000000000000000000000000000..324a5c2ed3a6986084338e510586dc61da71d000 --- /dev/null +++ b/marker2/ds9/EFTA00205984/EFTA00205984.md @@ -0,0 +1,31 @@ +Subject: RE: WPTV-- Jeffrey Epstein + +Date: Fri, 12 Aug 2011 20:36:45 +0000 + +Importance: Normal + +- We just left you a voicemail. Call if you c + +Ori inal Massa ,e + +Subject: RE: WPTV— Jeffrey Epstein + +Thanks for your email. I believe that agreement is not public. Additionally, we won't be making any out of court comments. + +Subject: WPTV-- Jeffrey Epstein + +Good afternoon-- I am attending the 2pm hearing in regards to case against the US attney over Jeffrey Epstein's non-prosecution agreement. + +Case is 08-80736. Can u please send me a copy? In addition, please call me when you get a moment. + +Thank you! + +Katie LaGrone + +WPTV + +561-313.6334 + +Sent from iPhone + +Scripps Media, Inc., certifies that its advertising sales agreements do not discriminate on the basis of race or ethnicity. All advertising sales agreements contain nondiscrimination clauses. \ No newline at end of file diff --git a/marker2/ds9/EFTA00205984/EFTA00205984.metadata.json b/marker2/ds9/EFTA00205984/EFTA00205984.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..8a1e72a827a53630f04a358eadce8207355c3301 --- /dev/null +++ b/marker2/ds9/EFTA00205984/EFTA00205984.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205984.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 850, + "elapsed_seconds": 0.85, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 38 + ], + [ + "Line", + 19 + ], + [ + "Text", + 18 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205984" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205985/EFTA00205985.md b/marker2/ds9/EFTA00205985/EFTA00205985.md new file mode 100644 index 0000000000000000000000000000000000000000..4910a730bfd1df19a11d9e16c9421f9f2c2069e4 --- /dev/null +++ b/marker2/ds9/EFTA00205985/EFTA00205985.md @@ -0,0 +1,33 @@ +To: "LaGrone, Katie (WPTV)" + +Cc: "Castillo, Annette (USAFL + +Subject: RE: WPTV-- Jeffrey Epstei + +Date: Fri, 12 Aug 2011 18:15:12 +0000 + +Importance: Normal + +Thanks for your email. I believe that agreement is not public. Additionally, we won't be making any out of court comments. + +Message---- + +From: LaGrone, Katie (WPTVJI + +Sent: Friday, August 12, 2011 1: + +To: + +Subject: WPTV-- Jeffrey Epstein + +Good afternoon-- I am attending the 2pm hearing in regards to case against the US attney over Jeffrey Epstein's non-prosecution agreement. + +Case is 08-80736. Can u please send me a copy? In addition, please call me when you get a moment. + +Thank you! + +Katie LaGrone + +Sent from iPhone + +Scripps Media, Inc., certifies that its advertising sales agreements do not discriminate on the basis of race or ethnicity. All advertising sales agreements contain nondiscrimination clauses. \ No newline at end of file diff --git a/marker2/ds9/EFTA00205985/EFTA00205985.metadata.json b/marker2/ds9/EFTA00205985/EFTA00205985.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..0431cbd509fc1eb1d849982fc745e6e4306b9521 --- /dev/null +++ b/marker2/ds9/EFTA00205985/EFTA00205985.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205985.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 869, + "elapsed_seconds": 0.86, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 41 + ], + [ + "Line", + 21 + ], + [ + "Text", + 19 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205985" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205986/EFTA00205986.md b/marker2/ds9/EFTA00205986/EFTA00205986.md new file mode 100644 index 0000000000000000000000000000000000000000..a1f137ecf3001dd05069265de38f7d0e72bd26d0 --- /dev/null +++ b/marker2/ds9/EFTA00205986/EFTA00205986.md @@ -0,0 +1,13 @@ +Subject: Read: RE: Epstein + +Date: Fri, 12 Aug 2011 21:40:44 +0000 + +Importance: Normal + +Your message + +Subject: RE: Epstein + +Sent: Friday, August 12, 2011 5:39:46 PM (UTC-05:00) Eastern Time (US & Canada) + +was read on Friday, August 12, 2011 5:40:44 PM (UTC-05:00) Eastern Time (US & Canada). \ No newline at end of file diff --git a/marker2/ds9/EFTA00205986/EFTA00205986.metadata.json b/marker2/ds9/EFTA00205986/EFTA00205986.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..ad544ec1e9a211be7fea079b599c876b25ae9ddc --- /dev/null +++ b/marker2/ds9/EFTA00205986/EFTA00205986.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205986.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 290, + "elapsed_seconds": 0.41, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 15 + ], + [ + "Line", + 8 + ], + [ + "Text", + 7 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205986" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205987/EFTA00205987.md b/marker2/ds9/EFTA00205987/EFTA00205987.md new file mode 100644 index 0000000000000000000000000000000000000000..813b39b19f26d5a190ebea6a9ef0d8d657315a7d --- /dev/null +++ b/marker2/ds9/EFTA00205987/EFTA00205987.md @@ -0,0 +1,41 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA + +CASE No. 08-80736-CIV-MARRA/JOHNSON + +JANE DOE 1 and JANE DOE 2, + +Plaintiffs, + +![](_page_0_Picture_4.jpeg) + +UNITED STATES OF AMERICA, + +Defendant. + +## UNOPPOSED MOTION OF PROPOSED INTERVENORS FOR A ONE-WEEK EXTENSION OF TIME To FILE ADDITIONAL BRIEFING + +Following the hearing on August 12, 2011, the Court gave proposed intervenors Black, Weinberg, and Lefkowitz until Friday, August 26 to file supplemental briefing on the issues raised concerning plea negotiations with Jeffrey Epstein. Also following the hearing, the decision was made for Mr. Epstein to file a motion seeking limited intervention so that there are no procedural issues regarding whether the protections and policies relating to Federal Rules of Evidence 410 and 408 should be fully considered by the Court in determining whether to grant or deny the plaintiffs' discovery requests for plea negotiation correspondence between Mr. Epstein's lawyers and the U.S. Attorney's Office. We intended to file Mr. Epstein's motion to intervene by the Court's deadline of August 26, 2011. + +We now anticipate that our office will be closed all day Thursday due to Hurricane Irene, and our office may be closed part of the day Wednesday as well. We won't know until after Irene arrives whether our office will be closed on Friday as well. With these time limitations, we will not be able to file our papers as well as Mr. Epstein's motion to intervene and supporting memorandum by the + +present deadline of August 26. We have spoke with counsel for Jane Doe 1 and Jane Doe 2 as well as counsel for the government, and all have stated that they do not object to the extension of time requested here. + +Accordingly, we respectfully request an extension of time until Friday, September 2, 2011, to file the supplemental briefing of proposed intervenors Black, Weinberg & Lefkowitz, and to file a motion for limited intervention to assert rights under Rules of Evidence 408 and 410. + +We certify that on August 22, 2011, the foregoing document was filed electronically with the Clerk of the Court using the CM/ECF system. + +Respectfully submitted, + +BLACK, SREBNICIC, KORNSPAN + +Miami, Florida 33131 + +By /S/ + +ROY BLAC ES . + +Florida Bar N + +JACKIE PERCZEK, ESQ. + +Florida Bar No \ No newline at end of file diff --git a/marker2/ds9/EFTA00205987/EFTA00205987.metadata.json b/marker2/ds9/EFTA00205987/EFTA00205987.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..cf1dc0b7a920d1fd151835c9ec6d6ca2c27d7077 --- /dev/null +++ b/marker2/ds9/EFTA00205987/EFTA00205987.metadata.json @@ -0,0 +1,141 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205987.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2282, + "elapsed_seconds": 0.71, + "image_assets": [ + "_page_0_Picture_4.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF FLORIDA", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 206.24400000000003, + 71.28 + ], + [ + 405.5263977050781, + 71.28 + ], + [ + 405.5263977050781, + 100.353515625 + ], + [ + 206.24400000000003, + 100.353515625 + ] + ] + }, + { + "title": "UNOPPOSED MOTION OF PROPOSED INTERVENORS FOR A \nONE-WEEK EXTENSION OF TIME To FILE ADDITIONAL BRIEFING", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 138.312, + 297.27 + ], + [ + 471.91326904296875, + 297.27 + ], + [ + 471.91326904296875, + 326.8535461425781 + ], + [ + 138.312, + 326.8535461425781 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 49 + ], + [ + "Line", + 24 + ], + [ + "Text", + 8 + ], + [ + "SectionHeader", + 2 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 35 + ], + [ + "Line", + 18 + ], + [ + "Text", + 11 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205987" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205987/_page_0_Picture_4.jpeg b/marker2/ds9/EFTA00205987/_page_0_Picture_4.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..d0f87e91dd739bab269e2a2e5129393f6a804cd9 --- /dev/null +++ b/marker2/ds9/EFTA00205987/_page_0_Picture_4.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:52a2e4836afc7046cd566a7e8037d5dddbccf2c093a9eda472ad9733a3cb5549 +size 874 diff --git a/marker2/ds9/EFTA00205989/EFTA00205989.md b/marker2/ds9/EFTA00205989/EFTA00205989.md new file mode 100644 index 0000000000000000000000000000000000000000..204d33f4b5592188ab8866296ce44e74f24fab08 --- /dev/null +++ b/marker2/ds9/EFTA00205989/EFTA00205989.md @@ -0,0 +1,15 @@ +To: (USAFLS)" alMIN> + +Subject: Epstein Stuff + +Date: Tue, 02 Aug 2011 14:56:32 +0000 + +Importance: Normal + +Hi • — I have been dealing with a 2255 on a case that was litigated by Orlando Prescott in 1998. This guy files new motions every day. I filed a response to a motion to recuse yesterday and I have to respond to another motion today. I should have it finished in a couple of hours and then I will give you a call about the Epstein letter. + +I was wondering if you and picked out a time on Thursday to get together? + +Assistant U.S. Attorney + +Fax \ No newline at end of file diff --git a/marker2/ds9/EFTA00205989/EFTA00205989.metadata.json b/marker2/ds9/EFTA00205989/EFTA00205989.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..38aeb648cd5fc58c64c44ac01db8d88c9a55e935 --- /dev/null +++ b/marker2/ds9/EFTA00205989/EFTA00205989.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205989.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 547, + "elapsed_seconds": 0.63, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 25 + ], + [ + "Text", + 13 + ], + [ + "Line", + 13 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205989" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205990/EFTA00205990.md b/marker2/ds9/EFTA00205990/EFTA00205990.md new file mode 100644 index 0000000000000000000000000000000000000000..109a5d4f721ee351bad17e8406b5b7884f907434 --- /dev/null +++ b/marker2/ds9/EFTA00205990/EFTA00205990.md @@ -0,0 +1,150 @@ +To: + +Subject: Re: Jane Does 1 and 2 1 United States - Hearing on Friday, August 12, 2011, at 2:00 p.m. + +Date: Tue, 16 Aug 2011 22:22:48 +0000 + +Importance: Normal + +I read them - do you want to talk about something specific? 202 258 8965. In car for next 40 minutes + +From: + +To: Rotker, Michael + +Sent: Tue Aug 16 17:39:59 2011 + +Subject: FW: Jane Does 1 and 21 United States - Hearing on Friday, August 12, 2011, at 2:00 p.m. + +Hi Mike — Can you start with Dexter's email down at the bottom and then read mine? Also, I was reading 3771(d)(3) [the venue provision] for the 1000th time, and I wonder — could it refer to habeas proceedings99999 + +Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 561-209-1047 Fax 561-802-1787 + +From: + +Sent: Tuesday, August 16, 2011 5:32 PM + +To: + +Cc + +Subject: RE: Jane Does 1 and 21 United States - Hearing on Friday, August 12, 2011, at 2:00 p.m. + +Hi Dexter — Karen and I have been bouncing some ideas around and wanted to share them with you before we shared them with the whole group. + +It seems that there were two points that were left hanging that were not completely answered during the argument. One was Judge Marra's repeated questions about "how would this really impact the government's discretion," alternatively phrased as, "couldn't you just have picked up the phone and called them?" The second was Cassell's claim that "the floodgates hadn't opened" since the decision in In re Dean. + +As to the first, I don't think that Judge Marra truly grasped the magnitude of what he was suggesting and certain examples would seem to bring the issue into clearer focus. For example, the position of the movants would require AUSAs (not agents, not victim-witness coordinators, not secretaries), to personally "consult" with every victim in advance of declining a case or deferring to a state prosecution. Imagine how burdensome this would be in cases like these: + +- A credit card "skimmer" case, where the defendant may have "skimmed" the credit card numbers of hundreds of victims. +- A child pornography case, where the defendant may have up to a million images of child pornography on his computer. +- A theft of mail case where the defendant may have stolen dozens or hundreds of pieces of mail. +- A white collar fraud case with a large number of victims. + +The court also should consider a situation, like the one here, where one of the "victims" is essentially in the defense camp. By consulting with him/her, especially in a case where we plan to defer to the State, we would be disclosing what could be a confidential investigation. + +The Court asked Cassell "how far back does it go?" The distinction between pie-charge and post-charge is the clearest line, and a line is necessary. It also is an appropriate line for two reasons. First, as I mentioned during the hearing, the United States has sovereign immunity from suit. We waive that immunity when we submit to the court's jurisdiction — via the filing of a criminal complaint or an indictment. Thus, drawing the line at the point of filing a charge is consistent with separation of powers principles. Second, prior to the filing of a public charge, there are constitutional due process principles (as incorporated in part in Rule 6(e)) governing the defendant's right not to be publicly accused of a crime without the opportunity to defend himself. By waiting until there is a public charge, there can be no claim of violation of grand jury secrecy. Also by waiting until there is a public charge, there can be no claim of the type of "conflict of interest" that has arisen in this case — where Epstein could manufacture a claim that we are investigating him due to pressure brought to bear by the victims' suit. + +As to the second point, Cassell's claim that the "floodgates hadn't opened," I beg to differ. I spent about 4 hours yesterday going through district court filings on Lexis Courtlink, and although I wasn't able to review each and every one, I did find several good examples: + +- Thibeaux I. Doherty, 08-CV-61848, S.D. Fla. (Judge Cohn). Plaintiff sued 2 U.S. District Judges, several AUSAs, the clerk of court, and 2 U.S. Magistrate Judges claiming that they committed the crime of obstruction of justice in connection with his 2255 Petition. The plaintiff asked for relief pursuant to 3771(d)(3). +- Piskanin I Cameron, 11-CV-76 (W.D. Pa.) Plaintiff sued the Superintendent and Warden of the Prison along with the Pennsylvania Board of Probation and Parole. Plaintiff asked the court to order the USAO to "meet and confer with this crime victim to determine the procedure and need to initial Federal Criminal Prosecutions against petitioner's retaliators." +- Hentges 1 State of Minnesota, et al., 10-CV-4081 (D. Minn.) Plaintiff sued State of Minnesota, Minnesota Attorney General, 2 Minnesota trial court judges, 1 Minnesota appellate judges, the child support enforcement unit officers in Colorado and Minnesota, and various County Attorneys. Plaintiff demanded immediate "federal protection, including restraining orders" and issuance of arrest warrants, and crime victim compensation. Plaintiff claimed that the defendants violated 18 USC 514 "Presentation of Fictitious Obligations" by forcing him to pay child support that he claimed he had previously paid. Plaintiff demanded the issuance of arrest warrants and charges based on 3771. + +Do you think it is worth asking Judge Marra for permission to file supplemental briefing addressing these two discrete issues? + +Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 561-209-1047 Fax 561-802-1787 + +From: + +Sent: Tuesday, August 16, 2011 9:39 AM + +To: Ferrer, Wifredo A. (USAFLS);. , ( I" - -), tl - • ' ( ti - -1, ti ." I r1' — -) + +Cc: + +The hearing last 2.5 hours. Judge Marra first heard from the proposed intervenors, and Roy Black. MN seeks to intervene to move for sanctions against the victims' attorneys for making baseless allegations against Reinhart for purported violations of DOJ and Florida Bar rules. Black seeks to intervene to prevent the unsealing and use of Epstein's defense attorneys' work product, as referenced in the series of one-sided e-mails provided to the victims' attorneys in the civil litigation against Epstein. Judge Marra gave Black and the government two weeks to submit additional briefing on the issue, with an opportunity for the victims to respond. Marra questioned how a matter could still be protected attorney work-product if it had been revealed to the government, the opposing side, in the Epstein criminal investigation. Black argued that criminal defense attorneys should be allowed to be candid and frank with prosecutors, free from any fear that their thoughts and impressions will be made public at some future time. + +The court denied the victims' motion to accept facts. Judge Marra said the victims had not denominated their motion as one for summary judgment, recognized that many of the alleged "facts" were opinions and conclusions, and said it was unfair to make the government stipulate or disagree with those "facts." The Court heard argument on the motion to compel the government to provide relevant information helpful to their case, and the motion for a finding that the CVRA had been violated. + +During our portion of the argument, I emphasized section 3771(d)(6)'s admonition that In]othing in this chapter shall be construed to impair the prosecutorial discretion of the Attorney General or any officer under his direction." I suggested that, if the court was faced with two possible interpretations of a provision, and one would impair the A/G's prosecutorial discretion and one would not, the court was obligated to choose the one that would not. + +Judge Marra was skeptical that applying 3771(a)(5), the right to reasonably consult with the attorney for the government in the case, would really impair prosecutorial discretion. At one point, he stated that, if the government had consulted with the victims prior to entering into the non-prosecution agreement, while the victims may not have agreed with that course of action, there was nothing they could do. He asked how that would impair prosecutorial discretion. I argued that U.S. Attorney's Offices decline prosecutions frequently, and that construing 3771(a)(5) to apply prior to the filing of a formal charge, would require the government to consult with identified victims prior to declining a case for prosecution. Additionally, I expressed pessimism that victims would not try to seek court intervention in the event an unfavorable decision had been made by the U.S. Attorney's Office. + +The Court inquired about an evidentiary hearing. I told the Court that the government had asserted a 'best efforts" defense, and that the resolution of that issue would require an evidentiary hearing. On the issue of discovery, the Court asked me if it had the authority to permit discovery. I said yes, if the court believed discovery was necessary to resolve disputed factual issues in the case. + +I do not ex ect -te court to rule until the round of briefing on the work-product issue is completed. I have included IMP and n this e-mail. They both attended the hearing and I welcome any comments they might want to add. + +Dexter + +From: Ferrer, Wifredo A. (USAFLS) + +Sent: Tuesday, August 16, 2011 9:02 AM + +To: , Al Lee, , D~ gem + +Subject: RE: Jane Does 1 and 2 II United States - Hearing on Friday, August 12, 2011, at 2:00 p.m. + +What happened at the hearing? + +From: Valle, Alicia (USAFLS) + +Sent: Friday, August 12, 2011 9:16 AM + +To: Ferrer, Wifredo A. (USAFLS); ViliefewerAncsOlecir err + +CC: + +From: Ferrer, Wifredo A. (USAFLS) + +Sent: Friday, August 12, 2011 9:07 AM + +To + +Cc: + +Subject: Re: Jane Does 1 and 21 United States - Hearing on Friday, August 12, 2011, at 2:00 p.m. + +Best of luck, Dexter. We're in good hands with you there. Thanks for all your hard work in this difficult matter. + +From: Sanchez, Eduardo (USN-LS) + +Sent: Friday, August 12, 2011 12:06 AM + +To: ienti 1111:',-.44,-. A (I !CACI C"), (i tcAri c), (''"') + +Cc: + +Subject: Re: Jane Does 1 and 2 United States - Hearing on Friday, August 12, 2011, at 2:00 p.m. + +I agree that we should go forward with our best efforts defense, at least at this point. + +Good luck tomorrow, algal. Hopefully, the judge will realize that he never needs to get to the best efforts defense or to any evidentiary hearing. + +From. Lee, uener kubRit) + +Sent: Thursday, August 11, 2011 07:38 PM + +To: Ferrer, Wifredo A. (USAFLS); Greenbelt + +Cr Sanchear + +Subject: Jane Does 1 and 21 United States - Hearing on Friday, August 12, 2011, at 2:00 p.m. + +Colleagues, + +Judge Marra will be holding a hearing tomorrow, August 12, at 2:00 p.m., on the victims four (4) motions. In the court's order, he stated he would be asking for the parties' positions on whether an evidentiary hearing is necessary. For our part, on the legal issue of whether rights under the Crime Victims Rights Act attached prior to the filing of a formal charge, the government does not believe any evidentiary hearing is necessary. The only two facts which are relevant are not disputed by the victims: (1) no formal charge was ever filed against Epstein in the S.D.Fla.; and (2) Epstein entered pleas of guilty to state charges on June 30, 2008, in Palm Beach County Circuit Court. + +If the court were to find that CVRA rights did attach in the absence of a formal charge against Epstein, the government has asserted that it used its "best efforts" to comply with the CVRA. In October 2007, after the non-prosecution agreement was signed, FBI agents met with four victims and advised them of the agreement. There is a dispute over what was told to these individuals, and the reasons why notifications to other victims did not occur. The victims also claim that CVRA letters sent to them by the FBI in January 2008 and May 2008 were deceptive, since an agreement with Epstein had already been reached (although not fully approved by Main Justice). + +I believe an evidentiary hearing would be necessary for the government to present its "best efforts" defense. This would involve the government calling witnesses, including 001•Pl. the FBI agents, and other current and former DOJ employees with relevant knowledge of our efforts to comply with the CVRA. + +We need to decide whether to maintain our best efforts defense, since it exposes us to an opportunity for the victims to probe what we did, and why we did it, and provide a platform for making us look bad. One consideration is whether our chances of prevailing, e.g. convincing the Court that we did use our best efforts, is sufficiently great to justify the effort and ordeal. + +I believe we should go forward with our best efforts defense. Our office did its best to ensure the victims were apprised of events in the matter involving Epstein, despite howls of protest coming from Epstein's attorneys. Our office had to walk a narrow path between perceived CVRA responsibilities, the incessant complaining from Epstein's legal camp, and preserving what might still have been a federal prosecution of Epstein had he gotten the agreement overturned at DOJ, or reneged on it completely. Giving up on the best efforts defense would be conceding too much. + +Alicia: We will call you tomorrow after the hearing, to let you know about what went on, and the press coverage. + +I will be leaving here at 9:00 a.m. and hope to be at the West Palm Beach office by 11:00 a.m. Thanks. + +Dexter \ No newline at end of file diff --git a/marker2/ds9/EFTA00205990/EFTA00205990.metadata.json b/marker2/ds9/EFTA00205990/EFTA00205990.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..be9bea24a2939875234bebda19d381318bb93998 --- /dev/null +++ b/marker2/ds9/EFTA00205990/EFTA00205990.metadata.json @@ -0,0 +1,190 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205990.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 5, + "chars": 13461, + "elapsed_seconds": 1.57, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 81 + ], + [ + "Line", + 40 + ], + [ + "Text", + 20 + ], + [ + "ListItem", + 4 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 102 + ], + [ + "Line", + 47 + ], + [ + "Text", + 11 + ], + [ + "ListItem", + 3 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 91 + ], + [ + "Line", + 45 + ], + [ + "Text", + 17 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 3, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 84 + ], + [ + "Line", + 41 + ], + [ + "Text", + 24 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 4, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 29 + ], + [ + "Line", + 15 + ], + [ + "Text", + 5 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205990" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205995/EFTA00205995.md b/marker2/ds9/EFTA00205995/EFTA00205995.md new file mode 100644 index 0000000000000000000000000000000000000000..ae5d480b04365d4b69c5426831de07b9d86b5f1b --- /dev/null +++ b/marker2/ds9/EFTA00205995/EFTA00205995.md @@ -0,0 +1,65 @@ +From: To: • (USAFLS)" < USAFLS)" (USAFLS)" Cc: "a i FliS-i"; >, at + +Subject: RE: Jane Does 1 and 2 g United States - Hearing on Friday, August 12, 2011, at 2:00 p.m. + +Date: Tue, 16 Aug 2011 23:02:58 +0000 + +Importance: Normal + +Thank you, Mike. I really appreciate it. + +Assistant U.S. Attorney + +Fax + +From: (CRM) + +Sent Tuesday, August 16, 2011 6:38 PM + +To: (USAFLS) + +Subject: Re: Jane Does 1 and 2 1 United States - Hearing on Friday, August 12, 2011, at 2:00 p.m. + +I admire you for how hard you've fought this case. Stay strong. + +From: (USAFLS) < + +To: + +Sent: Tue Aug 16 17:39:59 2011 + +Subject: FW: Jane Does 1 and 21 United States - Hearing on Friday, August 12, 2011, at 2:00 p.m. + +Hi Mike — Can you start with email down at the bottom and then read mine? Also, I was reading 3771(d)(3) [the venue provision] for the 1000th time, and I wonder — could it refer to habeas proceedings7???7 + +Assistant U.S. Attorne + +Fax + +From: (USAFLS) + +Sent: Tuesda August 16, 2011 5:32 PM + +To: Lee USAFLS) + +Cc: (USAFLS) + +Subject: RE: Jane Does 1 and 21 United States - Hearing on Friday, August 12, 2011, at 2:00 p.m. + +Hi and I have been bouncing some ideas around and wanted to share them with you before we shared them with the whole group. + +It seems that there were two points that were left hanging that were not completely answered during the argument. One was Judge Marra's repeated questions about "how would this really impact the government's discretion," alternatively phrased as, "couldn't you just have picked up the phone and called them?" The second was Cassell's claim that "the floodgates hadn't opened" since the decision in In re Dean. + +As to the first, I don't think that Judge Marra truly grasped the magnitude of what he was suggesting and certain examples would seem to bring the issue into clearer focus. For example, the position of the movants would require AUSAs (not agents, not victim-witness coordinators, not secretaries), to personally "consult" with every victim in advance of declining a case or deferring to a state prosecution. Imagine how burdensome this would be in cases like these: + +- A credit card "skimmer" case, where the defendant may have "skimmed" the credit card numbers of hundreds of victims. +- A child pornography case, where the defendant may have up to a million images of child pornography on his computer. +- A theft of mail case where the defendant may have stolen dozens or hundreds of pieces of mail. +- A white collar fraud case with a large number of victims. + +The court also should consider a situation, like the one here, where one of the "victims" is essentially in the defense camp. By consulting with him/her, especially in a case where we plan to defer to the State, we would be disclosing what could be a confidential investigation. + +The Court asked Cassell "how far back does it go?" The distinction between pre-charge and post-charge is the clearest line, and a line is necessary. It also is an appropriate line for two reasons. First, as I mentioned during the hearing, the United States has sovereign immunity from suit. We waive that immunity when we submit to the court's jurisdiction — via the filing of a criminal complaint or an indictment. Thus, drawing the line at the point of filing a charge is consistent with separation of powers principles. Second, prior to the filing of a public charge, there are constitutional due process principles (as incorporated in part in Rule 6(e)) governing the defendant's right not to be publicly accused of a crime without the opportunity to defend himself. By waiting until there is a public charge, there can be no claim of violation of grand jury secrecy. Also by waiting until there is a public charge, there can be no claim of the type of "conflict of interest" that has arisen in this case — where Epstein could manufacture a claim that we are investigating him due to pressure brought to bear by the victims' suit. + +As to the second point, Cassell's claim that the "floodgates hadn't opened," I beg to differ. I spent about 4 hours yesterday going through district court filings on Lexis Courtlink, and although I wasn't able to review each and every one, I did find several good examples: + +- Thibeaux Doherty, 08-CV-61848, S.D. Fla. (Judge Cohn). Plaintiff sued 2 U.S. District Judges, several AUSAs, the clerk of court, and 2 U.S. Magistrate Judges claiming that they committed the crime of obstruction of justice in connection with his 2255 Petition. The plaintiff asked for relief pursuant to 3771(d)(3). +- Piskanin Cameron, 11-CV-76 (W.D. Pa.) Plaintiff sued the Superintendent and Warden of the Prison along with the Pennsylvania Board of Probation and Parole. Plaintiff asked the court to order the USAO to "meet and confer with this crime victim to determine the procedure and need to initial Federal Criminal Prosecutions against petitioner's retaliators." +- Hentges I State of Minnesota, et al., 10-CV-4081 (D. Minn.) Plaintiff sued State of Minnesota, Minnesota Attorney General, 2 Minnesota trial court judges, 1 Minnesota appellate judges, the child support enforcement unit officers in Colorado and Minnesota, and various County Attorneys. Plaintiff demanded immediate "federal protection, including restraining orders" and issuance of arrest warrants, and crime victim compensation. Plaintiff claimed that the defendants violated 18 USC 514 "Presentation of Fictitious Obligations" by forcing him to pay child support that he claimed he had previously paid. Plaintiff demanded the issuance of arrest warrants and charges based on 3771. + +Do you think it is worth asking Judge Marra for permission to file supplemental briefing addressing these two discrete issues? + +Assistant U.S. Attorney + +From: Lee, (USAFLS) + +Sent: Tuesda Au ust 16, 2011 9:39 AM + +To: USAFLS); US (USAFLS); (USAFLS) + +Cc: . (USAFLS); (USAFLS) + +Subject: RE: Jane Does 1 and 2 1 United States - Hearing on Friday, August 12, 2011, at 2:00 p.m. + +The hearing last 2.5 hours. Judge Marra first heard from the proposed intervenors, Bruce Reinhart and Roy Black. Bruce seeks to intervene to move for sanctions against the victims' attorneys for making baseless allegations against Reinhart for purported violations of DOJ and Florida Bar rules. Black seeks to intervene to prevent the unsealing and use of Epstein's defense attorneys' work product, as referenced in the series of one-sided e-mails provided to the victims' attorneys in the civil litigation against Epstein. Judge Marra gave Black and the government two weeks to submit additional briefing on the issue, with an opportunity for the victims to respond. Marra questioned how a matter could still be protected attorney work-product if it had been revealed to the government, the opposing side, in the Epstein criminal investigation. Black argued that criminal defense attorneys should be allowed to be candid and frank with prosecutors, free from any fear that their thoughts and impressions will be made public at some future time. + +The court denied the victims' motion to accept facts. Judge Marra said the victims had not denominated their motion as one for summary judgment, recognized that many of the alleged "facts" were opinions and conclusions, and said it was unfair to make the government stipulate or disagree with those "facts." The Court heard argument on the motion to compel the government to provide relevant information helpful to their case, and the motion for a finding that the CVRA had been violated. + +During our portion of the argument, I emphasized section 3771(d)(6)'s admonition that "In]othing in this chapter shall be construed to impair the prosecutorial discretion of the Attorney General or any officer under his direction." I suggested that, if the court was faced with two possible interpretations of a provision, and one would impair the A/G's prosecutorial discretion and one would not, the court was obligated to choose the one that would not. + +Judge Marra was skeptical that applying 3771(a)(5), the right to reasonably consult with the attorney for the government in the case, would really impair prosecutorial discretion. At one point, he stated that, if the government had consulted with the victims prior to entering into the non-prosecution agreement, while the victims may not have agreed with that course of action, there was nothing they could do. He asked how that would impair prosecutorial discretion. I argued that U.S. Attorney's Offices decline prosecutions frequently, and that construing 3771(a)(5) to apply prior to the filing of a formal charge, would require the government to consult with identified victims prior to declining a case for prosecution. Additionally, I expressed pessimism that victims would not try to seek court intervention in the event an unfavorable decision had been made by the U.S. Attorney's Office. + +The Court inquired about an evidentiary hearing. I told the Court that the government had asserted a 'best efforts" defense, and that the resolution of that issue would require an evidentiary hearing. On the issue of discovery, the Court asked me if it had the authority to permit discovery. I said yes, if the court believed discovery was necessary to resolve disputed factual issues in the case. + +I do not expect the court to rule until the round of briefing on the work-product issue is completed. I have included Marie and on this e-mail. They both attended the hearing and I welcome any comments they might want to add. + +From: (USAFLS) Sent: Tuesda August 16, 2011 9:02 AM To: (USAFLS); (USAFLS); Lee, (USAFLS); Subject: RE: Jane Does 1 and 2 United States - Hearing on Friday, August 12, 2011, at 2:00 p.m. (USAFLS) + +What happened at the hearing? + +From: (USAFLS) Sent: Frida Au ust 12, 2011 9:16 AM To: (USAFLS); (USAFLS); Lee, (USAFLS); .(USAFLS Cc: (USAFLS); (USAFLS); (USAFLS) Subject: RE: Jane Does 1 and 2 United States - Hearing on Friday, August 12, 2011, at 2:00 p.m. (USAFLS); + +Good luck. Let me know what happens after the hearing. Sure to get press calls. + +Alicia + +From: (USAFLS) Sent: Frida Au ust 12, 2011 9:07 AM To: (USAFLS • Lee USAFLS); (USAFLS); Cc: (USAFLS); (USAFLS); (USAFLS) Subject: Re: Jane Does 1 and 2 United States - Hearing on Friday, August 12, 2011, at 2:00 p.m. .(USAFLS) + +Best of luck, We're in good hands with you there. Thanks for all your hard work in this difficult matter. + +From: (USAFLS) Sent: FrIda August 12, 2011 12:06 AM To: Lee USAFLS); USAFLS); (USAFLS); Cc: (USAFLS); (USAFLS); (USAFLS) Subject: Re: Jane Does 1 and 2 United States - Hearing on Friday, August 12, 2011, at 2:00 p.m. (USAFLS) + +I agree that we should go forward with our best efforts defense, at least at this point. + +Good luck tomorrow, Hopefully, the judge will realize that he never needs to get to the best efforts defense or to any evidentiary hearing. + +(USAFLS) Rust 11, 2011 07:38 PM (USAFLS); (USAFLS USAFLS (USAFLS); (USAFLS); (USAFLS); (USAFLS) Subject: Jane Does 1 and 2 1 United States - Hearing on Friday, August 12, 2011, at 2:00 p.m. + +Colleagues, + +Judge Marra will be holding a hearing tomorrow, August 12, at 2:00 p.m., on the victims four (4) motions. In the court's order, he stated he would be asking for the parties' positions on whether an evidentiary hearing is necessary. For our part, on the legal issue of whether rights under the Crime Victims Rights Act attached prior to the filing of a formal charge, the government does not believe any evidentiary hearing is necessary. The only two facts which are relevant are not disputed by the victims: (1) no formal charge was ever filed against Epstein in the S.D.Fla.; and (2) Epstein entered pleas of guilty to state charges on June 30, 2008, in Palm Beach County Circuit Court. + +If the court were to find that CVRA rights did attach in the absence of a formal charge against Epstein, the government has asserted that it used its "best efforts" to comply with the CVRA. In October 2007, after the non-prosecution agreement was signed, FBI agents met with four victims and advised them of the agreement. There is a dispute over what was told to these individuals, and the reasons why notifications to other victims did not occur. The victims also claim that CVRA letters sent to them by the FBI in January 2008 and May 2008 were deceptive, since an agreement with Epstein had already been reached (although not fully approved by Main Justice). + +I believe an evidentiary hearing would be necessary for the government to present its "best efforts" defense. This would involve the government calling witnesses, including Marie, the FBI agents, and other current and former DOJ employees with relevant knowledge of our efforts to comply with the CVRA. + +We need to decide whether to maintain our best efforts defense, since it exposes us to an opportunity for the victims to probe what we did, and why we did it, and provide a platform for making us look bad. One consideration is whether our chances of prevailing, e.g. convincing the Court that we did use our best efforts, is sufficiently great to justify the effort and ordeal. + +I believe we should go forward with our best efforts defense. Our office did its best to ensure the victims were apprised of events in the matter involving Epstein, despite howls of protest coming from Epstein's attorneys. Our office had to walk a narrow path between perceived CVRA responsibilities, the incessant complaining from Epstein's legal camp, and preserving what might still have been a federal prosecution of Epstein had he gotten the agreement overturned at DOJ, or reneged on it completely. Giving up on the best efforts defense would be conceding too much. + +Alicia: We will call you tomorrow after the hearing, to let you know about what went on, and the press coverage. + +I will be leaving here at 9:00 a.m. and hope to be at the West Palm Beach office by 11:00 a.m. Thanks. + +![](_page_4_Picture_6.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00205998/EFTA00205998.metadata.json b/marker2/ds9/EFTA00205998/EFTA00205998.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..8e72feb1073721d7f12204ca4744c561427b25ee --- /dev/null +++ b/marker2/ds9/EFTA00205998/EFTA00205998.metadata.json @@ -0,0 +1,188 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00205998.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 5, + "chars": 13840, + "elapsed_seconds": 1.82, + "image_assets": [ + "_page_4_Picture_6.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 75 + ], + [ + "Line", + 35 + ], + [ + "Text", + 33 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 93 + ], + [ + "Line", + 47 + ], + [ + "ListItem", + 7 + ], + [ + "Text", + 5 + ], + [ + "ListGroup", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 86 + ], + [ + "Line", + 43 + ], + [ + "Text", + 18 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 3, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 89 + ], + [ + "Line", + 45 + ], + [ + "Text", + 13 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 4, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 47 + ], + [ + "Line", + 24 + ], + [ + "Text", + 6 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00205998" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00205998/_page_4_Picture_6.jpeg b/marker2/ds9/EFTA00205998/_page_4_Picture_6.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..67efd24d55fbbce7ae80e0f32fd093422ec36a85 --- /dev/null +++ b/marker2/ds9/EFTA00205998/_page_4_Picture_6.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:bbd385eb60ab82b6d552fda56afa349c10cb667423db600e695b9c5b61129171 +size 1143 diff --git a/marker2/ds9/EFTA00206003/EFTA00206003.md b/marker2/ds9/EFTA00206003/EFTA00206003.md new file mode 100644 index 0000000000000000000000000000000000000000..f56722631011e060a0d6c7664bf19afd0343f92f --- /dev/null +++ b/marker2/ds9/EFTA00206003/EFTA00206003.md @@ -0,0 +1,4507 @@ +From: + +Sent: Tuesday, November 22, 2011 12:27 PM + +To: Brad Edwards + +«111711Epstein NY Appellate Division Dedsion.pdf>> + +Assistant U.S. Attorney + +500 S. Australian Ave, Suite 400 + +West Palm Beach, FL 33401 + +From: Sent: To: Subject: Attachments: Morse, Deborah + +Tuesday, November 22, 2011 12:15 PM + +FW: Jeffrey E. Epstein 111711Epstein.docx + +FYI, I will call you later today or tomorrow. Meantime, thanks for your kind words. + +Best, + +\*\*\*\*\*\*\*\* \*\*\*\*\*\* \*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* + +This email communication and any files transmitted with it contain privileged and confidential + +information from the New York County District Attorney's Office and are intended solely for the use of the individuals or entity to whom it has been addressed. If you are not the intended recipient, you are + +hereby notified that any dissemination or copying of this email is strictly prohibited. If you have + +received this email in error, please delete it and notify the sender by return email. + +\*\*\*\*\*\*\*\* \*\*\*\*\*\*\*\*\*\*\* \*\*\*\*\*\*\*\*\*\*\* \*\*\*\*\*\*\*\*\*\*\*\*\* \*\* \*\*\*\*\*\* + +From: + +To: + +Subject: FW: Jeffrey E. Epstein + +Sent: Tuesday, November 22, 2011 12:15:09 PM (UTC-05:00) Eastern Time (US & Canada) + +was read on Tuesday, November 22, 2011 12:15:04 PM (UTC-05:00) Eastern Time (US & Canada). + +From: + +Sent: Wednesda November 30 2011 5:29 PM + +To: Cc: + +Subject: RE: Telephone Conference re: Epstein nited States + +Yes. I can be available. + +Assistant U.S. Attorney + +500 S. Australian Ave, Suite 400 + +West Palm Beach, FL 33401 + +From: + +Se • • + +To: Cc: + +Subject: RE: Telephone Conference re: Epstein 8i. Enited States + +I just spoke to He is available tomorrow at 1:30, for about an hour, or on Friday either from 10:00- + +11:30 am or from 1:00-3:30 pm. + +Are you both available tomorrow at 1:30? + +From: + +Sent: uesda November 29, 2011 6:11 PM + +To: Cc: + +Subject: Telephone Conference re: Epstein & Jane Doe Enited States + +Hi, + +As we had previously discussed, I am contacting you to see if we can set up a telephone conference to address some of the outstanding matters that we need to discuss to complete the transfer of the criminal case to your district and meet our obligations under USAP 3-2.170.001. (I also left a message with your assistant earlier today.) Those matters include: the nature and scope of any charges/investigation that may potentially remain + +viable in the SDFL following the entry of the Non-Prosecution Agreement; the need to advise the FBI in + +connection with the agents' pending requests for grand jury subpoenas and their expressed intent to continue investigating allegations against Epstein, advice which in all likelihood will require informing the FBI agents about other USAOs that might be able to assist them in light of the grand jury evidence previously obtained; + +and the handling of the criminal case file. + +We who was previously assigned to the criminal investigation; M, who is handling the + +CVRA litigation; and me) can make ourselves available to confer with you after 10:30 tomorrow morning, + +tomorrow afternoon, or Thursday morning. If those blocks of time do not work, please let us know and we can + +make other arrangements to accommodate your schedule. + +Thanks, + +Counselor to the United States Attorney + +United States Attorney's Office + +99 N.E. 4th Street, Suite 800 + +Miami, FL 33132 + +Telephone: + +From: To: Sent: Subject: + +Wednesday, November 30, 2011 5:29 PM + +Read: Telephone Conference re: Epstein & Jane Doe I Enited States + +Your message + +T + +Subject: : elephone on erence re: Epstein & Jane Doe I Enited States + +Sent: Wednesday, November 30, 2011 5:28:51 PM (UTC-05:00) Eastern Time (US & Canada) + +was read on Wednesday, November 30, 2011 5:29:01 PM (UTC-05:00) Eastern Time (US & Canada). + +From: Sent: To: Cc: Subject: + +Tuesday, November 29, 2011 6:11 PM + +Telephone Conference re: Epstein & Jane Doe I Enited States + +I hope you had a great Thanksgiving. + +As we had previously discussed, I am contacting you to see if we can set up a telephone conference to address some of the outstanding matters that we need to discuss to complete the transfer of the criminal case to your district and meet our obligations under USAP 3-2.170.001. (I also left a message with your assistant earlier today.) Those matters include: the nature and scope of any charges/investigation that may potentially remain + +viable in the SDFL following the entry of the Non-Prosecution Agreement; the need to advise the FBI in + +connection with the agents' pending requests for grand jury subpoenas and their expressed intent to continue investigating allegations against Epstein, advice which in all likelihood will require informing the FBI agents about other USAOs that might be able to assist them in light of the grand jury evidence previously obtained; + +and the handling of the criminal case file. + +We who was previously assigned to the criminal investigation;=., who is handling the + +CVRA litigation; and me) can make ourselves available to confer with you after 10:30 tomorrow morning, + +tomorrow afternoon, or Thursday morning. If those blocks of time do not work, please let us know and we can + +make other arrangements to accommodate your schedule. + +Thanks, + +Counselor to the United States Attorney + +United States Attorney's Office + +99 N.E. 4th Street, Suite 800 + +Miami, FL 33132 + +Telephone: + +E•mail + +From: Sent: To: Cc: + +Subject: RE: Telephone Conference re: Epstein & Jane Doe l Enited States + +I just spoke to He is available tomorrow at 1:30, for about an hour, or on Friday either from 10:00- + +11:30 am or from 1:00-3:30 pm. + +Are you both available tomorrow at 1:30? + +Sent: Tuesda November 29, 2011 6:11 PM + +To: Cc: + +Subject: Telephone Conference re: Epstein & Jane Doe Enited States + +H + +I hope you had a great Thanksgiving. + +As we had previously discussed, I am contacting you to see if we can set up a telephone conference to address some of the outstanding matters that we need to discuss to complete the transfer of the criminal case to your district and meet our obligations under USAP 3-2.170.001. (I also left a message with your assistant earlier today.) Those matters include: the nature and scope of any charges/investigation that may potentially remain + +viable in the SDFL following the entry of the Non-Prosecution Agreement; the need to advise the FBI in + +connection with the agents' pending requests for grand jury subpoenas and their expressed intent to continue investigating allegations against Epstein, advice which in all likelihood will require informing the FBI agents about other USAOs that might be able to assist them in light of the grand jury evidence previously obtained; + +and the handling of the criminal case file. + +We i• , who was previously assigned to the criminal investigation-, who is handling the + +CVRA litigation; and me) can make ourselves available to confer with you after 10:30 tomorrow morning, + +tomorrow afternoon, or Thursday morning. If those blocks of time do not work, please let us know and we can + +make other arrangements to accommodate your schedule. + +Thanks, + +Counselor to the United States Attorney + +United States Attorney's Office + +99 N.E. 4th Street, Suite 800 + +Miami, FL 33132 + +Telephone: + +E-mail: + +From: Sent: To: Cc: Subject: + +Tuesday, December 06, 2011 3:34 PM + +RE: Telephone Conference re: Epstein & Jane Doe l Enited States + +Best regards, + +From: + +Sent: Wednesday, November 30, 2011 7:35 PM + +To: Cc: + +Subject: RE: Telephone Conference re: Epstein & Jane Doe Enited States + +We're on for 1:30 tomorrow. I'll set things up for a conference call at that time and send out the call-in + +information. + +Thanks, + +From: + +Sent: Tuesda November 29, 2011 6:11 PM + +To: Cc: + +Subje : eep one on erence re: pstein ane e nite tates + +H + +I hope you had a great Thanksgiving. + +As we had previously discussed, I am contacting you to see if we can set up a telephone conference to address some of the outstanding matters that we need to discuss to complete the transfer of the criminal case to your district and meet our obligations under USAP 3-2.170.001. (I also left a message with your assistant earlier today.) Those matters include: the nature and scope of any charges/investigation that may potentially remain + +viable in the SDFL following the entry of the Non-Prosecution Agreement; the need to advise the FBI in + +connection with the agents' pending requests for grand jury subpoenas and their expressed intent to continue investigating allegations against Epstein, advice which in all likelihood will require informing the FBI agents about other USAOs that might be able to assist them in light of the grand jury evidence previously obtained; + +and the handling of the criminal case file. + +who was previously assigned to the criminal investigation; who is handling the + +CVRA litigation; and me) can make ourselves available to confer with you after 10:30 tomorrow morning, + +tomorrow afternoon, or Thursday morning. If those blocks of time do not work, please let us know and we can + +Counselor to the United States Attorney + +United States Attorneys Office + +99 N.E. 4th Street. Suite 800 + +Miami. FL 33132 + +Telephone + +E-mail: + +From: Sent: To: Subject: Attachments: + +Monday, December 05, 2011 8:57 PM + +Jane Does Responses + +DE127\_20111205 Jane Does Resp to Motn to Dismiss.pdf; DE13O\_2O1112O5 Jane Does Motn to Compel.pdf; DE129\_20111205 Jane Does Resp to Motn to Stay Discovery.pdf; + +DE128\_20111205 Jane Does Protective Motion for Remedies.pdf + +Hi everyone: Here are the responses of the Jane Does. If they filed anything under seal I haven't received it. + +«DE127\_20111205 \_Jane Does Resp to Motn to Dismiss.pdf» «DE130\_20111205 \_Jane Does Motn to Compel.pdf» «DE129\_20111205 \_Jane Does Resp to Motn to Stay Discovery.pdf» «DE128\_20111205 \_Jane Does Protective Motion + +for Remedies.pdf» + +Assistant U.S. Attorney + +500 S. Australian Ave, Suite 400 + +West Palm Beach, FL 33401 + +From: Sent: To: Subject: + +Thursday, December 08, 2011 4:44 PM + +RE: Jane Does I US -- Sealed Response to Motion to Dismiss + +I recall that most of the victims invoked the NPA provision that required Epstein not to raise the absence of a predicate federal conviction as a defense to subject matter jurisdiction. would + +know for sure. + +From: + +Sent: Thwnia, December 08, 2011 4:31 PM + +To: M, (USAFLS); I. (USAFLS) + +Subject: Re: Jane Does US -- Sealed Response to Motion to Dismiss + +Do we have the case numbers of the Jane Does' civil cases against Epstein? What about the other victims cases? It would be interesting to see if they invoked the NPAs provisions against Epstein. + +From: M, (USAFLS) + +Sent: Thursda mber 08, 2011 04:26 PM + +To: (USAFLS); I. (USAFLS) Subject: RE: Jane Does I. US -- Sealed Response to Motion to Dismiss + +Mid morning is fine for me. + +From: (USAFLS) + +Sent: Thursda , December 08, 2011 4:20 PM + +To: , (USAFLS); (USAFLS) + +Subject: Re: Jane Does US -- Sealed Response to Motion to Dismiss + +Would mid-morning (about 10:30) work for everyone, or do you have another preference? + +From: i M I. (USAFLS) Sent: Thwnla, December 08, 2011 04:16 PM + +To: M, (USAFLS; (USAFLS) + +Subject: Re: Jane Does I. US -- Sealed Response to Motion to Dismiss + +Let me know what time A. , AUSA + +Sent: Thursda mber 08, 2011 04:09 PM + +To: (USAFLS); I. (USAFLS) Subject: RE: Jane Does I. US -- Sealed Response to Motion to Dismiss + +Let's do it tomorrow. I will have my Blackberry on. I believe our replies are due on December 15. + +I am set to go to trial before Judge Ungaro during the two week term commencing January 16, 2012. + +She just denied my motion for continuance, so it looks like the case is going forward. + +From: (USAFLS) + +Sent: Thim lay, December 08, 2011 4:02 PM + +To: M, (USAFLS\_); . M I. (USAFLS) + +Subject: Re: Jane Does I. US -- Sealed Response to Motion to Dismiss + +I'm actually out of the office today on sick leave. If you want to talk today, I can call in, but I have not yet had a chance to review the sealed pleading and I was not inclined to forward the sealed document + +to my gmail account. + +Let me know what you both prefer. + +• + +From: M, (USAFLS) + +Sent: Thursda mber 08, 2011 03:54 PM + +To: (USAFLS); I. (USAFLS) Subject: RE: Jane Does I. US -- Sealed Response to Motion to Dismiss + +I will be out of the office tomorrow, but I can call in. Do you want to try something today? + +Sent: Thursda , December 08, 2011 3:39 PM + +To: , . (USAFLS); (USAFLS) + +Subject: Re: Jane Doesi US -- Sealed Response to Motion to Dismiss + +Can all three of us get together on the phone tomorrow? + +From: i M I. (USAFLS) Sent: Thursda , December 08, 2011 11:47 AM + +To: , (USAFLS); M, (USAFLS) + +Subject: Jane Does US -- Sealed Response to Motion to Dismiss + +Hi and — Here is the sealed portion of their response. Judge Marra's clerk called to confirm + +that we had no objection to the Motion to Seal. I stated that we had no objection. + +I am on vacation next week. We really HAVE to get this file transferred to the Middle District. + +«20111206 Sealed Response to Motn to Dismiss.pdf» + +Assistant U.S. Attorney + +500 S. Australian Ave, Suite 400 + +West Palm Beach, FL 33401 + +Fax + +From: (USAFLS) .: > + +Sent: Thursday, December 08, 2011 4:31 PM + +To: M , + +(USAFLS); , M I. (USAFLS) + +Subject: Re: Jane Does I US -- Sealed Response to Motion to Dismiss + +Do we have the case numbers of the Jane Does' civil cases against Epstein? What about the other victims cases? It would be interesting to see if they invoked the NPAs provisions against Epstein. + +From: M, (USAFLS) + +Sent: Thursda mber 08, 2011 04:26 PM + +To: (USAFLS); I. (USAFLS) Subject: RE: Jane Does I. US -- Sealed Response to Motion to Dismiss + +From: (USAFLS) + +Sent: Thursda , December 08, 2011 4:20 PM + +To: (USAFLS); (USAFLS) + +Subject: Re: Jane Does US -- Sealed Response to Motion to Dismiss + +Would mid-morning (about 10:30) work for everyone, or do you have another preference? + +From: i M I. (USAFLS) Sent: Thi.nla, December 08, 2011 04:16 PM + +To: M, (USAFLS; , (USAFLS) + +Subject: Re: Jane Does I US -- Sealed Response to Motion to Dismiss + +Let me know what time + +AUSA + +From: M, (USAFLS) + +Sent: Thursda mber 08, 2011 04:09 PM + +To: (USAFLS); I. (USAFLS) Subject: RE: Jane Does I. US -- Sealed Response to Motion to Dismiss + +Let's do it tomorrow. I will have my Blackberry on. I believe our replies are due on December 15. + +I am set to go to trial before Judge Ungaro during the two week term commencing January 16, 2012. + +She just denied my motion for continuance, so it looks like the case is going forward. + +From: (USAFLS) + +Sent: Thwnia, December 08, 2011 4:02 PM + +To: M, (USAFLS); . M I. (USAFLS) + +Subject: Re: Jane Does I US -- Sealed Response to Motion to Dismiss + +I'm actually out of the office today on sick leave. If you want to talk today, I can call in, but I have not yet had a chance to review the sealed pleading and I was not inclined to forward the sealed document + +Let me know what you both prefer. + +From: M, (USAFLS) + +Sent: Thursda mber 08, 2011 03:54 PM + +To: (USAFLS); I. (USAFLS) Subject: RE: Jane Does I. US -- Sealed Response to Motion to Dismiss + +I will be out of the office tomorrow, but I can call in. Do you want to try something today? + +From: (USAFLS) + +Sent: Thursda , December 08, 2011 3:39 PM + +To: , (USAFLS); (USAFLS) + +Subject: Re: Jane Does US -- Sealed Response to Motion to Dismiss + +Can all three of us get together on the phone tomorrow? + +From: i M I. (USAFLS) Sent: Thursda , December 08, 2011 11:47 AM + +To: , (USAFLS); M, (USAFLS) + +Subject: Jane Does US -- Sealed Response to Motion to Dismiss + +Hi and — Here is the sealed portion of their response. Judge Marra's clerk called to confirm + +that we had no objection to the Motion to Seal. I stated that we had no objection. + +I am on vacation next week. We really HAVE to get this file transferred to the Middle District. + +«20111206 Sealed Response to Motn to Dismiss.pdf» + +Fax + +From: Paul Cassell < > Sent: Sunday, December 04, 2011 1:55 PM + +To: (USAFLS); I. (USAFLS) + +Cc: Brad Edwards Subject: RE: extra pages + +Hey IMBMand + +Sorry I had to leave the call early Friday. Meant to check with you on this then. + +I am working with Brad to finalize our pleadings to be filed on Monday in response to the motion to dismiss. We are filing an unsealed pleading (that does not discuss grand jury material) as well as a sealed pleading (that discusses only the grand jury material and related issues). The unseal pleading is 24 pages long and the sealed pleading is 7 pages long. + +We also have a response to the motion to stay which is well under the 20 page limit. + +Any objection to a motion for the extra pages (4 + 7, although I'm not sure whether we count the 7) to respond to your + +motion to dismiss? + +Thanks for your help on getting back to us. PC + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the University of Utah + +332 S. 1400 E. , Room 101 Salt Lake Cit , UT 84112-0730 + +(phone) fax + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, + +please immediately notify the sender by reply electronic mail and delete the original message. Thank you. + +From: II., (USAFLS) + +Sent: Thursday, December 01, 2011 3:23 PM + +To: Paul Cassell; + +, + +(USAFLS); + +Cc: Brad Edwards + +Subject: RE: Conference call 11:15 AM Florida time - Friday + +Paul, + +(USAFLS) + +We will take care of the arrangements for tomorrow at 11:15 a.m. Thanks. + +From: Paul Cassell + +Sent ThursdaOecember 01, 2011 4:59 PM + +To: USAFLS); (USAFLS) + +If so, please call my cell phone + +call in number? + +Looking forward to chatting. PC + +as well as Brad —a/' can y'all initiate the conference call or set up a + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the University of Utah + +332 South 1400 East, Room 101 Salt Lake City. UT 84112-0730 + +Voice: Fax: Email: + +http://wwwlaw.uTah.eduiprofiles/default.asp?PersonID=57&name=Cassell,Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, + +please immediately notify the sender by reply electronic mail and delete the original message. Thank you. + +From: + +,M N. (USAFLS) [mailto: + +Sent: Thursda , December 01, 2011 2:34 PM To: , USAFLS); Paul Cassell Cc: Brad Edwards; (USAFLS) + +Subject: RE: Discovery Issues in Epstein - conference call at 5 PM today? + +Hi everyone — Sorry, I am having a very busy duty week. Tomorrow I have court at 9:00 probably until 11:00 and then again from 3:00 until 5:00. I have a debriefing at 1:00, but I should be able to step out after 1:30. So, 11:15 or 1:30 are + +best for me, but your schedules take priority. + +ssistan mey + +500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 + +From: (USAFLS) + +Sent: Thursday, December 01, 2011 3:52 PM + +To: Paul Cassell + +Cc: (USAFLS); (USAFLS) Subject: RE: Discovery Issues in Epstein - conference call at 5 PM today? + +Unfortunately, that doesn't work for us today. Can we set up a time for tomorrow? + +• + +Counselor States Attorney + +United States Attorney's Office 99 N.E. 4th Street, Suite 800 + +Miami, FL 33132 Telephone: + +E-mail: + +Sent: Thursda DecemberiMPIIIII + +To: N. (USAFLS): (USAFLS); li., (USAFLS) + +Cc: + +Subjec iscovery Issues in Epstein - conference call at 5 PM today? + +Hi and Co., + +Thanks for the call. Sorry I was on the other line. + +Can we set up a time certain? That way Brad can participate. + +He is in a depo until 4:30, but should be free at 5 PM your time today (Thursday). Does that work? + +Looking forward to chatting. PC + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law + +S.J. Quinney College of Law at the University of Utah + +332 South 1400 East, Room 101 + +Salt Lake City, UT 84112-0730 + +Voice: + +Fax: + +Email + +http://www.law.utah.edu/profiles/default.asp?PersonID=578,name=Cassell,Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, + +please immediately notify the sender by reply electronic mail and delete the original message. Thank you. + +Sent: Thursday, December 01, 2011 11:25 AM + +To: (USAFLS)'; (USAFLS)'; (USAFLS)' + +Cc: + +Subject: RE: Discovery Issues in Epstein + +Dear Mr. + +We will shortly be filing a motion to compel Government responses to our discovery requests — discovery which, as you know, Judge Marra has already ordered. We realize, of course, that the Government has filed a motion to dismiss/stay. But if the Government's position is rejected on those motions, then the next issue is what discovery can we expect to + +receive from the Government. + +If the motions are denied, will the Government voluntarily produce anything to us? Will the government at least agree to + +produce the following: + +(1) The Government's initial disclosures pursuant to Fed. R. Civ. P. 26; + +(2) Answers to all of the victims' requests for admission; + +(3) All documents, correspondence, and other information that the Government distributed to persons or entities outside of + +the federal Government or received from persons or entities outside of the federal government; and + +(4) All documents, correspondence, and other information covered by the victims' discovery request that is not subject to a + +claim of privilege. + +And, for all other information withheld, will the Government agree to produce a document-by-document privilege log, as + +required by the local rules? + +Thanks for your help on these questions and Brad and I have. + +Sincerely, + +Paul Cassell + +Co-Counsel for Jane Doe #1 and Jane Doe #2 + +Salt Lake City, UT 84112-0730 + +Voice: + +Fax: + +Email: + +http://www.law.utah.edu/profiles/default.asp?PersonID=578,name=Cassell,Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, + +please immediately notify the sender by reply electronic mail and delete the original message. Thank you. + +Subject: + +Start: End: + +Recurrence: + +Organizer: + +11:15 Conf Call re Epstein/Jane Does + +Fri 12/2/2011 11:00 AM Fri 12/2/2011 12:00 PM + +(none) + +(USAFLS) + +From: Paul Cassell + +Sent: Sunday, December 04, 2011 2:07 PM + +To: I. (USAFLS); (USAFLS) + +Cc: Brad Edwards Subject: RE: extra pages + +Thanks for asking -- yes everything went smoothly. Paul + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the University of Utah + +332 S. 1400 E. , Room 101 Salt Lake Cit . UT 84112-0730 + +(phone) (fax) + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, + +please immediately notify the sender by reply electronic mail and delete the original message. Thank you. + +Sent: Sunday, December 04, 2011 12:00 PM To: Paul Cassell; (USAFLS) + +Cc: Brad Edwards Subject: RE: extra pages + +No objection to the extra pages. I hope that all went well on Friday. + +ssistant U.S. Attorney + +Original Message From: Paul Cassell + +Sent: Sunda December 04, 2011 1:55 PM + +To: In MEI (USAFLS); (USAFLS) + +Cc: Brad Edwards Subject: RE: extra pages + +Hey IMB =and M, + +Sorry I had to leave the call early Friday. Meant to check with you on this then. + +I am working with Brad to finalize our pleadings to be filed on Monday in response to the motion to dismiss. We are filing an unsealed pleading (that does not discuss grand jury material) as well as a sealed pleading (that discusses only the grand jury material and related issues). The unseal pleading is 24 pages long and the sealed pleading is 7 pages long. + +We also have a response to the motion to stay which is well under the 20 page limit. + +Any objection to a motion for the extra pages (4 + 7, although I'm not sure whether we count the 7) to respond to your + +motion to dismiss? + +Thanks for your help on getting back to us. PC + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the University of Utah + +332 S. 1400 E. , Room 101 Salt Lake City, UT 84112-0730 + +(phone) (fax) + +cassellp@law.utah.edu + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, + +please immediately notify the sender by reply electronic mail and delete the original message. Thank you. + +From: In (USAFLS) + +Sent: Thursday, December 01, 2011 3:23 PM + +To: Paul Cassell; + +, MI I. (USAFLS); + +Cc: Brad Edwards + +Subject: RE: Conference call 11:15 AM Florida time - Friday + +I I + +Paul, + +(USAFLS) + +We will take care of the arrangements for tomorrow at 11:15 a.m. Thanks. + +From: Paul Cassell [mailto:cassellp@law.utah.edu) Sent: Thursda ecember 01, 2011 4:59 PM + +, m IMI To: lir\_AFLS): (USAFLS) + +Does 11:15 AM Florida time on Friday work? + +If so, please call my cell phone + +call in number? + +Looking forward to chatting. PC + +as well as Brad - NM can y'all initiate the conference call or set up a + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the University of Utah + +332 South 1400 East, Room 101 Salt Lake Cit , UT 84112-0730 + +Voice: Fax: Email: + +http://www. aw.0 a .e u pro es eau .asp erson = name=Cassell,Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, + +please immediately notify the sender by reply electronic mail and delete the original message. Thank you. + +From: + +,M I. (USAFLS) [mailto: + +Sent: Thursda , December 01, 2011 2:34 PM To: , USAFLS); Paul Cassell Cc: Brad Edwards; (USAFLS) + +Subject: RE: Discovery Issues in Epstein - conference call at 5 PM today? + +Hi everyone - Sorry, I am having a very busy duty week. Tomorrow I have court at 9:00 probably until 11:00 and then again from 3:00 until 5:00. I have a debriefing at 1:00, but I should be able to step out after 1:30. So, 11:15 or 1:30 are best for + +me, but your schedules take priority. + +500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 + +Fax + +From: (USAFLS) + +Sent: Thursday, December 01, 2011 3:52 PM + +To: Paul Cassell + +Cc: Brad Edwards; (USAFLS); (USAFLS) Subject: RE: Discovery Issues in Epstein - conference call at 5 PM today? + +Unfortunately, that doesn't work for us today. Can we set up a time for tomorrow? + +• + +Coi selor...ed States Attorney + +United States Attorney's Office 99 N.E. 4th Street, Suite 800 + +Miami, FL 33132 Telephone: + +E-mail: + +(USAFLS) + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, + +please immediately notify the sender by reply electronic mail and delete the original message. Thank you. + +Sent: Thursday, December 01, 2011 11:25 AM + +To: N. (USAFLS)'; (USAFLS)'; (USAFLS)' + +Cc: 'Brad Edwards' + +Subject: RE: Discovery Issues in Epstein + +Dear Mr. + +We will shortly be filing a motion to compel Government responses to our discovery requests — discovery which, as you know, Judge Marra has already ordered. We realize, of course, that the Government has filed a motion to dismiss/stay. But if the Government's position is rejected on those motions, then the next issue is what discovery can we expect to + +receive from the Government. + +If the motions are denied, will the Government voluntarily produce anything to us? Will the government at least agree to + +produce the following: + +(1) The Government's initial disclosures pursuant to Fed. R. Civ. R 26; + +(2) Answers to all of the victims' requests for admission; + +(3) All documents, correspondence, and other information that the Government distributed to persons or entities outside of + +the federal Government or received from persons or entities outside of the federal government; and + +(4) All documents, correspondence, and other information covered by the victims' discovery request that is not subject to a + +claim of privilege. + +And, for all other information withheld, will the Government agree to produce a document-by-document privilege log, as + +required by the local rules? + +Thanks for your help on these questions and Brad and I have. + +Sincerely, + +Paul Cassell + +Co-Counsel for Jane Doe #1 and Jane Doe #2 + +Salt Lake City, UT 84112-0730 + +Voice: + +Fax: + +Email: + +http://www.law.utah.edu/profiles/default.asp?PersonID=578,name=Cassell,Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, + +please immediately notify the sender by reply electronic mail and delete the original message. Thank you. + +From: (USAFLS) Sent: Sunday, December 04, 2011 2:00 PM To: Paul Cassell; MI, (USAFLS) + +Cc: Brad Edwards Subject: RE: extra pages + +No objection to the extra pages. I hope that all went well on Friday. + +A. Villafana Assistant U.S. Attorney + +----Original Message + +From: Paul Cassell [mailto:cassellp@law.utah.edu] Sent: Sun December 04 2011 1:55 PM + +To: I., (USAFLS); (USAFLS) + +Cc: Brad Edwards Subject: RE: extra pages + +Hey MR ' and + +Sorry I had to leave the call early Friday. Meant to check with you on this then. + +I am working with Brad to finalize our pleadings to be filed on Monday in response to the motion to dismiss. We are filing an unsealed pleading (that does not discuss grand jury material) as well as a sealed pleading (that discusses only the grand jury material and related issues). The unseal pleading is 24 pages long and the sealed pleading is 7 pages long. + +We also have a response to the motion to stay which is well under the 20 page limit. + +Any objection to a motion for the extra pages (4 + 7, although I'm not sure whether we count the 7) to respond to your + +motion to dismiss? + +Assistant U.S. Attorney + +500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 + +From: (USAFLS) + +Sent: Thursday, December 01, 2011 3:52 PM + +To: Paul Cassell Cc: Brad Edwards; + +, N. (USAFLS); (USAFLS) + +Subject: RE: Discovery Issues in Epstein - conference call at 5 PM today? + +Unfortunately, that doesn't work for us today. Can we set up a time for tomorrow? + +• + +Counselor to the United States Attorney + +United States Attorney's Office 99 N.E. 4th Street, Suite 800 + +Miami, FL 33132 Telephone: + +E-mail: + +Sent: Thursda ecember 01, 2011 2:22 PM + +To: .= g. (USAFLS); (USAFLS); M, (USAFLS) + +Cc: Brad Edwards + +Subject: RE: Discovery Issues in Epstein - conference call at 5 PM today? + +Hi and Co., + +Thanks for the call. Sorry I was on the other line. + +Can we set up a time certain? That way Brad can participate. + +He is in a depo until 4:30, but should be free at 5 PM your time today (Thursday). Does that work? + +S.J. Quinney College of Law at the University of Utah + +332 South 1400 East, Room 101 + +Salt Lake City, UT 84112-0730 + +Voice: + +Fax: + +Email: + +http://www.law.utah.edu/profiles/default.asp?PersonID=578tname=Cassell,Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, + +please immediately notify the sender by reply electronic mail and delete the original message. Thank you. + +Original Message + +From: Paul Cassell + +Sent: Thursday, December 01, 2011 11:25 AM + +To: N. (USAFLS)'; (USAFLS)'; (USAFLS)' + +Cc: 'Brad Edwards' + +Subject: RE: Discovery Issues in Epstein + +Dear Mr. + +We will shortly be filing a motion to compel Government responses to our discovery requests — discovery which, as you know, Judge Marra has already ordered. We realize, of course, that the Government has filed a motion to dismiss/stay. But if the Government's position is rejected on those motions, then the next issue is what discovery can we expect to + +receive from the Government. + +If the motions are denied, will the Government voluntarily produce anything to us? Will the government at least agree to + +produce the following: + +(4) All documents, correspondence, and other information covered by the victims' discovery request that is not subject to a + +claim of privilege. + +And, for all other information withheld, will the Government agree to produce a document-by-document privilege log, as + +required by the local rules? + +Thanks for your help on these questions and Brad and I have. + +Sincerely, + +Paul Cassell + +Co-Counsel for Jane Doe #1 and Jane Doe #2 + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the University of Utah + +332 South 1400 East, Room 101 + +Salt Lake City, UT 84112-0730 + +Voice: + +Fax: + +Email: cassellp@law.utah.edu + +http://www.law.utah.edu/profiles/default.asp?PersonID=578,name=Cassell,Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, + +please immediately notify the sender by reply electronic mail and delete the original message. Thank you. + +From: (USAFLS) + +Sent: Friday, January 06, 2012 12:37 PM + +There are several motions that are fully briefed but have not been decided: + +DE50: Petitioners' Motion for an Order Directing the U.S. Attorney's Office Not to Withhold Relevant + +Evidence (this was "held in abeyance" while the Court ordered "limited discovery"). + +DE51: Petitioners' Motion to Use Correspondence to Provide Violations of the CVRA and to Have their + +Unredacted Pleadings Unsealed. + +DE56: Motion to Intervene by Roy Black, Martin Weinberg, and Jay Lefkowitz + +DE93: Motion for Limited Intervention by Jeffrey Epstein + +The first three were all addressed by the Court at the August 12, 2011 hearing, although the Court allowed + +supplemental briefing after the hearing on DE56. The last of that supplemental briefing was filed on 10/31/2011. + +DE93 was fully briefed on 10/14/2011. + +The 90-day mark on DE93 will be January 12th. My reading of Rule 7.1(b)(3)(B) is that if there is a hearing, even with supplemental briefing thereafter, one counts from the date of the hearing, and that date has long since + +passed, so there is nothing to report on DE50, DE51, and DE56. + +With regard to the outstanding motions, there are: + +DE119: Our motion to dismiss for lack of subject matter jurisdiction was filed on 11/8/2011. The Jane Does' + +Opposition was filed on 12/5/2011. Our Reply has not yet been filed. + +DE121: Our motion to stay discovery was filed on 11/8/2011. The Jane Does' Opposition was filed on + +12/5/2011. Our Reply has not yet been filed. + +DE128: Petitioners' Protective Motion for Remedies was filed on 12/5/2011. Our Opposition has not yet been + +filed. + +DE130: Petitioners' Protective Motion to Compel was filed on 12/5/2011. We have not yet filed our Opposition. + +One does not begin calculating the 90 days on these motions until briefing is completed. + +As to the rest of Mr. Cassell's email, I don't recall promising early discovery, I only remember promising that, if the motion to stay was denied, we would be ready with our production. Is my memory off? I was going to recommend that I talk to Brad about some of the requests and ask if they have information that leads them to believe that there is evidence to be found (for example, re Bill Clinton or Prince Andrew) so that they can point us in the right direction. I would hate for us to deny something based on my knowledge and find out later about + +some obscure contact in DC. Thoughts? + +To be ready with our production, though, I really need a legal assistant or attorney from Miami to come up here and sort through all of my boxes with me. And someone needs to order Jeff and Alex's records back from Archives (I don't know if Matt or Andy's materials are in archives or any closed file rooms). And someone + +needs to reach out to CEOS and the DAAG and AAG's offices, as well as DOJ Appellate. + +This discovery issue is going to be massive if we are ordered to respond, so it would help to have a civil legal + +500 S. Australian Ave, Suite 400 + +West Palm Beach, FL 33401 + +Fax + +From: (USAFLS) + +Sent: Friday, January 06, 2012 2:36 PM + +To: (USAFLS); I. (USAFLS) + +Subject: RE: Status of Outstanding Motions/Discovery issue + +and M, + +Since Cassell has conditioned his nonopposition with conditions, and since we don't agree with what the + +conditions, shall we just file our motion and say that the victims oppose it? That seems easier than engaging + +in a never-ending debate with Cassell on the construction and interpretation of the 90 day rule. + +My trial will begin on January 17, at 10:00 a.m. I am in the process now of notifying my witnesses and arranging times for their trial preparation interviews next week. I can put together a second motion for + +enlargement of time, but it will be after close of business. Thanks. + +From: (USAFLS) Sen icy, la JanuLq16,\_2012 2:24 PM + +To: I. (USAFLS); (USAFLS) Subject: RE: Status of Outstanding Motions/Discovery issue + +Under Local Rule 7.1(b)(4), the motions/responses/replies that would be the subject of the extension are not subject to the 90-day notice because none is a "motion or other matter which has been pending and fully briefed with no hearing set thereon for a period of ninety (90) days" and none is a "motion or other matter as to which the Court has conducted a hearing." Cassell's concern regarding those motions is thus unmerited. With respect to the other matters that has identified, they are not our motions, and Rule 7.1(b)(4) makes clear that the notice obligation is imposed on the "the movant or applicant." Notably, under the terms of the recently amended and renumbered rule, the notice must be "serve[d] on all parties and any affected non- + +parties." The explicit filing requirement was deleted from the rule. + +As to "initial discovery," my recollection is that, notwithstanding the motion to stay discovery, we expressed a willingness to look at and consider a request for the government to provide discovery of discrete items where the resulting production would be relevant, not burdensome, and not otherwise objectionable. But I am unaware of any communication asking us to consider any more limited discovery request. I don't recall any representation that we would provide "a list of additional discovery that we could expect if [Petitioners'] + +From: M I. (USAFLS) SenStih January 06, 2012 12:37 PM + +To: (USAFLS); I., (USAFLS) Subject: Status of Outstanding Motions/Discovery issue + +Hi • and + +There are several motions that are fully briefed but have not been decided: + +DE50: Petitioners' Motion for an Order Directing the U.S. Attorney's Office Not to Withhold Relevant + +Evidence (this was "held in abeyance" while the Court ordered "limited discovery"). + +DE51: Petitioners' Motion to Use Correspondence to Provide Violations of the CVRA and to Have their + +Unredacted Pleadings Unsealed. + +DE56: Motion to Intervene by Roy Black, Martin Weinberg, and Jay Lefkowitz + +DE93: Motion for Limited Intervention by Jeffrey Epstein + +The first three were all addressed by the Court at the August 12, 2011 hearing, although the Court allowed supplemental briefing after the hearing on DE56. The last of that supplemental briefing was filed on + +10/31/2011. + +DE93 was fully briefed on 10/14/2011. + +The 90-day mark on DE93 will be January 12'h. My reading of Rule 7.1(b)(3)(B) is that if there is a hearing, even with supplemental briefing thereafter, one counts from the date of the hearing, and that date has long + +since passed, so there is nothing to report on DE50, DE51, and DE56. + +With regard to the outstanding motions, there are: + +DE119: Our motion to dismiss for lack of subject matter jurisdiction was filed on 11/8/2011. The Jane Does' + +Opposition was filed on 12/5/2011. Our Reply has not yet been filed. + +DE121: Our motion to stay discovery was filed on 11/8/2011. The Jane Does' Opposition was filed on + +12/5/2011. Our Reply has not yet been filed. + +DE128: Petitioners' Protective Motion for Remedies was filed on 12/5/2011. Our Opposition has not yet + +been filed. + +DE130: Petitioners' Protective Motion to Compel was filed on 12/5/2011. We have not yet filed our + +Opposition. + +One does not begin calculating the 90 days on these motions until briefing is completed. + +that, if the motion to stay was denied, we would be ready with our production. Is my memory off? I was going to recommend that I talk to Brad about some of the requests and ask if they have information that + +leads them to believe that there is evidence to be found (for example, re Bill Clinton or Prince Andrew) so that they can point us in the right direction. I would hate for us to deny something based on my + +knowledge and find out later about some obscure contact in DC. Thoughts? + +To be ready with our production, though, I really need a legal assistant or attorney from Miami to come up + +here and sort through all of my boxes with me. And someone needs to order Jeff and Alex's records back from Archives (I don't know if Matt or Andy's materials are in archives or any closed file rooms). And someone needs to reach out to CEOS and the DAAG and AAG's offices, as well as DOJ Appellate. + +This discovery issue is going to be massive if we are ordered to respond, so it would help to have a civil legal + +assistant assigned. + +Assistant U.S. Attorney + +500 S. Australian Ave, Suite 400 + +West Palm Beach, FL 33401 + +Fax + +From: (USAFLS) Sent: Friday, January 06, 2012 2:24 PM + +To: Il • • . (USAFLS); M, (USAFLS) Subject: RE: Status of Outstanding Motions/Discovery issue + +Under Local Rule 7.1(b)(4), the motions/responses/replies that would be the subject of the extension are not subject to the 90-day notice because none is a "motion or other matter which has been pending and fully briefed with no hearing set thereon for a period of ninety (90) days" and none is a "motion or other matter as to which the Court has conducted a hearing." Cassell's concern regarding those motions is thus unmerited. With respect to the other matters that has identified, they are not our motions, and Rule 7.1(b)(4) makes clear that the notice obligation is imposed on the "the movant or applicant." Notably, under the terms of the recently amended and renumbered rule, the notice must be "serve[d] on all parties and any affected non- + +parties." The explicit filing requirement was deleted from the rule. + +As to "initial discovery," my recollection is that, notwithstanding the motion to stay discovery, we expressed a willingness to look at and consider a request for the government to provide discovery of discrete items where the resulting production would be relevant, not burdensome, and not otherwise objectionable. But I am unaware of any communication asking us to consider any more limited discovery request. I don't recall any representation that we would provide "a list of additional discovery that we could expect if [Petitioners'] + +motion to dismiss is denied," or anything else of the sort. It is not anything to which I would have been inclined + +to agree. + +From: IN I. (USAFLS) Sen iciia, Januar 2012 12:37 PM + +To: , (USAFLS); I., (USAFLS) Subject: Status of Outstanding Motions/Discovery issue + +Hi • and + +There are several motions that are fully briefed but have not been decided: + +DE50: Petitioners' Motion for an Order Directing the U.S. Attorney's Office Not to Withhold Relevant + +Evidence (this was "held in abeyance" while the Court ordered "limited discovery"). + +DE51: Petitioners' Motion to Use Correspondence to Provide Violations of the CVRA and to Have their + +Unredacted Pleadings Unsealed. + +DE56: Motion to Intervene by Roy Black, Martin Weinberg, and Jay Lefkowitz + +DE93: Motion for Limited Intervention by Jeffrey Epstein + +The first three were all addressed by the Court at the August 12, 2011 hearing, although the Court allowed supplemental briefing after the hearing on DE56. The last of that supplemental briefing was filed on + +10/31/2011. + +DE93 was fully briefed on 10/14/2011. + +The 90-day mark on DE93 will be January 12th. My reading of Rule 7.1(b)(3)(B) is that if there is a hearing, even with supplemental briefing thereafter, one counts from the date of the hearing, and that date has long + +since passed, so there is nothing to report on DE50, DE51, and DE56. + +With regard to the outstanding motions, there are: + +DE119: Our motion to dismiss for lack of subject matter jurisdiction was filed on 11/8/2011. The Jane Does' + +Opposition was filed on 12/5/2011. Our Reply has not yet been filed. + +DE121: Our motion to stay discovery was filed on 11/8/2011. The Jane Does' Opposition was filed on + +12/5/2011. Our Reply has not yet been filed. + +DE128: Petitioners' Protective Motion for Remedies was filed on 12/5/2011. Our Opposition has not yet + +been filed. + +DE130: Petitioners' Protective Motion to Compel was filed on 12/5/2011. We have not yet filed our + +Opposition. + +One does not begin calculating the 90 days on these motions until briefing is completed. + +As to the rest of Mr. Cassell's email, I don't recall promising early discovery, I only remember promising + +that, if the motion to stay was denied, we would be ready with our production. Is my memory off? I was going to recommend that I talk to Brad about some of the requests and ask if they have information that leads them to believe that there is evidence to be found (for example, re Bill Clinton or Prince Andrew) so that they can point us in the right direction. I would hate for us to deny something based on my + +here and sort through all of my boxes with me. And someone needs to order Jeff and Alex's records back from Archives (I don't know if Matt or Andy's materials are in archives or any closed file rooms). And someone needs to reach out to CEOS and the DAAG and AAG's offices, as well as DOJ Appellate. + +This discovery issue is going to be massive if we are ordered to respond, so it would help to have a civil legal + +assistant assigned. + +Assistant U.S. Attorney + +500 S. Australian Ave, Suite 400 + +West Palm Beach, FL 33401 + +Fax + +From: + +Sent: Friday, December 09, 2011 11:22 AM To: (USAFLS) + +Subject: FW: Jeffrey Epstein lawyers want to depose Scott Rothstein + +Endless... + +From: + +Sent: " . To: Sheehan, Evelyn B. (USAFLS) + +Subject: Jeffrey Epstein lawyers want to depose Scott Rothstein + +http://www.dailybusinessreview.com/PubArticleDBR.jsp? + +id=1202534991568&Jeffrey\_Epstein\_lawyers\_want\_to\_depose\_Scott\_Rothstein=&et=editorial&bu=D + +aily%20Business%20Review&cn=12.09.11&src=EMC- + +Email&pt=Daily%20am&kw=Jeffrey%20Epstein%20lawyers%20want%20to%20depose%20Scott%20 + +Rothstein &sl retu rn=1 + +Jeffrey Epstein lawyers want to depose Scott + +Rothstein + +Lawyers for convicted billionaire Jeffrey Epstein will ask a bankruptcy judge for permission to depose + +Ponzi scammer Scott Rothstein during his two-week deposition beginning next week. + +U.S. Bankruptcy Judge Raymond Ray in Fort Lauderdale set the hearing on Epstein's arguments. + +Epstein, who pleaded guilty in 2008 to soliciting prostitution following accusations that he had sex with + +girls, completed his year of house arrest last year. + +Epstein also is suing Rothstein and former Rothstein Rosenfeldt Adler attorney Bradley Edwards for + +allegedly filing a frivolous case. + +Rothstein's deposition begins Monday in Miami and is set to last through Christmas Eve with about 30 lawyers in line to question the former lawyer convicted of masterminding a \$1.2 billion settlement + +financing fraud. + +Rothstein, who is in protective custody, is serving a 50-year sentence at an undisclosed location. + +From: Sent: To: Subject: + +Friday, January 06, 2012 2:45 PM + +I. (USAFLS); (USAFLS) + +RE: Status of Outstanding Motions/Discovery issue + +Yes. Has Brad asked for preliminary responses? Can we actually respond in writing within the allotted 30 + +days? If we can, I think we should do so. + +From: . + +I. (USAFLS) + +Sent: Frida 06, 2012 2:42 PM + +To: M, (USAFLS); , (USAFLS) Subject: RE: Status of Outstanding Motions/Discovery issue + +Am I authorized to talk through the Requests for Admissions with Brad and give him my preliminary responses? + +Assistant U.S. Attorney + +500 S. Australian Ave, Suite 400 + +West Palm Beach, FL 33401 + +Fax + +and M, + +Since Cassell has conditioned his nonopposition with conditions, and since we don't agree with what the + +conditions, shall we just file our motion and say that the victims oppose it? That seems easier than engaging + +in a never-ending debate with Cassell on the construction and interpretation of the 90 day rule. + +My trial will begin on January 17, at 10:00 a.m. I am in the process now of notifying my witnesses and arranging times for their trial preparation interviews next week. I can put together a second motion for + +enlargement of time, but it will be after close of business. Thanks. + +From: (USAFLS) Sen ic :a ye JanuLy16,\_2012 2:24 PM + +To: MI (USAFLS); (USAFLS) Subject: RE: Status of Outstanding Motions/Discovery issue + +Under Local Rule 7.1(b)(4), the motions/responses/replies that would be the subject of the extension are not subject to the 90-day notice because none is a "motion or other matter which has been pending and fully briefed with no hearing set thereon for a period of ninety (90) days" and none is a "motion or other matter as to which the Court has conducted a hearing." Cassell's concern regarding those motions is thus unmerited. With respect to the other matters that has identified, they are not our motions, and Rule 7.1(b)(4) makes clear that the notice obligation is imposed on the "the movant or applicant." Notably, under the terms of the recently amended and renumbered rule, the notice must be "serve[d] on all parties and any affected non- + +parties!' The explicit filing requirement was deleted from the rule. + +As to "initial discovery," my recollection is that, notwithstanding the motion to stay discovery, we expressed a willingness to look at and consider a request for the government to provide discovery of discrete items where the resulting production would be relevant, not burdensome, and not otherwise objectionable. But I am unaware of any communication asking us to consider any more limited discovery request. I don't recall any representation that we would provide "a list of additional discovery that we could expect if [Petitioners'] + +motion to dismiss is denied," or anything else of the sort. It is not anything to which I would have been inclined + +to agree. + +• + +From: IMI I. (USAFLS) + +Sert ia + +, + +, Jant. 06, 2012 12:37 PM To: (USAFLS); IM, (USAFLS) Subject: Status of Outstanding Motions/Discovery issue + +Hi and + +DE51: Petitioners' Motion to Use Correspondence to Provide Violations of the CVRA and to Have their + +Unredacted Pleadings Unsealed. + +DE56: Motion to Intervene by Roy Black, Martin Weinberg, and Jay Lefkowitz + +DE93: Motion for Limited Intervention by Jeffrey Epstein + +The first three were all addressed by the Court at the August 12, 2011 hearing, although the Court allowed supplemental briefing after the hearing on DE56. The last of that supplemental briefing was filed on + +10/31/2011. + +DE93 was fully briefed on 10/14/2011. + +The 90-day mark on DE93 will be January 12th. My reading of Rule 7.1(b)(3)(B) is that if there is a hearing, even with supplemental briefing thereafter, one counts from the date of the hearing, and that date has long + +since passed, so there is nothing to report on DE50, DE51, and DE56. + +With regard to the outstanding motions, there are: + +DE119: Our motion to dismiss for lack of subject matter jurisdiction was filed on 11/8/2011. The Jane Does' + +Opposition was filed on 12/5/2011. Our Reply has not yet been filed. + +DE121: Our motion to stay discovery was filed on 11/8/2011. The Jane Does' Opposition was filed on + +12/5/2011. Our Reply has not yet been filed. + +DE128: Petitioners' Protective Motion for Remedies was filed on 12/5/2011. Our Opposition has not yet + +been filed. + +DE130: Petitioners' Protective Motion to Compel was filed on 12/5/2011. We have not yet filed our + +Opposition. + +One does not begin calculating the 90 days on these motions until briefing is completed. + +As to the rest of Mr. Cassell's email, I don't recall promising early discovery, I only remember promising + +that, if the motion to stay was denied, we would be ready with our production. Is my memory off? I was going to recommend that I talk to Brad about some of the requests and ask if they have information that leads them to believe that there is evidence to be found (for example, re Bill Clinton or Prince Andrew) so that they can point us in the right direction. I would hate for us to deny something based on my + +knowledge and find out later about some obscure contact in DC. Thoughts? + +To be ready with our production, though, I really need a legal assistant or attorney from Miami to come up + +here and sort through all of my boxes with me. And someone needs to order Jeff and Alex's records back from Archives (I don't know if Matt or Andy's materials are in archives or any closed file rooms). And someone needs to reach out to CEOS and the DAAG and AAG's offices, as well as DOJ Appellate. + +This discovery issue is going to be massive if we are ordered to respond, so it would help to have a civil legal + +assistant assigned. + +West Palm Beach, FL 33401 + +Fax + +From: I. (USAFLS) < Sent: Friday, December 09, 2011 9:39 AM + +To: USAFLS) (USAFLS) + +Subject: My active items summary + +Attachments: Case Status Reporting Form December 2011.wpd + +I II I Sony, I meant to send this out last night, too. + +«Case Status Reporting Form December 2011.wpd>> + +Assistant U.S. Attorney + +500 S. Australian Ave, Suite 400 + +West Palm Beach, FL 33401 + +Fax + +From: (USAFLS) < Sent: Friday, January 06, 2012 2:42 PM + +To: M (USAFLS); , (USAFLS) Subject: RE: Status of Outstanding Motions/Discovery issue + +Am I authorized to talk through the Requests for Admissions with Brad and give him my preliminary responses? + +Assistant U.S. Attorney + +500 S. Australian Ave, Suite 400 + +West Palm Beach, FL 33401 + +From: IMI, (USAFLS) + +Sen icila, Janita 06, 2012 2:36 PM To: (USAFLS); . + +I. (USAFLS) + +Subject: RE: Status of Outstanding Motions/Discovery issue + +and M, + +Since Cassell has conditioned his nonopposition with conditions, and since we don't agree with what the + +conditions, shall we just file our motion and say that the victims oppose it? That seems easier than engaging + +in a never-ending debate with Cassell on the construction and interpretation of the 90 day rule. + +My trial will begin on January 17, at 10:00 a.m. I am in the process now of notifying my witnesses and arranging times for their trial preparation interviews next week. I can put together a second motion for + +enlargement of time, but it will be after close of business. Thanks. + +From: (USAFLS) Sen i(:yla f JanuLry16,\_2012 2:24 PM + +To: MM, MI (USAFLS); (USAFLS) Subject: RE: Status of Outstanding Motions/Discovery issue + +Under Local Rule 7.1(b)(4), the motions/responses/replies that would be the subject of the extension are not subject to the 90-day notice because none is a "motion or other matter which has been pending and fully briefed with no hearing set thereon for a period of ninety (90) days" and none is a "motion or other matter as to which the Court has conducted a hearing." Cassell's concern regarding those motions is thus unmerited. With respect to the other matters that has identified, they are not our motions, and Rule 7.1(b)(4) makes clear that the notice obligation is imposed on the "the movant or applicant." Notably, under the terms of the recently amended and renumbered rule, the notice must be "serve[d] on all parties and any affected non- + +parties!" The explicit filing requirement was deleted from the rule. + +As to "initial discovery," my recollection is that, notwithstanding the motion to stay discovery, we expressed a willingness to look at and consider a request for the government to provide discovery of discrete items where the resulting production would be relevant, not burdensome, and not otherwise objectionable. But I am unaware of any communication asking us to consider any more limited discovery request. I don't recall any representation that we would provide "a list of additional discovery that we could expect if [Petitioners'] + +motion to dismiss is denied," or anything else of the sort. It is not anything to which I would have been inclined + +to agree. + +• + +From: MI I. (USAFLS) Senit ia, Jar.Jari06, 2012 12:37 PM + +To: , (USAFLS); M, (USAFLS) Subject: Status of Outstanding Motions/Discovery issue + +DE50: Petitioners' Motion for an Order Directing the U.S. Attorney's Office Not to Withhold Relevant + +Evidence (this was "held in abeyance" while the Court ordered "limited discovery"). + +DE51: Petitioners' Motion to Use Correspondence to Provide Violations of the CVRA and to Have their + +Unredacted Pleadings Unsealed. + +DE56: Motion to Intervene by Roy Black, Martin Weinberg, and Jay Lefkowitz + +DE93: Motion for Limited Intervention by Jeffrey Epstein + +The first three were all addressed by the Court at the August 12, 2011 hearing, although the Court allowed supplemental briefing after the hearing on DE56. The last of that supplemental briefing was filed on + +10/31/2011. + +DE93 was fully briefed on 10/14/2011. + +The 90-day mark on DE93 will be January 12th. My reading of Rule 7.1(b)(3)(B) is that if there is a hearing, even with supplemental briefing thereafter, one counts from the date of the hearing, and that date has long + +since passed, so there is nothing to report on DE50, DE51, and DE56. + +With regard to the outstanding motions, there are: + +DE119: Our motion to dismiss for lack of subject matter jurisdiction was filed on 11/8/2011. The Jane Does' + +Opposition was filed on 12/5/2011. Our Reply has not yet been filed. + +DE121: Our motion to stay discovery was filed on 11/8/2011. The Jane Does' Opposition was filed on + +12/5/2011. Our Reply has not yet been filed. + +DE128: Petitioners' Protective Motion for Remedies was filed on 12/5/2011. Our Opposition has not yet + +been filed. + +DE130: Petitioners' Protective Motion to Compel was filed on 12/5/2011. We have not yet filed our + +Opposition. + +One does not begin calculating the 90 days on these motions until briefing is completed. + +As to the rest of Mr. Cassell's email, I don't recall promising early discovery, I only remember promising + +that, if the motion to stay was denied, we would be ready with our production. Is my memory off? I was going to recommend that I talk to Brad about some of the requests and ask if they have information that leads them to believe that there is evidence to be found (for example, re Bill Clinton or Prince Andrew) so that they can point us in the right direction. I would hate for us to deny something based on my + +knowledge and find out later about some obscure contact in DC. Thoughts? + +To be ready with our production, though, I really need a legal assistant or attorney from Miami to come up + +here and sort through all of my boxes with me. And someone needs to order Jeff and Alex's records back from Archives (I don't know if Matt or Andy's materials are in archives or any closed file rooms). And someone needs to reach out to CEOS and the DAAG and AAG's offices, as well as DOJ Appellate. + +Assistant U.S. Attorney + +500 S. Australian Ave, Suite 400 + +West Palm Beach, FL 33401 + +Fax + +From: (USAFLS) < Sent: Friday, January 06, 2012 6:32 PM + +To: (USAFLS); (USAFLS) + +Subject: Re: Jane Doe litigation + +Were either of you able to confirm that these plaintiffs are our petitioners? + +From: (USAFLS) + +Sent: Wednesda January 04, 2012 08:26 PM + +To: , = I. (USAFLS); M, (USAFLS) + +Subject: Jane Doe litigation + +Can you confirm that the plaintiffs in the cases cited below are the petitioners in our CVRA matter? + +First Am. Compl. 11132-33, Doei Epstein, Case No. 08-80893-CIV-MARRA ("assert[ing] a cause of + +action against the Defendant, Jeffrey Epstein, pursuant to [18 . § 2255] and the [Non- + +Prosecution] agreement between the Defendant, Jeffrey Epstein, and the United States Government"); Compl. 11119-20, L.M. U Epstein, Case No. 09- 81092-CIV-Cohn (asserting that plaintiff was "covered by" provisions of the Non-Prosecution Agreement between the government and Epstein and that + +Epstein was thus "estopped by his plea and agreement with the Federal Government from denying the + +acts alleged in [the] Complaint, and must effectively admit liability to the Plaintiff, L.M., including + +admitting liability for all counts enumerated in this Complaint") + +From: M I. (USAFLS) Sent: Friday, January 06, 2012 2:49 PM + +To: M• (USAFLS); I , (USAFLS) Subject: RE: Status of Outstanding Motions/Discovery issue + +I can only respond within 30 days based upon my own knowledge. Someone needs to gather information from DC and figure out what happened within the Miami office. So, no, I do not believe that we can answer within + +the allotted time. But we can at least provide some "preliminary" discovery. + +Assistant U.S. Attorney + +500 S. Australian Ave, Suite 400 + +West Palm Beach, FL 33401 + +Fax + +From: (USAFLS) + +Sen icyla, Januaiyi61\_2012 2:45 PM + +To: (USAFLS); (USAFLS) Subject: RE: Status of Outstanding Motions/Discovery issue + +Yes. Has Brad asked for preliminary responses? Can we actually respond in writing within the allotted 30 + +days? If we can, I think we should do so. + +From: (USAFLS) Sent: FricEanuary 06, 2012 2:42 PM + +To: M, (USAFLS); (USAFLS) Subject: RE: Status of Outstanding Motions/Discovery issue + +Am I authorized to talk through the Requests for Admissions with Brad and give him my preliminary responses? + +Assistant U.S. Attorney + +500 S. Australian Ave, Suite 400 + +Fax + +From: U, (USAFLS) + +Sen ida t M06, 2012 2:36 PM + +To: (USAFLS); I. (USAFLS) Subject: RE: Status of Outstanding Motions/Discovery Issue + +and + +Since Cassell has conditioned his nonopposition with conditions, and since we don't agree with what the + +conditions, shall we just file our motion and say that the victims oppose it? That seems easier than engaging + +in a never-ending debate with Cassell on the construction and interpretation of the 90 day rule. + +My trial will begin on January 17, at 10:00 a.m. I am in the process now of notifying my witnesses and arranging times for their trial preparation interviews next week. I can put together a second motion for + +enlargement of time, but it will be after close of business. Thanks. + +From: (USAFLS) Sen icyla l JanuLy16/\_2012 2:24 PM + +To: (USAFLS); (USAFLS) Subject: RE: Status of Outstanding Motions/Discovery issue + +Under Local Rule 7.1(b)(4), the motions/responses/replies that would be the subject of the extension are not subject to the 90-day notice because none is a "motion or other matter which has been pending and fully briefed with no hearing set thereon for a period of ninety (90) days" and none is a "motion or other matter as to which the Court has conducted a hearing." Cassell's concern regarding those motions is thus unmerited. With respect to the other matters that has identified, they are not our motions, and Rule 7.1(b)(4) makes clear that the notice obligation is imposed on the "the movant or applicant." Notably, under the terms of the recently amended and renumbered rule, the notice must be "serve[d] on all parties and any affected non- + +parties." The explicit filing requirement was deleted from the rule. + +As to "initial discovery," my recollection is that, notwithstanding the motion to stay discovery, we expressed a willingness to look at and consider a request for the government to provide discovery of discrete items where the resulting production would be relevant, not burdensome, and not otherwise objectionable. But I am unaware of any communication asking us to consider any more limited discovery request. I don't recall any representation that we would provide "a list of additional discovery that we could expect if [Petitioners'] + +motion to dismiss is denied," or anything else of the sort. It is not anything to which I would have been inclined + +to agree. + +• + +From: IMI I. (USAFLS) Sen icla, iiii06, Jan 2012 12:37 PM + +To: , (USAFLS); M, (USAFLS) Subject: Status of Outstanding Motions/Discovery issue + +Hi • and + +There are several motions that are fully briefed but have not been decided: + +DE50: Petitioners' Motion for an Order Directing the U.S. Attorney's Office Not to Withhold Relevant + +Evidence (this was "held in abeyance" while the Court ordered "limited discovery"). + +DE51: Petitioners' Motion to Use Correspondence to Provide Violations of the CVRA and to Have their + +Unredacted Pleadings Unsealed. + +DE56: Motion to Intervene by Roy Black, Martin Weinberg, and Jay Lefkowitz + +DE93: Motion for Limited Intervention by Jeffrey Epstein + +The first three were all addressed by the Court at the August 12, 2011 hearing, although the Court allowed supplemental briefing after the hearing on DE56. The last of that supplemental briefing was filed on + +10/31/2011. + +DE93 was fully briefed on 10/14/2011. + +The 90-day mark on DE93 will be January 12th. My reading of Rule 7.1(b)(3)(B) is that if there is a hearing, even with supplemental briefing thereafter, one counts from the date of the hearing, and that date has long + +since passed, so there is nothing to report on DE50, DE51, and DE56. + +With regard to the outstanding motions, there are: + +DE119: Our motion to dismiss for lack of subject matter jurisdiction was filed on 11/8/2011. The Jane Does' + +Opposition was filed on 12/5/2011. Our Reply has not yet been filed. + +DE121: Our motion to stay discovery was filed on 11/8/2011. The Jane Does' Opposition was filed on + +12/5/2011. Our Reply has not yet been filed. + +DE128: Petitioners' Protective Motion for Remedies was filed on 12/5/2011. Our Opposition has not yet + +been filed. + +DE130: Petitioners' Protective Motion to Compel was filed on 12/5/2011. We have not yet filed our + +Opposition. + +One does not begin calculating the 90 days on these motions until briefing is completed. + +As to the rest of Mr. Cassell's email, I don't recall promising early discovery, I only remember promising + +that, if the motion to stay was denied, we would be ready with our production. Is my memory off? I was going to recommend that I talk to Brad about some of the requests and ask if they have information that leads them to believe that there is evidence to be found (for example, re Bill Clinton or Prince Andrew) so that they can point us in the right direction. I would hate for us to deny something based on my + +knowledge and find out later about some obscure contact in DC. Thoughts? + +To be ready with our production, though, I really need a legal assistant or attorney from Miami to come up + +here and sort through all of my boxes with me. And someone needs to order Jeff and Alex's records back from Archives (I don't know if Matt or Andy's materials are in archives or any closed file rooms). And someone needs to reach out to CEOS and the DAAG and AAG's offices, as well as DOJ Appellate. + +Assistant U.S. Attorney + +500 S. Australian Ave, Suite 400 + +West Palm Beach, FL 33401 + +Fax + +From: (USAFLS) + +Sent: Friday, December 09, 2011 1:10 PM + +To: (USAFLS); (USAFLS) + +Cc: Lavecchio, (USAFLS) + +Subject: FW: Jeffrey Epstein lawyers want to depose Scott Rothstein + +FYI - I assume they are trying to get some information on Brad Edwards. + +Larry — are you handling this? I will be out next week. and are handling the Epstein matter, + +so can you keep them up to date on this? + +Assistant U.S. Attorney + +500 S. Australian Ave, Suite 400 + +West Palm Beach, FL 33401 + +Fax + +From: + +Sen Kyla, December 09, 2011 11:22 AM To: I. (USAFLS) + +Subject: FW: Jeffrey Epstein lawyers want to depose Scott Rothstein + +From: Sen • To: + +Subject: Jeffrey Epstein lawyers want to depose Scott Rothstein + +http://www.dailybusinessreview.com/PubArticleDBR.jsp? + +id=12025349915688deffrey\_Epstein\_lawyers\_want\_to\_depose\_Scott\_Rothstein=&et=editorial&bu=D + +aily%20Business%20Review&cn=12.09.118'src=EMC- + +Email&pt=Daily%20am&kw=Jeffrey%20Epstein°/020lawyers%20want%20to%20deposec/020Scote/020 + +Rothstein &sl retu rn=1 + +Jeffrey Epstein lawyers want to depose Scott + +Rothstein + +Lawyers for convicted billionaire Jeffrey Epstein will ask a bankruptcy judge for permission to depose + +Ponzi scammer Scott Rothstein during his two-week deposition beginning next week. + +U.S. Bankruptcy Judge Raymond Ray in Fort Lauderdale set the hearing on Epstein's arguments. + +Epstein, who pleaded guilty in 2008 to soliciting prostitution following accusations that he had sex with + +girls, completed his year of house arrest last year. + +Epstein also is suing Rothstein and former Rothstein Rosenfeldt Adler attorney Bradley Edwards for + +allegedly filing a frivolous case. + +Rothstein's deposition begins Monday in Miami and is set to last through Christmas Eve with about 30 lawyers in line to question the former lawyer convicted of masterminding a \$1.2 billion settlement + +financing fraud. + +Rothstein, who is in protective custody, is serving a 50-year sentence at an undisclosed location. + +From: (USAFLS) < + +Sent: Thursday, December 01, 2011 5:13 PM + +To: Brad Edwards; Paul Cassell; (USAFLS); (USAFLS) + +Subject: RE: Conference call 11:15 AM Florida time - Friday + +From: Brad Edwards [mailto ] + +Sent: Thursday, December , + +To: Paul Cassell; i M I. (USAFLS); + +Cc: M, (USAFLS) + +Subject: RE: Conference call 11:15 AM Florida time - Friday + +11:15 is good for me. + +Brad Edwards + +Civil Justice Attorney + +Farmer, Jaffe, Weissing, + +Edwards, Fistos & Lehrman, P.L. + +425 North Andrews Avenue, Suite 2 + +Fort Lauderdale, Florida 33301 + +Telephone: + +Facsimile: + +Toll-free: 1 + +www.pathtojustice.com + +f logo Become our fan on Facebook + +P Please consider the environment before printing this e-mail. + +(USAFLS) + +IRS Circular 230 Disclosure: Please note that the views expressed herein or in any attachments hereto are not intended to constitute a "reliance opinion" under applicable Treasury Regulations, and + +accordingly are not intended or written to be used, and may not be used or relied upon, for the + +purpose of (i) avoiding tax-related penalties that may be imposed by the Internal Revenue Service, or (ii) promoting, marketing or recommending to another party any tax-related matters addressed herein. + +NOTICE: THE INFORMATION CONTAINED IN THIS TRANSMISSION IS ATTORNEY PRIVILEGED AND CONFIDENTIAL. IT IS INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY NAMED ABOVE. IF THE READER OF THIS MESSAGE IS NOT THE INTENDED RECIPIENT, YOU + +ARE HEREBY NOTIFIED THAT ANY DISSEMINATION, DISTRIBUTION OR COPY OF THIS + +COMMUNICATION IS STRICTLY PROHIBITED. IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONE TOLL FREE AND + +DELETE THE MATERIAL FROM ANY COMPUTER. THANK YOU. + +From: Paul Cassell [mailto: + +Sent: Thursda ecember 01, 2011 4:59 PM + +To: , = USAFLS); (USAFLS) + +Cc: Brad Edwards'', (USAFLS) + +Subject: RE: Conference call 11:15 AM Florida time - Friday + +Hi all, + +Does 11:15 AM Florida time on Friday work? + +If so, please call my cell phone + +conference call or set up a call in number? + +Looking forward to chatting. PC + +as well as Brad — can y'all initiate the + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law + +S.J. Quinney College of Law at the University of Utah + +332 South 1400 East, Room 101 + +Salt Lake City, UT 84112-0730 + +Voice: + +Fax: + +Email: + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the + +sender by reply electronic mail and delete the original message. Thank you. + +From: I. (USAFLS) [mailto: Sent: Thursda , December 01, 2011 2:34 PM To: (USAFLS); Paul Cassell Cc: Brad Edwards; (USAFLS) + +Subject: RE: Discovery Issues in Epstein - conference call at 5 PM today? + +Hi everyone — Sorry, I am having a very busy duty week. Tomorrow I have court at 9:00 probably until 11:00 and then again from 3:00 until 5:00. I have a debriefing at 1:00, but I should be able to step out + +after 1:30. So, 11:15 or 1:30 are best for me, but your schedules take priority. + +Assistant U.S. Attorney + +500 S. Australian Ave, Suite 400 + +West Palm Beach, FL 33401 + +Fax + +From: (USAFLS) + +Sent: Thursday, December 01, 2011 3:52 PM + +To: Paul Cassell + +Cc: Brad Edwards; (USAFLS); (USAFLS) Subject: RE: Discovery Issues in Epstein - conference call at 5 PM today? + +Unfortunately, that doesn't work for us today. Can we set up a time for tomorrow? + +• + +United States Attorney's Office + +99 N.E. 4th Street, Suite 800 + +Miami, FL 33132 + +Telephone: + +E-mail: + +Original Message From: Paul Cassell [mailto:( + +Sent: Thursda , December 01, 2011 2:22 PM + +To: , I. (USAFLS); (USAFLS); (USAFLS) + +Cc: Brad Edwards + +Subject: RE: Discovery Issues in Epstein - conference call at 5 PM today? + +Hi and Co., + +Thanks for the call. Sorry I was on the other line. + +Can we set up a time certain? That way Brad can participate. + +He is in a depo until 4:30, but should be free at 5 PM your time today (Thursday). Does that work? + +Looking forward to chatting. PC + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law + +Salt Lake City, UT 84112-0730 + +Voice: + +Fax: + +Email: + +http://www.law.utah.edu/profiles/defaultasp?PersonID=57&name=Cassell,Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the + +sender by reply electronic mail and delete the original message. Thank you. + +Original Message + +From: Paul Cassell + +Sent: Thursday, December 01, 2011 11:25 AM + +To: ' + +, • + +Cc: 'Brad Edwards' + +(USAFLS); \$ + +Subject: RE: Discovery Issues in Epstein + +Dear Mr. + +(USAFLS); (USAFLS)' + +We will shortly be filing a motion to compel Government responses to our discovery requests - discovery which, as you know, Judge Marra has already ordered. We realize, of course, that the Government has filed a motion to dismiss/stay. But if the Government's position is rejected on those + +motions, then the next issue is what discovery can we expect to receive from the Government. + +If the motions are denied, will the Government voluntarily produce anything to us? Will the + +government at least agree to produce the following: + +(2) Answers to all of the victims' requests for admission; + +(3) All documents, correspondence, and other information that the Government distributed to persons or entities outside of the federal Government or received from persons or entities outside of the federal + +government; and + +(4) All documents, correspondence, and other information covered by the victims' discovery request + +that is not subject to a claim of privilege. + +And, for all other information withheld, will the Government agree to produce a document-by-document + +privilege log, as required by the local rules? + +Thanks for your help on these questions and Brad and I have. + +Sincerely, + +Paul Cassell + +Co-Counsel for Jane Doe #1 and Jane Doe #2 + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the University + +of Utah + +332 South 1400 East, Room 101 + +Salt Lake City, UT 84112-0730 + +Voice: + +Fax: + +Ema + +http://www.law.utah.edu/profiles/defaultasp?PersonID=57&name=Cassell,Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or + +From: Brad Edwards < + +Sent: Thursday, December 01, 2011 5:04 PM + +To: Paul Cassell; • (USAFLS); + +Cc: (USAFLS) + +Subject: RE: Conference call 11:15 AM Florida time - Friday + +11:15 is good for me. + +Brad Edwards + +Civil Justice Attorney + +Farmer, Jaffe, Weissing, + +Edwards, Fistos & Lehrman, P.L. + +425 North Andrews Avenue, Suite 2 + +Fort Lauderdale, Florida 33301 + +Telephone: + +Facsimile: + +Toll-free: 1 + +www.pathtojustice.com + +f logo Become our fan on Facebook + +P Please consider the environment before printing this e-mail. + +(USAFLS) + +IRS Circular 230 Disclosure: Please note that the views expressed herein or in any attachments hereto are not intended to constitute a "reliance opinion" under applicable Treasury Regulations, and + +accordingly are not intended or written to be used, and may not be used or relied upon, for the + +purpose of (i) avoiding tax-related penalties that may be imposed by the Internal Revenue Service, or (ii) promoting, marketing or recommending to another party any tax-related matters addressed herein. + +NOTICE: THE INFORMATION CONTAINED IN THIS TRANSMISSION IS ATTORNEY PRIVILEGED AND CONFIDENTIAL. IT IS INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY NAMED ABOVE. IF THE READER OF THIS MESSAGE IS NOT THE INTENDED RECIPIENT, YOU + +ARE HEREBY NOTIFIED THAT ANY DISSEMINATION, DISTRIBUTION OR COPY OF THIS + +COMMUNICATION IS STRICTLY PROHIBITED. IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONE TOLL FREE AND + +DELETE THE MATERIAL FROM ANY COMPUTER. THANK YOU. + +From: Paul Cassell [mailto: ) + +Sent: Thursda ,December 01, 2011 4:59 PM + +To: , = USAFLS); (USAFLS) + +Cc: Brad Edwards'', (USAFLS) + +Subject: RE: Conference call 11:15 AM Florida time - Friday + +Hi all, + +Does 11:15 AM Florida time on Friday work? + +If so, please call my cell phone + +conference call or set up a call in number? + +Looking forward to chatting. PC + +as well as Brad — can y'all initiate the + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law + +S.J. Quinney College of Law at the University of Utah + +332 South 1400 East, Room 101 + +Salt Lake City, UT 84112-0730 + +Voice: + +Fax: + +Email: + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the + +sender by reply electronic mail and delete the original message. Thank you. + +From: I. (USAFLS) [mailto: Sent: Thursda , December 01, 2011 2:34 PM To: (USAFLS); Paul Cassell Cc: Brad Edwards; (USAFLS) + +Subject: RE: Discovery Issues in Epstein - conference call at 5 PM today? + +Hi everyone — Sorry, I am having a very busy duty week. Tomorrow I have court at 9:00 probably until 11:00 and then again from 3:00 until 5:00. I have a debriefing at 1:00, but I should be able to step out + +after 1:30. So, 11:15 or 1:30 are best for me, but your schedules take priority. + +Assistant U.S. Attorney + +500 S. Australian Ave, Suite 400 + +West Palm Beach, FL 33401 + +Fax + +From: (USAFLS) + +Sent: Thursday, December 01, 2011 3:52 PM + +To: Paul Cassell + +Cc: Brad Edwards; (USAFLS); (USAFLS) Subject: RE: Discovery Issues in Epstein - conference call at 5 PM today? + +Unfortunately, that doesn't work for us today. Can we set up a time for tomorrow? + +• + +United States Attorney's Office + +99 N.E. 4th Street, Suite 800 + +Miami, FL 33132 + +Telephone: + +E-mail: + +Original Message From: Paul Cassell [mailto: + +Sent: Thursda , December 01, 2011 2:22 PM + +To: , I. (USAFLS); (USAFLS); (USAFLS) + +Cc: Brad Edwards + +Subject: RE: Discovery Issues in Epstein - conference call at 5 PM today? + +Hi and Co., + +Thanks for the call. Sorry I was on the other line. + +Can we set up a time certain? That way Brad can participate. + +He is in a depo until 4:30, but should be free at 5 PM your time today (Thursday). Does that work? + +Looking forward to chatting. PC + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law + +Salt Lake City, UT 84112-0730 + +Voice: + +Fax: + +Email: + +http://www.law.utah.edu/profiles/defaultasp?PersonID=57&name=Cassell,Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the + +sender by reply electronic mail and delete the original message. Thank you. + +Original Message + +From: Paul Cassell + +Sent: Thursday, December 01, 2011 11:25 AM + +To: ' + +, • + +Cc: 'Brad Edwards' + +(USAFLS); \$ + +Subject: RE: Discovery Issues in Epstein + +Dear Mr. + +(USAFLS); (USAFLS)' + +We will shortly be filing a motion to compel Government responses to our discovery requests - discovery which, as you know, Judge Marra has already ordered. We realize, of course, that the Government has filed a motion to dismiss/stay. But if the Government's position is rejected on those + +motions, then the next issue is what discovery can we expect to receive from the Government. + +If the motions are denied, will the Government voluntarily produce anything to us? Will the + +government at least agree to produce the following: + +(2) Answers to all of the victims' requests for admission; + +(3) All documents, correspondence, and other information that the Government distributed to persons or entities outside of the federal Government or received from persons or entities outside of the federal + +government; and + +(4) All documents, correspondence, and other information covered by the victims' discovery request + +that is not subject to a claim of privilege. + +And, for all other information withheld, will the Government agree to produce a document-by-document + +privilege log, as required by the local rules? + +Thanks for your help on these questions and Brad and I have. + +Sincerely, + +Paul Cassell + +Co-Counsel for Jane Doe #1 and Jane Doe #2 + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the University + +of Utah + +332 South 1400 East, Room 101 + +Salt Lake City, UT 84112-0730 + +Voice: + +Fax: + +Email: + +http://www.law.utah.edu/profiles/defaultasp?PersonID=57&name=Cassell,Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or + +From: Paul Cassell < + +Sent: Thursday, December 01, 2011 4:59 PM + +To: (USAFLS); (USAFLS) + +Cc: Brad Edwards; (USAFLS) + +Subject: RE: Conference call 11:15 AM Florida time - Friday + +Hi all, + +Does 11:15 AM Florida time on Friday work? + +If so, please call my cell phone + +conference call or set up a call in number? + +Looking forward to chatting. PC + +as well as Brad — can y'all initiate the + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law + +S.J. Quinney College of Law at the University of Utah + +332 South 1400 East, Room 101 + +Salt Lake City, UT 84112-0730 + +Voice: + +Fax: + +Email: + +http://www.law.utah.edu/profiles/defaultasp?PersonID=57&name=Cassell,Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or + +From: I. (USAFLS) [mailto: Sent: Thursda , December 01, 2011 2:34 PM To: (USAFLS); Paul Cassell Cc: Brad Edwards; (USAFLS) + +Subject: RE: Discovery Issues in Epstein - conference call at 5 PM today? + +Hi everyone — Sorry, I am having a very busy duty week. Tomorrow I have court at 9:00 probably until 11:00 and then again from 3:00 until 5:00. I have a debriefing at 1:00, but I should be able to step out + +after 1:30. So, 11:15 or 1:30 are best for me, but your schedules take priority. + +Assistant U.S. Attorney + +500 S. Australian Ave, Suite 400 + +West Palm Beach, FL 33401 + +Fax + +From: (USAFLS) + +Sent: Thursday, December 01, 2011 3:52 PM + +To: Paul Cassell + +Cc: Brad Edwards; (USAFLS); (USAFLS) Subject: RE: Discovery Issues in Epstein - conference call at 5 PM today? + +Unfortunately, that doesn't work for us today. Can we set up a time for tomorrow? + +• + +Miami, FL 33132 + +Telephone: + +E-mail: + +Original Message + +From: Paul Cassell [t J1 + +Sent: Thursda , December 01, 2011 2:22 PM + +To: , I. (USAFLS); (USAFLS); (USAFLS) + +Cc: Brad Edwards + +Subject: RE: Discovery Issues in Epstein - conference call at 5 PM today? + +Hi and Co., + +Thanks for the call. Sorry I was on the other line. + +Can we set up a time certain? That way Brad can participate. + +He is in a depo until 4:30, but should be free at 5 PM your time today (Thursday). Does that work? + +Looking forward to chatting. PC + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law + +S.J. Quinney College of Law at the University of Utah + +332 South 1400 East, Room 101 + +Fax: + +Email: + +http://www.law.utah.edu/profiles/default.asp?PersonID=57&name=Cassell,Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the + +sender by reply electronic mail and delete the original message. Thank you. + +Original Message + +From: Paul Cassell + +Sent: Thursday, December 01, 2011 11:25 AM + +To: ' + +, • + +Cc: 'Brad Edwards' + +(USAFLS);' + +Subject: RE: Discovery Issues in Epstein + +Dear Mr. + +(USAFLS); (USAFLS)' + +We will shortly be filing a motion to compel Government responses to our discovery requests - discovery which, as you know, Judge Marra has already ordered. We realize, of course, that the Government has filed a motion to dismiss/stay. But if the Government's position is rejected on those + +motions, then the next issue is what discovery can we expect to receive from the Government. + +If the motions are denied, will the Government voluntarily produce anything to us? Will the + +government at least agree to produce the following: + +(1) The Government's initial disclosures pursuant to Fed. R. Civ. R 26; + +(3) All documents, correspondence, and other information that the Government distributed to persons or entities outside of the federal Government or received from persons or entities outside of the federal + +government; and + +(4) All documents, correspondence, and other information covered by the victims' discovery request + +that is not subject to a claim of privilege. + +And, for all other information withheld, will the Government agree to produce a document-by-document + +privilege log, as required by the local rules? + +Thanks for your help on these questions and Brad and I have. + +Sincerely, + +Paul Cassell + +Co-Counsel for Jane Doe #1 and Jane Doe #2 + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the University + +of Utah + +http://www.law.utah.edu/profiles/defaultasp?PersonID=57&name=Cassell,Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the + +sender by reply electronic mail and delete the original message. Thank you. + +From: Maria Kelljchian Sent: Thursday, December 01, 2011 4:55 PM To: (USAFLS) Cc: Brad Edwards; 'Paul Cassell' + +Subject: JANE DOE #1 and JANE DOM vs. US Attachments: Doe\_1st\_Req4Admissions\_to\_US.pdf + +Please see attached. Mailed out today. + +Thank you, + +Maria + +Maria W. Kelljchian + +Florida Registered Paralegal + +Farmer, Jaffe, Weissing, + +Edwards, Fistos & Lehrman, P.L. + +f logo Become our fan on Facebook + +From: (USAFLS) + +To: M, (USAFLS) + +Subject: RE: Discovery Issues in Epstein - conference call at 5 PM today? + +Sent: Thursday, December 01, 2011 4:33:54 PM (UTC-05:00) Eastern Time (US & Canada) + +was read on Thursday, December 01, 2011 4:37:50 PM (UTC-05:00) Eastern Time (US & Canada). + +From: (USAFLS) Sent: Thursday, December 01, 2011 8:19 PM + +To: (USAFLS) + +Subject: RE: Conference call 11:15 AM Florida time - Friday + +Hi — I am going to have to call in from the Igloo at the courthouse. If you can send me an email + +with all the info, I would appreciate it. + +Assistant U.S. Attorney + +500 S. Australian Ave, Suite 400 + +West Palm Beach, FL 33401 + +Fax + +From: M, (USAFLS) + +Sent: Thursday, December 01, 2011 5:24 PM + +To: Paul Cassell; (USAFLS); + +Cc: Brad Edwards + +Subject: RE: Conference call 11:15 AM Florida time - Friday + +Paul, + +(USAFLS) + +We will take care of the arrangements for tomorrow at 11:15 a.m. Thanks. + +Sent: Thursda ecember 01, 2011 4:59 PM + +To: , = USAFLS); (USAFLS) + +Cc: Brad Edwards; (USAFLS) + +Subject: RE: Conference call 11:15 AM Florida time - Friday + +Hi all, + +Does 11:15 AM Florida time on Friday work? + +If so, please call my cell phone + +conference call or set up a call in number? + +Looking forward to chatting. PC + +as well as Brad — can y'all initiate the + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law + +S.J. Quinney College of Law at the University of Utah + +332 South 1400 East, Room 101 + +Salt Lake City, UT 84112-0730 + +Voice: + +Fax: + +Email: cassellp@law.utah.edu + +http://www.law.utah.edu/profiles/default.asp?PersonID=57&name=Cassell,Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the + +sender by reply electronic mail and delete the original message. Thank you. + +From: I. (USAFLS) [mailto: Sent: Thursda , December 01, 2011 2:34 PM To: (USAFLS); Paul Cassell Cc: Brad Edwards; (USAFLS) + +Subject: RE: Discovery Issues in Epstein - conference call at 5 PM today? + +Hi everyone — Sorry, I am having a very busy duty week. Tomorrow I have court at 9:00 probably until 11:00 and then again from 3:00 until 5:00. I have a debriefing at 1:00, but I should be able to step out + +after 1:30. So, 11:15 or 1:30 are best for me, but your schedules take priority. + +Assistant U.S. Attorney + +500 S. Australian Ave, Suite 400 + +West Palm Beach, FL 33401 + +Fax + +From: (USAFLS) + +Sent: Thursday, December 01, 2011 3:52 PM + +To: Paul Cassell + +Cc: Brad Edwards; I. (USAFLS); (USAFLS) Subject: RE: Discovery Issues in Epstein - conference call at 5 PM today? + +Unfortunately, that doesn't work for us today. Can we set up a time for tomorrow? + +• + +Counselor to the United States Attorney + +United States Attorney's Office + +99 N.E. 4th Street, Suite 800 + +E-mail: + +Original Message + +From: Paul Cassell [mailto:cassellp@law.utah.edul Sent: Thursda , December 01, 2011 2:22 PM + +To: , I. (USAFLS); (USAFLS); (USAFLS) + +Cc: Brad Edwards + +Subject: RE: Discovery Issues in Epstein - conference call at 5 PM today? + +Hi and Co., + +Thanks for the call. Sorry I was on the other line. + +Can we set up a time certain? That way Brad can participate. + +He is in a depo until 4:30, but should be free at 5 PM your time today (Thursday). Does that work? + +Looking forward to chatting. PC + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law + +S.J. Quinney College of Law at the University of Utah + +332 South 1400 East, Room 101 + +Salt Lake City, UT 84112-0730 + +Voice: + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the + +sender by reply electronic mail and delete the original message. Thank you. + +Original Message + +From: Paul Cassell + +Sent: Thursday, December 01, 2011 11:25 AM + +To: ' + +, • + +Cc: 'Brad Edwards' + +(USAFLS); \$ + +Subject: RE: Discovery Issues in Epstein + +Dear Mr. + +(USAFLS); (USAFLS)' + +We will shortly be filing a motion to compel Government responses to our discovery requests - discovery which, as you know, Judge Marra has already ordered. We realize, of course, that the Government has filed a motion to dismiss/stay. But if the Government's position is rejected on those + +motions, then the next issue is what discovery can we expect to receive from the Government. + +If the motions are denied, will the Government voluntarily produce anything to us? Will the + +government at least agree to produce the following: + +(1) The Government's initial disclosures pursuant to Fed. R. Civ. R 26; + +(2) Answers to all of the victims' requests for admission; + +(3) All documents, correspondence, and other information that the Government distributed to persons or entities outside of the federal Government or received from persons or entities outside of the federal + +government; and + +And, for all other information withheld, will the Government agree to produce a document-by-document + +privilege log, as required by the local rules? + +Thanks for your help on these questions and Brad and I have. + +Sincerely, + +Paul Cassell + +Co-Counsel for Jane Doe #1 and Jane Doe #2 + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the University + +of Utah + +332 South 1400 East, Room 101 + +Salt Lake City, UT 84112-0730 + +Voice: + +Fax: + +Email: + +http://www.law.utah.edu/profiles/defaultasp?PersonID=57&name=Cassell,Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the + +sender by reply electronic mail and delete the original message. Thank you. + +From: M I. (USAFLS) Sent: Thursday, December 01, 20114:3 + +To: (USAFLS); Paul Cassell Cc: Brad Edwards; M, ( US A F LS ) + +Subject: RE: Discovery Issues in Epstein - conference call at 5 PM today? + +Hi everyone — Sorry, I am having a very busy duty week. Tomorrow I have court at 9:00 probably until 11:00 and then again from 3:00 until 5:00. I have a debriefing at 1:00, but I should be able to step out + +after 1:30. So, 11:15 or 1:30 are best for me, but your schedules take priority. + +A. Villafatia + +Assistant U.S. Attorney + +500 S. Australian Ave, Suite 400 + +West Palm Beach, FL 33401 + +Fax + +From: (USAFLS) + +Sent: Thursday, December 01, 2011 3:52 PM + +To: Paul Cassell + +Cc: Brad Edwards; I. (USAFLS); (USAFLS) Subject: RE: Discovery Issues in Epstein - conference call at 5 PM today? + +Unfortunately, that doesn't work for us today. Can we set up a time for tomorrow? + +• + +Counselor to the United States Attorney + +United States Attorney's Office + +99 N.E. 4th Street, Suite 800 + +Miami, FL 33132 + +Telephone: + +E-mail: + +Original Message + +From: Paul Cassell [mailto:cassellp@law.utah.edul + +Sent: Thursda , December 01, 2011 2:22 PM + +To: , I. (USAFLS); (USAFLS); (USAFLS) + +Cc: Brad Edwards + +Subject: RE: Discovery Issues in Epstein - conference call at 5 PM today? + +Hi and Co., + +Thanks for the call. Sorry I was on the other line. + +Can we set up a time certain? That way Brad can participate. + +He is in a depo until 4:30, but should be free at 5 PM your time today (Thursday). Does that work? + +Looking forward to chatting. PC + +Paul G. Cassell + +Salt Lake City, UT 84112-0730 + +Voice: + +Fax: + +Email: + +http://www.law.utah.edu/profiles/default.asp?PersonID=57&name=Cassell,Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the + +sender by reply electronic mail and delete the original message. Thank you. + +Original Message + +From: Paul Cassell + +Sent: Thursday, December 01, 2011 11:25 AM + +To: (USAFLS); (USAFLS); (USAFLS)' + +Cc: 'Brad Edwards' + +Subject: RE: Discovery Issues in Epstein + +Dear Mr. + +We will shortly be filing a motion to compel Government responses to our discovery requests - discovery which, as you know, Judge Marra has already ordered. We realize, of course, that the Government has filed a motion to dismiss/stay. But if the Government's position is rejected on those + +motions, then the next issue is what discovery can we expect to receive from the Government. + +If the motions are denied, will the Government voluntarily produce anything to us? Will the + +government at least agree to produce the following: + +(2) Answers to all of the victims' requests for admission; + +(3) All documents, correspondence, and other information that the Government distributed to persons or entities outside of the federal Government or received from persons or entities outside of the federal + +government; and + +(4) All documents, correspondence, and other information covered by the victims' discovery request + +that is not subject to a claim of privilege. + +And, for all other information withheld, will the Government agree to produce a document-by-document + +privilege log, as required by the local rules? + +Thanks for your help on these questions and Brad and I have. + +Sincerely, + +Paul Cassell + +Co-Counsel for Jane Doe #1 and Jane Doe #2 + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the University + +of Utah + +332 South 1400 East, Room 101 + +Salt Lake City, UT 84112-0730 + +Voice: + +Fax: + +Email + +http://www.law.utah.edu/profiles/defaultasp?PersonID=57&name=Cassell,Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the + +person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the + +sender by reply electronic mail and delete the original message. Thank you. + +From: Sent: To: Subject: Attachments: (USAFLS) + +Thursday, December 01, 2011 6:00 PM + +(USAFLS); (USAFLS) + +FW: JANE DOE #1 and JANE DOE#2 vs. US Doe\_1st\_Req4Admissions\_to\_US.pdf + +Look what I received by email today! + +Assistant U.S. Attorney + +500 S. Australian Ave, Suite 400 + +West Palm Beach, FL 33401 + +Fax + +From: Maria Kelljchian [mailtc ] + +Sent: Thursda , December 01, 2011 4:55 PM + +To: , (USAFLS) Cc: Brad Edwards; 'Paul Cassell' + +Subject: JANE DOE #1 and JANE DOE#2 vs. US + +Please see attached. Mailed out today. + +Thank you, + +Maria + +Maria W. Kelljchian + +Edwards, Fistos & Lehrman, P.L. + +425 North Andrews Avenue, Suite 2 + +Fort Lauderdale, Florida 33301 + +fax + +f logo Become our fan on Facebook + +From: (USAFLS) + +Sent: Thursday, December 01, 2011 5:24 PM + +To: Paul Cassell; • (USAFLS); + +Cc: Brad Edwards + +Subject: RE: Conference call 11:15 AM Florida time - Friday + +Paul, + +We will take care of the arrangements for tomorrow at 11:15 a.m. Thanks. + +From: Paul Cassell [mailto:cassellp@law.utah.edu] + +Sent: Thursda ecember 01, 2011 4:59 PM + +To: , = USAFLS); (USAFLS) + +Cc: Brad Edwards'', (USAFLS) + +Subject: RE: Conference call 11:15 AM Florida time - Friday + +(USAFLS) + +Does 11:15 AM Florida time on Friday work? + +If so, please call my cell phone as well as Brad — can y'all initiate the + +conference call or set up a call in number? + +Looking forward to chatting. PC + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law + +S.J. Quinney College of Law at the University of Utah + +332 South 1400 East, Room 101 + +Salt Lake City, UT 84112-0730 + +Voice: + +Fax: + +Email: + +http://www.law.utah.edu/profiles/default.asp?PersonID=57&name=Cassell,Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the + +sender by reply electronic mail and delete the original message. Thank you. + +From: I. (USAFLS) [mailto Sent: Thursda December 01, 2011 2:34 PM To: (USAFLS); Paul Cassell Cc: Brad Edwards; (USAFLS) + +Subject: RE: Discovery Issues in Epstein - conference call at 5 PM today? + +Hi everyone — Sorry, I am having a very busy duty week. Tomorrow I have court at 9:00 probably until 11:00 and then again from 3:00 until 5:00. I have a debriefing at 1:00, but I should be able to step out + +Assistant U.S. Attorney + +500 S. Australian Ave, Suite 400 + +West Palm Beach, FL 33401 + +Fax + +From: (USAFLS) + +Sent: Thursday, December 01, 2011 3:52 PM + +To: Paul Cassell + +Cc: Brad Edwards; (USAFLS); (USAFLS) Subject: RE: Discovery Issues in Epstein - conference call at 5 PM today? + +Unfortunately, that doesn't work for us today. Can we set up a time for tomorrow? + +• + +I. Sanchez + +Counselor to the United States Attorney + +United States Attorney's Office + +99 N.E. 4th Street, Suite 800 + +Miami, FL 33132 + +Telephone: + +E-mail: + +Original Message From: Paul Cassell [mailto Sent: Thursda ecember + +To: , I. (USAFLS); (USAFLS); (USAFLS) + +Cc: Brad Edwards + +Subject: RE: Discovery Issues in Epstein - conference call at 5 PM today? + +Hi and Co., + +Thanks for the call. Sorry I was on the other line. + +Can we set up a time certain? That way Brad can participate. + +He is in a depo until 4:30, but should be free at 5 PM your time today (Thursday). Does that work? + +Looking forward to chatting. PC + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law + +S.J. Quinney College of Law at the University of Utah + +332 South 1400 East, Room 101 + +Salt Lake City, UT 84112-0730 + +Voice: + +Fax: + +Email: cassellp@law.utah.edu + +http://www.law.utah.edu/profiles/default.asp?PersonID=57&name=Cassell,Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the + +sender by reply electronic mail and delete the original message. Thank you. + +Original Message + +From: Paul Cassell + +Sent: Thursday, December 01, 2011 11:25 AM + +To: • + +Cc: 'Brad Edwards' + +(USAFLS); + +Subject: RE: Discovery Issues in Epstein + +Dear Mr. + +(USAFLS); sM, (USAFLS)' + +We will shortly be filing a motion to compel Government responses to our discovery requests - discovery which, as you know, Judge Marra has already ordered. We realize, of course, that the Government has filed a motion to dismiss/stay. But if the Government's position is rejected on those + +motions, then the next issue is what discovery can we expect to receive from the Government. + +If the motions are denied, will the Government voluntarily produce anything to us? Will the + +government at least agree to produce the following: + +(1) The Government's initial disclosures pursuant to Fed. R. Civ. R 26; + +(2) Answers to all of the victims' requests for admission; + +(3) All documents, correspondence, and other information that the Government distributed to persons or entities outside of the federal Government or received from persons or entities outside of the federal + +government; and + +(4) All documents, correspondence, and other information covered by the victims' discovery request + +that is not subject to a claim of privilege. + +And, for all other information withheld, will the Government agree to produce a document-by-document + +privilege log, as required by the local rules? + +Sincerely, + +Paul Cassell + +Co-Counsel for Jane Doe #1 and Jane Doe #2 + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the University + +of Utah + +332 South 1400 East, Room 101 + +Salt Lake City, UT 84112-0730 + +Voice: + +Fax: + +Email: cassellp@law.utah.edu + +http://www.law.utah.edu/profiles/defaultasp?PersonID=57&name=Cassell,Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the + +sender by reply electronic mail and delete the original message. Thank you. + +From: (USAFLS) + +Sent: Wednesday, January 04, 2012 8:27 PM + +To: (USAFLS); (USAFLS) + +Subject: Jane Doe litigation + +First Am. Compl. ¶11132-33, Doet Epstein, Case No. 08-80893-CIV-MARRA cassert[ing] a cause of + +action against the Defendant, Jeffrey Epstein, pursuant to [18 . § 2255] and the [Non- + +Prosecution] agreement between the Defendant, Jeffrey Epstein, and the United States Government"); Compl. ¶1119-20, L.M. U Epstein, Case No. 09- 81092-CIV-Cohn (asserting that plaintiff was "covered by" provisions of the Non-Prosecution Agreement between the government and Epstein and that + +Epstein was thus "estopped by his plea and agreement with the Federal Government from denying the + +acts alleged in [the] Complaint, and must effectively admit liability to the Plaintiff, L.M., including + +admitting liability for all counts enumerated in this Complaint") + +Thanks, + +• + +From: (USAFLS) + +Sent: Friday, January 06, 2012 11:32 AM + +To: (USAFLS); (USAFLS) Subject: RE: Replies and Responses Due on January 6, 2012 + +I think there may be at least one motion that is fully briefed that wasn't addressed at the hearing — Epstein's Motion to Intervene. I will look at the docket sheet and figure this out. I still think that we are + +beyond the 90 days + 14, so let me check. + +A. Villafatia + +Assistant U.S. Attorney + +500 S. Australian Ave, Suite 400 + +West Palm Beach, FL 33401 + +Fax + +From: , (USAFLS) Sent: Fridslanuary 06, 2012 10:52 AM + +To: M, (USAFLS); , M I. (USAFLS) Subject: Re: Replies and Responses Due on January 6, 2012 + +From: Paul Cassell [mailto:cassellp@law.utah.edu] + +Sent: Frida , January 06, 2012 10:40 AM + +To: , USAFLS); Brad Edwards + +Cc: , (USAFLS); , I. (USAFLS) + +Subject: RE: Replies and Responses Due on January 6, 2012 + +Hey + +As you know, we're happy to try and be accommodating. We would be glad to consent to additional + +time, but would ask in exchange for two things: + +1. The various delays mean that several motions have now been (or will shortly be) pending for more than 90 days, triggering a 90 day report obligation under the local rules. We would trust you + +would be willing to file that with Judge Marra. + +2. When we finished our telephone call with you some weeks back, Brad and I understood that we would be receiving (a) some initial discovery in the case and (b) a list of additional discovery that we could expect if your motion to dismiss is denied. But we have yet to receive anything at all regarding discovery. We would trust that you will carry through on what we understood you had agreed to in the + +telephone call. + +Again, we are happy to help - but would ask you to help us on these two points. Thanks! + +Paul Cassell + +Co-counsel for Jane Doe #1 and Jane Doe #2 + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law + +S.J. Quinney College of Law at the University of Utah + +332 South 1400 East, Room 101 + +Salt Lake City, UT 84112-0730 + +Voice: + +http://www.law.utah.edu/profiles/default.asp?PersonID=578fflame=Cassell,Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the + +sender by reply electronic mail and delete the original message. Thank you. + +From: M, (USAFLS) [mailto + +Sent: Thursday, January 05, 2012 5:24 PM + +To: Paul Cassell; Brad Edwards + +Cc: , (USAFLS); M I. (USAFLS) + +Subject: Replies and Responses Due on January 6, 2012 + +Paul and Brad, + +Happy New Year. I need to ask if you have an objection to the government seeking a second + +enlargement of time, up to Tuesday, January 24, 2012, to file replies to the victims' two responses to the government's motion to dismiss and motion to stay discovery, and responses to the victims' + +protective motion to compel and protective motion for remedies. + +is preparing for an evidentiary hearing in a 28 . 2255 motion, which is scheduled for January 24, 2012. I am scheduled to go to trial in a tort case sometime during the two week trial + +period commencing January 17, 2012. I have spent most of the prec, two weeks getting ready for the trial. My colleague • , with sporadic assistance from and I, will be preparing the + +responses and replies. + +Please let me know if you have any objections. Thanks. + +From: , (USAFLS) + +Sent: Thursda , December 01, 2011 11:00 AM + +To: , = I. (USAFLS); M, (USAFLS + +Subject: RE: Telephone Conference re: Epstein & Jane Doe I. Enited States + +Shall we confer briefly at 1:30 to make sure we're on the same page and then call him? Is there any reason why we need to make this a scheduled conference call including Edwards, or should we just initiate the call to + +Cassell and let him decide if he wants to postpone it to bring in Edwards? + +From: . + +I. (USAFLS) + +Sent: Thursdathecember 01, 2011 10:17 AM + +To: I , (USAFLS); M, (USAFLS) + +Cc: Greenberg, Benjamin (USAFLS) + +Subject: RE: Telephone Conference re: Epstein & Jane Doe I Enited States + +Yes, I think we need to call him. Do you want to try for 1:30 since we have the time already set aside? + +A. + +Assistant U.S. Attorney + +500 S. Australian Ave, Suite 400 + +West Palm Beach, FL 33401 + +Fax + +From: (USAFLS) + +Sent: Thursda December 01, 2011 10:15 AM + +To: , U. (USAFLS); (USAFLS) + +Cc: Greenberg, Benjamin (USAFLS) + +Subject: RE: Telephone Conference re: Epstein & Jane Doe I Enited States + +I just received a call from Bentley's assistant. Bentley is canceling today's conference call; he is feeling a little under the weather and is not coming into the office today. She told me that he will call me tomorrow to reschedule. Sorry. Given that it is unlikely that we are going to have a substantive discussion with Bentley this week, do you think we should reach out and call Cassell back before the week is over? I admit that thought is + +also making me feel a little bit under the weather. + +We're on for 1:30 tomorrow. I'll set things up for a conference call at that time and send out the call-in + +information. + +Thanks, + +• + +From: (USAFLS) + +Sent: Tuesda November 29, 2011 6:11 PM + +To: ."Be , USAFLM) + +Cc: I. (USAFLS); (USAFLS); Greenberg, Benjamin (USAFLS) + +Subject: Telephone Conference re: Epstein & Jane Doe I Enited States + +Hi, M. + +I hope you had a great Thanksgiving. + +As we had previously discussed, I am contacting you to see if we can set up a telephone conference to address some of the outstanding matters that we need to discuss to complete the transfer of the criminal case to your district and meet our obligations under USAP 3-2.170.001. (I also left a message with your assistant earlier today.) Those matters include: the nature and scope of any charges/investigation that may potentially remain + +viable in the SDFL following the entry of the Non-Prosecution Agreement; the need to advise the FBI in + +connection with the agents' pending requests for grand jury subpoenas and their expressed intent to continue investigating allegations against Epstein, advice which in all likelihood will require informing the FBI agents about other USAOs that might be able to assist them in light of the grand jury evidence previously obtained; + +and the handling of the criminal case file. + +We ( Villafana, who was previously assigned to the criminal investigation; M, who is handling the + +CVRA litigation; and me) can make ourselves available to confer with you after 10:30 tomorrow morning, + +tomorrow afternoon, or Thursday morning. If those blocks of time do not work, please let us know and we can + +make other arrangements to accommodate your schedule. + +Thanks, + +• + +L + +Counselor to the United States Attorney + +United States Attorney's Office + +From: (USAFLS) + +Sent: Thursda December 01, 2011 10:15 AM + +To: (USAFLS); (USAFLS) + +Cc: Greenberg, Benjamin (USAFLS) + +Subject: RE: Telephone Conference re: Epstein & Jane Doe I Enited States + +I just received a call from Bentley's assistant. Bentley is canceling today's conference call; he is feeling a little under the weather and is not coming into the office today. She told me that he will call me tomorrow to reschedule. Sorry. Given that it is unlikely that we are going to have a substantive discussion with Bentley this week, do you think we should reach out and call Cassell back before the week is over? I admit that thought is + +also making me feel a little bit under the weather. + +From: 'MI, (USAFLS) + +Sent: Wednesday, November 30, 2011 7:35 PM + +We're on for 1:30 tomorrow. I'll set things up for a conference call at that time and send out the call-in + +information. + +Thanks, + +From: (USAFLS) + +Sent: Tuesda November 29, 2011 6:11 PM + +To: .iBer t USAFLM) + +Cc: I. (USAFLS); (USAFLS); Greenberg, Benjamin (USAFLS) + +Subject: Telephone Conference re: Epstein 8( Jane Doe I Enited States + +Hi, M. + +I hope you had a great Thanksgiving. + +As we had previously discussed, I am contacting you to see if we can set up a telephone conference to address some of the outstanding matters that we need to discuss to complete the transfer of the criminal case to your district and meet our obligations under USAP 3-2.170.001. (I also left a message with your assistant earlier today.) Those matters include: the nature and scope of any charges/investigation that may potentially remain + +viable in the SDFL following the entry of the Non-Prosecution Agreement; the need to advise the FBI in + +connection with the agents' pending requests for grand jury subpoenas and their expressed intent to continue investigating allegations against Epstein, advice which in all likelihood will require informing the FBI agents about other USAOs that might be able to assist them in light of the grand jury evidence previously obtained; + +and the handling of the criminal case file. + +We ( Villafalia, who was previously assigned to the criminal investigation; M, who is handling the + +CVRA litigation; and me) can make ourselves available to confer with you after 10:30 tomorrow morning, + +tomorrow afternoon, or Thursday morning. If those blocks of time do not work, please let us know and we can + +make other arrangements to accommodate your schedule. + +Thanks, + +• + +L Sanchez + +Counselor to the United States Attorney + +United States Attorney's Office + +99 N.E. 4th Street, Suite 800 + +E-mail: + +We (= Villafana, who was previously assigned to the criminal investigation; M, who is handling the CVRA litigation; and me) can make ourselves available to confer with you after 10:30 tomorrow morning, tomorrow afternoon, or Thursday morning. If those blocks of time do not work, + +please let us know and we can make other arrangements to accommodate your schedule. + +Thanks, + +I. Sanchez + +Counselor to the United States Attorney + +United States Attorney's Office + +99 N.E. 4th Street, Suite 800 + +Miami, FL 33132 + +Telephone: + +E-mail: + +From: Paul Cassell Sent: Thursday, December 01, 2011 1:25 PM + +To: I. (USAFLS); (USAFLS); (USAFLS) + +Cc: Brad Edwards + +Subject: RE: Discovery Issues in Epstein + +Dear Mr. + +We will shortly be filing a motion to compel Government responses to our discovery requests -- discovery which, as you know, Judge Marra has already ordered. We realize, of course, that the Government has filed a motion to dismiss/stay. But if the Governments position is rejected on those motions, then the next issue is what discovery can we expect to + +receive from the Government. + +of the federal Government or received from persons or entities outside of the federal government; and + +(4) All documents, correspondence, and other information covered by the victims' discovery request that is not subject to + +a claim of privilege. + +And, for all other information withheld, will the Government agree to produce a document-by-document privilege log, as + +required by the local rules? + +Thanks for your help on these questions and Brad and I have. + +Sincerely, + +Paul Cassell + +Co-Counsel for Jane Doe #1 and Jane Doe #2 + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the University of Utah + +332 South 1400 East, Room 101 Salt Lake City, UT 84112-0730 + +Voice: Fax: + +Email: cassellp@law.utah.edu + +http://www.law.utah.edu/profiles/default.asp?PersonID=578'name=Cassell,Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, + +please immediately notify the sender by reply electronic mail and delete the original message. Thank you. + +From: Paul Cassell Sent: Thursday, December 01, 2011 12:49 PM + +To: I. (USAFLS); (USAFLS); (USAFLS) + +Cc: Brad Edwards + +Subject: RE: Redacted Pleading Rather than Sealing the Entire Pleading + +Dear Mr. + +We haven't heard back from you on the issue regarding sealing of the Government's leading in the Epstein case. (See email below sent earlier this week.) I was hoping that you (or Ms. or Mr. IM) could get back to Brad and me + +quickly on this issue. + +As you know, we have a series of pleadings that we need to file on Monday. We are trying to understand the + +Government's position on sealing these pleadings. + +As you also know, we think there is absolutely no basis for sealing the majority of the Government's pleadings. We hope + +you agree so that we can move forward consensually, at least on this issue. + +Thank you in advance for your assistance. + +Paul Cassell + +Co-Counsel for Jane Doe #1 and Jane Doe #2 + +Voice: Fax: + +Email: cassellp@law.utah.edu + +http://www.law.utah.edu/profiles/default.asp?PersonID=57&name=Cassell,Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, + +please immediately notify the sender by reply electronic mail and delete the original message. Thank you. + +Original Message From: Paul Cassell + +Sent: Monday, November 28, 2011 2:29 PM + +To: N. (USAFLS)'; (USAFLS)'; (USAFLS)' + +Cc: 'Brad Edwards' + +Subject: RE: Redacted Pleading Rather than Sealing the Entire Pleading + +Dear Mr. + +I am writing as co-counsel in the Jane Doe case. I understand that you are supervising the case for U.S. Attorney's Office + +there. + +I am writing to request that the Government file new, redacted copies of its currently pending motion to dismiss and motion for stay. As you may know, the Government has filed these two motions entirely under seal. Yet the vast bulk of both + +motions do not deal with any material that needs to be under seal. + +As you may know, Judge Marra has previously unsealed other pleadings in this case, recognizing the considerable public interest in the issues being discussed. As you also know, Jane Doe #1 and Jane Doe #2 have tried to work cooperatively with the Government wherever possible. For example, we earlier stipulated to proposed redactions of material proposed + +by Ms. to avoid disclosing information that she viewed as confidential. + +In light of all this, the victims are writing to inquire whether the Government would file a motion to place redacted copies of its two motions in the public court file in the case. Attached are two redacted pleadings that we believe remove all + +information that is properly subject to sealing to protect confidential grand jury material - but no more. + +Please let me know whether the Government is willing to move forward on that basis. + +Sincerely, + +Paul Cassell + +Co-Counsel for Jane Doe #1 and Jane Doe #2 + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the University of Utah + +332 South 1400 East, Room 101 Salt Lake City, UT 84112-0730 + +Voice: Fax: + +Email: cassellp@law.utah.edu + +http://www.law.utah.edu/profiles/default.asp?PersonID=57&name=Cassell,Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, + +please immediately notify the sender by reply electronic mail and delete the original message. Thank you. + +Subject: RE: Discovery Issues in Epstein - conference call at 5 PM today? + +Hi and Co., + +Thanks for the call. Sorry I was on the other line. + +Can we set up a time certain? That way Brad can participate. + +He is in a depo until 4:30, but should be free at 5 PM your time today (Thursday). Does that work? + +Looking forward to chatting. PC + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the University of Utah + +332 South 1400 East, Room 101 Salt Lake City, UT 84112-0730 + +Voice: Fax: + +Email: cassellp@law.utah.edu + +http://www.law.utah.edu/profiles/default.asp?PersonID=578'name=Cassell,Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, + +please immediately notify the sender by reply electronic mail and delete the original message. Thank you. + +Original Message From: Paul Cassell + +Sent: Thursday ecember 01, 2011 11:25 AM + +To: ' . M N. (USAFLS)'; 'I ll, (USAFLS)'; 'In (USAFLS)' + +Cc: 'Brad Edwards' + +Subject: RE: Discovery Issues in Epstein + +Dear Mr. + +We will shortly be filing a motion to compel Government responses to our discovery requests -- discovery which, as you know, Judge Marra has already ordered. We realize, of course, that the Government has filed a motion to dismiss/stay. But if the Government's position is rejected on those motions, then the next issue is what discovery can we expect to + +receive from the Government. + +If the motions are denied, will the Government voluntarily produce anything to us? Will the government at least agree to + +produce the following: + +(1) The Government's initial disclosures pursuant to Fed. R. Civ. P. 26; + +(2) Answers to all of the victims' requests for admission; + +(3) All documents, correspondence, and other information that the Government distributed to persons or entities outside + +of the federal Government or received from persons or entities outside of the federal government; and + +(4) All documents, correspondence, and other information covered by the victims' discovery request that is not subject to + +a claim of privilege. + +And, for all other information withheld, will the Government agree to produce a document-by-document privilege log, as + +required by the local rules? + +Thanks for your help on these questions and Brad and I have. + +Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the University of Utah + +332 South 1400 East, Room 101 Salt Lake City, UT 84112-0730 + +Voice: Fax: + +Email: cassellp©law.utah.edu + +http://www.law.utah.edu/profiles/default.asp?PersonID=578'name=Cassell,Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, + +please immediately notify the sender by reply electronic mail and delete the original message. Thank you. + +From: -(USAFLS) + +Sent: Thursday, December 01, 2011 1:35 PM To: (USAFLS) + +Subject: RE: Telephone Conference re: Epstein & Jane Doe I Enited States + +Do you want to call us in my office? I still can't get through to your office. + +From: IMI I. (USAFLS) Sent: Thursclgyamber 01, 2011 10:17 AM + +To: , (USAFLS); ill, (USAFLS) + +Cc: Greenberg, Benjamin (USAFLS) + +Subject: RE: Telephone Conference re: Epstein & Jane Doe l Enited States + +Yes, I think we need to call him. Do you want to try for 1:30 since we have the time already set aside? + +A. Villafaiia + +Assistant U.S. Attorney + +500 S. Australian Ave, Suite 400 + +West Palm Beach, FL 33401 + +From: (USAFLS) + +Sent: Wednesday, November 30, 2011 7:35 PM + +To: alliUSAFLILI) Be + +Cc: I. (USAFLS); M, (USAFLS); Greenberg, Benjamin (USAFLS) + +Subject: RE: Telephone Conference re: Epstein & Jane Doe I Enited States + +We're on for 1:30 tomorrow. I'll set things up for a conference call at that time and send out the call-in + +information. + +Thanks, + +From: (USAFLS) + +Sent: Tuesda November 29, 2011 6:11 PM + +To: AB / USAFLM) + +Cc: (USAFLS); (USAFLS); Greenberg, Benjamin (USAFLS) + +Subject: Telephone Conference re: Epstein & Jane Doe I. Enited States + +Hi, M. + +I hope you had a great Thanksgiving. + +As we had previously discussed, I am contacting you to see if we can set up a telephone conference to address some of the outstanding matters that we need to discuss to complete the transfer of the criminal case to your district and meet our obligations under LEAP 3-2.170.001. (I also left a message with your assistant earlier today.) Those matters include: the nature and scope of any charges/investigation that may potentially remain + +viable in the SDFL following the entry of the Non-Prosecution Agreement; the need to advise the FBI in + +connection with the agents' pending requests for grand jury subpoenas and their expressed intent to continue investigating allegations against Epstein, advice which in all likelihood will require informing the FBI agents about other USAOs that might be able to assist them in light of the grand jury evidence previously obtained; + +and the handling of the criminal case file. + +We ( Villafafia, who was previously assigned to the criminal investigation; M, who is handling the + +CVRA litigation; and me) can make ourselves available to confer with you after 10:30 tomorrow morning, + +tomorrow afternoon, or Thursday morning. If those blocks of time do not work, please let us know and we can + +make other arrangements to accommodate your schedule. + +Thanks, + +From: Paul Cassell Sent: Thursday, December 01, 2011 4:00 PM + +To: (USAFLS) + +Cc: Brad Edwards; (USAFLS); (USAFLS) Subject: RE: Discovery Issues in Epstein - conference call at 5 PM today? + +Am checking with Brad and will get back to you. + +P.S. We may need an extra 5 pages to reply to the government's motion to dismiss. Any objection? + +PC + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law + +S.J. Quinney College of Law at the University of Utah + +332 South 1400 East, Room 101 + +Salt Lake City, UT 84112-0730 + +Voice: + +Fax: + +Email: cassellp@law.utah.edu + +http://www.law.utah.edu/profiles/defaultasp?PersonID=57&name=Cassell,Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the + +sender by reply electronic mail and delete the original message. Thank you. + +From: (USAFLS) [mailto Sent: Thursday, December 01, 2011 1:52 PM + +To: Paul Cassell + +Cc: Brad Edwards; (USAFLS); (USAFLS) Subject: RE: Discovery Issues in Epstein - conference call at 5 PM today? + +Unfortunately, that doesn't work for us today. Can we set up a time for tomorrow? + +I. Sanchez + +Counselor to the United States Attorney + +United States Attorney's Office + +99 N.E. 4th Street, Suite 800 + +Miami, FL 33132 + +Telephone: + +E-mail: + +Original Message + +From: Paul Cassell [mailto:cassellp@law.utah.edul Sent: Thursda , December 01, 2011 2:22 PM + +To: , I. (USAFLS); (USAFLS); (USAFLS) + +Cc: Brad Edwards + +Subject: RE: Discovery Issues in Epstein - conference call at 5 PM today? + +Hi and Co., + +He is in a depo until 4:30, but should be free at 5 PM your time today (Thursday). Does that work? + +Looking forward to chatting. PC + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law + +S.J. Quinney College of Law at the University of Utah + +332 South 1400 East, Room 101 + +Salt Lake City, UT 84112-0730 + +Voice: + +Fax: + +Email: cassellp@law.utah.edu + +http://www.law.utah.edu/profiles/default.asp?PersonID=57&name=Cassell,Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the + +sender by reply electronic mail and delete the original message. Thank you. + +Original Message + +From: Paul Cassell + +Sent: Thursday, December 01, 2011 11:25 AM + +To: ' + +, • + +(USAFLS);' (USAFLS); (USAFLS)' + +Dear Mr. + +We will shortly be filing a motion to compel Government responses to our discovery requests - discovery which, as you know, Judge Marra has already ordered. We realize, of course, that the Government has filed a motion to dismiss/stay. But if the Government's position is rejected on those + +motions, then the next issue is what discovery can we expect to receive from the Government. + +If the motions are denied, will the Government voluntarily produce anything to us? Will the + +government at least agree to produce the following: + +(1) The Government's initial disclosures pursuant to Fed. R. Civ. R 26; + +(2) Answers to all of the victims' requests for admission; + +(3) All documents, correspondence, and other information that the Government distributed to persons or entities outside of the federal Government or received from persons or entities outside of the federal + +government; and + +(4) All documents, correspondence, and other information covered by the victims' discovery request + +that is not subject to a claim of privilege. + +And, for all other information withheld, will the Government agree to produce a document-by-document + +privilege log, as required by the local rules? + +Thanks for your help on these questions and Brad and I have. + +Sincerely, + +Paul Cassell + +Co-Counsel for Jane Doe #1 and Jane Doe #2 + +332 South 1400 East, Room 101 + +Salt Lake City, UT 84112-0730 + +Voice: + +Fax: + +Email: cassellp@law.utah.edu + +http://www.law.utah.edu/profiles/defaultasp?PersonID=57&name=Cassell,Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the + +sender by reply electronic mail and delete the original message. Thank you. + +From: (USAFLS) + +Sent: Thursday, December 01, 2011 3:52 PM + +To: Paul Cassell + +Cc: Brad Edwards; (USAFLS); (USAFLS) Subject: RE: Discovery Issues in Epstein - conference call at 5 PM today? + +Unfortunately, that doesn't work for us today. Can we set up a time for tomorrow? + +• + +I. Sanchez + +Counselor to the United States Attorney + +United States Attorney's Office + +99 N.E. 4th Street, Suite 800 + +Miami, FL 33132 + +Original Message + +From: Paul Cassell [mailto:cassellp@law.utah.eduj + +Sent: Thursda , December 01, 2011 2:22 PM + +To: , I. (USAFLS); (USAFLS); (USAFLS) + +Cc: Brad Edwards + +Subject: RE: Discovery Issues in Epstein - conference call at 5 PM today? + +Hi and Co., + +Thanks for the call. Sorry I was on the other line. + +Can we set up a time certain? That way Brad can participate. + +He is in a depo until 4:30, but should be free at 5 PM your time today (Thursday). Does that work? + +Looking forward to chatting. PC + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law + +S.J. Quinney College of Law at the University of Utah + +332 South 1400 East, Room 101 + +Salt Lake City, UT 84112-0730 + +Voice: + +Fax: + +Email: cassellp@law.utah.edu + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the + +sender by reply electronic mail and delete the original message. Thank you. + +Original Message + +From: Paul Cassell + +Sent: Thursday, December 01, 2011 11:25 AM + +To: ' (USAFLS); (USAFLS); (USAFLS)' + +Cc: 'Brad Edwards' + +Subject: RE: Discovery Issues in Epstein + +Dear Mr. + +We will shortly be filing a motion to compel Government responses to our discovery requests - discovery which, as you know, Judge Marra has already ordered. We realize, of course, that the Government has filed a motion to dismiss/stay. But if the Government's position is rejected on those + +motions, then the next issue is what discovery can we expect to receive from the Government. + +If the motions are denied, will the Government voluntarily produce anything to us? Will the + +government at least agree to produce the following: + +(1) The Government's initial disclosures pursuant to Fed. R. Civ. R 26; + +(2) Answers to all of the victims' requests for admission; + +(3) All documents, correspondence, and other information that the Government distributed to persons or entities outside of the federal Government or received from persons or entities outside of the federal + +government; and + +(4) All documents, correspondence, and other information covered by the victims' discovery request + +that is not subject to a claim of privilege. + +And, for all other information withheld, will the Government agree to produce a document-by-document + +privilege log, as required by the local rules? + +Thanks for your help on these questions and Brad and I have. + +Sincerely, + +Paul Cassell + +Co-Counsel for Jane Doe #1 and Jane Doe #2 + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the University + +of Utah + +332 South 1400 East, Room 101 + +Salt Lake City, UT 84112-0730 + +Voice: + +Fax: + +Email: cassellp@law.utah.edu + +http://www.law.utah.edu/profiles/defaultasp?PersonID=57&name=Cassell,Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the + +sender by reply electronic mail and delete the original message. Thank you. + +Sent: Friday, December 09, 2011 11:20 AM + +To: Sheehan, Evelyn B. (USAFLS) + +Subject: Jeffrey Epstein lawyers want to depose Scott Rothstein + +http://www.dailybusinessreview.com/PubArticleDBR.jsp? + +id=12025349915688Jeffrey\_Epstein\_lawyers\_want\_to\_depose\_Scott\_Rothstein=&et=editorial&bu=D + +aily%20Business%20Review&cn=12.09.118arc=EMC- + +Email&pt=Daily%20am&kw=Jeffrey%20Epstein%2Olawyers%20want%20to%20depose/020Scote/020 + +Rothstein &sl retu rn=1 + +Jeffrey Epstein lawyers want to depose Scott + +Rothstein + +Lawyers for convicted billionaire Jeffrey Epstein will ask a bankruptcy judge for permission to depose + +Ponzi scammer Scott Rothstein during his two-week deposition beginning next week. + +U.S. Bankruptcy Judge Raymond Ray in Fort Lauderdale set the hearing on Epstein's arguments. + +Epstein, who pleaded guilty in 2008 to soliciting prostitution following accusations that he had sex with + +girls, completed his year of house arrest last year. + +Epstein also is suing Rothstein and former Rothstein Rosenfeldt Adler attorney Bradley Edwards for + +allegedly filing a frivolous case. + +Rothstein's deposition begins Monday in Miami and is set to last through Christmas Eve with about 30 lawyers in line to question the former lawyer convicted of masterminding a \$1.2 billion settlement + +financing fraud. + +Rothstein, who is in protective custody, is serving a 50-year sentence at an undisclosed location. + +From: -,\_•. (USAFLS) + +Sent: Friday, December 09, 2011 1:10 PM + +To: Sheehan, Evelyn B. (USAFLS) + +Subject: RE: Jeffrey Epstein lawyers want to depose Scott Rothstein + +Thanks for the heads up. It is still going on and on and on for me. + +A. Villafana + +From: Sheehan, Evelyn B. (USAFLS) Sent: F -ic la y, December 09, 2011 11:22 AM To: I. (USAFLS) + +Subject: FW: Jeffrey Epstein lawyers want to depose Scott Rothstein + +Endless... + +From: Evelyn Sheehan [mailto:evelynbsheehan@gmail.corn] + +Sent: Friday, December 09, 2011 11:20 AM + +To: Sheehan, Evelyn B. (USAFLS) + +Subject: Jeffrey Epstein lawyers want to depose Scott Rothstein + +http://www.dailybusinessreview.com/PubArticleDBR.jsp? + +id=12025349915688deffrey\_Epstein\_lawyers\_want\_to\_depose\_Scott\_Rothstein=&et=editorial&bu=D + +aily%20Business%20Review&cn=12.09.118'src=EMC- + +Email&pt=Daily%20am&kw=Jeffre"20Epstein°/020lawyers%20want%20to%20deposec/020Scote/020 + +Rothstein &sl retu rn=1 + +Jeffrey Epstein lawyers want to depose Scott + +Rothstein + +Lawyers for convicted billionaire Jeffrey Epstein will ask a bankruptcy judge for permission to depose + +Ponzi scammer Scott Rothstein during his two-week deposition beginning next week. + +U.S. Bankruptcy Judge Raymond Ray in Fort Lauderdale set the hearing on Epstein's arguments. + +Epstein, who pleaded guilty in 2008 to soliciting prostitution following accusations that he had sex with + +girls, completed his year of house arrest last year. + +Rothstein's deposition begins Monday in Miami and is set to last through Christmas Eve with about 30 lawyers in line to question the former lawyer convicted of masterminding a \$1.2 billion settlement + +financing fraud. + +Rothstein, who is in protective custody, is serving a 50-year sentence at an undisclosed location. + +From: (USAFLS) + +To: I. (USAFLS) Sent: Friday, December 09, 2011 1:25 PM + +Subject: Read: Jeffrey Epstein lawyers want to depose Scott Rothstein + +Your message + +To: (USAFLS) + +Subject: FW: Jeffrey Epstein lawyers want to depose Scott Rothstein + +Sent: Friday, December 09, 2011 1:10:01 PM (UTC-05:00) Eastern Time (US & Canada) + +was read on Friday, December 09, 2011 1:24:33 PM (UTC-05:00) Eastern Time (US & Canada). + +From: Sheehan, Evelyn B. (USAFLS) + +Sent: Friday, December 09, 2011 2:23 PM To: (USAFLS) + +Subject: Re: Jeffrey Epstein lawyers want to depose Scott Rothstein + +That's nuts. Absolutely nuts. Facing similar nonsense in Rothstein and Tolz. Victims are eating each + +other alive while fighting for the pie of forfeited assets + +From: •. (USAFLS) Sent: Friday, December 09, 2011 02:08 PM + +To: Sheehan, Evelyn B. (USAFLS) + +Subject: RE: Jeffrey Epstein lawyers want to depose Scott Rothstein + +I know. I don't think it will ever go away. And I was just telling someone that I don't really ever want to do a victim case again. Paul Cassell is actually asking for sanctions in a 61° Circuit case against a PSC prosecutor because the Appellate Division in DC decided to take a different position on appeal than the USAO did in the district court and did not confer with the victim. And then, on remand, they are going to ask that same PSC prosecutor to go into court and argue for a \$1 million restitution + +award! + +A. Villafatia + +Assistant U.S. Attorney + +From: Sheehan, Evelyn B. (USAFLS) Sen ic niy, December 09, 2011 1:38 PM To: I. (USAFLS) + +Subject: Re: Jeffrey Epstein lawyers want to depose Scott Rothstein + +Really? That's nuts. So demoralizing + +From: (USAFLS) Sent: Friday, December 09, 2011 01:10 PM + +To: Sheehan, Evelyn B. (USAFLS) + +Subject: RE: Jeffrey Epstein lawyers want to depose Scott Rothstein + +Thanks for the heads up. It is still going on and on and on for me. + +A. Villafana + +Assistant U.S. Attorney + +500 S. Australian Ave, Suite 400 + +West Palm Beach, FL 33401 + +Sent: Friday, December 09, 2011 11:20 AM + +To: Sheehan, Evelyn B. (USAFLS) + +Subject: Jeffrey Epstein lawyers want to depose Scott Rothstein + +http://www.dailybusinessreview.com/PubArticleDBR.jsp? + +id=12025349915688Jeffrey\_Epstein\_lawyers\_want\_to\_depose\_Scott\_Rothstein=&et=editorial&bu=D + +aily%20Business%20Review&cn=12.09.118arc=EMC- + +Email&pt=Daily%20am&kw=Jeffrey%20Epstein%20lawyers%20want%20to%20depose/020Scote/020 + +Rothstein &sl retu rn=1 + +Jeffrey Epstein lawyers want to depose Scott + +Rothstein + +Lawyers for convicted billionaire Jeffrey Epstein will ask a bankruptcy judge for permission to depose + +Ponzi scammer Scott Rothstein during his two-week deposition beginning next week. + +U.S. Bankruptcy Judge Raymond Ray in Fort Lauderdale set the hearing on Epstein's arguments. + +Epstein, who pleaded guilty in 2008 to soliciting prostitution following accusations that he had sex with + +girls, completed his year of house arrest last year. + +Epstein also is suing Rothstein and former Rothstein Rosenfeldt Adler attorney Bradley Edwards for + +allegedly filing a frivolous case. + +Rothstein's deposition begins Monday in Miami and is set to last through Christmas Eve with about 30 lawyers in line to question the former lawyer convicted of masterminding a \$1.2 billion settlement + +financing fraud. + +Rothstein, who is in protective custody, is serving a 50-year sentence at an undisclosed location. + +From: Lavecchio, (USAFLS) + +Sent: Friday, December 09, 2011 2:58 PM + +To: M I. (USAFLS); , (USAFLS); M, (USAFLS) + +Subject: RE: Jeffrey Epstein lawyers want to depose Scott Rothstein + +On December 2, attorney Joseph Ackerman contacted me in an attempt to get himself and Lily + +cleared to participate in the Rothstein deposition. I thereafter sent him the following + +message: + +Due to the late date of our request, I was unable to obtain clearance from the U S. Marshal's Service for you or Ms. to participate in the deposition of Scott Rothstein. Additionally, under the + +protocol established by Judge Ray, parties were required to obtain leave of the court in which litigation is pending to participate in the deposition and to cross-notice adverse parties. I am unaware as to whether that was done with reference to the Epstein litigation. I am copying this response to Chuck Lichtman, counsel to the Trustee in bankruptcy, who has largely organized this proceeding and who + +may be able to answer any other questions which you may have in this regard. + +Sincerely, + +Larry LaVecchio, AUSA + +Lichtman responded to Ackerman as follows: + +As I have explained, there will be a large number of parties already authorized to ask questions on discrete issues all of which are interrelated and will take nearly the full time allotted for the deposition. Everybody already feels they don't have enough allotted time for their respective cases. The topics to + +be discussed have nothing to do whatsoever with the claims existing regarding Jeffrey Epstein + +Under the circumstances, the Marshal's Service is not going to allow the admittance of Epstein's + +attorneys. + +From: ,M I. (USAFLS) Sent: F -ic ia i , December 09, 2011 1:10 PM + +To: , MISAFLS); M, (USAFLS) + +Cc: Lavecchio (USAFLS) + +Subject: FW: Jeffrey Epstein lawyers want to depose Scott Rothstein + +FYI — I assume they are trying to get some information on Brad Edwards. + +A. Villafatia + +Assistant U.S. Attorney + +500 S. Australian Ave, Suite 400 + +West Palm Beach, FL 33401 + +Fax + +From: Sheehan, Evelyn B. (USAFLS) Sent:F -ic aiy, December 09, 2011 11:22 AM To: I. (USAFLS) + +Subject: FW: Jeffrey Epstein lawyers want to depose Scott Rothstein + +Endless... + +From: Evelyn Sheehan [mailto:evelynbsheehan@gmail.corn] + +Sent: Friday, December 09, 2011 11:20 AM + +To: Sheehan, Evelyn B. (USAFLS) + +Subject: Jeffrey Epstein lawyers want to depose Scott Rothstein + +http://www.dailybusinessreview.com/PubArticleDBR.jsp? + +id=1202534991568&Jeffrey\_Epstein\_lawyers\_want\_to\_depose\_Scott\_Rothstein=&et=editorial&bu=D + +aily%20Business%20Review&cn=12.09.11&src=EMC- + +Email&pt=Daily%20am&kw=Jeffrey%20Epsteiec2Olawyers%20want%20to°/020deposeck2OScote/020 + +Rothstein &sl retu rn=1 + +Jeffrey Epstein lawyers want to depose Scott + +Rothstein + +Epstein, who pleaded guilty in 2008 to soliciting prostitution following accusations that he had sex with + +girls, completed his year of house arrest last year. + +Epstein also is suing Rothstein and former Rothstein Rosenfeldt Adler attorney Bradley Edwards for + +allegedly filing a frivolous case. + +Rothstein's deposition begins Monday in Miami and is set to last through Christmas Eve with about 30 lawyers in line to question the former lawyer convicted of masterminding a \$1.2 billion settlement + +financing fraud. + +Rothstein, who is in protective custody, is serving a 50-year sentence at an undisclosed location. + +From: (USAFLS) + +Sent: Friday, December 09, 2011 2:09 PM + +To: Sheehan, Evelyn B. (USAFLS) + +Subject: RE: Jeffrey Epstein lawyers want to depose Scott Rothstein + +I know. I don't think it will ever go away. And I was just telling someone that I don't really ever want to do a victim case again. Paul Cassell is actually asking for sanctions in a 61° Circuit case against a PSC prosecutor because the Appellate Division in DC decided to take a different position on appeal than the USAO did in the district court and did not confer with the victim. And then, on remand, they are going to ask that same PSC prosecutor to go into court and argue for a \$1 million restitution + +award! + +A. Villafatia + +Assistant U.S. Attorney + +500 S. Australian Ave, Suite 400 + +West Palm Beach, FL 33401 + +From: Sheehan, Evelyn B. (USAFLS) Sen -ic aiy, December 09, 2011 11:22 AM To: I. (USAFLS) + +Subject: FW: Jeffrey Epstein lawyers want to depose Scott Rothstein + +Endless. + +From: Evelyn Sheehan [mailto:evelynbsheehan@gmail.com] + +Sent: Friday, December 09, 2011 11:20 AM + +To: Sheehan, Evelyn B. (USAFLS) + +Subject: Jeffrey Epstein lawyers want to depose Scott Rothstein + +http://www.dailybusinessreview.com/PubArticleDBR.jsp? + +id=1202534991568&Jeffrey\_Epstein\_lawyers\_want\_to\_depose\_Scott\_Rothstein=&et=editorial&bu=D + +aily%20Business%20Review&cn=12.09.11&src=EMC- + +Email&pt=Daily%20am&kw=Jeffrey%20Epstein°/020lawyers%20want%20to%20depose%20Scote/020 + +Rothstein &sl retu rn=1 + +Jeffrey Epstein lawyers want to depose Scott + +Rothstein + +Lawyers for convicted billionaire Jeffrey Epstein will ask a bankruptcy judge for permission to depose + +Ponzi scammer Scott Rothstein during his two-week deposition beginning next week. + +U.S. Bankruptcy Judge Raymond Ray in Fort Lauderdale set the hearing on Epstein's arguments. + +Epstein, who pleaded guilty in 2008 to soliciting prostitution following accusations that he had sex with + +girls, completed his year of house arrest last year. + +Epstein also is suing Rothstein and former Rothstein Rosenfeldt Adler attorney Bradley Edwards for + +allegedly filing a frivolous case. + +Rothstein's deposition begins Monday in Miami and is set to last through Christmas Eve with about 30 lawyers in line to question the former lawyer convicted of masterminding a \$1.2 billion settlement + +financing fraud. + +Rothstein, who is in protective custody, is serving a 50-year sentence at an undisclosed location. + +From: Sheehan, Evelyn B. (USAFLS) + +To: I. (USAFLS) Sent: Friday, December 09, 2011 2:21 PM + +Subject: Read: RE: Jeffrey Epstein lawyers want to depose Scott Rothstein + +Your message + +To: Sheehan, Evelyn B. (USAFLS) + +Subject: RE: Jeffrey Epstein lawyers want to depose Scott Rothstein + +Sent: Friday, December 09, 2011 2:08:37 PM (UTC-05:00) Eastern Time (US & Canada) + +was read on Friday, December 09, 2011 2:21:04 PM (UTC-05:00) Eastern Time (US & Canada). \ No newline at end of file diff --git a/marker2/ds9/EFTA00206003/EFTA00206003.metadata.json b/marker2/ds9/EFTA00206003/EFTA00206003.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..fbaac00aeea3ef4ab1f9e0c0fa26b8debdf0b879 --- /dev/null +++ b/marker2/ds9/EFTA00206003/EFTA00206003.metadata.json @@ -0,0 +1,4236 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206003.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 163, + "chars": 152807, + "elapsed_seconds": 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WEINBERG, P.C. +ATTORNEY AT LAW + +20 PARK PLAZA, SUITE 1000 +BOSTON, MASSACHUSETTS 02116 + +EMAIL ADDRESSES: + +owlmcb@att.net +owlmgw@att.net + +(617) 227-3700 + +FAX (617) 338-9538 + +NIGHT EMERGENCY: +(617) 901-3472 + +July 22, 2011 + +[REDACTED] + +Southern District of Florida +500 S. Australian Ave. Suite 400 +West Palm Beach, Florida 33401 + +Re: Jeffrey Epstein + +Dear [REDACTED] + +Roy Black forwarded to me your letter to him dated July 21, 2011, from the District Attorney of the County of New York. We thank you for providing notice of the intended disclosure but we do object to any disclosure of the Non-Prosecution Agreement and the related list of witness/victims on the basis of the confidentiality provisions of paragraph 13. Absent an enforceable subpoena - which we would have the right to move to quash in the Court from which it was issued - there exists no right or duty to disclose the confidential Non-Prosecution Agreement or the non-public witness/victim list which was referenced in paragraph 7 of the NPA. Further, given that the witness/victim list was compiled based on the federal grand jury investigation, we object under Fed. R. Crim. P. 6(e) to its disclosure absent an appropriate court order. + +Very truly yours, + +![]()cc: Roy Black \ No newline at end of file diff --git a/marker2/ds9/EFTA00206166/EFTA00206166.metadata.json b/marker2/ds9/EFTA00206166/EFTA00206166.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..4d8c4c213dc2c615bf173bcd28b1e617984d11f3 --- /dev/null +++ b/marker2/ds9/EFTA00206166/EFTA00206166.metadata.json @@ -0,0 +1,82 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206166.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1263, + "elapsed_seconds": 5.18, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "MARTIN G. WEINBERG, P.C. 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Thank you. + +[Redacted] + +Suite 400 + +13401 + +![](_page_0_Picture_54.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00206167/EFTA00206167.metadata.json b/marker2/ds9/EFTA00206167/EFTA00206167.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f0a64d4e5a5b9d52db33a5fa39ecf451374165ef --- /dev/null +++ b/marker2/ds9/EFTA00206167/EFTA00206167.metadata.json @@ -0,0 +1,60 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206167.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 387, + "elapsed_seconds": 2.6, + "image_assets": [ + "_page_0_Picture_54.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 24 + ], + [ + "Span", + 19 + ], + [ + "Line", + 10 + ], + [ + "PageFooter", + 2 + ], + [ + "Picture", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206167" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206167/_page_0_Picture_54.jpeg b/marker2/ds9/EFTA00206167/_page_0_Picture_54.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..49bccd023e83f1e9276d8163049cf773cc9eb857 --- /dev/null +++ b/marker2/ds9/EFTA00206167/_page_0_Picture_54.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:ea0aa27c255c533806787969254e2ec5a4d966631e0aa1502e3d7a95f718f20d +size 1069 diff --git a/marker2/ds9/EFTA00206168/EFTA00206168.md b/marker2/ds9/EFTA00206168/EFTA00206168.md new file mode 100644 index 0000000000000000000000000000000000000000..48a36ee6b38e6e96b208877b7e35997543de2065 --- /dev/null +++ b/marker2/ds9/EFTA00206168/EFTA00206168.md @@ -0,0 +1,21 @@ +![](_page_0_Picture_0.jpeg) + +![](_page_0_Picture_2.jpeg) + +## DELIVERY BY ELECTRONIC MAIL + +Roy Black, Esq. Black Srebnick Komspan & Stumpf P.A. 201 S. Biscayne Blvd, Suite 1300 Miami, FL 33131 + +Re: Jeffrey Epstein + +Dear Mr. Black: + +On July 17, 2011, the Office received a written request from the District Attorney of the County of New York for a copy of the signed Non-Prosecution Agreement and the list of identified victims that was provided to Mr. Epstein pursuant to the Non-Prosecution Agreement. Pursuant to the District Attorney's request, the U.S. Attorney's Office intends to disclose these items to Assistant District Attorney, at 5:00 p.m. on Friday, July 22, 2011. Pursuant to RIP= of the Non-Prosecution Agreement, the Office is hereby giving you notice of this intended disclosure. + +Sincerely, + +Wifredo A. Ferrer + +![](_page_0_Picture_10.jpeg) + +![](_page_0_Picture_11.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00206168/EFTA00206168.metadata.json b/marker2/ds9/EFTA00206168/EFTA00206168.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..bc8f011e1f4cb927adb960cd244c572401b54f4d --- /dev/null +++ b/marker2/ds9/EFTA00206168/EFTA00206168.metadata.json @@ -0,0 +1,114 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206168.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 886, + "elapsed_seconds": 0.65, + "image_assets": [ + "_page_0_Picture_0.jpeg", + "_page_0_Picture_2.jpeg", + "_page_0_Picture_10.jpeg", + "_page_0_Picture_11.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "U.S. Department of Justice", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 164.62800000000001, + 48.599999999999994 + ], + [ + 306.8807678222656, + 48.599999999999994 + ], + [ + 306.8807678222656, + 64.23748779296875 + ], + [ + 164.62800000000001, + 64.23748779296875 + ] + ] + }, + { + "title": "DELIVERY BY ELECTRONIC MAIL", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 71.604, + 230.03999999999996 + ], + [ + 266.5238342285156, + 230.03999999999996 + ], + [ + 266.5238342285156, + 246.48748779296875 + ], + [ + 71.604, + 246.48748779296875 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 35 + ], + [ + "Line", + 18 + ], + [ + "Text", + 6 + ], + [ + "Picture", + 4 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206168" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206168/_page_0_Picture_0.jpeg b/marker2/ds9/EFTA00206168/_page_0_Picture_0.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..a2937a73c3a83c23446423e1f4a9d5206741b22d --- /dev/null +++ b/marker2/ds9/EFTA00206168/_page_0_Picture_0.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:0f5783ba5d1886abe33ffeaeff9d8c794d93fad67f26ade3c7c55b2e284faf19 +size 10934 diff --git a/marker2/ds9/EFTA00206168/_page_0_Picture_10.jpeg b/marker2/ds9/EFTA00206168/_page_0_Picture_10.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..bd664eef6d12e5f9f77cd70b4c52df121af53230 --- /dev/null +++ b/marker2/ds9/EFTA00206168/_page_0_Picture_10.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:d0c092809da9d2b6e4b7e918dcb21d42097103857f39a274899083e1d8823e56 +size 5292 diff --git a/marker2/ds9/EFTA00206168/_page_0_Picture_11.jpeg b/marker2/ds9/EFTA00206168/_page_0_Picture_11.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..a452989a7e8950364a5425dafb5574420cadd430 --- /dev/null +++ b/marker2/ds9/EFTA00206168/_page_0_Picture_11.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:4c323f546fcc31fa965b256212a0a8a9307dc3dcc8a0dc00844a3dcb83296f03 +size 7224 diff --git a/marker2/ds9/EFTA00206168/_page_0_Picture_2.jpeg b/marker2/ds9/EFTA00206168/_page_0_Picture_2.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..6ff7f4fde8771b2ba5f8cc70a9a2f38324395114 --- /dev/null +++ b/marker2/ds9/EFTA00206168/_page_0_Picture_2.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:80658c5bfe49379e51afec3eac350eeeb0089c3f050cbc1f3e4480e4ab26eff4 +size 8578 diff --git a/marker2/ds9/EFTA00206169/EFTA00206169.md b/marker2/ds9/EFTA00206169/EFTA00206169.md new file mode 100644 index 0000000000000000000000000000000000000000..ec03265b4f313c6d478c98ae5d2b4483f44dfdcf --- /dev/null +++ b/marker2/ds9/EFTA00206169/EFTA00206169.md @@ -0,0 +1,15 @@ +Date: Wed, 20 Jul 2011 20:58:20 +0000 + +Importance: Normal + +This is Jacob Albert, research assistant for Wayne Barrett, at Newsweek. I know you've said that you wouldn't comment on our questions, but I wanted to give you the chance to hear what we're asking before declining. If you'd rather speak by phone, on or off record, + +1) The nonprosecution deal that you worked out specified that Epstein would do 30 months in jail? What's your understanding of why he did only 13 of the 18mo of his jail sentence, and why was he excused from the carrying out the remainder of his sentence? Who approved the sentence reduction, at state or federal level, and why? + +2) Do you have any knowledge of how Jeffrey Epstein was able to preserve personal and corporate tax benefits/exemption in the Virgin Islands, in 2009, which requires residency (183 days) that Epstein was unable to meet, as he was under house arrest during that period? Do you know whether VI residency requirements for tax benefits/exemptions are waived if you're in prison or under house arrest in another state? + +If you still have no comment, please let me know; the article running in Newsweek will state that your office wouldn't comment. + +Thanks, + +Jacob Albert Research Assitant for Wayne Barrett \ No newline at end of file diff --git a/marker2/ds9/EFTA00206169/EFTA00206169.metadata.json b/marker2/ds9/EFTA00206169/EFTA00206169.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..291db92973ba139faf92b5afac98e3e5b0a23b5e --- /dev/null +++ b/marker2/ds9/EFTA00206169/EFTA00206169.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206169.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1257, + "elapsed_seconds": 0.5, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 33 + ], + [ + "Line", + 17 + ], + [ + "Text", + 9 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206169" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206170/EFTA00206170.md b/marker2/ds9/EFTA00206170/EFTA00206170.md new file mode 100644 index 0000000000000000000000000000000000000000..a15dcd06f234f12f8dfb4285a55d8795e6a0209d --- /dev/null +++ b/marker2/ds9/EFTA00206170/EFTA00206170.md @@ -0,0 +1,15 @@ +Subject: Read: Epstein Hearing + +Date: Fri, 12 Aug 2011 23:00:09 +0000 + +Importance: Normal + +Your message + +To: + +Subject: Epstein Hearing + +Sent: Friday, August 12, 2011 7:00:17 PM (UTC-05:00) Eastern Time (US & Canada) + +was read on Friday, August 12, 2011 7:00:09 PM (UTC-05:00) Eastern Time (US & Canada). \ No newline at end of file diff --git a/marker2/ds9/EFTA00206170/EFTA00206170.metadata.json b/marker2/ds9/EFTA00206170/EFTA00206170.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..3c7b037676a70f504400ea52afa87e1c70820e14 --- /dev/null +++ b/marker2/ds9/EFTA00206170/EFTA00206170.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206170.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 303, + "elapsed_seconds": 0.48, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 17 + ], + [ + "Line", + 9 + ], + [ + "Text", + 8 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206170" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206171/EFTA00206171.md b/marker2/ds9/EFTA00206171/EFTA00206171.md new file mode 100644 index 0000000000000000000000000000000000000000..771998cf413119b73386758816d214e0606bb065 --- /dev/null +++ b/marker2/ds9/EFTA00206171/EFTA00206171.md @@ -0,0 +1,21 @@ +To:' + +Subject: Magistrate Interview + +Date: Wed, 24 Aug 2011 21:51:46 +0000 + +Importance: Normal + +Hi — I had my interview with the committee this afternoon, and it seemed to go pretty well (knock wood). Only one hostile question, and I think I answered the question satisfactorily. No questions about Epstein or Judgaat all. + +Thank you so much for all the good thoughts. + +They are finishing up the interviews on Saturday and everyone thinks we will have an answer on whom they are sending through to the District Judges on Saturday night or Sunday. + +Fingers crossed for a little while longer, please. + +Assistant U.S. Attorney + +500 S. Australian Ave, Suite 400 + +West Palm Beach, FL 33401 \ No newline at end of file diff --git a/marker2/ds9/EFTA00206171/EFTA00206171.metadata.json b/marker2/ds9/EFTA00206171/EFTA00206171.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..3f2b876a451cdda7eec5aea7f139f7098dbad36a --- /dev/null +++ b/marker2/ds9/EFTA00206171/EFTA00206171.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206171.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 684, + "elapsed_seconds": 0.58, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 31 + ], + [ + "Line", + 16 + ], + [ + "Text", + 12 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206171" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206172/EFTA00206172.md b/marker2/ds9/EFTA00206172/EFTA00206172.md new file mode 100644 index 0000000000000000000000000000000000000000..2dca6975ca668cb2a0b40f1b619e40b11cba1fbb --- /dev/null +++ b/marker2/ds9/EFTA00206172/EFTA00206172.md @@ -0,0 +1,15 @@ +From: + +To: + +Cc: + +Subject: + +Date: Fri, 29 Jul 2011 18:24:18 +0000 + +Importance: Normal + +Attachments: Epstein\_doc\_dated\_7\_29\_11.pdf + +«Epstein doc dated 7 29 ltpdf» \ No newline at end of file diff --git a/marker2/ds9/EFTA00206172/EFTA00206172.metadata.json b/marker2/ds9/EFTA00206172/EFTA00206172.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..841ccc7b4949512aeea05ff9f2d73762881ea845 --- /dev/null +++ b/marker2/ds9/EFTA00206172/EFTA00206172.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206172.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 165, + "elapsed_seconds": 0.45, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 17 + ], + [ + "Line", + 9 + ], + [ + "Text", + 8 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206172" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206173/EFTA00206173.md b/marker2/ds9/EFTA00206173/EFTA00206173.md new file mode 100644 index 0000000000000000000000000000000000000000..760ab470f8d45c16d88bef19fa8dc7b3573988c7 --- /dev/null +++ b/marker2/ds9/EFTA00206173/EFTA00206173.md @@ -0,0 +1,12819 @@ +From: " . (USAFLS)" To: " . (USAFLS)" + +Subject: Recovered emails #4 + +Date: Tue, 25 Jun 2013 15:19:18 +0000 + +Importance: Normal + +From: (USAFLS) < + +Sent: Thursday, February 24, 2011 4:55 PM To: (USAFLS) + +Subject: RE: Proposed email to Paul Cassell and Brad Edwards + +This is fine. + +From: (USAFLS) Sent: Thursda February 24, 2011 4:44 PM + +To: USAFLS) Cc: (USAFLS) + +Subject: Proposed email to Paul rasseii and Brad Edwards + +Hi - I would like to send the following response to Paul Cassell's email from yesterday. Please let me + +know if it is acceptable. + +Dear Paul and Brad: + +As I promised, since returning to work on Tuesday, I have been working diligently on trying to provide you with the answers that you have requested in connection with the Jane Doe v. United States lawsuit. Both the referral of your allegations to the Office of Professional Responsibility and the request for our Office to "step aside" in the Jane Doe litigation are not insignificant matters. As you doubtless are aware, the position that you are asking us to adopt, simply by "stepping aside," will have repercussions for every U.S. Attorney's Office throughout the + +country, and, therefore, requires a from the Department in Washington, D.C. We also are trying to balance our obligations to Ms. with our obligations to the other identified victims in the Epstein matter. + +and I are doing our due diligence, both within and outside our Office. My recommendation is that we schedule a conference call for the afternoon of Thursday, March 10'h. If, by that time, we still have no definitive answer, then we can tell you that and discuss how best to proceed. If we receive an answer prior to the 10'h, of + +course, I will let you know right away. + +What time are you all available on the 10d1 + +Fax + +From: (USAFLS) ‹ > + +Sent: Thursday, February 24, 2011 4:44 PM + +To: (CRM); (CRM) Cc: (USAFLS); (USAFLS) + +Subject: RE: Jeffrey Epstein Matter + +Great. and I will give you a call. + +Assistant U.S. Attorney + +Fax + +From: (CRM) + +Sent: Thursda Februa 24, 2011 4:27 PM + +To: . (USAFLS - + +Cc: (USAFLS); Subject: RE: Jeffrey Epstein Matter + +I can be available at 11:30 tomorrow. + +From: + +Sent: Thursday, February 24, 2011 4:13 PM + +To: + +Cc: (USAFLS); Subject: Jeffrey Epstein Matter + +(USAFLS) + +(USAFLS) [mailto: + +(CRM) + +(USAFLS) + +Good afternoon, and Sony to trouble you about this case from what seems like long ago, but here in the Southern District, one of Jeffrey Epstein's victims has sued our Office for alleged + +violations of the Crime Victims' Rights Act. + +The victim's lawyers in the case have asked us to take a position in the case that we believe would have national implications, especially in child exploitation cases. Are you available any time soon to discuss this? At this point we are not looking for a definitive policy statement, but we would like to + +bounce ideas off of you. + +OPR also has asked for a preliminary examination of materials, and I think that we need to discuss + +that matter, too. + +I am available from 11:30 to 1:30 and after 3:00 tomorrow, or any time on Monday to discuss. + +Thank you. + +Assistant U.S. Attorney + +Fax + +From: .(USAFLS) + +Sent: Thursday, February 24, 2011 4:58 PM + +To: Paul Cassell; Brad Edwards + +Cc: (USAFLS); (USAFLS) Subject: FW: Proposed email to Paul Cassell and Brad Edwards + +Dear Paul and Brad: + +As I promised, since returning to work on Tuesday, I have been working diligently on trying to provide you with the answers that you have requested in connection with the Jane Doe I. United States lawsuit. Both the referral of your allegations to the Office of Professional Responsibility and the request for our Office to "step aside" in the Jane Doe litigation are not insignificant matters. As you doubtless are aware, the position that you are asking us to adopt, simply by "stepping aside," will have repercussions for every U.S. Attorney's Office throughout the + +country, and, therefore, requires a from the Department in Washington, D.C. We also are trying to balance our obligations to Ms. with our obligations to the other identified victims in the Epstein matter. + +and I are doing our due diligence, both within and outside our Office. My recommendation is that we schedule a conference call for the afternoon of Thursday, March 10'h. If, by that time, we still have no definitive answer, then we can tell you that and discuss how best to proceed. If we receive an answer prior to the 10'h, of + +course, I will let you know right away. + +Assistant U.S. Attorney + +Fax + +From: (USAFIS) Sent: Thursday, February 24, 2011 4:13 PM + +To: (CRM); (CRM) Cc: (USAFLS); (USAFL5) + +Subject: Jeffrey Epstein Matter + +Good afternoon, and-. Sony to trouble you about this case from what seems like long ago, but here in the Southern District, one of Jeffrey Epstein's victims has sued our Office for alleged violations of the + +Crime Victims' Rights Act. + +The victim's lawyers in the case have asked us to take a position in the case that we believe would have national implications, especially in child exploitation cases. Are you available any time soon to discuss this? At this point we are not looking for a definitive policy statement, but we would like to bounce ideas off of you. + +OPR also has asked for a preliminary examination of materials, and I think that we need to discuss that matter, + +too. + +I am available from 11:30 to 1:30 and after 3:00 tomorrow, or any time on Monday to discuss. + +Thank you. + +Assistant U.S. Attorney + +Fax + +From: (USAFLS)c Sent: Thursday, February 24, 2011 3:59 PM To: (USAFLS) + +I sent this to at EOUSA General Counsel on February 15, after had spoken with at the Conference at the NAC. I have not heard back. I did not send anything to CEOS. + +Please reach out to CEOS. I doubt they would recommend we just stand aside. Thanks. + +From: Sent: Tuesda + +To: Cc: Subject: + +Kris, + +(USAFLS) + +February 15, 2011 6:46 PM + +USAEO) + +(USAFLS); (USAFLS); -. (USAFLS) + +On Thursday, February 10, 2011, Deputy Chief AUSA and I spoke with Paul Cassell and Brad Edwards regarding the status of the Crime Victims Rights Act case. I told them Cassell's letter + +request for an investigation of the Non-Prosecution Agreement had been referred to OPR, and OPR had requested various documents from our office. I also told them the EOUSA General Counsel's office advised that our office could go ahead and represent the United States in the CVRA lawsuit. (We had sought guidance + +on whether our office should be recused due to the allegation of improprieties in entering into the Non- + +Prosecution Agreement). I suggested that the parties were ready to move forward with filing documents with + +the court so it could resolve this case. + +I asked whether it might be useful to engage in mediation in an attempt to resolve the case. Cassell told us they wanted the Non-Prosecution Agreement to be set aside. I told him that was not likely to happen. Cassell then suggested that the United States Government should step aside and allow them to "go after" Epstein to get the agreement set aside. I asked him how he expected that would be done, since the only parties to the Non-Prosecution Agreement were Epstein and the Government. Cassell said they would file their summary judgment motion, and the government would take no position on their motion. Presumably, + +Epstein would either intervene, or be brought in as a necessary party, and defend the Non-Prosecution + +Agreement. I told them this would have to be approved by the U.S. Attorney and Main Justice. + +I have serious misgivings about not defending the Executive Branch's prerogative to engage in a Non- + +Prosecution Agreement, free from supervision or oversight by the judiciary. If we stand by the sidelines, Cassell will be arguing the Government was obligated to consult with the victims, and because we failed to do so, the agreement is a nullity. Whatever we may think of the Agreement, it was the prerogative of the U.S. Attorney's Office to enter into it with Epstein, and we should be willing to defend what we did. The DOJ's position is that the rights in the CVRA do not attach until there is a federal court proceeding. Since Epstein was never charged, we were not obligated to consult with the victims before entering into the Non-Prosecution + +Agreement. + +We wanted to seek your views on Cassell's suggestion before we responded to him. I can be reached at + +From: Sent: To: Cc: Subject: (CRM) < + +Thursday, February 24, 2011 4:27 PM + +. (USAFLS); + +(USAFLS); + +RE: Jeffrey Epstein Matter + +I can be available at 11:30 tomorrow. + +From: + +Sent: Thursday, February 24, 2011 4:13 PM + +To: + +Cc: (USAFLS); Subject: Jeffrey Epstein Matter + +(USAFLS) [mailto: + +(CRM) + +(USAFLS) + +(USAFLS) + +Good afternoon, and Sorry to trouble you about this case from what seems like long ago, but here in the Southern District, one of Jeffrey Epstein's victims has sued our Office for alleged + +violations of the Crime Victims' Rights Act. + +The victim's lawyers in the case have asked us to take a position in the case that we believe would have national implications, especially in child exploitation cases. Are you available any time soon to discuss this? At this point we are not looking for a definitive policy statement, but we would like to + +bounce ideas off of you. + +OPR also has asked for a preliminary examination of materials, and I think that we need to discuss + +that matter, too. + +I am available from 11:30 to 1:30 and after 3:00 tomorrow, or any time on Monday to discuss. + +Thank you. + +Assistant U.S. Attorney + +Fax + +Hi — I would like to send the following response to Paul Cassell's email from yesterday. Please let me + +know if it is acceptable. + +Dear Paul and Brad: + +As I promised, since returning to work on Tuesday, I have been working diligently on trying to provide you with the answers that you have requested in connection with the Jane Doe I United States lawsuit. Both the referral of your allegations to the Office of Professional Responsibility and the request for our Office to "step aside" in the Jane Doe litigation are not insignificant matters. As you doubtless are aware, the position that you are asking us to adopt, simply by "stepping aside," will have repercussions for every U.S. Attorney's Office throughout the + +country, and, therefore, requires a from the Department in Washington, D.C. We also are trying to balance our obligations to Ms. with our obligations to the other identified victims in the Epstein matter. + +and I are doing our due diligence, both within and outside our Office. My recommendation is that we schedule a conference call for the afternoon of Thursday, March 10`h. If, by that time, we still have no definitive answer, then we can tell you that and discuss how best to proceed. If we receive an answer prior to the 10th, of + +course, I will let you know right away. + +What time are you all available on the 10t°? + +Assistant U.S. Attorney + +Fax + +From: Sent: To: + +Cc: Subject: (USAFI-S)< > + +Monday, February 28, 2011 12:28 PM (USAEO); + +(OLP) (JMD) + +(USAFLS); + +RE: Jane Does 1 and 2 v. United States - CVRA + +Those times are good for me also. + +(USAFLS); (USAEO); + +(USAFLS) Lawsuit (S.D.Fla.) + +Cc: (USAFLS); . (USAFLS) + +Subject: Re: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +I apologize, but we didn't schedule since we hadn't heard regarding everyone's availability. Does 1:00 + +or 1:30 work? + +From: (USAFLS) Sent: Monda Februa 28, 2011 11:54 AM + +To: USAEO); + +(USAFLS); + +SMO); MilaUSAFLS) + +Cc: . (USAFLS); (USAEO) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +Are we speaking at noon? What is the call-in number? + +Thank you. + +Assistant U.S. Attorney + +Fax + +(USAEO) + +February 28, 2011 9:08 AM + +SMO); USAFLS + +. (USAFLS); (USAFLS); + +(USAEO) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +. (USAFLS); + +If you mean can I get a conference call line, yes, I can. + +(SMO) February 28, 2011 9:07 AM + +USAEO); USAFLS + +. (USAFLS); (USAFLS); . (USAFLS); + +(USAEO) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +: Can you set up a call? I have a 10:00 meeting (30 minutes), and an as yet unscheduled obligation to assist in briefing the AG for his testimony on the Hill tomorrow. Sometime between noon + +and 1 is likely to be best for me. + +(USAEO) + +February 28, 2011 8:43 AM + +SMO); USAFLS + +. (USAFLS); (USAFLS); + +(USAEO) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +I agree, as well. I am available anytime between noon and 3:00 today. + +From: (SMO) + +Sent: Saturda February 26, 2011 4:19 PM + +To: (USAFLS); + +Cc: . (USAFLS); (USAFLS); Subject: Re: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +USAEO + +I agree completely. Let's try and talk Monday, with on the phone if possible. + +From: + +Sent: Saturda + +To: Cc: + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +(USAFLS) + +February 26, 2011 04:08 PM + +SMO); + +. (USAFLS); + +USAEO + +. (USAFLS); + +. (USAFLS) + +(USAFLS); . (USAFLS) + +Mr. + +I'm looking for the appropriate officials in the Department with programmatic responsibility for the + +CVRA, so that we may obtain guidance on our litigating position. What Cassell wants the + +government to do is abdicate its role in defending its actions. If the DOJ's position is that no rights attach until a charging instrument is filed, then we should vigorously defend that position. Our office is + +most reluctant to do what Cassell asks, since negotiating the non-prosecution agreement was clearly within the prerogatives granted to the Executive Branch. Whether the bargain struck with Epstein + +was wise or not should not be the issue. + +I will be in the office all day Monday. Thanks for your assistance. + +From: (SMO) + +Sent: Saturda February 26, 2011 3:40 PM + +To: (USAFLS); + +Cc: . (USAFLS); (USAFLS) Subject: Re: Jane Does 1 and 2I. United States - CVRA Lawsuit (S.D.Fla.) + +USAEO + +Thanks. Perhaps we should try and find a time to talk on Monday. This scenario raises a variety of policy issues that extend well beyond the question of "when do the rights attach." Frankly, I don't think the court should even reach that question given the posture of the case as you describe it. + +From: (USAFLS) + +Sent: Saturda February 26, 2011 02:23 PM + +To: SMO); USAEO + +Cc: . (USAFLS); (USAFLS) Subject: Jane Does 1 and 2 1 United States - CVRA Lawsuit (S.D.Fla.) + +Ms. and Mr. + +Our office is currently litigating a Crime Victims Rights Act (CVRA) lawsuit filed by Jane Does 1 and 2, who were victims of sexual abuse by Jeffrey Epstein, a multi-millionaire investor living in Palm Beach, Florida. Jane Does 1 and 2 v. United States Case No. 08-80736-CIV-MARRA (S.D.Fla.). We are seeking your advice and guidance on a proposal from the victims' attorneys, that the government take + +no position on whether the CVRA granted rights to the victims, when the U.S. Attorney's Office + +negotiated a non-prosecution agreement with Epstein. + +In 2006, the Palm Beach Police Department began investigating allegations that Jeffrey Epstein was enticing underage girls into prostitution. Epstein was alleged to have paid underage girls to provide him with massages, while the young girls were unclothed. The case was referred to the FBI and U.S. Attorney's Office, and the FBI began its own investigation. Epstein hired a number of highlypaid attorneys, including Alan Dershowitz and Kenneth Starr, to attempt to stave off criminal charges. + +On Thursday, February 10, 2011, Deputy Chief AUSA and I spoke with Cassell and Edwards regarding the status of the case. I told them Cassell's letter request for an investigation of the Non-Prosecution Agreement had been referred to OPR, and OPR had requested various documents from our office. I also told them the EOUSA General Counsel's office advised that our office could go ahead and represent the United States in the CVRA lawsuit. I suggested that the parties were ready to move forward with filing documents with the court so it could resolve this + +case. + +I asked whether it might be useful to engage in mediation in an attempt to resolve the case. Cassell told us they wanted the Non-Prosecution Agreement to be set aside. I told him that was not likely to happen. Cassell then suggested that the United States Government should step aside and allow them to "go after" Epstein to get the agreement set aside. I asked him how he expected that would + +be done, since the only parties to the Non-Prosecution Agreement were Epstein and the + +Government. Cassell said they would file their summary judgment motion, and the government would take no position on their motion. Presumably, Epstein would either intervene, or be brought in as a necessary party, and defend the Non-Prosecution Agreement. I told them this would have to be + +approved by the U.S. Attorney and Main Justice. + +I have serious misgivings about not defending the Executive Branch's prerogative to engage in a Non- + +Prosecution Agreement, free from supervision or oversight by the judiciary. If we stand by the sidelines, Cassell will be arguing the Government was obligated to consult with the victims, and because we failed to do so, the agreement is a nullity. Whatever we may think of the Agreement, it was the prerogative of the U.S. Attorney's Office to enter into it with Epstein, and we should be willing to defend what we did. The DOJ's position is that the rights in the CVRA do not attach until there is a federal court proceeding. Since Epstein was never charged in federal court, we were not obligated + +to consult with the victims before entering into the Non-Prosecution Agreement. + +We wanted to seek your views on Cassell's suggestion before we responded to him. We are currently + +scheduled to have a conference call with Cassell and Edwards on Tuesday, March 1. I can be + +reached at . Thanks. + +• + +From: (USAFLS) ‹ > + +Sent: Friday, February 25, 2011 3:52 PM + +To: (CRM); (USAFLS); + +Cc: (CRM) + +Subject: RE: Epstein matter + +Thank you, + +(USAFLS) + +ntoiAs per our conversation this afternoon, I will leave you to call and I have a call + +in at the Appellate Section. + +Fax + +From: (CRM) + +Sent: Frida Februa 25, 2011 3:35 PM To: . (USAFLS) + +Cc: (CRM) + +Subject: Epstein matter + +I spoke to a contact in the Deputy Atta i General's Office, who directed me to in the Department's Office of Legal Policy. indicated to me that the Department's view is that right to confer does not attach until a char in instrument has been filed. For additional questions, I suggest + +you speak to him and to + +and + +at EOUSA. They can be reached at + +Please let me know if you have any + +questions. Thanks, + +Child Exploitation and Obscenity Section + +U.S. Department of Justice + +From: (SMO) c • + +Sent: Monday, February 28, 2011 12:27 PM + +To: . (USAFLS); (USAEO); (USAFLS) Cc: (USAFLS); (USAFLS) + +Me too. + +From: (USAFLS) Sent: Monda , February 28, 2011 12:25 PM + +To: (USAEO); (USAEO); - + +(USAFLSL\_ + +Cc: (USAFLS); . (USAFLS) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +Either of those times works for me. Thank you. + +Assistant U.S. Attorney + +Fax + +. (SMO); + +From: (USAEO) + +Sent: Monda Februa 28, 2011 12:25 PM + +To: . (USAFLS); (USAEO); . (SMO); + +Cc: (USAFLS); . (USAFLS) + +Subject: Re: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +I apologize, but we didn't schedule since we hadn't heard regarding everyone's availability. Does 1:00 + +or 1:30 work? + +From: . (USAFLS) Sent: Monda Februar 28, 2011 11:54 AM + +To: USAEO); + +(USAFLS); + +SMO); USAFLS) + +Cc: . (USAFLS); (USAEO) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +Thank you. + +Assistant U.S. Attorney + +Fax + +(USAEO) + +February 28, 2011 9:08 AM + +SMO); USAFLS + +. (USAFLS); (USAFLS); + +(USAEO) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +If you mean can I get a conference call line, yes, I can. + +(SMO) February 28, 2011 9:07 AM + +USAEO); USAFLS + +. (USAFLS); (USAFLS); + +(USAEO) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +. (USAFLS); + +. (USAFLS); + +: Can you set up a call? I have a 10:00 meeting (30 minutes), and an as yet unscheduled obligation to assist in briefing the AG for his testimony on the Hill tomorrow. Sometime between noon + +and 1 is likely to be best for me. + +From: + +Sent: Monda + +To: Cc: (USAEO) + +sm + +, February 28, 2011 8:43 AM SMO); + +. (USAFLS); + +USAFLS + +(USAFLS); . (USAFLS); + +I agree, as well. I am available anytime between noon and 3:00 today. + +From: (SMO) + +Sent: Saturda February 26, 2011 4:19 PM + +To: (USAFLS); + +Cc: . (USAFLS); (USAFLS); Subject: Re: Jane Does 1 and 2 I. United States - CVRA Lawsuit (S.D.Fla.) + +USAEO + +I agree completely. Let's try and talk Monday, with on the phone if possible. + +From: (USAFLS) + +Sent: Saturda February 26, 2011 04:08 PM + +To: SMO); USAEO + +Cc: . (USAFLS); (USAFLS); Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +Mr. + +. (USAFLS) + +. (USAFLS) + +I'm looking for the appropriate officials in the Department with programmatic responsibility for the + +CVRA, so that we may obtain guidance on our litigating position. What Cassell wants the + +government to do is abdicate its role in defending its actions. If the DOJ's position is that no rights attach until a charging instrument is filed, then we should vigorously defend that position. Our office is most reluctant to do what Cassell asks, since negotiating the non-prosecution agreement was clearly within the prerogatives granted to the Executive Branch. Whether the bargain struck with Epstein + +was wise or not should not be the issue. + +I will be in the office all day Monday. Thanks for your assistance. + +From: (SMO) + +Sent: Saturda February 26, 2011 3:40 PM + +To: USAFLS ; + +USAEO + +I have serious misgivings about not defending the Executive Branch's prerogative to engage in a Non- + +Prosecution Agreement, free from supervision or oversight by the judiciary. If we stand by the sidelines, Cassell will be arguing the Government was obligated to consult with the victims, and because we failed to do so, the agreement is a nullity. Whatever we may think of the Agreement, it was the prerogative of the U.S. Attorney's Office to enter into it with Epstein, and we should be willing to defend what we did. The DOJ's position is that the rights in the CVRA do not attach until there is a federal court proceeding. Since Epstein was never charged in federal court, we were not obligated + +to consult with the victims before entering into the Non-Prosecution Agreement. + +We wanted to seek your views on Cassell's suggestion before we responded to him. We are currently + +scheduled to have a conference call with Cassell and Edwards on Tuesday, March 1. I can be + +reached at . Thanks. + +• + +Subject: Conf Call re Epstein + +Start: End: + +Mon 2/28/2011 1:30 PM Mon 2/28/2011 2:30 PM + +Recurrence: (none) + +Organizer: (USAFLS) + +From: (USAEO) + +Sent: Monday, February 28, 2011 1:12 PM + +To: (USAEO); . (OLP) (JMD); (USAFLS) Cc: (USAFLS); (USAFLS) Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.FIa.) + +The call in number for 1:30 is , pass code + +From: (USAEO) + +Sent: Monda February 28, 2011 12:29 PM + +To: . (SMO); . (USAFLS); + +Cc: (USAFLS); . (USAFLS) + +Subject: Re: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.FIa.) + +Let's say 1:30. We will get a call in #. Thanks. + +. (USAFLS); + +(USAEO); + +Cc: (USAFLS); (USAFLS) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +Me too. + +From: (USAFLS) Sent: Monda , February 28, 2011 12:25 PM + +To: (USAEO); (USAEO); - + +(USAFLS + +Cc: (USAFLS); . (USAFLS) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +Either of those times works for me. Thank you. + +Assistant U.S. Attorney + +Fax + +From: + +Sent: Monda + +To: + +(USAEO) + +February 28, 2011 12:25 PM + +. (USAFLS); (USAEO); + +Cc: (USAFLS); . (USAFLS) + +Subject: Re: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +. (SMO); + +. (SMO); + +I apologize, but we didn't schedule since we hadn't heard regarding everyone's availability. Does 1:00 + +or 1:30 work? + +From: + +Sen Monda + +To: Cc: . (USAFLS) + +si t: , Februar a 28, 2011 11:54 AM + +USAEO); (USAFLS); SMO); USAFLS) + +Are we speaking at noon? What is the call-in number? + +Thank you. + +Assistant U.S. Attorney + +Fax + +(USAEO) + +February 28, 2011 9:08 AM + +SMO); USAFLS + +. (USAFLS); (USAFLS); + +(USAEO) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +If you mean can I get a conference call line, yes, I can. + +(SMO) February 28, 2011 9:07 AM + +USAEO); (USAFLS) + +. (USAFLS); (USAFLS); + +(USAEO) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +. (USAFLS); + +. (USAFLS); + +: Can you set up a call? I have a 10:00 meeting (30 minutes), and an as yet unscheduled obligation to assist in briefing the AG for his testimony on the Hill tomorrow. Sometime between noon + +and 1 is likely to be best for me. + +February 28, 2011 8:43 AM + +SMO); USAFLS + +. (USAFLS); (USAFLS);U + +(USAEO) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +I agree, as well. I am available anytime between noon and 3:00 today. + +From: (SMO) + +Sent: Saturda February 26, 2011 4:19 PM + +To: (USAFLS); + +Cc: . (USAFLS); (USAFLS); Subject: Re: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +USAEO + +I agree completely. Let's try and talk Monday, with on the phone if possible. + +From: (USAFLS) + +Sent: Saturda February 26, 2011 04:08 PM + +To: SMO); USAEO + +Cc: . (USAFLS); (USAFLS); Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +Mr. + +. (USAFLS); + +. (USAFLS) + +. (USAFLS) + +I'm looking for the appropriate officials in the Department with programmatic responsibility for the + +CVRA, so that we may obtain guidance on our litigating position. What Cassell wants the + +government to do is abdicate its role in defending its actions. If the DOJ's position is that no rights attach until a charging instrument is filed, then we should vigorously defend that position. Our office is most reluctant to do what Cassell asks, since negotiating the non-prosecution agreement was clearly within the prerogatives granted to the Executive Branch. Whether the bargain struck with Epstein + +was wise or not should not be the issue. + +I will be in the office all day Monday. Thanks for your assistance. + +would take no position on their motion. Presumably, Epstein would either intervene, or be brought in as a necessary party, and defend the Non-Prosecution Agreement. I told them this would have to be + +approved by the U.S. Attorney and Main Justice. + +I have serious misgivings about not defending the Executive Branch's prerogative to engage in a Non- + +Prosecution Agreement, free from supervision or oversight by the judiciary. If we stand by the sidelines, Cassell will be arguing the Government was obligated to consult with the victims, and because we failed to do so, the agreement is a nullity. Whatever we may think of the Agreement, it was the prerogative of the U.S. Attorney's Office to enter into it with Epstein, and we should be willing to defend what we did. The DOJ's position is that the rights in the CVRA do not attach until there is a federal court proceeding. Since Epstein was never charged in federal court, we were not obligated + +to consult with the victims before entering into the Non-Prosecution Agreement. + +We wanted to seek your views on Cassell's suggestion before we responded to him. We are currently + +scheduled to have a conference call with Cassell and Edwards on Tuesday, March 1. I can be + +reached at . Thanks. + +• + +From: (USAEO) + +Sent: Monday, February 28, 2011 12:29 PM + +To: . (OLP) (JMD); (USAFLS); (USAEO); (USAFLS) Cc: (USAFLS); (USAFLS) Subject: Re: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +Let's say 1:30. We will get a call in #. Thanks. + +From: (SMO) + +Sent: Monda Februar 28, 2011 12:27 PM + +To: . (USAFLS); (USAEO); + +Cc: (USAFLS); (USAFLS) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +Me too. + +From: (USAFLS) Sent: Monda , February 28, 2011 12:25 PM + +To: (USAEO); (USAEO); - + +(USAFLSL\_ + +Cc: (USAFLS); . (USAFLS) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +(USAEO); + +. (SMO); + +Assistant U.S. Attorney + +Fax + +From: (USAEO) + +Sent: Monda Februa 28, 2011 12:25 PM + +To: . (USAFLS); (USAEO); . (SMO); + +Cc: (USAFLS); . (USAFLS) + +Subject: Re: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +I apologize, but we didn't schedule since we hadn't heard regarding everyone's availability. Does 1:00 + +or 1:30 work? + +From: . (USAFLS) Sent: Monda Februar 28, 2011 11:54 AM + +To: USAEO); + +(USAFLS); + +SMO); USAFLS) + +Cc: . (USAFLS); (USAEO) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +Are we speaking at noon? What is the call-in number? + +Thank you. + +Assistant U.S. Attorney + +(USAEO) + +February 28, 2011 9:08 AM + +SMO); USAFLS + +. (USAFLS); (USAFLS); + +(USAEO) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +If you mean can I get a conference call line, yes, I can. + +(SMO) February 28, 2011 9:07 AM + +USAEO); USAFLS + +. (USAFLS); (USAFLS); + +(USAEO) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +. (USAFLS); + +. (USAFLS); + +: Can you set up a call? I have a 10:00 meeting (30 minutes), and an as yet unscheduled obligation to assist in briefing the AG for his testimony on the Hill tomorrow. Sometime between noon + +and 1 is likely to be best for me. + +(USAEO) + +February 28, 2011 8:43 AM + +SMO); USAFLS + +. (USAFLS); (USAFLS); + +(USAEO) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +I agree, as well. I am available anytime between noon and 3:00 today. + +From: (SMO) + +Sent: Saturda February 26, 2011 4:19 PM + +To: (USAFLS); + +Cc: . (USAFLS); (USAFLS); . (USAFLS) + +Subject: Re: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +USAEO + +. (USAFLS); + +Absolutely. I agree with you. Thanks. + +From: (USAFLS) + +Sent: Monda , Februa 28, 2011 1:24 PM + +To: (USAFLS); (USAFLS) Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.FIa.) + +I really don't think we can do what Cassell asks, to stand by and do nothing. Can I represent that as + +our office's position? + +From: (USAFLS) Sent: Monda , February 28, 2011 1:21 PM + +To: (USAFLS); (USAFLS) + +Subject: FW: Jane Does 1 and 2 United States - CVRA Lawsuit (S.D.Fla.) + +I'm going to call in but really only to listen. Thanks. + +From: (USAEO) + +Sent: Monda , February 28, 2011 1:12 PM + +To: (USAEO); . (SMO); + +(USAFLSL\_\_ + +Cc: (USAFLS); . (USAFLS) + +Subject: RE: Jane Does 1 and 2 1 United States - CVRA Lawsuit (S.D.FIa.) + +The call in number for 1:30 is , pass code + +. (USAFLS); + +Cc: (USAFLS); . (USAFLS) + +Subject: Re: Jane Does 1 and 2 I. United States - CVRA Lawsuit (S.D.Fla.) + +Let's say 1:30. We will get a call in #. Thanks. + +From: + +Sent: Monda Februar + +To: + +(SMO) + +28, 2011 12:27 PM + +. (USAFLS); (USAEO); + +Cc: (USAFLS); (USAFLS) + +Subject: RE: Jane Does 1 and 2I. United States - CVRA Lawsuit (S.D.Fla.) + +Me too. + +From: (USAFLS) Sent: Monda , February 28, 2011 12:25 PM + +To: (USAEO); (USAEO); - + +(USAFLS + +Cc: (USAFLS); . (USAFLS) + +Subject: RE: Jane Does 1 and 21 United States - CVRA Lawsuit (S.D.Fla.) + +Either of those times works for me. Thank you. + +Assistant U.S. Attorney + +Fax + +From: + +Sent: Monda + +To: + +(USAEO) + +February 28, 2011 12:25 PM . (USAFLS); + +(USAEO); + +(USAEO); + +. (SMO); + +. (SMO); + +I apologize, but we didn't schedule since we hadn't heard regarding everyone's availability. Does 1:00 + +or 1:30 work? + +From: . (USAFLS) Sent: Monda Februar 28, 2011 11:54 AM + +To: USAEO); + +(USAFLS); + +SMO); USAFLS) + +Cc: . (USAFLS); (USAEO) + +Subject: RE: Jane Does 1 and 2I. United States - CVRA Lawsuit (S.D.Fla.) + +Are we speaking at noon? What is the call-in number? + +Thank you. + +Assistant U.S. Attorney + +Fax + +(USAEO) + +February 28, 2011 9:08 AM + +SMO); USAFLS + +. (USAFLS); (USAFLS); + +(USAEO) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +If you mean can I get a conference call line, yes, I can. + +. (USAFLS); + +From: (SMO) + +Sent: Monda , Februa 28, 2011 9:07 AM + +To: USAEO); (USAFLS) + +: Can you set up a call? I have a 10:00 meeting (30 minutes), and an as yet unscheduled obligation to assist in briefing the AG for his testimony on the Hill tomorrow. Sometime between noon + +and 1 is likely to be best for me. + +(USAEO) + +February 28, 2011 8:43 AM + +SMO); USAFLS + +. (USAFLS); (USAFLS); + +(USAEO) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +I agree, as well. I am available anytime between noon and 3:00 today. + +From: (SMO) + +Sent: Saturda February 26, 2011 4:19 PM + +To: (USAFLS); + +Cc: . (USAFLS); (USAFLS); Subject: Re: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +USAEO + +I agree completely. Let's try and talk Monday, with on the phone if possible. + +From: + +Sent: Saturda + +To: Cc: + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +(USAFLS) + +February 26, 2011 04:08 PM + +SMO); + +. (USAFLS); + +USAEO + +. (USAFLS); + +. (USAFLS) + +(USAFLS); . (USAFLS) + +Mr. + +I'm looking for the appropriate officials in the Department with programmatic responsibility for the + +CVRA, so that we may obtain guidance on our litigating position. What Cassell wants the + +government to do is abdicate its role in defending its actions. If the DOJ's position is that no rights attach until a charging instrument is filed, then we should vigorously defend that position. Our office is most reluctant to do what Cassell asks, since negotiating the non-prosecution agreement was clearly within the prerogatives granted to the Executive Branch. Whether the bargain struck with Epstein + +was wise or not should not be the issue. + +I asked whether it might be useful to engage in mediation in an attempt to resolve the case. Cassell told us they wanted the Non-Prosecution Agreement to be set aside. I told him that was not likely to happen. Cassell then suggested that the United States Government should step aside and allow them to "go after" Epstein to get the agreement set aside. I asked him how he expected that would + +be done, since the only parties to the Non-Prosecution Agreement were Epstein and the + +Government. Cassell said they would file their summary judgment motion, and the government would take no position on their motion. Presumably, Epstein would either intervene, or be brought in as a necessary party, and defend the Non-Prosecution Agreement. I told them this would have to be + +approved by the U.S. Attorney and Main Justice. + +I have serious misgivings about not defending the Executive Branch's prerogative to engage in a Non- + +Prosecution Agreement, free from supervision or oversight by the judiciary. If we stand by the sidelines, Cassell will be arguing the Government was obligated to consult with the victims, and because we failed to do so, the agreement is a nullity. Whatever we may think of the Agreement, it was the prerogative of the U.S. Attorney's Office to enter into it with Epstein, and we should be willing to defend what we did. The DOJ's position is that the rights in the CVRA do not attach until there is a federal court proceeding. Since Epstein was never charged in federal court, we were not obligated + +to consult with the victims before entering into the Non-Prosecution Agreement. + +We wanted to seek your views on Cassell's suggestion before we responded to him. We are currently + +scheduled to have a conference call with Cassell and Edwards on Tuesday, March 1. I can be + +reached at . Thanks. + +• + +From: (USAFLS) < + +Sent: Saturday, February 26, 2011 2:24 PM + +To: . (OLP) (JMD); (USAEO) Cc: (USAFLS); (USAFLS) Subject: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +Ms. and Mr. =, + +Our office is currently litigating a Crime Victims Rights Act (CVRA) lawsuit filed by Jane Does 1 and 2, who were victims of sexual abuse by Jeffrey Epstein, a multi-millionaire investor living in Palm Beach, Florida. Jane Does 1 and 2 v. United States Case No. 08-80736-CIV-MARRA (S.D.Fla.). We are seeking your advice and guidance on a proposal from the victims' attorneys, that the government take no position on whether the CVRA granted rights to the victims, when the U.S. Attorney's Office negotiated a non-prosecution agreement with Epstein. + +In 2006, the Palm Beach Police Department began investigating allegations that Jeffrey Epstein was enticing + +underage girls into prostitution. Epstein was alleged to have paid underage girls to provide him with + +massages, while the young girls were unclothed. The case was referred to the FBI and U.S. Attorney's Office, and the FBI began its own investigation. Epstein hired a number of highly-paid attorneys, including Alan + +Dershowitz and Kenneth Starr, to attempt to stave off criminal charges. + +Ultimately, in 2007, Epstein was charged in state court with soliciting minors for prostitution. In September 2007, the U.S. Attorney's Office entered into a Non-Prosecution Agreement with Epstein, in which he agreed to plead guilty to the state criminal charge, and serve a sentence of 18 months. Epstein also agreed that, in any + +civil action under 18 U.S.C. 2255 by the underage victims, he would not raise the lack of a federal sex offense as a defense. In July 2008, Epstein plead guilty, and was sentenced to serve six months at the Palm Beach + +County Detention Facility, followed by 12 months in home detention. + +In July 2008, after the Non-Prosecution Agreement had been executed, two victims,. and filed an action under the CVRA, 18 U.S.C. 3771. They claimed that the government was obligated, under 18 U.S.C. 3771(a) (5), to speak with the victims prior to the execution of the Non-Prosecution Agreement. An emergency hearing was held on July 11, 2008, before U.S. District Judge Kenneth Marra. Since Epstein had entered his state court plea and been sentenced already, the court found there was no emergency. He directed the + +parties to meet and determine if there were any factual disputes and whether an evidentiary hearing would be + +necessary. + +Attorney Brad Edwards initially represented the victims. Soon, he was joined by Paul Cassell, a University of Utah law professor, and former federal judge who served in the District of Utah from 2002-2007. Cassell is a victims' rights advocate who has appeared in many cases throughout the United States. The victims' rights suit was inactive for the next two years, with Edwards and Cassell using the civil suit as a means to attempt to gain access to information helpful in their civil actions for damages against Epstein. They were able to obtain + +a copy of the Non-Prosecution Agreement through the civil litigation. + +In August 2010, the district court, noting that the last civil suit had been settled, entered an order closing the case. Edwards and Cassell immediately filed documents with the court, advising that the case should not be closed or dismissed, and they wanted to pursue final action by the court. Since September 2010, AUSA + +and I have been dealing with Cassell and Edwards on how to resolve the case. They claim the victims + +had a right to be consulted prior to the execution of the Non-Prosecution Agreement, and that we violated the + +CVRA by not consulting them. The remedy they seek is a set aside by the court of the Non-Prosecution + +Agreement, and a prosecution of Epstein. + +On December 10, 2010, United States Attorney Wifredo A. + +and I, met with Cassell, Edwards, and S one of the victims. We discussed the posture of the + +case, and told us her views of what occurred and her desire to see Epstein receive justice for what he did. Cassell presented U.S. Attorney a four-page letter, requesting an investigation of the Jeffrey Epstein + +prosecution. He claims there may have been improper influence exercising by Epstein, noting that Epstein is a "politically-connected billionaire." Cassell cites to an alleged tip off to Epstein that a search warrant on his residence was to be executed; that a former AUSA, left the West Palm Beach office and soon began appearing on behalf of individuals aligned with Epstein; and an unprecedented level of secrecy between the FBI and the U.S. Attorney's Office, where the FBI was purportedly kept in the dark about the impending Non-Prosecution Agreement. He also claims that the victims were deceived regarding the existence of the + +Non-Prosecution Agreement. + +Cassell's request for an investigation was referred to DOJ OPR on December 16, 2010. has requested various documents from our office, presumably to determine whether an investigation should be opened. Cassell and Edwards had planned to file a motion for summary judgment on December 17, 2010. Due to concerns that the U.S. Attorney's Office might have to be recused, due to the allegations of misconduct, Cassell agreed to defer filing their motion. We have since been advised by EOUSA General Counsel's Office that there is no need for our office to recuse itself, since we are only litigating the legal issue of whether rights + +under the CVRA attached. + +On Thursday, February 10, 2011, Deputy Chief AUSA and I spoke with Cassell and Edwards regarding the status of the case. I told them Cassell's letter request for an investigation of the Non-Prosecution Agreement had been referred to OPR, and OPR had requested various documents from our office. I also told them the EOUSA General Counsel's office advised that our office could go ahead and + +represent the United States in the CVRA lawsuit. I suggested that the parties were ready to move forward with + +filing documents with the court so it could resolve this case. + +I asked whether it might be useful to engage in mediation in an attempt to resolve the case. Cassell told us they wanted the Non-Prosecution Agreement to be set aside. I told him that was not likely to happen. Cassell then suggested that the United States Government should step aside and allow them to "go after" Epstein to get the agreement set aside. I asked him how he expected that would be done, since the only parties to the Non-Prosecution Agreement were Epstein and the Government. Cassell said they would file their summary judgment motion, and the government would take no position on their motion. Presumably, + +Epstein would either intervene, or be brought in as a necessary party, and defend the Non-Prosecution + +Agreement. I told them this would have to be approved by the U.S. Attorney and Main Justice. + +I have serious misgivings about not defending the Executive Branch's prerogative to engage in a Non- + +Prosecution Agreement, free from supervision or oversight by the judiciary. If we stand by the sidelines, Cassell will be arguing the Government was obligated to consult with the victims, and because we failed to do so, the agreement is a nullity. Whatever we may think of the Agreement, it was the prerogative of the U.S. Attorney's Office to enter into it with Epstein, and we should be willing to defend what we did. The DOJ's position is that the rights in the CVRA do not attach until there is a federal court proceeding. Since Epstein was never charged in federal court, we were not obligated to consult with the victims before entering into the + +Non-Prosecution Agreement. + +We wanted to seek your views on Cassell's suggestion before we responded to him. We are currently scheduled to have a conference call with Cassell and Edwards on Tuesday, March 1. I can be reached at + +. Thanks. + +From: .(USAFLS) + +Sent: Wednesday, February 23, 2011 1:52 PM + +To: (USAFLS); (USAFLS); + +Subject: RE: Jeffrey Epstein — OPR Request / Lit. Hold # 2010-FLS-0004 + +Apparently already worked with to get a copy of that disc to do the review. (USAFLS) + +to get all of his emails and electronic documents. 'just need + +Can you send the relevant request to ISS for and emails? This happened less than 7 years ago. + +Thank you. + +Assistant U.S. Attorney + +Fax + +From: (USAFLS) + +Sent: Wednesday, February 23, 2011 1:35 PM + +To: .(USAFLS); (USAFLS); + +Subject: RE: Jeffrey Epstein -- OPR Request / Lit. Hold # 2010-FLS-0004 + +(USAFLS) + +Current employees identify and preserve (those are the forms you completed a couple of months ago). Departed users still in the retain period (3 years) will be done by 155. AUSA's preservation is 7 years if I'm not + +mistaken. + +From: (USAFLS) Sent: Wednesda February 23 2011 1:26 PM + +To: (USAFLS); (USAFLS); (USAFLS) Subject: RE: Jeffrey Epstein -- OPR Request / Lit. Hold # 2010-FLS-0004 + +Hi Does that apply to + +And am I coffee t that and + +Assistant U.S. Attorney + +Fax + +email, too? Or only attorneys who are no longer employed here? + +emails are no longer accessible, even at EOUSA? + +From: (USAFLS) + +Sent: Wednesday, Februa 23, 2011 1:25 PM + +To: (USAFLS); . (USAFLS); + +Subject: RE: Jeffrey Epstein -- OPR Request / Lit. Hold # 2010-FLS-0004 + +(USAFLS) + +Understood however, search for emails is done at the EOUSA level. The District has no access to mailboxes, + +mailboxes not longer reside in local servers. + +From: (USAFLS) + +Sent: Wednesday, February 23, 2011 1:20 PM + +To: .(USAFLS); (USAFLS); + +Subject: RE: Jeffrey Epstein -- OPR Request / Lit. Hold # 2010-FLS-0004 + +(USAFLS) + +I am not aware that OPR has started any process regarding a search of e-mails of the previous U.S. Attorneys in Miami. OPR received an allegation of misconduct, and they asked for e-mails pertaining to the Epstein case, presumably so they could determine whether to open a full investigation. Since OPR was seeking preliminary + +information, they asked me to obtain certain e-mails regarding certain topics. + +From: (USAFLS) Sent: Wednesda February 23 2011 1:16 PM + +To: (USAFLS); (USAFLS); (USAFLS) Subject: RE: Jeffrey Epstein -- OPR Request / Lit. Hold # 2010-FLS-0004 + +I li has had all contact with OPR, so I do not know. + +Assistant U.S. Attorney + +Fax + +From: (USAFLS) + +Sent: Wednesday, February 23, 2011 1:06 PM + +To: I . (USAFLS); (USAFLS); + +Subject: Jeffrey Epstein -- OPR Request / Lit. Hold # 2010-FLS-0004 + +(USAFLS) + +Ann Please note that per EOUSA Preservation Officer, EOUSA will be the one doing the search for the emails. This is done by the EOUSA's Information Systems Security Staff. OPR should contact them directly with the desired search strings. Do you know if your OPR POC has started the process ? + +From: (USAEO) + +Sent: Tuesda January 18, 2011 4:21 PM + +To: USAFLS) + +Cc: . (USAFLS); + +Subject: RE: 2010-FLS-0004 + +(USAFLS) + +Definitely it goes through staff. Anytime OPR is involved in the reviewing something, it goes to staff + +first. I sent him an email and am waiting on a response—I will verify this, but I'm 98% certain. + +It shouldn't have had to be at your request—OPR should have known to contact M. I'll let you know as soon + +as I know. + +Thanks for all of your help! + +To: MAIO) + +I don't believe group has been involved on this. At least not per our request. + +Yes, Sloman and Acosta were USAs during the 2005-present period. + +Another question, if OPR needs to review current AUSAs mailboxes is the search also done by group or do + +we put the emails on a PST for them to review. + +From: (USAEO) + +Sent: Tuesda January 18, 2011 4:10 PM + +To: USAFLS) + +Cc: . (USAFLS); + +Subject: RE: 2010-FLS-0004 + +(USAFLS) + +If and departed prior to USAMail implementation in FLS, we won't have theirs. I can talk to our tech folks to see if it's even worth doing additional searching, but I believe the answer is that it's simply not + +available because of the way our systems were set up prior to USAMail. + +Acosta and Sloman were USAs during the 2005-present applicable period, right? I think that for the OPR question I need to double check with I believe what happens is that TechOne provides access to their account data to someone on staff and they run the relevant searches and provide the search results. + +Do you know whether anyone from staff is aware of the OPR interest in this hold? + +Thanks, + +From: (USAFLS) + +Sent: Tuesda January 18, 2011 2:33 PM + +To: USAEO); Ratliffe, USAEO + +Cc: . (USAFLS); + +Subject: Ref: 2010-FLS-0004 + +Need help again O. Lit Hold 2010-FLS-0004 + +(USAFLS) + +I don't have Attachment 1 or 5 for Alex Acosta, MSloman, Or all no longer with us. Acosta and Sloman served as USA and their email should be at TechOne. How do we go about + +Any help with this will be greatly appreciated. + +From: (USAFLS) + +Sent: Wednesday, February 23, 2011 1:35 PM + +To: (USAFLS); (USAFLS); + +Subject: RE: Jeffrey Epstein -- OPR Request / Lit. Hold # 2010-FLS-0004 + +(USAFLS) + +Current employees identify and preserve (those are the forms you completed a couple of months ago). Departed users still in the retain period (3 years) will be done by ISS. AUSA's preservation is 7 years if I'm not + +mistaken. + +From: (USAFLS) Sent: Wednesda February 23 2011 1:26 PM + +To: (USAFLS); (USAFLS); (USAFLS) Subject: RE: Jeffrey Epstein -- OPR Request / Lit. Hold # 2010-FLS-0004 + +Hi - Does that apply to + +And am I correct that and + +Assistant U.S- Attorney + +Fax + +email, too? Or only attorneys who are no longer employed here? + +emails are no longer accessible, even at EOUSA? + +From: (USAFLS) + +Sent: Wednesday, Februa 23, 2011 1:25 PM + +To: (USAFLS); . (USAFLS); + +Subject: RE: Jeffrey Epstein -- OPR Request / Lit. Hold # 2010-FLS-0004 + +(USAFLS) + +Understood however, search for emails is done at the EOUSA level. The District has no access to mailboxes, + +mailboxes not longer reside in local servers. + +From: (USAFLS) + +Sent: Wednesday, February 23, 2011 1:20 PM + +To: I . (USAFLS); (USAFLS); + +Subject: RE: Jeffrey Epstein -- OPR Request / Lit. Hold # 2010-FLS-0004 + +(USAFLS) + +I am not aware that OPR has started any process regarding a search of e-mails of the previous U.S. Attorneys in Miami. OPR received an allegation of misconduct, and they asked for e-mails pertaining to the Epstein case, presumably so they could determine whether to open a full investigation. Since OPR was seeking preliminary + +information, they asked me to obtain certain e-mails regarding certain topics. + +From: (USAFLS) Sent: Wednesda February 23 2011 1:16 PM + +To: (USAFLS); (USAFLS); (USAFLS) Subject: RE: Jeffrey Epstein -- OPR Request / Lit. Hold # 2010-FLS-0004 + +I li has had all contact with OPR, so I do not know. + +Assistant U.S. Attorney + +Fax + +From: (USAFLS) + +Sent: Wednesday, February 23, 2011 1:06 PM + +To: I . (USAFLS); (USAFLS); + +Subject: Jeffrey Epstein -- OPR Request / Lit. Hold # 2010-FLS-0004 + +(USAFLS) + +Ann Please note that per EOUSA Preservation Officer, EOUSA will be the one doing the search for the emails. This is done by the EOUSA's Information Systems Security Staff. OPR should contact them directly with the desired search strings. Do you know if your OPR POC has started the process ? + +From: (USAEO) + +Sent: Tuesda January 18, 2011 4:21 PM + +To: USAFLS) + +Cc: . (USAFLS); + +Subject: RE: 2010-FLS-0004 + +(USAFLS) + +Definitely it goes through staff. Anytime OPR is involved in the reviewing something, it goes to staff + +first. I sent him an email and am waiting on a response—I will verify this, but I'm 98% certain. + +It shouldn't have had to be at your request—OPR should have known to contact M. I'll let you know as soon + +as I know. + +Thanks for all of your help! + +I don't believe group has been involved on this. At least not per our request. + +Yes, Sloman and Acosta were USAs during the 2005-present period. + +Another question, if OPR needs to review current AUSAs mailboxes is the search also done by group or do + +we put the emails on a PST for them to review. + +From: (USAEO) + +Sent: Tuesda January 18, 2011 4:10 PM + +To: USAFLS) + +Cc: . (USAFLS); + +Subject: RE: 2010-FLS-0004 + +(USAFLS) + +If and departed prior to USAMail implementation in FLS, we won't have theirs. I can talk to our tech folks to see if it's even worth doing additional searching, but I believe the answer is that it's simply not + +available because of the way our systems were set up prior to USAMail. + +Acosta and Sloman were USAs during the 2005-present applicable period, right? I think that for the OPR question I need to double check with I believe what happens is that TechOne provides access to their account data to someone on staff and they run the relevant searches and provide the search results. + +Do you know whether anyone from staff is aware of the OPR interest in this hold? + +Thanks, + +From: (USAFLS) + +Sent: Tuesda January 18, 2011 2:33 PM + +To: USAEO); RaIliffe, USAEO + +Cc: . (USAFLS); + +Subject: Ref: 2010-FLS-0004 + +Need help again O. Lit Hold 2010-FLS-0004 + +(USAFLS) + +I don't have Attachment 1 or 5 for Alex Acosta, MSloman, Or all no longer with us. Acosta and Sloman served as USA and their email should be at TechOne. How do we go about + +Any help with this will be greatly appreciated. + +From: (USAFLS) + +Sent: Wednesday, February 23, 2011 1:26 PM + +To: (USAFLS); (USAFLS); + +Subject: RE: Jeffrey Epstein -- OPR Request / Lit. Hold ti 2010-FLS-0004 + +Hi Does that apply to + +And am I correct that and + +Assistant U.S. Attorney + +(USAFLS) + +email, too? Or only attorneys who are no longer employed here? + +emails are no longer accessible, even at EOUSA? + +From: (USAFLS) + +Sent: Wednesday, Februa 23, 2011 1:25 PM + +To: (USAFLS); . (USAFLS); + +Subject: RE: Jeffrey Epstein -- OPR Request / Lit. Hold # 2010-FLS-0004 + +(USAFLS) + +Understood however, search for emails is done at the EOUSA level. The District has no access to mailboxes, + +mailboxes not longer reside in local servers. + +From: (USAFLS) + +Sent: Wednesday, February 23, 2011 1:20 PM + +To: . (USAFLS); (USAFLS); + +Subject: RE: Jeffrey Epstein -- OPR Request / Lit. Hold # 2010-FLS-0004 + +(USAFLS) + +I am not aware that OPR has started any process regarding a search of e-mails of the previous U.S. Attorneys in Miami. OPR received an allegation of misconduct, and they asked for e-mails pertaining to the Epstein case, presumably so they could determine whether to open a full investigation. Since OPR was seeking preliminary + +information, they asked me to obtain certain e-mails regarding certain topics. + +fli has had all contact with OPR, so I do not know. + +Assistant U.S. Attorney + +Fax + +From: (USAFLS) + +Sent: Wednesday, February 23, 2011 1:06 PM + +To: . (USAFLS); (USAFLS); + +Subject: Jeffrey Epstein OPR Request / Lit. Hold # 2010-FLS-0004 + +(USAFLS) + +Ann Please note that per EOUSA Preservation Officer, EOUSA will be the one doing the search for the emails. This is done by the EOUSA's Information Systems Security Staff. OPR should contact them directly with the desired search strings. Do you know if your OPR POC has started the process ? + +From: (USAEO) + +Sent: Tuesda January 18, 2011 4:21 PM + +To: USAFLS) + +Cc: . (USAFLS); + +Subject: RE: 2010-FLS-0004 + +(USAFLS) + +Definitely it goes through staff. Anytime OPR is involved in the reviewing something, it goes to staff + +first. I sent him an email and am waiting on a response—I will verify this, but I'm 98% certain. + +It shouldn't have had to be at your request—OPR should have known to contact •. I'll let you know as soon + +as I know. + +Thanks for all of your help! + +From (USAFLS) + +Sent: Tuesda January 18, 2011 4:18 PM + +To: USAEO) + +Cc: . (USAFLS); + +Subject: RE: 2010-FLS-0004 + +(USAFLS) + +I don't believe group has been involved on this. At least not per our request. + +Yes, Sloman and Acosta were USAs during the 2005-present period. + +From: (USAEO) + +Sent: Tuesda January 18, 2011 4:10 PM + +To: USAFLS) + +Cc: . (USAFLS); + +Subject: RE: 2010-FLS-0004 + +(USAFLS) + +If and departed prior to USAMail implementation in FLS, we won't have theirs. I can talk to our tech folks to see if it's even worth doing additional searching, but I believe the answer is that it's simply not + +available because of the way our systems were set up prior to USAMail. + +Acosta and Sloman were USAs during the 2005-present applicable period, right? I think that for the OPR question I need to double check with I believe what happens is that TechOne provides access to their account data to someone on staff and they run the relevant searches and provide the search results. + +Do you know whether anyone from staff is aware of the OPR interest in this hold? + +Thanks, + +From: (USAFLS) + +Sent: Tuesda January 18, 2011 2:33 PM To: USAEO); Ratliffe, Cc: . (USAFLS); + +Subject: Ref: 2010-FLS-0004 + +Need help again O. Lit Hold 2010-FLS-0004 + +(USAFLS) + +I don't have Attachment 1 or 5 for Alex Acosta, MSloman, or all no longer with us. Acosta and Sloman served as USA and their email should be at TechOne. How do we go about + +finding out if archived email for and exist in our system. + +How about getting Acosta and Sloman emails for review, I understand OPR is asking. + +We do have copies of their N drives. M, departure was previous to USAMail. + +Any help with this will be greatly appreciated. + +mailboxes not longer reside in local servers. + +From: (USAFLS) + +Sent: Wednesday, February 23, 2011 1:20 PM + +To: . (USAFLS); (USAFLS); + +Subject: RE: Jeffrey Epstein -- OPR Request / Lit. Hold # 2010-FLS-0004 + +(USAFLS) + +I am not aware that OPR has started any process regarding a search of e-mails of the previous U.S. Attorneys in Miami. OPR received an allegation of misconduct, and they asked for e-mails pertaining to the Epstein case, presumably so they could determine whether to open a full investigation. Since OPR was seeking preliminary + +information, they asked me to obtain certain e-mails regarding certain topics. + +From: (USAFLS) Sent: Wednesda February 23 2011 1:16 PM + +To: (USAFLS); (USAFLS); (USAFLS) Subject: RE: Jeffrey Epstein -- OPR Request / Lit. Hold # 2010-FLS-0004 + +I I i has had all contact with OPR, so I do not know. + +Assistant U.S. Attorney + +Fax + +From: (USAFLS) + +Sent: Wednesday, February 23, 2011 1:06 PM + +To: . (USAFLS); (USAFLS); + +Subject: Jeffrey Epstein -- OPR Request / Lit. Hold # 2010-FLS-0004 + +(USAFLS) + +Ann Please note that per EOUSA Preservation Officer, EOUSA will be the one doing the search for the emails. This is done by the EOUSA's Information Systems Security Staff. OPR should contact them directly with the desired search strings. Do you know if your OPR POC has started the process ? + +From: (USAEO) + +Sent: Tuesda January 18, 2011 4:21 PM + +first. I sent him an email and am waiting on a response—I will verify this, but I'm 98% certain. + +It shouldn't have had to be at your request—OPR should have known to contact M. I'll let you know as soon + +as I know. + +Thanks for all of your help! + +From: (USAFLS) + +Sent: Tuesda January 18, 2011 4:18 PM + +To: USAEO) + +Cc: . (USAFLS); + +Subject: RE: 2010-FLS-0004 + +(USAFLS) + +I don't believe group has been involved on this. At least not per our request. + +Yes, Sloman and Acosta were USAs during the 2005-present period. + +Another question, if OPR needs to review current AUSAs mailboxes is the search also done by group or do + +we put the emails on a PST for them to review. + +From: (USAEO) + +Sent: Tuesda January 18, 2011 4:10 PM + +To: USAFLS) + +Cc: . (USAFLS); + +Subject: RE: 2010-FLS-0004 + +(USAFLS) + +If and departed prior to USAMail implementation in FLS, we won't have theirs. I can talk to our tech folks to see if it's even worth doing additional searching, but I believe the answer is that it's simply not + +available because of the way our systems were set up prior to USAMail. + +Acosta and Sloman were USAs during the 2005-present applicable period, right? I think that for the OPR question I need to double check with I believe what happens is that TechOne provides access to their account data to someone on staff and they run the relevant searches and provide the search results. + +Do you know whether anyone from staff is aware of the OPR interest in this hold? + +Thanks, + +From: Sent: Tuesda + +To: Cc: + +(USAFLS) January 18, 2011 2:33 PM + +USAEO); Ratliffe, USAEO .(USAFLS); + +Need help again O. Lit Hold 2010-FLS-0004 + +I don't have Attachment 1 or 5 for Alex Acosta, MSloman, or all no longer with us. Acosta and Sloman served as USA and their email should be at TechOne. How do we go about + +finding out if archived email for and exist in our system. + +How about getting Acosta and Sloman emails for review, I understand OPR is asking. + +We do have copies of their N drives. M, departure was previous to USAMail. + +Any help with this will be greatly appreciated. + +From: (USAFLS) Sent: Thursday, February 24, 2011 2:38 PM + +To: Weeks, (USAMD) Cc: (USAFLS) + +Subject: Epstein Litigation Hold Documents from + +Hi — may have already asked you to do this, but, if not, can you give me the stuff that you athered from . I already searched through the disks that you gave me, but I need to take a look at + +stuff, too. + +Thanks. + +Assistant U.S. Attorney + +Fax + +From: Sent: To: Subject: + +I I: + +(USAFLS) + +Wednesday, February 23, 2011 1:16 PM + +(USAFLS); (USAFLS); RE: Jeffrey Epstein -- OPR Request/ Lit. Hold # 2010-FLS-0004 + +fl + +has had all contact with OPR, so I do not know. + +(USAFLS) + +Fax + +From: (USAFLS) + +Sent: Wednesday, February 23, 2011 1:06 PM + +To: I . (USAFLS); (USAFLS); + +Subject: Jeffrey Epstein -- OPR Request / Lit. Hold # 2010-FLS-0004 + +(USAFLS) + +Ann Please note that per EOUSA Preservation Officer, EOUSA will be the one doing the search for the emails. This is done by the EOUSA's Information Systems Security Staff. OPR should contact them directly with the desired search strings. Do you know if your OPR POC has started the process ? + +From: (USAEO) + +Sent: Tuesda January 18, 2011 4:21 PM + +To: USAFLS) + +Cc: . (USAFLS); + +Subject: RE: 2010-FLS-0004 + +(USAFLS) + +Definitely it goes through staff. Anytime OPR is involved in the reviewing something, it goes to staff + +first. I sent him an email and am waiting on a response—I will verify this, but I'm 98% certain. + +It shouldn't have had to be at your request—OPR should have known to contact M. I'll let you know as soon + +as I know. + +Thanks for all of your help! + +From: (USAFLS) + +Sent: Tuesda January 18, 2011 4:18 PM + +To: USAEO) + +Cc: . (USAFLS); + +Subject: RE: 2010-FLS-0004 + +(USAFLS) + +I don't believe group has been involved on this. At least not per our request. + +Yes, Sloman and were USAs during the 2005-present period. + +Another question, if OPR needs to review current AUSAs mailboxes is the search also done by group or do + +we put the emails on a PST for them to review. + +If and departed prior to USAMail implementation in FLS, we won't have theirs. I can talk to our tech folks to see if it's even worth doing additional searching, but I believe the answer is that it's simply not + +available because of the way our systems were set up prior to USAMail. + +Acosta and Sloman were USAs during the 2005-present applicable period, right? I think that for the OPR question I need to double check with I believe what happens is that TechOne provides access to their account data to someone on staff and they run the relevant searches and provide the search results. + +Do you know whether anyone from staff is aware of the OPR interest in this hold? + +Thanks, + +From: (USAFLS) + +Sent: Tuesda January 18, 2011 2:33 PM + +To: USAEO); Ratliffe, USAEO + +Cc: . (USAFLS); + +Subject: Ref: 2010-FLS-0004 + +Need help again O. Lit Hold 2010-FLS-0004 + +(USAFLS) + +I don't have Attachment 1 or 5 for Alex Acosta, MSloman, or all no longer with us. Acosta and Sloman served as USA and their email should be at TechOne. How do we go about + +finding out if archived email for and exist in our system. + +How about getting Acosta and Sloman emails for review, I understand OPR is asking. + +We do have copies of their N drives. M, departure was previous to USAMail. + +Any help with this will be greatly appreciated. + +From: (USAFLS) Sent: Monday, February 28, 2011 12:25 PM + +To: (USAEO); (USAEO); (OLP) (JMD); + +(USAFLS) Cc: (USAFLS); (USAFLS) Subject: RE: Jane Does 1 and 21 United States - CVRA Lawsuit (S.D.FIa.) + +Assistant U.S. Attorney + +Fax + +From: (USAEO) + +Sent: Monda Februa 28, 2011 12:25 PM + +To: . (USAFLS); (USAEO); . (SMO); + +Cc: (USAFLS); . (USAFLS) + +Subject: Re: Jane Does 1 and 2 I. United States - CVRA Lawsuit (S.D.Fla.) + +I apologize, but we didn't schedule since we hadn't heard regarding everyone's availability. Does 1:00 + +or 1:30 work? + +From: . (USAFLS) Sent: Monda Februar 28, 2011 11:54 AM + +To: USAEO); + +(USAFLS); + +SMO); MilaUSAFLS) + +Cc: . (USAFLS); (USAEO) + +Subject: RE: Jane Does 1 and 2I. United States - CVRA Lawsuit (S.D.Fla.) + +Are we speaking at noon? What is the call-in number? + +Thank you. + +Assistant U.S. Attorney + +(USAEO) + +February 28, 2011 9:08 AM + +SMO); USAFLS + +. (USAFLS); (USAFLS); + +(USAEO) + +Subject: RE: Jane Does 1 and 21 United States - CVRA Lawsuit (S.D.Fla.) + +If you mean can I get a conference call line, yes, I can. + +(SMO) February 28, 2011 9:07 AM + +USAEO); USAFLS + +. (USAFLS); (USAFLS);U + +(USAEO) + +Subject: RE: Jane Does 1 and 21 United States - CVRA Lawsuit (S.D.Fla.) + +. (USAFLS); + +. (USAFLS); + +: Can you set up a call? I have a 10:00 meeting (30 minutes), and an as yet unscheduled obligation to assist in briefing the AG for his testimony on the Hill tomorrow. Sometime between noon + +and 1 is likely to be best for me. + +(USAEO) + +February 28, 2011 8:43 AM + +SMO); USAFLS + +. (USAFLS); (USAFLS); + +(USAEO) + +Subject: RE: Jane Does 1 and 21 United States - CVRA Lawsuit (S.D.Fla.) + +I agree, as well. I am available anytime between noon and 3:00 today. + +From: (SMO) + +Sent: Saturda February 26, 2011 4:19 PM + +To: (USAFLS); + +Cc: . (USAFLS); (USAFLS); Subject: Re: Jane Does 1 and 2 I. United States - CVRA Lawsuit (S.D.Fla.) + +USAEO + +. (USAFLS); + +. (USAFLS) + +From: (USAFLS) + +Sent: Saturda February 26, 2011 04:08 PM + +To: SMO); USAEO + +Cc: . (USAFLS); (USAFLS); Subject: RE: Jane Does 1 and 2 United States - CVRA Lawsuit (S.D.Fla.) + +Mr. + +. (USAFLS) + +I'm looking for the appropriate officials in the Department with programmatic responsibility for the + +CVRA, so that we may obtain guidance on our litigating position. What Cassell wants the + +government to do is abdicate its role in defending its actions. If the DOJ's position is that no rights attach until a charging instrument is filed, then we should vigorously defend that position. Our office is most reluctant to do what Cassell asks, since negotiating the non-prosecution agreement was clearly within the prerogatives granted to the Executive Branch. Whether the bargain struck with Epstein + +was wise or not should not be the issue. + +I will be in the office all day Monday. Thanks for your assistance. + +From: (SMO) + +Sent: Saturda February 26, 2011 3:40 PM + +To: (USAFLS); + +Cc: . (USAFLS); (USAFLS) Subject: Re: Jane Does 1 and 2I. United States - CVRA Lawsuit (S.D.Fla.) + +USAEO + +Thanks. Perhaps we should try and find a time to talk on Monday. This scenario raises a variety of policy issues that extend well beyond the question of "when do the rights attach." Frankly, I don't think the court should even reach that question given the posture of the case as you describe it. + +From: (USAFLS) + +Sent: Saturda February 26, 2011 02:23 PM + +To: SMO); USAEO + +Cc: . (USAFLS); (USAFLS) Subject: Jane Does 1 and 2 1 United States - CVRA Lawsuit (S.D.Fla.) + +I am out of the District until Thursday and I have not heard from this week (he is out of the District as well, I believe). I know that last week he received some guidance from our Office, with a request that he gather additional information from DC. I don't know whether he was able to get that + +additional information. + +I know that you have been very patient, and I hate to ask you to wait a little longer. I am back in West Palm Beach on Thursday, but I am trying to finalize a plea to mandatory life in a double-homicide case that I am trying to schedule for Friday. If you can wait until Tuesday (because Monday is a holiday), you will have my undivided attention, and I can follow-up with DC or Miami or whomever else needs to + +be consulted to get a final answer. + +If I hear anything from in the meantime, I will let you know. + +Assistant U.S. Attorney + +From: Paul Cassell [mailto: + +Sent: Tuesda , February 15, 2011 10:26 AM To: USAFLS ; Brad Edwards Cc: . (USAFLS) + +Subject: RE: Avoiding an Unnecessary Fight + +Dear + +Brad and I look forward to hearing from you today (as you indicated that you would) about our + +proposal that the U.S. Attorney's Office will simple stand on the sidelines and not oppose our efforts to + +set aside the plea. I would hope that you would reiterate to the U.S. Attorney and the + +once again, how much we would like to avoid fighting with your Office so that we can focus our + +energies on Epstein the sex offender. We don't understand why the U.S. Attorney's Office feels that it needs to join this fight with the victims -- we hope that you will work to find a way to make this happen + +and avoid and entirely unnecessary clash between prosecutors and crime victims. + +We are happy to discuss with you ways to minimize any clash and any logistics that would be involved -- if we have agreement in principle on the concept. We are also available for a conference + +Sincerely, Paul Cassell, co-counsel for Jane Doe #1 and Jane Doe #2 + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law + +S.J. Quinney College of Law at the University of Utah + +Voice: + +Fax: + +Email: + +http://www.law.utah.edu/profiles/defaultasp?PersonID=57&name=Cassell,Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the + +sender by reply electronic mail and delete the original message. Thank you. + +From: (USAFLS) [mailto + +Sent: Thursday, December 16, 2010 9:03 AM + +To: Paul Cassell; Brad Edwards + +Cc: . (USAFLS) + +Subject: Request for Investigation Of Jeffrey Epstein Prosecution + +Brad and Paul, + +We enjoyed meeting in person with you and last Friday. I wanted to update you on the matters + +we discussed that day. + +First, Paul's request for an investigation of the Jeffrey Epstein prosecution has been referred to the Department of Justice's Office of Professional Responsibility. OPR is the component within the DOJ which investigates allegations of misconduct relating to the authority of DOJ attorneys to investigate, + +litigate, and give legal advice. The December 10, 2010 letter asks this office "to investigate through appropriate and independent channels the handling of the Epstein (non)prosecution." OPR is the appropriate and independent body within the DOJ to investigate and determine whether misconduct + +has occurred. + +Second, during the meeting on December 10, we advised you of the ethical standards applicable regarding a potential prosecution of Epstein by our office, and that a recusal would likely ensue. Given your request for an investigation of this Office's conduct in the Jeffrey Epstein case, and the referral of that request to OPR, we are seeking guidance from DOJ on whether this office can continue + +to defend the Crime Victim Rights Act case. + +Third, we discussed the sequence in the litigation. You asked us that, in the event the court decides that the CVRA applied, in the absence of a formal charge, that the government concede (1) the U.S. Attorney's Office failed to comply with the CVRA; and (2) the district court should set aside the Non-Prosecution Agreement. In light of what has occurred, we cannot give you an answer on those two + +points. + +You had told us earlier that you would be filing a dispositive motion by December 17, 2010. I expect to find out whether our office needs to recuse itself within the next week. I will be on leave from December 17-28, but will be back at the office on December 29. I am asking if you would defer filing + +any motion until after I return on December 29. Thank you. + +I can be reached by e-mail and cell phone, during my annual leave. + +From: (USAFLS) + +Sent: Wednesday, February 23, 2011 1:06 PM + +To: (USAFLS); (USAFLS); Subject: Jeffrey Epstein -- OPR Request / Lit. Hold # 2010-FLS-0004 (USAFLS) + +Ann Please note that per EOUSA Preservation Officer, EOUSA will be the one doing the search for the emails. This is done by the EOUSA's Information Systems Security Staff. OPR should contact them directly with the desired search strings. Do you know if your OPR POC has started the process ? + +From: (USAEO) + +Sent: Tuesda January 18, 2011 4:21 PM + +To: USAFLS) + +Cc: . (USAFLS); + +Subject: RE: 2010-FLS-0004 + +(USAFLS) + +Definitely it goes through staff. Anytime OPR is involved in the reviewing something, it goes to staff + +first. I sent him an email and am waiting on a response—I will verify this, but I'm 98% certain. + +It shouldn't have had to be at your request—OPR should have known to contact •. I'll let you know as soon + +as I know. + +Thanks for all of your help! + +Cc: (USAFLS); + +Subject: RE: 2010-FLS-0004 + +(USAFLS) + +I don't believe group has been involved on this. At least not per our request. + +Yes, Sloman and Acosta were USAs during the 2005-present period. + +Another question, if OPR needs to review current AUSAs mailboxes is the search also done by group or do + +we put the emails on a PST for them to review. + +From: (USAEO) + +Sent: Tuesda January 18, 2011 4:10 PM + +To: USAFLS) + +Cc: . (USAFLS); + +Subject: RE: 2010-FLS-0004 + +(USAFLS) + +If and departed prior to USAMail implementation in FLS, we won't have theirs. I can talk to our tech folks to see if it's even worth doing additional searching, but I believe the answer is that it's simply not + +available because of the way our systems were set up prior to USAMail. + +and were USAs during the 2005-present applicable period, right? I think that for the OPR question I need to double check with I believe what happens is that TechOne provides access to their account data to someone on staff and they run the relevant searches and provide the search results. + +Do you know whether anyone from staff is aware of the OPR interest in this hold? + +Thanks, + +From: (USAFLS) + +Sent: Tuesda January 18, 2011 2:33 PM + +To: USAEO); Ratliffe, USAEO + +Cc: . (USAFLS); + +Subject: Ref: 2010-FLS-0004 + +Need help again 0. Lit Hold 2010-FLS-0004 + +(USAFLS) + +I don't have Attachment 1 or 5 for Alex ,M , or all no longer with us. and served as USA and their email should be at TechOne. How do we go about + +Any help with this will be greatly appreciated. + +From: (USAFLS) Sent: Thursday, February 24, 2O11 1:O3 PM + +To: (FBI) Cc: (FBI) Subject: RE: Customs POC + +Hi Luz — I have reached out to Can you talk with about how we got the flight plans/flight manifests for Epstein's planes in that case? I think that was done through the FAA. + +Thank you. + +Assistant U.S. Attorney + +Fax + +From: (FBI) + +Sent: Wednesday, February 23, 2011 4:19 PM + +To: . (USAFLS) + +Subject: Customs POC + +The Point of Contact we have in our Miami office is: + +Investigative Operations Analyst + +FBI + +Palm Beach County RA + +(USAFLS) + +February 22, 2011 4:54 PM + +(USAFLS); (USAFLS) + +Subject: Sledgehammer Meeting Reminder + +Hi everyone — Just a quick reminder that we have our Master Meeting tomorrow at 2:00. + +The meeting will be in the 4th Floor Conference Room at the U.S. Attorney's Office, + +See you all there! + +Thank you. + +Assistant U.S. Attorney + +Fax + +From: (USAFLS) < + +Sent: Thursday, February 17, 2011 10:02 AM To: (USAFLS) + +Subject: FW: Epstein OPR matter + +> + +Have you been able to retrieve the documents requested by OPR? Thanks. + +From: (OPR) + +Sent: Wednesday, February 16, 2011 12:39 PM + +To: (USAFLS) Subject: Epstein OPR matter + +we spoke on January 4, 2011 — you were going to get me information related to the Epstein + +victims' allegations of misconduct. + +What is the status? + +Thanks, + +From: (USAFLS) + +Sent: Wednesday, February 23, 2011 2:27 PM + +To: (USAFLS); (USAFLS); + +Subject: RE: Jeffrey Epstein -- OPR Request / Lit. Hold # 2010-FLS-0004 + +(USAFLS) + +Sorry, I was talking about USA is 7, everybody else 3 and they left before the new USAP was in place. + +Apparently already worked with to get a copy of that disc to do the review. to get all of his emails and electronic documents. I just need + +Can you send the relevant request to ISS for and emails? This happened less than 7 years ago. + +Thank you. + +Assistant U.S. Attorney + +Fax + +From: (USAFLS) + +Sent: Wednesday, February 23, 2011 1:35 PM + +To: I .(USAFLS); (USAFLS); + +Subject: RE: Jeffrey Epstein -- OPR Request / Ut. Hold # 2010-F1S-0004 + +(USAFLS) + +Current employees identify and preserve (those are the forms you completed a couple of months ago). Departed users still in the retain period (3 years) will be done by ISS. AUSA's preservation is 7 years if I'm not + +mistaken. + +From: (USAFLS) Sent: Wednesda February 23 2011 1:26 PM + +To: (USAFLS); (USAFLS); (USAFLS) Subject: RE: Jeffrey Epstein -- OPR Request / Lit. Hold # 2010-FLS-0004 + +Hi - Does that apply to + +And am I correct that and + +Assistant U.S. Attorney + +email, too? Or only attorneys who are no longer employed here? + +emails are no longer accessible, even at EOUSA? + +Sent: Wednesday, Februa 23, 2011 1:25 PM + +To: (USAFLS); . (USAFLS); + +Subject: RE: Jeffrey Epstein OPR Request / Lit. Hold # 2010-FLS-0004 + +(USAFLS) + +Understood however, search for emails is done at the EOUSA level. The District has no access to mailboxes, + +mailboxes not longer reside in local servers. + +From: (USAFLS) + +Sent: Wednesday, February 23, 2011 1:20 PM + +To: I . (USAFLS); (USAFLS); + +Subject: RE: Jeffrey Epstein -- OPR Request / Lit. Hold # 2010-FLS-0004 + +(USAFLS) + +I am not aware that OPR has started any process regarding a search of e-mails of the previous U.S. Attorneys in Miami. OPR received an allegation of misconduct, and they asked for e-mails pertaining to the Epstein case, presumably so they could determine whether to open a full investigation. Since OPR was seeking preliminary + +information, they asked me to obtain certain e-mails regarding certain topics. + +From: (USAFLS) Sent: Wednesda February 23J\_\_\_\_2011 1:16 PM + +To: (USAFLS); (USAFLS); (USAFLS) Subject: RE: Jeffrey Epstein -- OPR Request / Lit. Hold # 2010-FLS-0004 + +Hi has had all contact with OPR, so I do not know. + +Assistant U.S. Attorney + +Fax + +From: (USAFLS) + +Sent: Wednesday, February 23, 2011 1:06 PM + +To: . (USAFLS); (USAFLS); + +Subject: Jeffrey Epstein -- OPR Request / Lit. Hold # 2010-FLS-0004 + +(USAFLS) + +Ann Please note that per EOUSA Preservation Officer, EOUSA will be the one doing the search for the emails. This is done by the EOUSA's Information Systems Security Staff. OPR should contact them directly with the desired search strings. Do you know if your OPR POC has started the process ? + +Sent: Tuesda January 18, 2011 4:21 PM + +To: USAFLS) + +Cc: . (USAFLS); + +Subject: RE: 2010-FLS-0004 + +(USAFLS) + +Definitely it goes through staff. Anytime OPR is involved in the reviewing something, it goes to staff + +first. I sent him an email and am waiting on a response—I will verify this, but I'm 98% certain. + +It shouldn't have had to be at your request—OPR should have known to contact M. I'll let you know as soon + +as I know. + +Thanks for all of your help! + +From: (USAFLS) + +Sent: Tuesda January 18, 2011 4:18 PM + +To: USAEO) + +Cc: . (USAFLS); + +Subject: RE: 2010-FLS-0004 + +(USAFLS) + +I don't believe group has been involved on this. At least not per our request. + +Yes, and were USAs during the 2005-present period. + +Another question, if OPR needs to review current AUSAs mailboxes is the search also done by group or do + +we put the emails on a PST for them to review. + +From: (USAEO) + +Sent: Tuesda January 18, 2011 4:10 PM + +To: USAFLS) + +Cc: . (USAFLS); + +Subject: RE: 2010-FLS-0004 + +(USAFLS) + +If and departed prior to USAMail implementation in FLS, we won't have theirs. I can talk to our tech folks to see if it's even worth doing additional searching, but I believe the answer is that it's simply not + +available because of the way our systems were set up prior to USAMail. + +and were USAs during the 2005-present applicable period, right? I think that for the OPR question I need to double check with I believe what happens is that TechOne provides access to their account data to someone on staff and they run the relevant searches and provide the search results. + +Do you know whether anyone from staff is aware of the OPR interest in this hold? + +Thanks, + +From: (USAFLS) + +Sent: Tuesda January 18, 2011 2:33 PM To: USAEO); Ratliffe, Cc: .(USAFLS); + +Subject: Ref: 2010-FLS-0004 + +Need help again O. Lit Hold 2010-FLS-0004 + +(USAFLS) + +I don't have Attachment 1 or 5 for Alex Acosta, MSloman, Or all no longer with us. Acosta and Sloman served as USA and their email should be at TechOne. How do we go about + +finding out if archived email for and exist in our system. + +How about getting Acosta and Sloman emails for review, I understand OPR is asking. + +We do have copies of their N drives. M, departure was previous to USAMail. + +Any help with this will be greatly appreciated. + +From: (USAFLS) < + +Sent: Tuesday, February 15, 2011 6:46 PM + +To: (USAEO) + +Cc: (USAFLS); (USAFLS); + +(USAFLS) + +Kris, + +On Thursday, February 10, 2011, Deputy Chief AUSA and I spoke with Paul Cassell and Brad Edwards regarding the status of the Crime Victims Rights Act case. I told them Cassell's letter + +request for an investigation of the Non-Prosecution Agreement had been referred to OPR, and OPR had requested various documents from our office. I also told them the EOUSA General Counsel's office advised that our office could go ahead and represent the United States in the CVRA lawsuit. (We had sought guidance + +on whether our office should be recused due to the allegation of improprieties in entering into the Non- + +Prosecution Agreement). I suggested that the parties were ready to move forward with filing documents with + +the court so it could resolve this case. + +I asked whether it might be useful to engage in mediation in an attempt to resolve the case. Cassell told us they wanted the Non-Prosecution Agreement to be set aside. I told him that was not likely to happen. Cassell then suggested that the United States Government should step aside and allow them to "go after" Epstein to get the agreement set aside. I asked him how he expected that would be done, since the only parties to the Non-Prosecution Agreement were Epstein and the Government. Cassell said they would file their summary judgment motion, and the government would take no position on their motion. Presumably, + +Epstein would either intervene, or be brought in as a necessary party, and defend the Non-Prosecution + +Agreement. I told them this would have to be approved by the U.S. Attorney and Main Justice. + +Cassell will be arguing the Government was obligated to consult with the victims, and because we failed to do so, the agreement is a nullity. Whatever we may think of the Agreement, it was the prerogative of the U.S. Attorney's Office to enter into it with Epstein, and we should be willing to defend what we did. The DOJ's position is that the rights in the CVRA do not attach until there is a federal court proceeding. Since Epstein was never charged, we were not obligated to consult with the victims before entering into the Non-Prosecution + +Agreement. + +We wanted to seek your views on Cassell's suggestion before we responded to him. I can be reached at + +. Thanks. + +From: (USAFLS) c > + +Sent: Wednesday, February 23, 2011 12:38 PM + +To: (USAFLS); (USAFLS); + +Cc: (FBI) + +Subject: Jeffrey Epstein — OPR Request Attachments: 20110223121742706.pdf + +(USAFLS) + +Hi and — These are the relevant items that I found in my stored emails. A hard copy also is coming to you via interoffice. In addition to my emails regarding the plea negotiations, I included a couple of things + +about + +My understanding of what DC is looking for is: + +(1) Correspondence showing an internal disagreement with the plea strategy + +(2) Correspondence showing that FBI knew about the plea strategy (and any agreement or disagreement + +therewith) + +(3) Any correspondence regarding notification to victims. + +I have not been given an access to Alex or stored emails, and my understanding is that + +EOUSA no longer has or stored emails. + +With respect to current DOJ employees in looldiaar my emails, it is possibl that + +relevant emails, too. I don't think that will have any. + +CEOS in DC may have relevant emails. + +and + +may have + +at + +-- In instructing EOUSA on what to search for, the most relevant time period was probably from Ma 1, + +2007 throw h October 15, 2007. I would recommend searchin for email exchanges with ( + +and (the , and at FBI, respectively), + +(from CEOS), and defense attorneys Lilly Ann Jay Lefkowitz, Gerald Lefcourt, Roy Black, + +Ken Starr, and Alan Dershowitz. + +If you want to obtain those records and have me or someone else review them, please let me know. Can we talk + +late this afternoon about what we are going to communicate to opposing counsel? + +Assistant U.S. Attorney + +Fax + +From: (USAFLS) + +Sent: Wednesday, February 23, 2011 12:23 PM + +To: (FBI) + +Subject: Epstein stuff + +Importance: High + +Hi — Have you had any luck looking around? And can you remind me of the names of the and the + +during the relevant period? + +I think was the only supervisor in WPB who would have sent an email, but remind me if there was anyone + +else who may have sent something. + +Thanks. + +Assistant U.S. Attorney + +Fax + +From: Paul Cassell < + +Sent: Wednesday, February 23, 2011 10:40 AM + +To: . (USAFLS); (USAFLS); Brad Edwards + +Subject: RE: Avoiding an Unnecessary Fight - where do things stand? + +Hi and + +person to the U.S. Attorney 11 weeks ago, echoing a request conveyed through you back in + +September (nearly five months ago) — that the Office simply stand on the sidelines and not oppose our efforts to have Epstein's non-prosecution agreement set aside. As you know, we have been diligently trying to avoid an unnecessary fight with your Office. We have only asked that you not affirmatively oppose our efforts to seek justice for the victims in the case. In other words, we are not asking you to + +lift a finger — we are merely asking you not to get in our way. + +We understood we were going to hear back from shortly after our December meeting with the U.S. Attorney ... then things stretched into January ... then February ... then last week ... then this week. We are willing to wait a reasonable amount of time to try and work something out with you. But where do things stand? We are having a bit of difficulty understanding why a simple request that you not actively take steps to undermine efforts of sexual abuse victims to obtain justice is taking so long to + +approve. + +Hoping that you can give us some further information soon. Paul Cassell, Co-Counsel for Jane Doe + +#1 and Jane Doe #2 + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law + +S.J. Quinney College of Law at the University of Utah + +Voice: + +Fax: + +Email: + +http://www.law.utah.edu/profiles/defaultasp?PersonID=57&name=Cassell,Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the + +sender by reply electronic mail and delete the original message. Thank you. + +Dear Paul and Brad: + +I am out of the District until Thursday and I have not heard from this week (he is out of the District as well, I believe). I know that last week he received some guidance from our Office, with a request that he gather additional information from DC. I don't know whether he was able to get that + +additional information. + +I know that you have been very patient, and I hate to ask you to wait a little longer. I am back in West Palm Beach on Thursday, but I am trying to finalize a plea to mandatory life in a double-homicide case that I am trying to schedule for Friday. If you can wait until Tuesday (because Monday is a holiday), you will have my undivided attention, and I can follow-up with DC or Miami or whomever else needs to + +be consulted to get a final answer. + +If I hear anything from in the meantime, I will let you know. + +Assistant U.S. Attorney + +From: Paul Cassell [mailto: + +Sent: Tuesda , February 15, 2011 10:26 AM To: USAFLS ; Brad Edwards Cc: . (USAFLS) + +Subject: RE: Avoiding an Unnecessary Fight + +Dear + +Brad and I look forward to hearing from you today (as you indicated that you would) about our + +proposal that the U.S. Attorney's Office will simple stand on the sidelines and not oppose our efforts to + +set aside the plea. I would hope that you would reiterate to the U.S. Attorney and the + +once again, how much we would like to avoid fighting with your Office so that we can focus our + +energies on Epstein the sex offender. We don't understand why the U.S. Attorney's Office feels that it needs to join this fight with the victims -- we hope that you will work to find a way to make this happen + +and avoid and entirely unnecessary clash between prosecutors and crime victims. + +We are happy to discuss with you ways to minimize any clash and any logistics that would be involved -- if we have agreement in principle on the concept. We are also available for a conference + +call today after 5:00 Florida time, if you would like further discussions. + +Sincerely, Paul Cassell, co-counsel for Jane Doe #1 and Jane Doe #2 + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law + +S.J. Quinney College of Law at the University of Utah + +Voice: + +Fax: + +Email: + +http://www.law.utah.edu/profiles/defaultasp?PersonID=57&name=Cassell,Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the + +sender by reply electronic mail and delete the original message. Thank you. + +From: (USAFLS) [mailto + +Sent: Thursday, December 16, 2010 9:03 AM + +To: Paul Cassell; Brad Edwards + +Cc: . (USAFLS) + +Subject: Request for Investigation Of Jeffrey Epstein Prosecution + +Brad and Paul, + +First, Paul's request for an investigation of the Jeffrey Epstein prosecution has been referred to the Department of Justice's Office of Professional Responsibility. OPR is the component within the DOJ which investigates allegations of misconduct relating to the authority of DOJ attorneys to investigate, litigate, and give legal advice. The December 10, 2010 letter asks this office "to investigate through appropriate and independent channels the handling of the Epstein (non)prosecution." OPR is the appropriate and independent body within the DOJ to investigate and determine whether misconduct + +has occurred. + +Second, during the meeting on December 10, we advised you of the ethical standards applicable regarding a potential prosecution of Epstein by our office, and that a recusal would likely ensue. Given your request for an investigation of this Office's conduct in the Jeffrey Epstein case, and the referral of that request to OPR, we are seeking guidance from DOJ on whether this office can continue + +to defend the Crime Victim Rights Act case. + +Third, we discussed the sequence in the litigation. You asked us that, in the event the court decides that the CVRA applied, in the absence of a formal charge, that the government concede (1) the U.S. Attorney's Office failed to comply with the CVRA; and (2) the district court should set aside the Non-Prosecution Agreement. In light of what has occurred, we cannot give you an answer on those two + +points. + +You had told us earlier that you would be filing a dispositive motion by December 17, 2010. I expect to find out whether our office needs to recuse itself within the next week. I will be on leave from December 17-28, but will be back at the office on December 29. I am asking if you would defer filing + +any motion until after I return on December 29. Thank you. + +I can be reached by e-mail and cell phone, during my annual leave. + +From: (FBI) < + +Sent: Wednesday, February 23, 2011 12:30 PM + +To: (USAFLS) + +Subject: Re: Epstein stuff + +The disk that the emails r on has to be opened on the computer that saved it to the cd. (I guess bureau security stuff) An a s that means a trip to Miami computer room. I may be going down next week, I'll let u know! I= at the time was + +and was + +II ask if he still has any emails from that time. + +From: (USAFLS) + +To: + +Sent: Wed Feb 23 12:23:13 2011 + +AF M - Have you had any luck looking around? And can you remind me of the names of the and the + +I think was the only supervisor in WPB who would have sent an email, but remind me if there was anyone + +else who may have sent something. + +Thanks. + +Assistant U.S. Attorney + +Fax + +From: Sent: To: Cc: Subject: (USAFLS) ‹ > + +Monday, February 28, 2011 11:54 AM + +(USAEO); (OLP) (JMD); (USAFLS); (USAFLS); + +RE: Jane Does 1 and 2 United States - CVRA Lawsuit (S.D.Fla.) + +Are we speaking at noon? What is the call-in number? + +Thank you. + +Assistant U.S. Attorney + +Fax + +From: + +Sent: Monda + +(USAEO) + +, February 28, 2011 9:08 AM miss. SMO); + +(USAFLS) (USAE0) + +If you mean can I get a conference call line, yes, I can. + +(SMO) February 28, 2011 9:07 AM + +USAEO); USAFLS + +. (USAFLS); (USAFLS);U + +(USAEO) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +. (USAFLS); + +: Can you set up a call? I have a 10:00 meeting (30 minutes), and an as yet unscheduled obligation to assist in briefing the AG for his testimony on the Hill tomorrow. Sometime between noon + +and 1 is likely to be best for me. + +(USAEO) + +February 28, 2011 8:43 AM + +SMO); USAFLS + +. (USAFLS); (USAFLS); + +(USAEO) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +I agree, as well. I am available anytime between noon and 3:00 today. + +From: (SMO) + +Sent: Saturda February 26, 2011 4:19 PM + +To: USAFLS ; + +Cc: . (USAFLS); (USAFLS); Subject: Re: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +USAEO + +I agree completely. Let's try and talk Monday, with on the phone if possible. + +. (USAFLS); + +. (USAFLS) + +From: (USAFLS) + +Sent: Saturda February 26, 2011 04:08 PM + +To: SMO); USAEO + +Cc: . (USAFLS); (USAFLS); . (USAFLS) + +judgment on December 17, 2010. Due to concerns that the U.S. Attorney's Office might have to be recused, due to the allegations of misconduct, Cassell agreed to defer filing their motion. We have since been advised by EOUSA General Counsel's Office that there is no need for our office to recuse + +itself, since we are only litigating the legal issue of whether rights under the CVRA attached. + +After the new year began, Cassell inquired about the status of the OPR complaint and the recusal + +issue. + +On Thursday, February 10, 2011, Deputy Chief AUSA and I spoke with Cassell and Edwards regarding the status of the case. I told them Cassell's letter request for an investigation of the Non-Prosecution Agreement had been referred to OPR, and OPR had requested various documents from our office. I also told them the EOUSA General Counsel's office advised that our office could go ahead and represent the United States in the CVRA lawsuit. I suggested that the parties were ready to move forward with filing documents with the court so it could resolve this + +case. + +I asked whether it might be useful to engage in mediation in an attempt to resolve the case. Cassell told us they wanted the Non-Prosecution Agreement to be set aside. I told him that was not likely to happen. Cassell then suggested that the United States Government should step aside and allow them to "go after" Epstein to get the agreement set aside. I asked him how he expected that would + +be done, since the only parties to the Non-Prosecution Agreement were Epstein and the + +Government. Cassell said they would file their summary judgment motion, and the government would take no position on their motion. Presumably, Epstein would either intervene, or be brought in as a necessary party, and defend the Non-Prosecution Agreement. I told them this would have to be + +approved by the U.S. Attorney and Main Justice. + +I have serious misgivings about not defending the Executive Branch's prerogative to engage in a Non- + +Prosecution Agreement, free from supervision or oversight by the judiciary. If we stand by the sidelines, Cassell will be arguing the Government was obligated to consult with the victims, and because we failed to do so, the agreement is a nullity. Whatever we may think of the Agreement, it was the prerogative of the U.S. Attorney's Office to enter into it with Epstein, and we should be willing to defend what we did. The DOJ's position is that the rights in the CVRA do not attach until there is a federal court proceeding. Since Epstein was never charged in federal court, we were not obligated + +to consult with the victims before entering into the Non-Prosecution Agreement. + +We wanted to seek your views on Cassell's suggestion before we responded to him. We are currently + +scheduled to have a conference call with Cassell and Edwards on Tuesday, March 1. I can be + +reached at . Thanks. + +• + +From: (USAEO) + +Sent: Monday, February 28, 2011 8:43 AM + +To: . (OLP) (JMD); (USAFLS) + +Cc: (USAFLS); (USAFLS); (USAFLS); (USAEO) Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.FIa.) + +I agree, as well. I am available anytime between noon and 3:00 today. + +Sent: Saturda February 26, 2011 4:19 PM + +To: (USAFLS); + +Cc: . (USAFLS); (USAFLS); Subject: Re: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +USAEO + +I agree completely. Let's try and talk Monday, with on the phone if possible. + +From: + +Sent: Saturda + +To: Cc: + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +(USAFLS) + +February 26, 2011 04:08 PM + +SMO); + +. (USAFLS); + +USAEO + +. (USAFLS) + +(USAFLS); . (USAFLS) + +Mr. + +I'm looking for the appropriate officials in the Department with programmatic responsibility for the + +CVRA, so that we may obtain guidance on our litigating position. What Cassell wants the + +government to do is abdicate its role in defending its actions. If the DOJ's position is that no rights attach until a charging instrument is filed, then we should vigorously defend that position. Our office is most reluctant to do what Cassell asks, since negotiating the non-prosecution agreement was clearly within the prerogatives granted to the Executive Branch. Whether the bargain struck with Epstein + +was wise or not should not be the issue. + +I will be in the office all day Monday. Thanks for your assistance. + +From: (SMO) + +Sent: Saturda February 26, 2011 3:40 PM + +To: (USAFLS); + +Cc: . (USAFLS); (USAFLS) Subject: Re: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +USAEO + +Thanks. Perhaps we should try and find a time to talk on Monday. This scenario raises a variety of policy issues that extend well beyond the question of "when do the rights attach." Frankly, I don't think the court should even reach that question given the posture of the case as you describe it. + +• + +From: Sent: To: Cc: Subject: + +(SMO) < Saturday, February 26, 2011 3:40 PM (USAFLS); + +(USAFLS); (USAFLS) + +Re: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +(USAEO) + +Thanks. Perhaps we should try and find a time to talk on Monday. This scenario raises a variety of policy issues that extend well beyond the question of "when do the rights attach." Frankly, I don't think the court should even reach that question given the posture of the case as you describe it. + +From: + +Sent: Saturda + +To: Cc: + +Subject: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +(USAFLS) + +February 26, 2011 02:23 PM + +SMO); + +. (USAFLS); + +USAEO + +(USAFLS) + +Ms. and Mr. =, + +Our office is currently litigating a Crime Victims Rights Act (CVRA) lawsuit filed by Jane Does 1 and 2, who were victims of sexual abuse by Jeffrey Epstein, a multi-millionaire investor living in Palm Beach, Florida. Jane Does 1 and 2 v. United States Case No. 08-80736-CIV-MARRA (S.D.Fla.). We are seeking your advice and guidance on a proposal from the victims' attorneys, that the government take no position on whether the CVRA granted rights to the victims, when the U.S. Attorney's Office negotiated a non-prosecution agreement with Epstein. + +In 2006, the Palm Beach Police Department began investigating allegations that Jeffrey Epstein was enticing + +underage girls into prostitution. Epstein was alleged to have paid underage girls to provide him with + +massages, while the young girls were unclothed. The case was referred to the FBI and U.S. Attorney's Office, and the FBI began its own investigation. Epstein hired a number of highly-paid attorneys, including Alan + +Dershowitz and Kenneth Starr, to attempt to stave off criminal charges. + +Ultimately, in 2007, Epstein was charged in state court with soliciting minors for prostitution. In September 2007, the U.S. Attorney's Office entered into a Non-Prosecution Agreement with Epstein, in which he agreed to plead guilty to the state criminal charge, and serve a sentence of 18 months. Epstein also agreed that, in any civil action under 18 U.S.C. 2255 by the underage victims, he would not raise the lack of a federal sex offense as a defense. In July 2008, Epstein plead guilty, and was sentenced to serve six months at the Palm Beach + +County Detention Facility, followed by 12 months in home detention. + +In July 2008, after the Non-Prosecution Agreement had been executed, two victims, Nand filed an action under the CVRA, 18 U.S.C. 3771. They claimed that the government was obligated, under 18 U.S.C. 3771(a) (5), to speak with the victims prior to the execution of the Non-Prosecution Agreement. An emergency hearing was held on July 11, 2008, before U.S. District Judge Kenneth Marra. Since Epstein had entered his + +necessary. + +Attorney Brad Edwards initially represented the victims. Soon, he was joined by Paul Cassell, a University of Utah law professor, and former federal judge who served in the District of Utah from 2002-2007. Cassell is a victims' rights advocate who has appeared in many cases throughout the United States. The victims' rights suit was inactive for the next two years, with Edwards and Cassell using the civil suit as a means to attempt to gain access to information helpful in their civil actions for damages against Epstein. They were able to obtain + +a copy of the Non-Prosecution Agreement through the civil litigation. + +In August 2010, the district court, noting that the last civil suit had been settled, entered an order closing the case. Edwards and Cassell immediately filed documents with the court, advising that the case should not be closed or dismissed, and they wanted to pursue final action by the court. Since September 2010, AUSA + +and I have been dealing with Cassell and Edwards on how to resolve the case. They claim the victims + +had a right to be consulted prior to the execution of the Non-Prosecution Agreement, and that we violated the + +CVRA by not consulting them. The remedy they seek is a set aside by the court of the Non-Prosecution + +Agreement, and a prosecution of Epstein. + +On December 10, 2010, United States Attorney Wifredo A. + +and I, met with Cassell, Edwards, and S one of the victims. We discussed the posture of the + +case, and told us her views of what occurred and her desire to see Epstein receive justice for what he did. Cassell presented U.S. Attorney a four-page letter, requesting an investigation of the Jeffrey Epstein + +prosecution. He claims there may have been improper influence exercising by Epstein, noting that Epstein is a "politically-connected billionaire." Cassell cites to an alleged tip off to Epstein that a search warrant on his residence was to be executed; that a former AUSA, left the West Palm Beach office and soon began appearing on behalf of individuals aligned with Epstein; and an unprecedented level of secrecy between the FBI and the U.S. Attorney's Office, where the FBI was purportedly kept in the dark about the impending Non-Prosecution Agreement. He also claims that the victims were deceived regarding the existence of the + +Non-Prosecution Agreement. + +Cassell's request for an investigation was referred to DOJ OPR on December 16, 2010. has requested various documents from our office, presumably to determine whether an investigation should be opened. Cassell and Edwards had planned to file a motion for summary judgment on December 17, 2010. Due to concerns that the U.S. Attorney's Office might have to be recused, due to the allegations of misconduct, Cassell agreed to defer filing their motion. We have since been advised by EOUSA General Counsel's Office that there is no need for our office to recuse itself, since we are only litigating the legal issue of whether rights + +under the CVRA attached. + +After the new year began, Cassell inquired about the status of the OPR complaint and the recusal issue. + +On Thursday, February 10, 2011, Deputy Chief AUSA and I spoke with Cassell and Edwards regarding the status of the case. I told them Cassell's letter request for an investigation of the Non-Prosecution Agreement had been referred to OPR, and OPR had requested various documents from our office. I also told them the EOUSA General Counsel's office advised that our office could go ahead and + +represent the United States in the CVRA lawsuit. I suggested that the parties were ready to move forward with + +I asked whether it might be useful to engage in mediation in an attempt to resolve the case. Cassell told us they wanted the Non-Prosecution Agreement to be set aside. I told him that was not likely to happen. Cassell then suggested that the United States Government should step aside and allow them to "go after" Epstein to get the agreement set aside. I asked him how he expected that would be done, since the only parties to the Non-Prosecution Agreement were Epstein and the Government. Cassell said they would file their summary judgment motion, and the government would take no position on their motion. Presumably, + +Epstein would either intervene, or be brought in as a necessary party, and defend the Non-Prosecution + +Agreement. I told them this would have to be approved by the U.S. Attorney and Main Justice. + +I have serious misgivings about not defending the Executive Branch's prerogative to engage in a Non- + +Prosecution Agreement, free from supervision or oversight by the judiciary. If we stand by the sidelines, Cassell will be arguing the Government was obligated to consult with the victims, and because we failed to do so, the agreement is a nullity. Whatever we may think of the Agreement, it was the prerogative of the U.S. Attorney's Office to enter into it with Epstein, and we should be willing to defend what we did. The DOJ's position is that the rights in the CVRA do not attach until there is a federal court proceeding. Since Epstein was never charged in federal court, we were not obligated to consult with the victims before entering into the + +Non-Prosecution Agreement. + +We wanted to seek your views on Cassell's suggestion before we responded to him. We are currently scheduled to have a conference call with Cassell and Edwards on Tuesday, March 1. I can be reached at + +. Thanks. + +From: (USAFLS) < + +Sent: Saturday, February 26, 2011 4:08 PM + +To: . (OLP) (JMD); (USAEO) Cc: (USAFLS); (USAFLS); + +(USAFLS) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.FIa.) + +Mr. + +I'm looking for the appropriate officials in the Department with programmatic responsibility for the + +CVRA, so that we may obtain guidance on our litigating position. What Cassell wants the + +government to do is abdicate its role in defending its actions. If the DOJ's position is that no rights attach until a charging instrument is filed, then we should vigorously defend that position. Our office is most reluctant to do what Cassell asks, since negotiating the non-prosecution agreement was clearly within the prerogatives granted to the Executive Branch. Whether the bargain struck with Epstein + +was wise or not should not be the issue. + +I will be in the office all day Monday. Thanks for your assistance. + +be done, since the only parties to the Non-Prosecution Agreement were Epstein and the + +Government. Cassell said they would file their summary judgment motion, and the government would take no position on their motion. Presumably, Epstein would either intervene, or be brought in as a necessary party, and defend the Non-Prosecution Agreement. I told them this would have to be + +approved by the U.S. Attorney and Main Justice. + +I have serious misgivings about not defending the Executive Branch's prerogative to engage in a Non- + +Prosecution Agreement, free from supervision or oversight by the judiciary. If we stand by the sidelines, Cassell will be arguing the Government was obligated to consult with the victims, and because we failed to do so, the agreement is a nullity. Whatever we may think of the Agreement, it was the prerogative of the U.S. Attorney's Office to enter into it with Epstein, and we should be willing to defend what we did. The DOJ's position is that the rights in the CVRA do not attach until there is a federal court proceeding. Since Epstein was never charged in federal court, we were not obligated + +to consult with the victims before entering into the Non-Prosecution Agreement. + +We wanted to seek your views on Cassell's suggestion before we responded to him. We are currently + +scheduled to have a conference call with Cassell and Edwards on Tuesday, March 1. I can be + +reached at . Thanks. + +• + +From: (FBI) + +Sent: Monday, February 28, 2011 11:27 AM To: (USAFLS) + +Subject: Fw: Customs POC + +From: To: + +Sent: Mon Feb 28 11:16:59 2011 Subject: Fw: Customs POC + +I talked to on Fri, they sent Subpoenas to the pilots. Not through FAA + +From: (USAFLS) < + +To: Cc: + +Sent: Thu Feb 24 13:03:22 2011 Subject: RE: Customs POC + +Hi Luz — I have reached out to Can you talk with about how we got the flight plans/flight manifests for Epstein's planes in that case? I think that was done through the FAA. + +Assistant U.S. Attorney + +Fax + +From: (FBI) + +Sent: Wednesday, February 23, 2011 4:19 PM + +To: . (USAFLS) + +Subject: Customs POC + +The Point of Contact we have in our Miami office is: + +Investigative Operations Analyst + +(USAFLS) + +February 22, 2011 4:54 PM + +(USAFLS); (USAFLS) + +Subject: Sledgehammer Meeting Reminder + +Hi everyone — Just a quick reminder that we have our Master Meeting tomorrow at 2:00. + +The meeting will be in the 4ft" Floor Conference Room at the U.S. Attorney's Office, + +See you all there! + +Thank you. + +Assistant U.S. Attorney + +Fax + +From: (SMO) < + +Sent: Monday, February 28, 2011 9:07 AM + +To: (USAEO); (USAFLS) + +Cc: (USAFLS); (USAFLS); (USAFLS); (USAEO) Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.FIa.) + +: Can you set up a call? I have a 10:00 meeting (30 minutes), and an as yet unscheduled obligation to assist in briefing the AG for his testimony on the Hill tomorrow. Sometime between noon + +and 1 is likely to be best for me. + +(USAEO) + +February 28, 2011 8:43 AM + +SMO); USAFLS + +. (USAFLS); (USAFLS); + +(USAEO) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +I agree, as well. I am available anytime between noon and 3:00 today. + +From: (SMO) + +Sent: Saturda February 26, 2011 4:19 PM + +To: (USAFLS); + +Cc: . (USAFLS); (USAFLS); Subject: Re: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +USAEO + +I agree completely. Let's try and talk Monday, with on the phone if possible. + +From: (USAFLS) + +Sent: Saturda February 26, 2011 04:08 PM + +To: SMO); USAEO + +Cc: . (USAFLS); (USAFLS); Subject: RE: Jane Does 1 and 2I. United States - CVRA Lawsuit (S.D.Fla.) + +Mr. + +. (USAFLS); + +. (USAFLS) + +. (USAFLS) + +I'm looking for the appropriate officials in the Department with programmatic responsibility for the + +CVRA, so that we may obtain guidance on our litigating position. What Cassell wants the + +government to do is abdicate its role in defending its actions. If the DOJ's position is that no rights attach until a charging instrument is filed, then we should vigorously defend that position. Our office is most reluctant to do what Cassell asks, since negotiating the non-prosecution agreement was clearly within the prerogatives granted to the Executive Branch. Whether the bargain struck with Epstein + +was wise or not should not be the issue. + +happen. Cassell then suggested that the United States Government should step aside and allow them to "go after" Epstein to get the agreement set aside. I asked him how he expected that would + +be done, since the only parties to the Non-Prosecution Agreement were Epstein and the + +Government. Cassell said they would file their summary judgment motion, and the government would take no position on their motion. Presumably, Epstein would either intervene, or be brought in as a necessary party, and defend the Non-Prosecution Agreement. I told them this would have to be + +approved by the U.S. Attorney and Main Justice. + +I have serious misgivings about not defending the Executive Branch's prerogative to engage in a Non- + +Prosecution Agreement, free from supervision or oversight by the judiciary. If we stand by the sidelines, Cassell will be arguing the Government was obligated to consult with the victims, and because we failed to do so, the agreement is a nullity. Whatever we may think of the Agreement, it was the prerogative of the U.S. Attorney's Office to enter into it with Epstein, and we should be willing to defend what we did. The DOJ's position is that the rights in the CVRA do not attach until there is a federal court proceeding. Since Epstein was never charged in federal court, we were not obligated + +to consult with the victims before entering into the Non-Prosecution Agreement. + +We wanted to seek your views on Cassell's suggestion before we responded to him. We are currently + +scheduled to have a conference call with Cassell and Edwards on Tuesday, March 1. I can be + +reached at . Thanks. + +• + +From: (USAEO) < Sent: Monday, February 28, 2011 9:08 AM + +To: . (OLP) (JMD); (USAFLS) + +Cc: (USAFLS); + +(USAFLS); (USAEO) Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +If you mean can I get a conference call line, yes, I can. + +(USAFLS); + +(SMO) Februa 28, 2011 9:07 AM + +USAEO); USAFLS + +. (USAFLS); (USAFLS); + +(USAEO) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +. (USAFLS); + +: Can you set up a call? I have a 10:00 meeting (30 minutes), and an as yet unscheduled obligation to assist in briefing the AG for his testimony on the Hill tomorrow. Sometime between noon + +and 1 is likely to be best for me. + +(USAEO) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +I agree, as well. I am available anytime between noon and 3:00 today. + +From: (SMO) + +Sent: Saturda February 26, 2011 4:19 PM + +To: (USAFLS); + +Cc: . (USAFLS); (USAFLS); Subject: Re: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +USAEO + +I agree completely. Let's try and talk Monday, with on the phone if possible. + +From: + +Sent: Saturda + +To: Cc: + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +(USAFLS) + +February 26, 2011 04:08 PM + +SMO); + +. (USAFLS); + +USAEO + +. (USAFLS) + +(USAFLS); . (USAFLS) + +Mr. + +I'm looking for the appropriate officials in the Department with programmatic responsibility for the + +CVRA, so that we may obtain guidance on our litigating position. What Cassell wants the + +government to do is abdicate its role in defending its actions. If the DOJ's position is that no rights attach until a charging instrument is filed, then we should vigorously defend that position. Our office is most reluctant to do what Cassell asks, since negotiating the non-prosecution agreement was clearly within the prerogatives granted to the Executive Branch. Whether the bargain struck with Epstein + +was wise or not should not be the issue. + +I will be in the office all day Monday. Thanks for your assistance. + +From: (SMO) + +Sent: Saturda , February 26, 2011 3:40 PM + +I have serious misgivings about not defending the Executive Branch's prerogative to engage in a Non- + +Prosecution Agreement, free from supervision or oversight by the judiciary. If we stand by the sidelines, Cassell will be arguing the Government was obligated to consult with the victims, and because we failed to do so, the agreement is a nullity. Whatever we may think of the Agreement, it was the prerogative of the U.S. Attorney's Office to enter into it with Epstein, and we should be willing to defend what we did. The DOJ's position is that the rights in the CVRA do not attach until there is a federal court proceeding. Since Epstein was never charged in federal court, we were not obligated + +to consult with the victims before entering into the Non-Prosecution Agreement. + +We wanted to seek your views on Cassell's suggestion before we responded to him. We are currently + +scheduled to have a conference call with Cassell and Edwards on Tuesday, March 1. I can be + +reached at . Thanks. + +• + +From: (USAFLS) < Sent: Monday, March 07, 2011 5:28 PM To: . (USAFLS) + +Subject: FW: Jeffrey Epstein + +> + +See below. Is this your case? Obviously we will make no comment. + +From: (SMO) + +Sent: Monday March 07, 2011 5:25 PM + +To: .(USAFLS) Subject: FW: Jeffrey Epstein + +I believe is out. See below. + +From: (SMO) + +Sent: Monc March 07, 2011 5:18 PM + +To: , (USAFLS) Subject: Jeffrey Epstein + +, Is your office handling this matter? A WSJ reporter is trying to get more information. + +The Justice Department is investigating Jeffrey Epstein for child trafficking, The Daily Beast has learned—and has widened the scope of its probe to include a famous modeling agency. + +federal requirements that arise from the prior proceedings in Palm Beach. There are no pending civil lawsuits. There are not and should not be any pending criminal investigations, given Mr. Epstein's complete fulfillment of all the terms of his non-prosecution agreement with the federal government." + +Read more: http://www.businessinsider.com/hedge-funder-joseph-epstein-investigated-for-child- + +trafficking-2010-7#ixzz1FxAJrd Fa + +From: (USAFLS)< > + +Sent: Monday, March 07, 2011 11:55 AM + +To: Jon Swaine + +Cc: (USAFLS) Subject: RE: Daily Telegraph of London + +Thanks for the email. + +Unfortunately, the USAO has no comment. Thanks for checking with us. + +Take care, + +From: Jon Swaine [mailto: + +Sent: Monc March 07, 2011 11:50 AM + +To: , (USAFLS) + +Subject: Re: Daily Telegraph of London + +I'm looking at the case of Jeffrey Epstein, who was imprisoned for two sex offence felonies in 2008, + +after coming to a plea deal with the US Attorney. + +I'd like to know whether any representations were made to the US Attorney's office by associates of Mr + +Epstein - not including his lawyers. + +I'm particularly keen to know whether any contact was made by Prince of Britain, former + +President Clinton or former Governor of Mexico Bill Richardson. + +Jon + +On 7 March 2011 11:36, + +Hi Jon. + +What do you need? Not at my desk. + +Thanks + +From: Jon Swaine [mailto: + +Sent: Monc March 07, 2011 11:36 AM + +To: ,M (USAFLS) + +Subject: Daily Telegraph of London + +(USAFLS) > wrote: + +Dear + +Please could I speak to you about an urgent media inquiry? + +Many thanks + +Jon Swaine + +The Dail Tele ra h of London + +Mobile: (+1),MI Office: (+1) + +The Dail Tele ra h of London + +From: Paul Cassell ‹ > Sent: Monday, March 07, 2011 5:33 PM + +To: (USAFLS); . (USAFLS) + +Cc: Brad Edwards + +Subject: Motion to Make Our Pleading Available to the Public - Government Position + +Dear and + +We are writing to inquire about the government's position on a motion that we will be filing on March 18 along with our "summary judgment" motion. As you know, the summary judgment motion will + +contain quotations from e-mails that are under the magistrate judge's order requiring prior notice to the court before they are disclosed. Accordingly, on March 18, we will be filing a full, unredacted summary judgment motion under seal with Judge Marra and, for the public PACER file, a summary judgment + +motion with quotations from the e-mails redacted. + +We will be filing simultaneously a motion for with the court for unsealing of the unredacted motion. We will provide (at least) three ground for unsealing. First, the confidentiality order was only based on an agreement to give advance notice to Epstein before using materials. Once advance notice has been given, there is no basis for confidentiality. Second, there is truly world-wide interest in the handling of the Epstein prosecution, and so our pleading should not remain under seal — instead the public should have access to it so that they can assess how this case was handled. Third, keeping the pleading under seal complicates the ability of Jane Does' attorneys to consult with victims' rights specialist + +about how best to proceed in the case. + +We are writing to determine the Government's position on our motion to unseal the redacted pleading so that we can include that position in our motion. We hope that you will not oppose the motion, which might produce the need for further litigation. As you know, Judge Marra has promptly unsealed other + +pleadings in this matter when the Government tried to object. + +Sincerely, + +Paul Cassell + +Co-Counsel for Jane Doe #1 and Jane Doe #2 + +Ronald N. Boyce Presidential Professor of Criminal Law + +S.J. Quinney College of Law at the University of Utah + +Voice: + +Fax: + +Email: + +http://www.law.utah.edu/profiles/defaultasp?PersonID=57&name=Cassell,Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the + +sender by reply electronic mail and delete the original message. Thank you. + +From: . (FBI) + +Sent: Friday, March 04, 2011 4:44 PM To: (USAFLS) + +Subject: Re: Jeffrey Epstein + +Call my cell. + +Ori inal Messa e + +From: . (USAFLS) + +To: + +Sent: Fri Mar 04 16:04:55 2011 Subject: FW: Jeffrey Epsteinl + +Can you please call me about this? I am at my desk. + +Assistant U.S. Attorne + +Fax + +HI Nick. + +Thank you for your email. This is always the best + +blackberry on me. + +As to your question, I will not be able to help you. or on our intention to open or close a matter. + +Sorry Thanks + +From: [mailto: + +Sent: FridAy,i'Aarch 04, 2011 3:16 PM + +To: =.= (USAFLiSil Subject: Jeffrey Epstein + +Dear + +way to get me. I am hardly ever at my desk, but always have my + +We cannot comment, confirm or deny the existence of any investigation + +I work for the Mail on Sunday newspaper in London, En land. The Mail on Sunday last week published an interview with about her time working for Jeffrey Epstein. We plan to publish more revelations this + +week. + +I have been led to believe that the FBI is interested in pursuing the allegations published in the Mail on Sunday - and that Epstein may have committed offences not covered by the non prosecution agreement. + +Can you give me any guidance as to whether my information is correct? + +You may contact me by email or on + +Regards, + +Nick Pryer + +Assistant Features Editor + +Mail on Sunday + +This e-mail and any attached files are intended for the named addressee only. It contains information which may be confidential and legally privileged and also protected by copyright. Unless you are the named addressee (or authorised to receive for the addressee) you may not copy or + +use it, or disclose it to anyone else. If you received it in error please notify the sender immediately and then delete it from your system. Please be advised that the views and opinions expressed in this e-mail may not reflect the views and opinions of Associated Newspapers Limited or any of its subsidiary companies. We make every effort to keep our network free from viruses. However, you do need to check this e-mail and any attachments to it for viruses as we can take no responsibility for any computer virus which may be transferred by way of this e-mail. Use of this or any other e-mail facility signifies consent to any interception we might lawfully + +carry out to prevent abuse of these facilities. Associated News a ers Ltd. Registered Office: + +This e-mail and any attached files are intended for the named addressee only. It contains information, which may be confidential and legally privileged and also protected by copyright. Unless you are the named addressee (or authorised to + +receive for the addressee) you may not copy or use it, or disclose it to anyone else. If you received it in error please notify the sender immediately and then delete it from your system. Please be advised that the views and opinions expressed in this e-mail may not reflect the views and opinions of Associated Newspapers Limited or any of its subsidiary companies. + +We make every effort to keep our network free from viruses. However, you do need to check this e-mail and any + +attachments to it for viruses as we can take no responsibility for any computer virus which may be transferred by way of this e-mail. Use of this or any other e-mail facility signifies consent to any interception we might lawfully carry out to prevent + +abuse of these facilit! + +ies. + +Associated Newspapers Ltd. Registered Office: + +From: (FBI) + +Sent: Monday, March 07, 2011 9:42 AM To: (USAFLS); + +Subject: Fw: FYI + +I'm sure u have heard! + +From: To: + +Cc: Longa, Waldo + +Sent: Mon Mar 07 02:56:29 2011 + +Subject: FYI + +(FBI) + +- This is front page stuff today just wanted to let you know FYI. The Guardian, a London + +paper, is running articles and alluding to FBI reopening its case. + +Prince big mistake: Humiliated Duke + +of York vows to end friendship with billionaire + +paedophile + +• Duke now said to recognise friendship was 'unwise' + +• Former Scotland Yard royalty protection chief: 'Prince is bringing the royal family into + +disrepute' + +Mistake: The duke has cut ties with the disgraced billionaire + +The Duke of York has finally admitted that meeting the disgraced billionaire recently was 'unwise' and has ruled out further visits to the Florida mansion where Epstein sexually exploited underage girls. + +In a warning that may have come from the Queen, the duke's aides have advised him that his continued association with the paedophile risked damaging the reputation of the monarchy. + +Now the humiliated duke, the fourth in line to the throne, has backed down and cut ties with Epstein, + +58, in the hope that he can draw a line under the sordid association. + +An impeccably-placed source said yesterday: 'The duke recognises now that the meeting in December + +2010, after Epstein's conviction, was unwise.' + +It was not clear last night if , a UK trade envoy, has acted before fresh revelations about the + +friendship are made public. + +Earlier this week, in a rare move, his conduct was raised on the floor of the House of Commons. + +But, whatever the motivation, his decision to sever ties with an old friend is a tacit admission that he + +has got it wrong with his choice of friends. + +From: • (FBI) + +Sent: Sunday, March 06, 2011 6:37 PM To: . (USAFLS) + +Subject: Re: Jeffrey Epstein + +Just what was in the email below. Nothing else. + +Ori inal Messa e + +From: . (USAFLS) < + +To: + +Sent: Fri Mar 04 16:04:55 2011 Subject: FW: Jeffrey Epstein + +Can you please call me about this? I am at my desk. + +Assistant U.S. Attorne + +Fax + +Ori\_girS Message From: =. (USAFLS) + +Sent: Frida March 04, 2011 3:56 PM + +To: + +Cc: (USAFL Subject: RE: Jeffrey Epstein + +> + +attachments to it for viruses as we can take no responsibility for any computer virus which may be transferred by way of this e-mail. Use of this or any other e-mail facility signifies consent to any interception we might lawfully carry out to prevent + +abuse of these facilit! + +ies. + +Associated Newspapers Ltd. Registered Office: + +From: (USAFLS) + +Sent: Thursday, March 10, 2011 8:04 AM To: (USAFLS) + +Subject: Re: Epstein/Conf. Call + +If you get a chance, could you send me a copy of the agreement before today's meeting? + +Thanks, + +From: (USAFLS) Sent: Tuesda , March 08. 2011 02:08 PM + +To: . (USAFLS); USAFLS) Cc: (USAFLS) Subject: RE: Epstein/Conf. Call + +(USAFLS); + +I have a change of plea at 9:30 and then the Health Care Fraud Task Force meeting at 10:00. + +Could we start at 11:30? + +Assistant U.S. Attorney + +Fax + +(USAFLS); + +0ri inalAppointment + +From: (USAFLS) + +Sent: Monday, March 07, 2011 6:53 PM + +To: (USAFLS) + +Can you please set up a meeting/conference call re: Epstein for Thursday morning with me, + +and Thanks. + +From: Ann + +Sent: Monday, March 14, 2011 12:29 AM To: . (USAFLS) + +Subject: Cassell or Edwards commenting to press re Jane Doe suit + +Attachments: Duke of York to face fresh questions as Epstein case takes new twist - Telegraph.pdf.zip + +Thought you should see this and we should discuss. + +From: (USAFL5) c > + +Sent: Tuesday, March 15, 2011 11:54 AM + +To: (USAFLS); . (USAFLS) Cc: . (USAFLS); (USAFLS); (USAFLS) + +Subject: Latest Draft of Letter to Paul Cassel Attachments: Cassell Response Letter - rev5.wpd + +and + +(USAFLS); + +Attached is the latest draft of the letter that intends to send to Mr. Cassel. Could you please review the draft and let us know if you have any comments or concerns concerning this draft? + +would like to send the letter out today. + +Thanks, + +• + +Subject: RE: Jeffrey Epstein + +Today Show just called. No joke. They are doing a story how the case was reopened. I won't confirm + +anything. + +• + +From: (USAFLS) Sent: Monda March 07, 2011 5:38 PM + +To: .(USAFLS) Subject: RE: Jeffrey Epstein + +How many more incorrect statements can be printed99??? It is like one feeds off another that feeds + +off another. That woman at the Daily Beast is just making things up at this point. + +What is SMO, by the way? + +Assistant U.S. Attorney + +Fax + +From: (USAFLS) Sent: Monda March 07, 2011 5:28 PM To: . (USAFLS) + +Subject: FW: Jeffrey Epstein + +See below. Is this your case? Obviously we will make no comment. + +Sent: Monday March 07, 2011 5:25 PM + +To: .(USAFLS) Subject: FW: Jeffrey Epstein + +I believe is out. See below. + +From: (SMO) + +Sent: Mon March 07, 2011 5:18 PM + +To: , (USAFLS) Subject: Jeffrey Epstein + +, Is your office handling this matter? A WSJ reporter is trying to get more information. + +The Justice Department is investigating Jeffrey Epstein for child trafficking, The Daily Beast has learned—and has widened the scope of its probe to include a famous modeling agency. + +Hedge-fund manager Jeffrey Epstein completed his sentence for soliciting prostitution with a minor last + +week. But it appears his problems may not be over. Now The Daily Beast has learned that: + +• Federal investigators continue to investigate Epstein's activities, to see whether there is evidence of child trafficking—a far more serious charge than the two in his non-prosecution agreement, the arrangement between Epstein and the Department of Justice allowing him to + +plead guilty to lower-level state crimes. Trafficking can carry a 20-year sentence. + +• The FBI is also investigating Epstein's friend Jean Luc Brunel, whose MC2 modeling agency appears to have been a source of girls from overseas who ended up on Epstein's private jets. + +Under the concept of double jeopardy, Epstein can no longer be prosecuted for any of the charges covered by his non-prosecution agreement, in which he agreed to serve a short term of incarceration, fund the civil suits of named victims, and register as a sex offender. The victims who accepted cash settlements in these civil suits agreed not to testify against him or speak publicly about the case. + +However, new evidence developed by the Department of Justice on other offenses not covered by the agreement, including allegations by additional victims who come forward, could lead to new charges. There is no statute of limitations in the federal sex-trafficking law, which was also enacted by the state of Florida in 2002. Because his predatory habits stretch back many years and involved dozens of young-looking girls, there may well be more evidence to uncover. (Several young women who claim to be Epstein victims have recently contacted a Ft. Lauderdale lawyer, but to date no new civil complaints + +have been filed.) + +These new developments come one week after the publication of two articles in The Daily Beast about Epstein's pattern of sexual contact with underage girls, which Palm Beach police began investigating + +deposition by then-Palm Beach Chief of Police Michael Reiter, in which he stated that Epstein, a billionaire with many powerful friends, had received special treatment in both his plea deal and the terms of his incarceration. Although federal investigators at one point produced a draft 53-page + +indictment against Epstein, he was eventually allowed to plead guilty to only two relatively minor state charges and receive a short term of incarceration: 13 months in the county jail, during which he went to the office every day, and one year of community control, during which he traveled frequently to New + +York and his private island in the Virgin Islands. + +The Daily Beast has now discovered another instance in which Epstein apparently received special consideration: As a convicted sex offender, he is required by law to undergo an impartial psychological evaluation prior to sentencing and to receive psychiatric treatment during and after incarceration. This is because child molesters tend to be repeat offenders with high rates of recidivism. According to a + +source in law enforcement, however, Epstein was allowed to submit a report by his private psychologist, Dr. Stephen Alexander of Palm Beach, Florida, whose phone has since been + +disconnected with no forwarding information. + +The Daily Beast's second article provided details about Epstein's systematic abuse of underage girls at his Palm Beach mansion, where members of his staff allegedly recruited and paid a parade of teenagers, most of them 16 or younger, to perform daily massages that devolved into masturbation, groping, and sometimes full-blown sexual contact. It also revealed a monetary relationship between Epstein and Jean Luc Brunel, a frequent visitor to whom he gave \$1 million around the same time that Brunel was starting his MC2 modeling agency. Some of the young girls MC2 recruited from overseas -often from Eastern Europe and South America—are known to have been passengers on Epstein's + +private jets. + +The U.S. Attorney General's Office in Florida says that it is against policy to confirm or deny the + +existence of an investigation. Jeffrey Epstein's lawyer, Jack Goldberger, says he has no knowledge of an ongoing probe, and he told The Daily Beast, "Jeffrey Epstein has fully complied with all state and federal requirements that arise from the prior proceedings in Palm Beach. There are no pending civil lawsuits. There are not and should not be any pending criminal investigations, given Mr. Epstein's complete fulfillment of all the terms of his non-prosecution agreement with the federal government." + +Read more: http://www.businessinsider.com/hedge-funder-joseph-epstein-investigated-for-child- + +trafficking-2010-7#ixzz1FxAJrd Fa + +From: (USAFLS) Sent: Monday, March 14, 2011 11:27 AM + +To: (USAFLS); (USAFLS); + +(USAFLS); (USAFLS) + +Subject: FW: Cassell or Edwards commenting to press re Jane Doe suit + +Attachments: Duke of York to face fresh questions as Epstein case takes new twist - Telegraph.pdf.zip + +(USAFLS); + +Thought you should see this. Don't know if we need to file anything with the court about disclosing matters before the court to the press? Or whether it appears that Edwards may be trying to use the new criminal investigation to assist him in his + +defense of Epstein's civil suit against him (or in Edwards' counterclaim for defamation)? + +From: (USAFLS) Sent: Tuesday, March 15, 2011 6:51 PM To: . (USAFLS) + +Cc: (USAFLS): (USAFLS); (USAFLS); + +(USAFLS) + +Subject: Epstein + +Hi M, + +I think you mentioned last week that you were preparing a memo addressing some of the legal and strategic issues relating to a potential new investigation into Epstein and/or other targets. Once you've done that, we should probably set aside some time to chat about the case generally. Also, reached out to + +and me last week and raised some issues that we can discuss as well. Thanks. + +From: Sent: To: Cc: Subject: (USAFLS)< > + +Friday, March 04, 2011 3:47 PM + +. (USAFLS) + +(USAFLS) + +FW: Jeffrey Epstein + +Here is his inquiry =— he wants me to confirm whether FBI is interested in this info. I will not. + +Original rslessage + +From: [mailto: + +Sent: FridAy,IMarch 04, 2011 3:16 PM + +To: =.= (USAFLS Subject: Jeffrey Epstein + +Dear + +I work for the Mail on Sunday newspaper in London, En land. The Mail on Sunday last week published an interview with about her time working for Jeffrey Epstein. We plan to publish more revelations this + +week. + +I have been led to believe that the FBI is interested in pursuing the allegations published in the Mail on Sunday - and that Epstein may have committed offences not covered by the non prosecution agreement. + +Can you give me any guidance as to whether my information is correct? + +You may contact me by email or on + +Regards, + +Nick Pryer + +Assistant Features Editor + +Mail on Sunday + +This e-mail and any attached files are intended for the named addressee only. It contains information which may be confidential and legally privileged and also protected by copyright. Unless you are the named addressee (or authorised to receive for the addressee) you may not copy or + +use it, or disclose it to anyone else. If you received it in error please notify the sender immediately and then delete it from your system. Please be advised that the views and opinions expressed in this e-mail may not reflect the views and opinions of Associated Newspapers Limited or any of its subsidiary companies. We make every effort to keep our network free from viruses. However, you do need to check this e-mail and any attachments to it for viruses as we can take no responsibility for any computer virus which may be transferred by way of this e-mail. Use of this or any other e-mail facility signifies consent to any interception we might lawfully + +carry out to prevent abuse of these facilities. Associated Newspapers Ltd. Registered Office: + +This e-mail and any attached files are intended for the named addressee only. It contains information, which may be confidential and legally privileged and also protected by copyright. Unless you are the named addressee (or authorised to receive for the addressee) you may not copy or use it, or disclose it to anyone else. If you received it in error please notify the sender immediately and then delete it from your system. Please be advised that the views and opinions expressed in this e-mail may not reflect the views and opinions of Associated Newspapers Limited or any of its subsidiary companies. + +We make every effort to keep our network free from viruses. However, you do need to check this e-mail and any + +attachments to it for viruses as we can take no responsibility for any computer virus which may be transferred by way of this e-mail. Use of this or any other e-mail facility signifies consent to any interception we might lawfully carry out to prevent + +abuse of these facilitl + +ies. + +Associated Newspapers Ltd. Registered Office: + +From: (USAFI-S) > + +Sent: Tuesday, March 01, 20114:51 PM + +To: (USAFLS); (USAFLS) Cc: (USAFLS); (USAFLS) + +Subject: Janes Does 1 and 2 v. United States - March 1, 2011 Conference Call with Cassell + +and MI, + +At 11:30 a.m. today, M, =, and I spoke with Paul Cassell and Brad Edwards on a conference call regarding the posture of the case. told them we had spoken with officials at the DOJ, and the government was not going to stand by the sidelines and allow the victims to litigate the impropriety of + +negotiating the non-prosecution agreement without consulting the victims. We told Cassell we were going to defend the government's actions. At this point, Cassell said they only wanted us to stand by the sidelines if the + +court determined that rights attached in the absence of a charging document. + +This was not my recollection of what was discussed on February 10. In any event, I told him the government + +believed the court was without authority to set aside the non-prosecution agreement, even if it found a + +violation of the CVRA. Cassell said our position was that the right to consult was a right without a remedy. I said yes, in our situation involving a non-prosecution agreement. He argued that in In Re Dean the Fifth Circuit found that the plea agreement could be set aside. I told Cassell that a plea agreement comes before + +We then began talking about information the victims wanted from the government. Cassell tried to analogize the victims as criminal defendants, entitled to information helpful to their cases, just like a defendant is entitled + +to exculpatory and impeachment information. I disagreed. The right of a criminal defendant to obtain + +exculpatory and impeachment information is based on the due process clause, which does not apply to our civil + +litigation. + +Cassell then suggested we should try to cooperate, and provide helpful information in our possession. When we told him we were not obligated to do that, Edwards asked if it would be alright to address their inquiries directly to the United States Attorney. I told him they were free to do so, as the United States Attorney was a + +public official. I expect you will be receiving a letter soon seeking access and disclosure of information + +pertaining to C.W. and T.M. + +Edwards said he would be sending us a draft statement of facts and their legal memorandum in the next few days. Cassell again mentioned the letters written by and others, expressing the view that the CVRA applied to the victims. I told them that such factual admissions did not create a legal duty, where one does not otherwise exist. If we had written a hundred letters stating no duty existed without a + +charging document, I don't think the victims would be voluntarily dismissing their case. + +While Cassell denied they were seeking to make our office look bad, he also said he believed it relevant that the court know about what was going on between the U.S. Attorney's Office and Epstein's attorneys, as well as the correspondence between the FBI and this Office, telling the victims of their rights under the CVRA. In previous phone conferences, he has suggested this office engaged in duplicity by telling victims they had rights under the + +CVRA, but negotiating the non-prosecution agreement without consulting with them. + +From: Sent: To: Subject: + +Nasty, huh? + +Original Message From: csamoff [mailto: + +Sent: TuestS March 01, 2011 4:02 PM + +To: 'MI= (USAFLS) + +Subject: Re: hypothetical question + +(USAFLS) < > + +Tuesday, March 01, 2011 4:08 PM + +(USAFLS); + +FW: hypothetical question + +(USAFLS) + +Yes this is a great inconvenience. Odd too that a practising lawyer cannot comment on a hypothetical case. + +Forgive me, I thought moot court was exactly this- to learn the law through simulated court proceedings. + +In the meantime, do you know a prosecutor in Fla who would speak to me who has nothing to do with Epstein case- since + +this is obviously your concern- who would answer this hypothetical question? + +Thank you, Conchita + +Original Message----- + +From: To: + +Hi Conchita. + +I received your voicemail and explained your conversation with her to me. Unfortunately, I cannot help you either. My answer is the same as hers: As prosecutors, we cannot give you a legal opinion on whether a hypothetical set of facts might or might not constitute a federal crime. + +Sorry for the inconvenience. + +Take care, + +----Original Message From: csamoff [mailto: + +Sent: TuescS March 01, 2011 2:09 PM + +To: Mg (USAFLS) + +Subject: + +Hello + +Left message on your VB. Spoke to this morning who said + +she would have you call me. + +Have a legal question re prosecution of adult sex offenders in Fla. + +If adult (pimp) pays a minor, to have sex with another adult (say transaction was negotiated in Fla or other state in the US), and minor has sex with another adult (not pimp) outside the US, is that considered + +a crime in Fla and the US? + +Secondly, can "pimp" be prosecuted in fia or other US state for paying + +minor to have sex with other adult outside US? + +n Tha + +Sent from my Verizon Wireless BlackBerry + +Sent from my Verizon Wireless BlackBerry + +From: (USAFLS) Sent: Tuesday, March 01, 2011 3:43 PM + +To: (USAFLS) Subject: RE: hypothetical question + +Wouldn't all of this have been easier if we had just prosecuted Epstein in the first place? + +Assistant U.S. Attorne + +Fax + +To: + +Cc: (USAFLS) Subject: RE: hypothetical question + +Hi Conchita. + +I received your voicemail and explained your conversation with her to me. Unfortunately, I cannot help you either. My answer is the same as hers: As prosecutors, we cannot give you a legal opinion on whether a hypothetical set of facts + +might or might not constitute a federal crime. Sorry for the inconvenience. + +Take care, + +Original Message-- From: csarnoff (mailta: + +Sent: TuescS March 01, 2011 2:09 PM + +To: IM, MMI (USAFLS) + +Subject: + +Hello + +Left message on your VB. Spoke to this morning who said she would have you call me. + +Have a legal question re prosecution of adult sex offenders in Fla. + +If adult (pimp) pays a minor, to have sex with another adult (say transaction was negotiated in Fla or other state in the US), + +and minor has sex with another adult (not pimp) outside the US, is that considered a crime in Fla and the US? + +Secondly, can "pimp" be prosecuted in fla or other US state for paying minor to have sex with other adult outside US? + +n Tha + +Sent from my Verizon Wireless BlackBerry + +From: (USAFLS) Sent: Tuesday, March 01, 2011 10:02 AM + +To: (USAFLS) + +Cc: (USAFLS); (USAFLS) + +Subject: RE: Press Inquiries re Jeffrey Epstein Case + +Attachments: jeffrey-epstein-introduc.pdf; Daily Mail Article.pdf + +al Hi and Annette — I just left a long involved voicemail because I received two calls from + +also about this story, asking for my opinion about what was reported in the Daily Mail story. I told Conchita that I cannot answer her questions and that she should be posing those uestions to the attorney for her + +newspaper, not to me. I told Conchita that you would call her. Her number is + +Anyhow, here is a copy of the Daily Mail story and a copy of a story that appeared in today's Palm Beach Daily + +News that just reiterates the Daily Mail story. + +In terms of what you can say, I would run it past and MI but just that the prior administration decided to defer prosecution in favor of prosecution by the State, which had originally opened the case. One important point of fact, which probably cannot be disclosed, is that refused to cooperate with the FBI + + + +Sent: Monday, February 28, 2011 1:35 PM To: . (USAFLS) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +Sure - who is by the way? + +From: (USAFLS) Sent: Monda , Februa 28, 2011 1:29 PM + +To: (USAFLS); (USAFLS) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +Maybe after we finish with DOJ, the four of us (you two and and I) can stay on and discuss a bit further? After my discussion with the person at Appellate and some case law research, I have some + +ideas. + +Assistant U.S. Attorney + +Fax + +From: (USAFLS) Sent: Monda , February 28, 2011 1:25 PM + +To: (USAFLS); (USAFLS) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.FIa.) + +Absolutely. I agree with you. Thanks. + +From: (USAFLS) + +Sent: Monda , Februa 28, 2011 1:24 PM + +To: (USAFLS); (USAFLS) Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.FIa.) + +I really don't think we can do what Cassell asks, to stand by and do nothing. Can I represent that as + +our office's position? + +From: (USAFLS) Sent: Monda , February 28, 2011 1:21 PM + +To: (USAFLS); (USAFLS) + +Subject: FW: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +I'm going to call in but really only to listen. Thanks. + +From: (USAEO) + +Sent: Monda , February 28, 2011 1:12 PM + +To: (USAEO); . (SMO); + +(USAFLS + +Cc: (USAFLS); . (USAFLS) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.FIa.) + +. (USAFLS); + +From: (USAEO) + +Sent: Monda February 28, 2011 12:29 PM + +To: . (SMO); . (USAFLS); + +Cc: (USAFLS); . (USAFLS) + +Subject: Re: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +Let's say 1:30. We will get a call in #. Thanks. + +From: + +Sent: Monda + +To: + +(SMO) Februa 28, 2011 12:27 PM + +. (USAFLS); (USAEO); + +Cc: (USAFLS); (USAFLS) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +Me too. + +From: (USAFLS) Sent: Monda , February 28, 2011 12:25 PM + +To: (USAEO); (USAEO); - + +(USAFLS + +Cc: (USAFLS); . (USAFLS) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +Either of those times works for me. Thank you. + +Assistant U.S. Attorney + +Fax + +(USAEO); + +(USAEO); + +. (SMO); + +Cc: (USAFLS); . (USAFLS) + +Subject: Re: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +I apologize, but we didn't schedule since we hadn't heard regarding everyone's availability. Does 1:00 + +or 1:30 work? + +From: (USAFLS) Sent: Monda Februa 28, 2011 11:54 AM + +To: USAEO); + +(USAFLS); + +SMO); MilaUSAFLS) + +Cc: . (USAFLS); (USAEO) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +Are we speaking at noon? What is the call-in number? + +Thank you. + +Assistant U.S. Attorney + +Fax + +(USAEO) + +February 28, 2011 9:08 AM + +SMO); USAFLS + +. (USAFLS); (USAFLS); + +(USAEO) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +. (USAFLS); + +If you mean can I get a conference call line, yes, I can. + +(SMO) February 28, 2011 9:07 AM + +USAEO); USAFLS + +. (USAFLS); (USAFLS); . (USAFLS); + +(USAEO) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +: Can you set up a call? I have a 10:00 meeting (30 minutes), and an as yet unscheduled obligation to assist in briefing the AG for his testimony on the Hill tomorrow. Sometime between noon + +and 1 is likely to be best for me. + +(USAEO) + +February 28, 2011 8:43 AM + +SMO); USAFLS + +. (USAFLS); (USAFLS); + +(USAEO) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +I agree, as well. I am available anytime between noon and 3:00 today. + +From: (SMO) + +Sent: Saturda February 26, 2011 4:19 PM + +To: (USAFLS); + +Cc: . (USAFLS); (USAFLS); Subject: Re: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +USAEO + +I agree completely. Let's try and talk Monday, with on the phone if possible. + +From: + +Sent: Saturda + +To: Cc: + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +(USAFLS) + +February 26, 2011 04:08 PM + +SMO); + +. (USAFLS); + +USAEO + +. (USAFLS); + +. (USAFLS) + +(USAFLS); . (USAFLS) + +Mr. + +I'm looking for the appropriate officials in the Department with programmatic responsibility for the + +CVRA, so that we may obtain guidance on our litigating position. What Cassell wants the + +government to do is abdicate its role in defending its actions. If the DOJ's position is that no rights attach until a charging instrument is filed, then we should vigorously defend that position. Our office is + +most reluctant to do what Cassell asks, since negotiating the non-prosecution agreement was clearly within the prerogatives granted to the Executive Branch. Whether the bargain struck with Epstein + +was wise or not should not be the issue. + +I will be in the office all day Monday. Thanks for your assistance. + +From: (SMO) + +Sent: Saturda February 26, 2011 3:40 PM + +To: (USAFLS); + +Cc: . (USAFLS); (USAFLS) Subject: Re: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +USAEO + +Thanks. Perhaps we should try and find a time to talk on Monday. This scenario raises a variety of policy issues that extend well beyond the question of "when do the rights attach." Frankly, I don't think the court should even reach that question given the posture of the case as you describe it. + +From: (USAFLS) + +Sent: Saturda February 26, 2011 02:23 PM + +To: SMO); USAEO + +Cc: . (USAFLS); (USAFLS) Subject: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +Ms. and Mr. + +Our office is currently litigating a Crime Victims Rights Act (CVRA) lawsuit filed by Jane Does 1 and 2, who were victims of sexual abuse by Jeffrey Epstein, a multi-millionaire investor living in Palm Beach, Florida. Jane Does 1 and 2 v. United States Case No. 08-80736-CIV-MARRA (S.D.Fla.). We are seeking your advice and guidance on a proposal from the victims' attorneys, that the government take + +no position on whether the CVRA granted rights to the victims, when the U.S. Attorney's Office + +negotiated a non-prosecution agreement with Epstein. + +In 2006, the Palm Beach Police Department began investigating allegations that Jeffrey Epstein was enticing underage girls into prostitution. Epstein was alleged to have paid underage girls to provide him with massages, while the young girls were unclothed. The case was referred to the FBI and U.S. Attorney's Office, and the FBI began its own investigation. Epstein hired a number of highlypaid attorneys, including Alan Dershowitz and Kenneth Starr, to attempt to stave off criminal charges. + +Fax + +From: (USAFLS) Sent: Monda , February 28, 2011 1:25 PM + +To: (USAFLS); (USAFLS) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.FIa.) + +Absolutely. I agree with you. Thanks. + +From: (USAFLS) + +Sent: Monda , Februa 28, 2011 1:24 PM + +To: (USAFLS); (USAFLS) Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.FIa.) + +I really don't think we can do what Cassell asks, to stand by and do nothing. Can I represent that as + +our office's position? + +From: (USAFLS) Sent: Monda , February 28, 2011 1:21 PM + +To: (USAFLS); (USAFLS) + +Subject: FW: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +I'm going to call in but really only to listen. Thanks. + +From: (USAEO) + +Sent: Monda , February 28, 2011 1:12 PM + +To: (USAEO); . (SMO); + +(USAFLS + +. (USAFLS); + +The call in number for 1:30 is , pass code + +From: (USAEO) + +Sent: Monda , February 28, 2011 12:29 PM + +To: . (SMO); . (USAFLS); (USAEO); + +Cc: (USAFLS); . (USAFLS) + +Subject: Re: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +Let's say 1:30. We will get a call in #. Thanks. + +From: + +Sent: Monda + +To: + +(SMO) Februa 28, 2011 12:27 PM + +. (USAFLS); (USAEO); + +Cc: (USAFLS); (USAFLS) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +Me too. + +From: (USAFLS) Sent: Monda . February 28. 2011 12:25 PM + +To: (USAEO); (USAEO); + +Cc: (USAFLS); -. (USAFLS) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +Either of those times works for me. Thank you. + +Assistant U.S. Attorney + +(USAEO); + +. (SMO); + +From: (USAEO) + +Sent: Monda Februa 28, 2011 12:25 PM + +To: . (USAFLS); (USAEO); + +Cc: (USAFLS); . (USAFLS) + +Subject: Re: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +. (SMO); + +I apologize, but we didn't schedule since we hadn't heard regarding everyone's availability. Does 1:00 + +or 1:30 work? + +From: . (USAFLS) Sent: Monda Februar 28, 2011 11:54 AM + +To: USAEO); + +(USAFLS); + +SMO); MilaUSAFLS) + +Cc: . (USAFLS); (USAEO) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +Are we speaking at noon? What is the call-in number? + +Thank you. + +Assistant U.S. Attorney + +Fax + +(USAEO) + +February 28, 2011 9:08 AM + +SMO); USAFLS + +. (USAFLS); (USAFLS);U + +(USAEO) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +. (USAFLS); + +(SMO) February 28, 2011 9:07 AM + +USAEO); USAFLS + +. (USAFLS); (USAFLS); + +(USAEO) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +. (USAFLS); + +: Can you set up a call? I have a 10:00 meeting (30 minutes), and an as yet unscheduled obligation to assist in briefing the AG for his testimony on the Hill tomorrow. Sometime between noon + +and 1 is likely to be best for me. + +(USAEO) + +February 28, 2011 8:43 AM + +SMO); USAFLS + +. (USAFLS); (USAFLS); + +(USAEO) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +I agree, as well. I am available anytime between noon and 3:00 today. + +From: (SMO) + +Sent: Saturda February 26, 2011 4:19 PM + +To: USAFLS ; + +Cc: . (USAFLS); (USAFLS); Subject: Re: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +USAEO + +I agree completely. Let's try and talk Monday, with on the phone if possible. + +. (USAFLS); + +. (USAFLS) + +From: (USAFLS) + +Sent: Saturda February 26, 2011 04:08 PM + +To: SMO); USAEO + +Cc: . (USAFLS); (USAFLS); . (USAFLS) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +After the new year began, Cassell inquired about the status of the OPR complaint and the recusal + +issue. + +On Thursday, February 10, 2011, Deputy Chief AUSA and I spoke with Cassell and Edwards regarding the status of the case. I told them Cassell's letter request for an investigation of the Non-Prosecution Agreement had been referred to OPR, and OPR had requested various documents from our office. I also told them the EOUSA General Counsel's office advised that our office could go ahead and represent the United States in the CVRA lawsuit. I suggested that the parties were ready to move forward with filing documents with the court so it could resolve this + +case. + +I asked whether it might be useful to engage in mediation in an attempt to resolve the case. Cassell told us they wanted the Non-Prosecution Agreement to be set aside. I told him that was not likely to happen. Cassell then suggested that the United States Government should step aside and allow them to "go after" Epstein to get the agreement set aside. I asked him how he expected that would + +be done, since the only parties to the Non-Prosecution Agreement were Epstein and the + +Government. Cassell said they would file their summary judgment motion, and the government would take no position on their motion. Presumably, Epstein would either intervene, or be brought in as a necessary party, and defend the Non-Prosecution Agreement. I told them this would have to be + +approved by the U.S. Attorney and Main Justice. + +I have serious misgivings about not defending the Executive Branch's prerogative to engage in a Non- + +Prosecution Agreement, free from supervision or oversight by the judiciary. If we stand by the sidelines, Cassell will be arguing the Government was obligated to consult with the victims, and because we failed to do so, the agreement is a nullity. Whatever we may think of the Agreement, it was the prerogative of the U.S. Attorney's Office to enter into it with Epstein, and we should be willing to defend what we did. The DOJ's position is that the rights in the CVRA do not attach until there is a federal court proceeding. Since Epstein was never charged in federal court, we were not obligated + +to consult with the victims before entering into the Non-Prosecution Agreement. + +We wanted to seek your views on Cassell's suggestion before we responded to him. We are currently + +scheduled to have a conference call with Cassell and Edwards on Tuesday, March 1. I can be + +reached at . Thanks. + +• + +From: (USAFLS) 'c > + +Sent: Monday, February 28, 2011 1:55 PM + +To: . (USAFLS); (USAFLS) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +Probably a conference call is just as easy. + +From: (USAFLS) Sent: Monda , Februa 28, 2011 1:54 PM + +To: (USAFLS); (USAFLS) + +Should we call the number again? Or should I just do a conf call? + +Assistant U.S. Attorney + +Fax + +From: (USAFLS) Sent: Monda , Februa 28, 2011 1:35 PM To: . (USAFLS) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +Sure - who is by the way? + +From: (USAFLS) Sent: Monda , Februa 28, 2011 1:29 PM + +To: (USAFLS); (USAFLS) + +Subject: RE: Jane Does 1 and 21 United States - CVRA Lawsuit (S.D.Fla.) + +Maybe after we finish with DOJ, the four of us (you two and and I) can stay on and discuss a bit further? After my discussion with the person at Appellate and some case law research, I have some + +ideas. + +Assistant U.S. Attorney + +From: (USAFLS) Sent: Monda , February 28, 2011 1:25 PM + +To: (USAFLS); (USAFLS) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.FIa.) + +Absolutely. I agree with you. Thanks. + +From: (USAFLS) + +Sent: Monda , Februa 28, 2011 1:24 PM + +To: (USAFLS); (USAFLS) Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.FIa.) + +I really don't think we can do what Cassell asks, to stand by and do nothing. Can I represent that as + +our office's position? + +From: (USAFLS) Sent: Monda , February 28, 2011 1:21 PM + +To: (USAFLS); (USAFLS) + +Subject: FW: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +I'm going to call in but really only to listen. Thanks. + +From: (USAEO) + +Sent: Monda , February 28, 2011 1:12 PM + +To: (USAEO); . (SMO); + +(USAFLS + +Cc: (USAFLS); . (USAFLS) + +. (USAFLS); + +The call in number for 1:30 is , pass code + +From: (USAEO) + +Sent: Monda February 28, 2011 12:29 PM + +To: . (SMO); . (USAFLS); + +Cc: (USAFLS); . (USAFLS) + +Subject: Re: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +Let's say 1:30. We will get a call in #. Thanks. + +From: (SMO) + +Sent: Monda Februa 28, 2011 12:27 PM + +To: . (USAFLS); (USAEO); + +Cc: (USAFLS); (USAFLS) + +Subject: RE: Jane Does 1 and 2I. United States - CVRA Lawsuit (S.D.Fla.) + +Me too. + +From: (USAFLS) Sent: Monda , February 28, 2011 12:25 PM + +To: (USAEO); (USAEO); - + +(USAFLS + +Cc: (USAFLS); . (USAFLS) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +Either of those times works for me. Thank you. + +Assistant U.S. Attorney + +(USAEO); + +(USAEO); + +. (SMO); + +From: (USAEO) + +Sent: Monda Februa 28, 2011 12:25 PM + +To: . (USAFLS); (USAEO); . (SMO); + +Cc: (USAFLS); . (USAFLS) + +Subject: Re: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +I apologize, but we didn't schedule since we hadn't heard regarding everyone's availability. Does 1:00 + +or 1:30 work? + +From: . (USAFLS) Sent: Monda Februar 28, 2011 11:54 AM + +To: USAEO); + +(USAFLS); + +SMO); MilaUSAFLS) + +Cc: . (USAFLS); (USAEO) + +Subject: RE: Jane Does 1 and 2I. United States - CVRA Lawsuit (S.D.Fla.) + +Are we speaking at noon? What is the call-in number? + +Thank you. + +Assistant U.S. Attorney + +Fax + +(USAEO) + +February 28, 2011 9:08 AM + +SMO); USAFLS + +. (USAFLS); (USAFLS); + +(USAEO) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +. (USAFLS); + +(SMO) February 28, 2011 9:07 AM + +USAEO); USAFLS + +. (USAFLS); (USAFLS); + +(USAEO) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +. (USAFLS); + +: Can you set up a call? I have a 10:00 meeting (30 minutes), and an as yet unscheduled obligation to assist in briefing the AG for his testimony on the Hill tomorrow. Sometime between noon + +and 1 is likely to be best for me. + +(USAEO) + +February 28, 2011 8:43 AM + +SMO); USAFLS + +. (USAFLS); (USAFLS); + +(USAEO) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +I agree, as well. I am available anytime between noon and 3:00 today. + +From: (SMO) + +Sent: Saturda February 26, 2011 4:19 PM + +To: (USAFLS); + +Cc: . (USAFLS); (USAFLS); Subject: Re: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +USAEO + +I agree completely. Let's try and talk Monday, with on the phone if possible. + +From: + +Sent: Saturda + +To: Cc: + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +(USAFLS) + +February 26, 2011 04:08 PM + +SMO); + +. (USAFLS); + +USAEO + +. (USAFLS); + +. (USAFLS) + +(USAFLS); . (USAFLS) + +Mr. + +Fax + +From: (USAFLS) Sent: Monda , Februa 28, 2011 1:35 PM To: . (USAFLS) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +Sure - who is by the way? + +From: (USAFLS) Sent: Monda , Februa 28, 2011 1:29 PM + +To: (USAFLS); (USAFLS) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +Maybe after we finish with DOJ, the four of us (you two and and I) can stay on and discuss a bit further? After my discussion with the person at Appellate and some case law research, I have some + +ideas. + +Assistant U.S. Attorney + +Fax + +From: (USAFLS) Sent: Monda , February 28, 2011 1:25 PM + +To: (USAFLS); (USAFLS) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +From: (USAFLS) + +Sent: Monda , Februa 28, 2011 1:24 PM + +To: (USAFLS); (USAFLS) Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.FIa.) + +I really don't think we can do what Cassell asks, to stand by and do nothing. Can I represent that as + +our office's position? + +From: (USAFLS) Sent: Monda , February 28, 2011 1:21 PM + +To: (USAFLS); (USAFLS) + +Subject: FW: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +I'm going to call in but really only to listen. Thanks. + +From: (USAEO) + +Sent: Monda , February 28, 2011 1:12 PM + +To: (USAEO); . (SMO); + +(USAFLS + +Cc: (USAFLS); . (USAFLS) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.FIa.) + +The call in number for 1:30 is , pass code + +From: (USAEO) + +Sent: Monda February 28, 2011 12:29 PM + +To: . (SMO); (USAFLS); + +Cc: (USAFLS); . (USAFLS) + +Subject: Re: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +. (USAFLS); + +(USAEO); + +From: (SMO) + +Sent: Monda Februar 28, 2011 12:27 PM + +To: . (USAFLS); (USAEO); + +Cc: (USAFLS); (USAFLS) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +Me too. + +From: (USAFLS) Sent: Monda , February 28, 2011 12:25 PM + +To: (USAEO); (USAEO); - + +(USAFLS + +Cc: (USAFLS); . (USAFLS) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +Either of those times works for me. Thank you. + +Assistant U.S. Attorney + +Fax + +(USAEO); + +. (SMO); + +From: (USAEO) + +Sent: Monda Februa 28, 2011 12:25 PM + +To: . (USAFLS); (USAEO); . (SMO); + +Cc: (USAFLS); . (USAFLS) + +Subject: Re: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +From: + +Sent: Monda + +To: Cc: + +Subject: RE: + +(USAFLS) + +February 28, 2011 11:54 AM + +USAEO); SMO); USAFLS) + +(USAFLS); . (USAFLS); (USAEO) + +Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +Are we speaking at noon? What is the call-in number? + +Thank you. + +Assistant U.S. Attorney + +Fax + +(USAEO) + +February 28, 2011 9:08 AM + +SMO); USAFLS + +. (USAFLS); (USAFLS); + +(USAEO) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +If you mean can I get a conference call line, yes, I can. + +(SMO) February 28, 2011 9:07 AM + +USAEO); USAFLS + +. (USAFLS); (USAFLS);U + +(USAEO) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +. (USAFLS); + +. (USAFLS); + +: Can you set up a call? I have a 10:00 meeting (30 minutes), and an as yet unscheduled obligation to assist in briefing the AG for his testimony on the Hill tomorrow. Sometime between noon + +and 1 is likely to be best for me. + +(USAEO) + +February 28, 2011 8:43 AM + +SMO); USAFLS + +. (USAFLS); (USAFLS); + +(USAEO) + +Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +I agree, as well. I am available anytime between noon and 3:00 today. + +From: (SMO) + +Sent: Saturda February 26, 2011 4:19 PM + +To: (USAFLS); + +Cc: . (USAFLS); (USAFLS); Subject: Re: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +USAEO + +I agree completely. Let's try and talk Monday, with on the phone if possible. + +From: (USAFLS) + +Sent: Saturda February 26, 2011 04:08 PM + +To: SMO); USAEO + +Cc: . (USAFLS); (USAFLS); Subject: RE: Jane Does 1 and 2 v. United States - CVRA Lawsuit (S.D.Fla.) + +Mr. + +. (USAFLS); + +. (USAFLS) + +. (USAFLS) + +I'm looking for the appropriate officials in the Department with programmatic responsibility for the + +CVRA, so that we may obtain guidance on our litigating position. What Cassell wants the + +government to do is abdicate its role in defending its actions. If the DOJ's position is that no rights attach until a charging instrument is filed, then we should vigorously defend that position. Our office is most reluctant to do what Cassell asks, since negotiating the non-prosecution agreement was clearly within the prerogatives granted to the Executive Branch. Whether the bargain struck with Epstein + +was wise or not should not be the issue. + +happen. Cassell then suggested that the United States Government should step aside and allow them to "go after" Epstein to get the agreement set aside. I asked him how he expected that would + +be done, since the only parties to the Non-Prosecution Agreement were Epstein and the + +Government. Cassell said they would file their summary judgment motion, and the government would take no position on their motion. Presumably, Epstein would either intervene, or be brought in as a necessary party, and defend the Non-Prosecution Agreement. I told them this would have to be + +approved by the U.S. Attorney and Main Justice. + +I have serious misgivings about not defending the Executive Branch's prerogative to engage in a Non- + +Prosecution Agreement, free from supervision or oversight by the judiciary. If we stand by the sidelines, Cassell will be arguing the Government was obligated to consult with the victims, and because we failed to do so, the agreement is a nullity. Whatever we may think of the Agreement, it was the prerogative of the U.S. Attorney's Office to enter into it with Epstein, and we should be willing to defend what we did. The DOJ's position is that the rights in the CVRA do not attach until there is a federal court proceeding. Since Epstein was never charged in federal court, we were not obligated + +to consult with the victims before entering into the Non-Prosecution Agreement. + +We wanted to seek your views on Cassell's suggestion before we responded to him. We are currently + +scheduled to have a conference call with Cassell and Edwards on Tuesday, March 1. I can be + +reached at . Thanks. + +• + +From: Paul Cassell < + +Sent: Monday, February 28, 2011 3:14 PM + +To: . (USAFLS); Brad Edwards Cc: (USAFLS); (USAFLS) + +Subject: RE: Jane Does v. United States - latest draft of statement of acts + +Attachments: motion-finding-violation-22411.doc + +Hi + +FYI: Here is the latest draft of our "summary judgment" motion and statement of facts. Hoping that we + +can begin narrowing down any differences on this as well. Paul + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law + +S.J. Quinney College of Law at the University of Utah + +http://www.law.utah.edu/profiles/default.asp?PersonID=578,name=Cassell,Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the + +sender by reply electronic mail and delete the original message. Thank you. + +From: (USAFLS) [mailto: Sent: Monday, February 28, 2011 12:42 PM + +To: Brad Edwards; Paul Cassell Cc: (USAFLS); + +Subject: Jane Does I United States + +Dear Brad and Paul: + +(USAFLS) + +Please let us know what time you are available to meet tomorrow or Wednesday to discuss the + +matter. I will set up a conference call. + +Thank you. + +Assistant U.S. Attorney + +Fax + +From: (USAFLS) < > + +Sent: Monday, February 28, 2011 4:40 PM To: (USAFLS) + +Cc: (USAFLS); (USAFLS); (USAFLS); + +(USAFLS) + +Subject: RE: Press Inquiries re Jeffrey Epstein Case + +From: (USAFLS) Sent: Monda February 28, 2011 3:56 PM + +To: USAFLS) + +Cc: (USAFLS); (USAFLS); (USAFLS) + +Subject: Press Inquiries re Jeffrey Epstein Case + +H i — [just got a call from a reporter for the Daily Mail, one of the Britain's main newspapers, about + +Epstein. There is a lot of hubbub over there about Epstein right now because he was recently photographed with + +Prince Andrew. + +I gave him your name and number and told him to call you. + +Assistant U.S. Attorney + +Fax + +From: Sent: To: Cc: Subject: (USAFLS) °c =' + +Monday, February 28, 2011 6:24 PM + +(USAFLS) + +(USAFLS) Re: Press Inquiries re Jeffrey Epstein Case + +Freudian slip--message not massage. LOL + +From: (USAFLS) + +Sent: Monda Februa 28, 2011 05:21 PM + +To: . (USAFLS) + +Cc: (USAFLS) + +Subject: RE: Press Inquiries re Jeffrey Epstein Case + +He just did and left massage. Can we speak to him, and what would we say? I suggest we pass, unless he just + +basic info about the charges. What do you think? + +From: (USAFLS) Sent: Monda February 28, 2011 3:56 PM + +To: USAFLS) + +Epstein. There is a lot of hubbub over there about Epstein right now because he was recently photographed with + +Prince + +I gave him your name and number and told him to call you. + +Assistant U.S. Attorney + +Fax + +From: (USAFLS)< > + +Sent: Monday, February 28, 2011 5:21 PM To: (USAFLS) Cc: (USAFLS) + +Subject: RE: Press Inquiries re Jeffrey Epstein Case + +He just did and left massage. Can we speak to him, and what would we say? I suggest we pass, unless he just + +basic info about the charges. What do you think? + +From: (USAFLS) Sent: Monda February 28, 2011 3:56 PM + +To: USAFLS) + +Cc: (USAFLS); (USAFLS); (USAFLS) + +Subject: Press Inquiries re Jeffrey Epstein Case + +Hi — I just got a call from a reporter for the Daily Mail, one of the Britain's main newspapers, about + +Epstein. There is a lot of hubbub over there about Epstein right now because he was recently photographed with + +Prince Andrew. + +I gave him your name and number and told him to call you. + +Assistant U.S. Attorney + +Fax + +Subject: Epstein/Conf. Call Location: Ofc. + +Start: Thu 3/10/2011 3:00 PM End: Thu 3/10/2011 3:30 PM + +Show Time As: Tentative + +Recurrence: (none) + +Organizer: -. (USAFLS) + +Required Attendees: (USAFLS); (USAFLS); (USAFLS); + +. (USAFLS) + +From: (USAFLS) + +Sent: Monday, March 07, 2011 6:53 PM + +To: (USAFLS) + +Can you please set up a meeting/conference call re: Epstein for Thursday morning with me, + +and 7 Thanks. + +Subject: Epstein/Conf. Call Location: Ofc. + +Start: Thu 3/10/2011 10:00 AM End: Thu 3/10/2011 10:30 AM + +Show Time As: Tentative + +Recurrence: (none) + +Meeting Status: Not yet responded + +Organizer: (USAFLS) + +Required Attendees: (USAFLS); (USAFLS); (USAFLS); + +. (USAFLS) + +When: Thursday, March 10, 2011 10:00 AM-10:30 AM (GMT-05:00) Eastern Time (US & Canada). + +Where: Ofc. + +Note: The GMT offset above does not reflect daylight saving time adjustments. + +Sent: Monday, March 07, 2011 6:53 PM + +To: (USAFLS) + +Can you please set up a meeting/conference call re: Epstein for Thursday morning with me, + +and Thanks. + +Subject: Epstein/Conf. Call Location: Ofc. + +Start: End: + +Thu 3/10/2011 3:00 PM Thu 3/10/2011 3:30 PM + +Recurrence: (none) + +Meeting Status: Meeting organizer + +Organizer: -. (USAFLS) + +Required Attendees: (USAFLS); (USAFLS); (USAFLS); + +. (USAFLS) + +From: (USAFLS) + +Sent: Monday, March 07, 2011 6:53 PM + +To: (USAFLS) + +Can you please set up a meeting/conference call re: Epstein for Thursday morning with me, + +and Thanks. + +From: (USAFLS) < Sent: Monday, March 07, 2011 6:03 PM + +To: (USAFLS); (USAFLS); =, (USAFLS); + +. (USAFLS); (USAFLS) + +Subject: RE: Jeffrey Epstein + +Just spoke to the producer. I told her it was against our policy to confirm or deny the existence of an + +investigation. + +From: (USAFLS) Sent: Monda March 07, 2011 6:02 PM + +To: USAFLS . (USAFLS); (USAFLS); + +Thanks. Please make sure is looped in on these e-mails as he is handling a civil matter + +with Epstein. Thanks. + +From: (USAFLS) Sent: Monda March 07, 2011 5:55 PM + +To: . (USAFLS); (USAFLS); (USAFLS); + +(USAFLS) + +Subject: RE: Jeffrey Epstein + +Today Show just called. No joke. They are doing a story how the case was reopened. I won't confirm + +anything. + +• + +From: (USAFLS) Sent: Monda March 07, 2011 5:38 PM + +To: .(USAFLS) Subject: RE: Jeffrey Epstein + +How many more incorrect statements can be printed99??? It is like one feeds off another that feeds + +off another. That woman at the Daily Beast is just making things up at this point. + +What is SMO, by the way? + +Assistant U.S. Attorney + +Fax + +From: (USAFLS) Sent: Monda March 07, 2011 5:28 PM To: . (USAFLS) + +Subject: FW: Jeffrey Epstein + +See below. Is this your case? Obviously we will make no comment. + +From: (SMO) + +Sent: Monda March 07, 2011 5:25 PM + +To: .(USAFLS) Subject: FW: Jeffrey Epstein + +I believe is out. See below. + +From: (SMO) + +Sent: Monc March 07, 2011 5:18 PM + +To: , (USAFLS) Subject: Jeffrey Epstein + +, Is your office handling this matter? A WSJ reporter is trying to get more information. + +The Justice Department is investigating Jeffrey Epstein for child trafficking, The Daily Beast has learned—and has widened the scope of its probe to include a famous modeling agency. + +Hedge-fund manager Jeffrey Epstein completed his sentence for soliciting prostitution with a minor last + +week. But it appears his problems may not be over. Now The Daily Beast has learned that: + +• Federal investigators continue to investigate Epstein's activities, to see whether there is evidence of child trafficking—a far more serious charge than the two in his non-prosecution agreement, the arrangement between Epstein and the Department of Justice allowing him to + +plead guilty to lower-level state crimes. Trafficking can carry a 20-year sentence. + +• The FBI is also investigating Epstein's friend Jean Luc Brunel, whose MC2 modeling agency appears to have been a source of girls from overseas who ended up on Epstein's private jets. + +Under the concept of double jeopardy, Epstein can no longer be prosecuted for any of the charges covered by his non-prosecution agreement, in which he agreed to serve a short term of incarceration, fund the civil suits of named victims, and register as a sex offender. The victims who accepted cash settlements in these civil suits agreed not to testify against him or speak publicly about the case. + +From: (USAFLS) Sent: Monday, March 07, 2011 6:34 PM To: (USAFLS) + +Cc: (USAFLS) + +Subject: FW: Motion to Make Our Pleading Available to the Public - Government Position + +FYI — Maybe we can discuss tomorrow? + +Assistant U.S. Attorney + +Fax + +From: Paul Cassell [mailto: + +Sent: Monda , March 07, 2011 5:33 PM + +To: (USAFLS); (USAFLS) + +Cc: Brad Edwards + +Subject: Motion to Make Our Pleading Available to the Public - Government Position + +Dear and + +We are writing to inquire about the government's position on a motion that we will be filing on March 18 along with our "summary judgment" motion. As you know, the summary judgment motion will + +contain quotations from e-mails that are under the magistrate judge's order requiring prior notice to the court before they are disclosed. Accordingly, on March 18, we will be filing a full, unredacted summary judgment motion under seal with Judge Marra and, for the public PACER file, a summary judgment + +motion with quotations from the e-mails redacted. + +We will be filing simultaneously a motion for with the court for unsealing of the unredacted motion. We will provide (at least) three ground for unsealing. First, the confidentiality order was only based on an agreement to give advance notice to Epstein before using materials. Once advance notice has been given, there is no basis for confidentiality. Second, there is truly world-wide interest in the handling of the Epstein prosecution, and so our pleading should not remain under seal — instead the public should have access to it so that they can assess how this case was handled. Third, keeping the pleading under seal complicates the ability of Jane Does' attorneys to consult with victims' rights specialist + +about how best to proceed in the case. + +We are writing to determine the Government's position on our motion to unseal the redacted pleading so that we can include that position in our motion. We hope that you will not oppose the motion, which might produce the need for further litigation. As you know, Judge Marra has promptly unsealed other + +pleadings in this matter when the Government tried to object. + +Sincerely, + +Paul Cassell + +Co-Counsel for Jane Doe #1 and Jane Doe #2 + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law + +S.J. Quinney College of Law at the University of Utah + +Voice: + +Fax: + +Email: + +http://www.law.utah.edu/profiles/defaultasp?PersonID=57&name=Cassell,Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the + +sender by reply electronic mail and delete the original message. Thank you. + +Hello. + +Thanks for your email. That is always the best way to contact me. + +It is against DOJ policy for us to either confirm or deny the existence of any investigation. + +Thanks for checking with us. + +From: Owen Bowcott [mailto:owen.bowcott@guardian.co.uk] + +Sent: Tuesca March 08, 2011 12:23 PM + +To: (USAFLS) + +Subject: request for information + +Good Morning, + +I'm afraid I have been unable to reach you directly by telephone but I understand that you are the public affairs official for the United States Attorney, southern district of Florida. I was referred to you by + +the FBI regional office. + +I am a journalist on The Guardian newspaper in London and am trying to establish whether a fresh investigation has been authorised or launched into allegations involving Jeffrey Epstein. He was + +convicted in 2008 of procuring young girls for prostitution. + +If you could confirm that, as has been reported, the FBI has launched an inquiry into the affair, I + +would be very grateful. + +Many Thanks, + +Owen Bowcott, + +Senior Reporter, The Guardian, + +This e-mail and all attachments are confidential and may also be privileged. If you are not the named recipient, please notify the sender and delete the e-mail and all attachments immediately. Do not disclose the contents to another person. You may not use the information for any purpose, or store, or copy, it in any way. + +Guardian News a Media Limited is not liable for any computer viruses or other material transmitted with or as part of this + +e-mail. You should employ virus checking software. + +Guardian News 6 Media Limited + +A member of Guardian Media Group plc + +Registered Office + +Registered in England Number 908396 + +From: (USAFLS) Sent: Tuesday, March 08, 2011 2:08 PM + +To: (USAFLS); (USAFLS); (USAFLS); + +(USAFLS) + +Cc: (USAFLS) Subject: RE: Epstein/Conf. Call + +I have a change of plea at 9:30 and then the Health Care Fraud Task Force meeting at 10:00. + +Could we start at 11:30? + +Assistant U.S. Attorney + +Fax + +Ori inal A ointment + +From: (USAFLS) On Behalf Of (USAFLS) + +Sent: Tuesday, March 08, 2011 8:56 AM + +To: I (USAFLS); (USAFLS); + +(USAFLS); . (USAFLS) + +Sent: Monday, March 07, 2011 6:53 PM + +To: (USAFLS) + +Can you please set up a meeting/conference call re: Epstein for Thursday morning with me, + +and 2 Thanks. + +From: (USAFLS) ‹ > + +Sent: Thursday, March 17, 2011 8:21 PM + +To: (USAFLS); (USAFLS); + +(USAFLS); (USAFLS) + +Subject: Fw: Call from Newsweek + +Sorry. Let me try this again. + +(USAFLS); + +Can and I have some of your time tomorrow? Preferably in the morning. I think we need to address this. + +Ono Sgir - + +From: (USAFLS) Sent: Thursda , March 17, 2011 07:54 PM + +To: . (USAFLS); (USAFLS) + +Subject: Fw: Call from Newsweek + +Sorry it keeps getting misdirected + +Ori , iriMIAessag - + +From: (USAFLS) Sent: Thursda , March 17, 2011 07:52 PM To: USAFLS ; + +; (USAFLS) + +Cc: (USAFLS) Subject: Re: Call from Newsweek < E>; 'eis@miamidade.gov' + +Can and I have some of your time tomorrow? Preferably in the morning. I think we need to address this. + +From: (USAFLS) Sent: Thursda , March 17, 2011 06:32 PM To: . (USAFLS) Subject: Re: Call from Newsweek + +I am wading through some of it now. + +---- Or:Vat + +From: (USAFLS) Sent: Thursda , March 17, 2011 06:31 PM To: (USAFLS) Subject: Re: Call from Newsweek + +Sent: Thursda March 17, 2011 06:30 PM To: (USAFLS) Subject: RE: Call from Newsweek + +BTW, do we know exactly which e-mails/correspondence Cassel obtained from Epstein's counsel in the civil litigation? + +Ori inal Messa e + +From: . (USAFLS) Sent: Thursda March 17, 2011 6:17 PM To: (USAFLS) Subject: Re: Call from Newsweek + +Thx. Sending from bberry + +Original Message From:•(USAFLS) + +Sent: Thursda , March 17, 2011 06:15 PM To: . (USAFLS) Subject: RE: Call from Newsweek + +Thanks - BTW I forwarded to and I think you used the old e-mail addresses. + +F + +Original Message + +rom: . (USAFLS) Sent: Thursda , March 17, 2011 6:14 PM + +To: USAFLS + +Cc: (USAFLS); (USAFLS); (USAFLS); + +'eis@miamidade.gov + +Subject: Call from Newsweek + +Hi Received a voicemail from Newsweek (which now includes ) while I was at the doctor's office + +from Lee Akin (sp?) And Samoff saying they wanted comment from me on a letter they received on the Epstein prosecution. My guess is it is either Cassell's letter or response thereto. They are going to print tomorrow. + +From: Paul Cassell ‹ > Sent: Thursday, March 17, 2011 8:41 PM + +To: (USAFLS) + +Cc: (USAFLS); Brad Edwards Subject: RE: Government's Position on Page Limits + +Dear + +1. Thank you for the information sent today. + +2. What is the Government's position on the page limits applicable to our "summary judgment" pleading — do you believe we are under the civil rules? Or under the criminal rules? Do you believe that we need to file a separate motion for a roughly 35 page pleading with roughly 19 pages of facts? + +If so, what is your position on such a motion? + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law + +S.J. Quinney College of Law at the University of Utah + +Voice: + +Fax: + +Email: + +http://www.law.utah.edu/profiles/defaultasp?PersonID=57&name=Cassell,Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the + +sender by reply electronic mail and delete the original message. Thank you. + +From: (USAFLS) [mailto + +Sent: Thursday, March 17, 2011 10:56 AM + +To: Paul Cassell + +Cc: . (USAFLS); Brad Edwards + +Subject: RE: Government's Position on Several Pending Issues? Still Waiting for Answer + +Paul, + +1. Yesterday, I provided you with the name and phone number for , OPR Acting + +Associate Counsel, who received your December 10, 2010 letter to Mir. asking for an + +investigation of the Jeffrey Epstein prosecution. + +2. The government will not be making initial disclosures to plaintiffs, because we do not believe + +Fed.R.Civ.P. 26 applies to this matter. + +3. The CVRA applies to the criminal case which has been filed in district court, where an individual is deemed to be a "victim," not any civil litigation which may be initiated to enforce those claimed rights. We do not believe there is any ht to in this case. Moreover, we do not believe that whatever Kenneth Starr or may have said to this office, or what this office said to Kenneth Starr or Lilly Ann , has any bearing on whether a duty existed under 18 U.S.C. 3771(a) to consult with plaintiffs prior to entering into a non-prosecution agreement, where no charges were filed in the district court. We will respond to your motion seeking access to this information. + +4. As I understand the Magistrate Judge's order in Jane Doe No. 2 v. Jeffrey Epstein (D.E. 226), you must give notice to Epstein, prior to making certain correspondence public by either filing the correspondence in a court file, attaching it to a deposition, releasing it to the media, or publically + +disseminating it in any other fashion. D.E. 226 at 4. Presumably, Epstein will raise any objections he + +believes are appropriate, and the court will resolve the matter. + +The U.S. Attorney's Office has no independent objection to the filing of "an unsealed, unredacted pleading reciting the U.S. Attorney's correspondence." In stating that the U.S. Attorney's Office has no independent objections, we wish to make clear that we are not, and cannot, relieve the plaintiffs of their obligation to comply with the Magistrate Judge's order by giving the appropriate notice to Epstein + +(D.E. 226). Thank you. + +From: Paul Cassell [mailto: + +Sent: Tuesda , March 15, 2011 7:21 PM + +To: USAFLS + +Cc: . (USAFLS); Brad Edwards + +Subject: RE: Government's Position on Several Pending Issues? Still Waiting for Answer + +Dear + +Brad and I have received Mr. letter of today. We are deeply disappointed. We will file our + +court pleadings on Friday. + +Mr. - again. letter still leaves unanswered a number of questions, which I am writing to raise with you - + +1. You still have not provided, as you promised you would, the name of the person coordinating the OPR investigation. As a result we have not been able to obtain any information about the status of the + +investigation. Just to be clear, we intend to include in our filing information that OPR has begun an investigation and to include the information that we currently have about — we assume + +that making that information public will not compromise OPR's work. + +2. We will be making initial disclosures to you under the Federal Rules of Civil Procedure shortly. We have not heard back from you on whether you will be making parallel disclosures. Accordingly, we understand your position to be that you are not obligated to provide to us any documents under Rule + +26. + +3. We understand your position to be that, despite the "best efforts" clause in the CVRA and your obligation to treat victims with fairness, you can withhold evidence from the victims that will help them prove CVRA violations. For example, we understand you to take the position that you can withhold the other half of the U.S. Attorney's correspondence, correspondence between the Department and Ken Starr and Lillian on behalf of Epstein, and information about role in the Epstein case. In short, we understand you to be asserting a blanket position that you can withhold information that will help prove the victims' CVRA case. If this is incorrect, please advise us promptly. If we have misunderstood you and you are willing to provide us relevant information, we will promptly provide you with a list of such information. If we have understood you correctly, we will be filing a motion with the Court shortly to block the Justice Department from suppressing such highly relevant + +information. + +4. You still have not given us your position on the victims' motion to file an unsealed, unredacted pleading reciting the U.S. Attorney's correspondence. What is your position on that motion: We have been asking for your position on this motion for some time now. If we have not heard back from you by c.o.b. Wednesday, March 16, 2011, we will include in our pleadings the following statement: "The Justice Department attorneys handling this case have been contacted several times for their position + +on this issue but have refused to respond to give their position." + +Thanks you in advance for your assistance. Sincerely, Paul Cassell, Co-Counsel for Jane Doe + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law + +S.J. Quinney College of Law at the University of Utah + +Voice: + +Fax: + +Email: + +http://www.law.utah.edu/profiles/defaultasp?PersonID=57&name=Cassell,Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the + +sender by reply electronic mail and delete the original message. Thank you. + +From: (USAFLS) ‹ > + +Sent: Thursday, March 17, 2011 7:54 PM + +To: (USAFLS); (USAFLS) + +Subject: Fw: Call from Newsweek + +Sorry it keeps getting misdirected + +Ori inal Messa e + +From: . (USAFLS) Sent: Thursda March 17, 2011 07:52 PM To: USAFLS + +; (USAFLS) + +Cc: (USAFLS) Subject: Re: Call from Newsweek ; 'eis@miamidade.gov' + +Can and I have some of your time tomorrow? Preferably in the morning. I think we need to address this. + +From: • (USAFLS) Sent: Thursda , March 17, 2011 06:32 PM To: . (USAFLS) Subject: Re: Call from Newsweek + +I am wading through some of it now. + +---- Cris + +From: (USAFLS) Sent Thursda , March 17, 2011 06:31 PM To: (USAFLS) Subject: Re: Call from Newsweek + +No + +OrLigirt + +From: • (USAFLS) Sent: Thursda , March 17, 2011 06:30 PM To: . (USAFLS) Subject: RE: Call from Newsweek + +BTW, do we know exactly which e-mails/correspondence Cassel obtained from Epstein's counsel in the civil litigation? + +----Ori inal Messa e--- + +From: . (USAFLS) Sent: Thursda , March 17, 2011 6:17 PM To: (USAFLS) Subject: Re: Call from Newsweek + +Sent: Thursda March 17, 2011 06:15 PM To: (USAFLS) Subject: RE: Call from Newsweek + +Thanks - BTW I forwarded to I= and I think you used the old e-mail addresses. + +---Ori inal Mess e-- + +From: . (USAFLS) Sent: Thursda , March 17, 2011 6:14 PM + +To: USAFLS + +Cc: (USAFLS); (USAFLS); (USAFLS); + +'eis@miamidade.gov' + +Subject: Call from Newsweek + +Hi from Received a voicemail from Newsweek (which now includes ) while I was at the doctor's office + +Akin (sp?) And Samoff saying they wanted comment from me on a letter they received on the Epstein + +prosecution. My guess is it is either Cassell's letter or response thereto. They are going to print tomorrow. + +From: (USAFLS) 'c > + +Sent: Thursday, March 17, 2011 6:33 PM To: . (USAFLS) + +Subject: Re: Call from Newsweek + +I am wading through some of it now. + +Ori inal Messa e + +From: . (USAFLS) Sent: Thursda , March 17, 2011 06:31 PM To: (USAFLS) Subject: Re: Call from Newsweek + +No + +Ori inal Messa e + +From: (USAFLS) Sent: Thursda , March 17, 2011 06:30 PM To: .(USAFLS) Subject: RE: Call from Newsweek + +BTW, do we know exactly which e-mails/correspondence Cassel obtained from Epstein's counsel in the civil litigation? + +Ori inal Mess e-- + +From: . (USAFLS) Sent: Thursda , March 17, 2011 6:17 PM To: (USAFLS) Subject: Re: Call from Newsweek + +Thx. Sending from bberry + +inal te — From: (USAFLS) Sent: Thursda , March 17, 2011 06:15 PM To: .(USAFLS) Subject: RE: Call from Newsweek + +----Ori inal Messa e— + +From: . (USAFLS) Sent: Thursda , March 17, 2011 6:14 PM + +To: USAFLS + +Cc: (USAFLS); (USAFLS); (USAFLS); + +'eis@miamidade.gov' + +Subject: Call from Newsweek + +Hi . Received a voicemail from Newsweek (which now includes Conchita Sarnoff) while I was at the doctor's office + +from Akin (sp?) And Samoff saying they wanted comment from me on a letter they received on the Epstein prosecution. My guess is it is either Cassell's letter or response thereto. They are going to print tomorrow. + +From: (USAFLS) ). + +Sent: Thursday, March 17, 2011 6:32 PM To: (USAFLS) Subject: Re: Call from Newsweek + +No + +From: (USAFLS) Sent: Thursda , March 17, 2011 06:30 PM To: . (USAFLS) Subject: RE: Call from Newsweek + +BTW, do we know exactly which e-mails/correspondence Cassel obtained from Epstein's counsel in the civil litigation? + +Ori inal Messa e--- + +From. . (USAFLS) Sent: Thursda , March 17, 2011 6:17 PM To: (USAFLS) Subject: Re: Call from Newsweek + +Thx. Sending from bberry + +Ori inal Messa e + +From: (USAFLS) Sent: Thursda , March 17, 2011 06:15 PM To: . (USAFLS) Subject: RE: Call from Newsweek + +Thanks - BTW I forwarded to I= and • - I think you used the old e-mail addresses. + +----Ori inal Messa e--- + +From: . (USAFLS) Sent: Thursda , March 17, 2011 6:14 PM + +To: USAFLS + +Cc: (USAFLS); (USAFLS); (USAFLS); + +'eis@miamidade.gov' + +Subject: Call from Newsweek + +from Lee Akin (sp?) And Samoff saying they wanted comment from me on a letter they received on the Epstein prosecution. My guess is it is either Cassell's letter or response thereto. They are going to print tomorrow. + +From: Sent: To: + +Cc: Subject: (USAFLS) ). + +Thursday, March 17, 2011 7:53 PM + +(USAFLS); + +(USAFLS) + +(USAFLS) + +Re: Call from Newsweek + +• eis@miamidade.gov; + +Can and I have some of your time tomorrow? Preferably in the morning. I think we need to address this. + +From: (USAFLS) Sent: Thursda , March 17, 2011 06:32 PM To: . (USAFLS) Subject: Re: Call from Newsweek + +I am wading through some of it now. + +From: (USAFLS) Sent: Thursda , March 17, 2011 06:31 PM To: (USAFLS) Subject: Re: Call from Newsweek + +No + +From: + +Seng:Thur ch + +To: + +Subject: RE: Call from + +(USAFLS) 17, 2011 06:30 PM . (USAFLS) Newsweek + +BTW, do we know exactly which e-mails/correspondence Cassel obtained from Epstein's counsel in the civil litigation? + +Ori inal Messa e---- + +From: . (USAFLS) Sent: Thursda , March 17, 2011 6:17 PM To: (USAFLS) Subject: Re: Call from Newsweek + +Thx. Sending from bberry + +From: + +To: + +Sent: Thur lagm.ch + +Subject: RE: Call from + +(USAFLS) 17, 2011 06:15 PM .(USAFLS) Newsweek + +Thanks - BTW I forwarded to and I think you used the old e-mail addresses. + +From: . (USAFLS) + +Ori inal Messa e + +Sent: Thursda , March 17, 2011 6:14 PM + +To: USAFLS + +Hi Received a voicemail from Newsweek (which now includes Conchita Sarnoff) while I was at the doctor's office + +from Lee Akin (sp?) And Samoff saying they wanted comment from me on a letter they received on the Epstein prosecution. My guess is it is either Cassell's letter or response thereto. They are going to print tomorrow. + +From: (USAFLS) ). + +Sent: Thursday, March 17, 2011 6:34 PM To: (USAFLS) Subject: Re: Call from Newsweek + +I am trying to convince edwards not to file tomorrow + +From: (USAFLS) Sent: Thursda , March 17, 2011 06:32 PM To: . (USAFLS) Subject: Re: Call from Newsweek + +I am wading through some of it now. + +Oggirat + +From: (USAFLS) Sent Thursda , March 17, 2011 06:31 PM To: (USAFLS) Subject: Re: Call from Newsweek + +No + +Ori inal Messa e -- + +From. (USAFLS) Sent: Thursda , March 17, 2011 06:30 PM To: . (USAFLS) Subject: RE: Call from Newsweek + +BTW, do we know exactly which e-mails/correspondence Cassel obtained from Epstein's counsel in the civil litigation? + +----Ori inal Messa e--- + +From: . (USAFLS) Sent: Thursda , March 17, 2011 6:17 PM To: (USAFLS) Subject: Re: Call from Newsweek + +Thx. Sending from bberry + +From: (USAFLS) Sent Thursda , March 17, 2011 06:15 PM To: . (USAFLS) Subject: RE: Call from Newsweek + +Thanks - BTW I forwarded to and • - I think you used the old e-mail addresses. + +Subject: Call from Newsweek + +Hi Received a voicemail from Newsweek (which now includes Conchita Sarnoff) while I was at the doctor's office + +from Akin (sp?) And Samoff saying they wanted comment from me on a letter they received on the Epstein prosecution. My guess is it is either Cassell's letter or response thereto. They are going to print tomorrow. + +From: Paul Cassell + +Sent: Friday, March 18, 2011 5:28 PM + +To: (USAFLS); + +Cc: Brad Edwards Subject: Courtesy Copy + +Attachments: motion-finding-violation-courtesy31811.doc + +Dear and + +. (USAFLS) + +As you know, while we strenuously disagree with your position on the CVRA, we have always tried to keep in close contact with you. In that spirit, attached is a courtesy copy of one of the pleadings we + +plan to file on Monday. + +Paul Cassell + +Co-Counsel for Jane Doe #1 and Jane Doe #2 + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law + +S.J. Quinney College of Law at the University of Utah + +Voice: + +Fax: + +Email: + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the + +sender by reply electronic mail and delete the original message. Thank you. + +Subject: Epstein Location: ofc + +Start: Fri 3/18/2011 10:30 AM End: Fri 3/18/2011 11:00 AM + +Show Time As: Tentative + +Recurrence: (none) + +Meeting Status: Not yet responded + +call in + +Organizer: (USAFLS) + +Required Attendees: (USAFLS); (USAFLS); (USAFLS); + +(USAFLS); (USAFLS); (USAFLS) + +When: Friday, March 18, 2011 10:30 AM-11:00 AM (GMT-05:00) Eastern Time (US & Canada). + +Where: ofc/ call in + +Note: The GMT offset above does not reflect daylight saving time adjustments. + +From: (USAFLS) + +Sent: Friday, March 18, 2011 9:06 AM + +To: (USAFLS) + +Hola. Can t ot. se set a conference call for 10:30 this morning in office re: Epstein with MI + +=. M. and and ask for a number we should call in WPB? Thanks. + +From: (USAFLS) Sent: Monday, March 21, 2011 10:36 AM + +To: (USAFLS) + +Cc: (USAFLS); (USAFLS) + +Subject: RE: Planned response to tomorrow's filing by Cassell + +I guess my question is, then, are we going to contest the factual misstatements in his statement of undisputed facts? Which will necessarily have to include filing affidavits and opening myself and the case agents up for + +Assistant U.S. Attorney + +Fax + +From: (USAFLS) + +Sent: Monday, March 21, 2011 9:57 AM To: . (USAFLS) + +Cc: (USAFLS); (USAFLS) Subject: RE: Planned response to tomorrow's filing by Cassell + +At the conclusion of the emergency hearing in July 2008, the court asked the parties to meet and decide whether there were any disputed facts, so the court could schedule a hearing. We told Edwards the only relevant fact was whether any charges had been filed against Epstein in federal court, and it was not disputed the answer was "no." Edwards disagreed and attempted to include other "facts" which he believed to be relevant to the resolution of the legal question of whether the government had a duty to consult with the + +victims under 18 U.S.C. 3771(a)(5). + +I don't believe the filing of the motion you suggest will achieve the result of preemptively striking Cassell's motion to enforce. The court will have to decide whether the resolution of any disputed facts is required, in order to resolve the legal issue. The government says no; the victims say yes. The court is not likely to + +resolve this question without looking at the factual issues the victims contend are relevant, and considering the + +arguments of each side as to why those issues are, or are not, relevant to the resolution of the dispute. + +If we file the motion you suggest, the victims will oppose it and argue the facts alleged in their motion to enforce are indeed relevant, and should be considered. We will argue the victims' factual issues are not material and/or relevant, and the court should only consider that no federal charges were ever filed against Epstein. This is what is going to happen when the government responds to the victims' motion to enforce. + +We have a number of arguments that victims are not entitled to full-blown discovery, as a party would be entitled to in a true civil action. It's more than a little ironic that Cassell told us he had done these cases all + +over the country, and he had never had to file a complaint. Now he claims the Federal Rules of Civil + +Procedure, to say nothing of Brady and Giglio, also apply. + +From: Sent: Sunda + +To: Cc: (USAFLS) + +March 20, 2011 2:40 PM + +USAFLS + +Hi What would you think about this plan for a response to tomorrow's filing by Cassell? Rather than wait our two weeks to file a response to his onslaught, we simply file something tomorrow (after Cassell's is filed) or Tuesday that is entitled: Request for Ruling on Emergency Petition. We can state that the petition was fully-briefed back in 2008 and that, as you stated in DEI7, the only relevant fact is that Epstein entered a guilty plea in state court. Their motion for summary judgment is an attempt to enlarge their "emergency petition" into a full fledged cause of action and 18 USC 3771(d)(6) specifically states that there is no separate cause of action for a violation, so they cannot file a Complaint. They also cannot reopen a plea or sentence under 3771(dX5). + +You may have already seen this, but take a look at US v. Hunter, 548 F3d 1308 (10'h Cir 2008), where Cassell tried to override the limitation on victims' rights to appeal sentences. Cassell represented the victims, and the 10th Circuit has a good discussion on how victims cannot override prosecutorial discretion, quoting from 18 USC + +377I(d)(6). + +Cassell has, however, been successful in the 11th, in In re Stewart, 552 F.3d 1285 (11th Cir. 2008), where Cassell filed a writ of mandamus to have the Middle District of Florida recognize home purchasers as victims in a guilty plea to an Information by a bank executive. The executive was pleading guilty to money laundering where the + +underlying criminal activity involved charging fraudulent loan origination fees to the victims. + +With regard to the issue of discovery, I think that the language in 18 USC 3771(d)(6) that there cannot be a separate cause of action is helpful. That means that this is not truly a civil case — it should have been filed + +annexed to a civil case, where civil discovery rules would not apply. Since there is not criminal case, the Clerk's + +Office filed it with a civil case number, but the Court has the discretion to decide that discovery is not + +appropriate. See Alphin v. United States, 809 F.2d 236 (4th Cir.), cert. denied 480 U.S. 935 (1987) (district court + +may suspend or limit application of civil rules in summary proceedings). + +Assistant U.S. Attorney + +From: (USAFLS) < + +Sent: Thursday, March 17, 2011 10:11 PM + +To: (USAFLS); (USAFLS); + +(USAFLS); (USAFLS); (USAFLS) + +Subject: Re: Call from Newsweek + +I should be available. El + +--- Original Message + +From: I . (USAFLS) Sent: Thursda March 17, 2011 08:20 PM + +To: . USAFLS); (USAFLS); + +(USAFLS); (USAFLS) + +(USAFLS); + +Subject: Fw: Call from Newsweek + +Sorry. Let me try this again. + +Can and I have some of your time tomorrow? Preferably in the morning. I think we need to address this. + +Sorry it keeps getting misdirected + +From: (USAFLS) Sent: Thursda , March 17, 2011 07:52 PM To: USAFLS ; + +; (USAFLS) + +Cc: (USAFLS) Subject: Re: Call from Newsweek 'eis@rniamidade.govi + +Can and I have some of your time tomorrow? Preferably in the morning. I think we need to address this. + +From: (USAFLS) Sent: Thursda , March 17, 2011 06:32 PM To: . (USAFLS) Subject: Re: Call from Newsweek + +I am wading through some of it now. + +From: (USAFLS) Sent Thursda , March 17, 2011 06:31 PM To: (USAFLS) Subject: Re: Call from Newsweek + +No + +Origirat + +From: (USAFLS) Sent: Thursda , March 17, 2011 06:30 PM To: . (USAFLS) Subject: RE: Call from Newsweek + +BTW, do we know exactly which e-mails/correspondence Cassel obtained from Epstein's counsel in the civil litigation? + +----Ori inal Messa e— + +From: . (USAFLS) Sent: Thursda , March 17, 2011 6:17 PM To: (USAFLS) Subject: Re: Call from Newsweek + +Thx. Sending from bberry + +From: (USAFLS) Sent: Thursda , March 17, 2011 06:15 PM To: . (USAFLS) Subject: RE: Call from Newsweek + +Thanks - BTW I forwarded to I= and • - I think you used the old e-mail addresses. + +----Ori inal Messa e--- + +From: . (USAFLS) Sent: Thursda , March 17, 2011 6:14 PM + +To: USAFLS + +Hi Received a voicemail from Newsweek (which now includes ) while I was at the doctor's office + +from Akin (sp?) And Samoff saying they wanted comment from me on a letter they received on the Epstein prosecution. My guess is it is either Cassell's letter or response thereto. They are going to print tomorrow. + +From: Sent: To: Cc: Subject: + +(USAFLS) < Monday, March 21, 20119:57 AM + +(USAFLS) + +(USAFLS); (USAFLS) + +RE: Planned response to tomorrow's filing by Cassell + +At the conclusion of the emergency hearing in July 2008, the court asked the parties to meet and decide whether there were any disputed facts, so the court could schedule a hearing. We told Edwards the only relevant fact was whether any charges had been filed against Epstein in federal court, and it was not disputed the answer was "no." Edwards disagreed and attempted to include other "facts" which he believed to be relevant to the resolution of the legal question of whether the government had a duty to consult with the + +victims under 18 U.S.C. 3771(a)(5). + +I don't believe the filing of the motion you suggest will achieve the result of preemptively striking Cassell's motion to enforce. The court will have to decide whether the resolution of any disputed facts is required, in order to resolve the legal issue. The government says no; the victims say yes. The court is not likely to + +resolve this question without looking at the factual issues the victims contend are relevant, and considering the + +arguments of each side as to why those issues are, or are not, relevant to the resolution of the dispute. + +If we file the motion you suggest, the victims will oppose it and argue the facts alleged in their motion to enforce are indeed relevant, and should be considered. We will argue the victims' factual issues are not material and/or relevant, and the court should only consider that no federal charges were ever filed against Epstein. This is what is going to happen when the government responds to the victims' motion to enforce. + +We have a number of arguments that victims are not entitled to full-blown discovery, as a party would be entitled to in a true civil action. It's more than a little ironic that Cassell told us he had done these cases all + +over the country, and he had never had to file a complaint. Now he claims the Federal Rules of Civil + +Procedure, to say nothing of Brady and Giglio, also apply. + +From: Sent: Sunda + +To: Cc: (USAFLS) + +March 20, 2011 2:40 PM + +USAFLS + +(USAFLS); (USAFLS) + +Subject: Planned response to tomorrow's filing by Cassell + +Hi — What would you think about this plan for a response to tomorrow's filing by Cassell? Rather than wait our two weeks to file a response to his onslaught, we simply file something tomorrow (after Cassell's is + +filed) or Tuesday that is entitled: Request for Ruling on Emergency Petition. We can state that the petition was fully-briefed back in 2008 and that, as you stated in DE17, the only relevant fact is that Epstein entered a guilty plea in state court. Their motion for summary judgment is an attempt to enlarge their "emergency petition" into a full fledged cause of action and 18 USC 3771(d)(6) specifically states that there is no separate cause of action for a violation, so they cannot file a Complaint. They also cannot reopen a plea or sentence under 3771(d)(5). + +You may have already seen this, but take a look at US v. Hunter, 548 F3d 1308 (10th Cir 2008), where Cassell tried to override the limitation on victims' rights to appeal sentences. Cassell represented the victims, and the 10'h Circuit has a good discussion on how victims cannot override prosecutorial discretion, quoting from 18 USC + +377I(d)(6). + +Cassell has, however, been successful in the 11th, in In re Stewart, 552 F.3d 1285 (11th Cir. 2008), where Cassell filed a writ of mandamus to have the Middle District of Florida recognize home purchasers as victims in a guilty plea to an Information by a bank executive. The executive was pleading guilty to money laundering where the + +underlying criminal activity involved charging fraudulent loan origination fees to the victims. + +With regard to the issue of discovery, I think that the language in 18 USC 3771(d)(6) that there cannot be a separate cause of action is helpful. That means that this is not truly a civil case — it should have been filed + +annexed to a civil case, where civil discovery rules would not apply. Since there is not criminal case, the Clerk's + +Office filed it with a civil case number, but the Court has the discretion to decide that discovery is not + +appropriate. See Alphin v. United States, 809 F.2d 236 (4th Cir.), cert. denied 480 U.S. 935 (1987) (district court + +may suspend or limit application of civil rules in summary proceedings). + +Assistant U.S. Attorney + +From: =, (USAFLS) <-> Sent: Monday, March 21, 2011 4:11 PM + +To: (USAFLS), (USAFLS); (USAFLS); (USAFLS) + +Subject: FW: Epstein + +Conchita Samoff is now calling DC — see emails below. + +Her first question (separate email) was based on her "understanding' that the appellate Chief in DC + +had approved all actions in that case (that was not the case) + +From: (USAFLS) + +Sent: Monday, March 21, 2011 4:09 PM + +To: (SMO) Cc: I (SMO); + +Subject: RE: Epstein + +She has not called me at all on this. + +(USAFLS) + +Sent: Monda + +To: Cc: + +Subject: RE: + +(SMO) March 21, 2011 4:01 PM + +USAFLS) + +. (SMO) + +Epstein + +Thanks - she doesn't appear to know this letter exists, as her two questions to me were: + +1) Who was Acosta's boss in 2007 + +2) Why was the defense team allowed to negotiate with Main Justice + +Are you guys talking to her at all on this? + +From: (USAFLS) + +Sent: Monda , March 21, 2011 3:22 PM + +To: (SMO) + +Subject: Epstein + +Attached letter from John Roth to Epstein attorneys. + +According to the prosecutor, the non-pros deal was already offered, but the defense wanted an + +independent review of the facts anyway. + +From: + +Sent: Mona + +To: + +(USAFLS) + +, March 21, 2011 3:18 PM + +(USAFLS) + +«080623 DAG Ltr to Lefkowitz and Starr.pdf» + +From: Sent: To: Subject: + +Thx. Sending from bberry + +(USAFLS) ). + +Thursday, March 17, 2011 6:17 PM + +(USAFLS) + +Re: Call from Newsweek + +Ori inal Messa e + +From: (USAFLS) Sent: Thursda , March 17, 2011 06:15 PM To: . (USAFLS) Subject: RE: Call from Newsweek + +Ori inal Messa e + +From: . (USAFLS) Sent: Thursda , March 17, 2011 6:14 PM + +To: USAFLS + +Cc: (USAFLS); WAF@miamidade.goV; (USAFLS); (USAFLS); + +'eis@miamidade.gov' + +Subject: Call from Newsweek + +Hi Received a voicemail from Newsweek (which now includes Conchita Sarnoff) while I was at the doctor's office + +from Akin (sp?) And Samoff saying they wanted comment from me on a letter they received on the Epstein prosecution. My guess is it is either Cassell's letter or response thereto. They are going to print tomorrow. + +From: (USAFLS) ‹ > + +Sent: Thursday, March 17, 2011 6:14 PM + +To: (USAFLS) + +Cc: (USAFLS); + +(USAFLS); eis@miamidade.gov + +Subject: Call from Newsweek + +(USAFLS); + +Hi Received a voicemail from Newsweek (which now includes Conchita Sarnoff) while I was at the doctor's office + +from Akin (sp?) And Samoff saying they wanted comment from me on a letter they received on the Epstein prosecution. My guess is it is either Cassell's letter or response thereto. They are going to print tomorrow. + +From: (USAFLS) < + +Sent: Thursday, March 17, 2011 12:56 PM + +To: Paul Cassell + +Cc: (USAFLS); Brad Edwards + +Subject: RE: Government's Position on Several Pending Issues? Still Waiting for Answer + +Paul, + +1. Yesterday, I provided you with the name and phone number for , OPR Acting + +Associate Counsel, who received your December 10, 2010 letter to Mir. asking for an + +investigation of the Jeffrey Epstein prosecution. + +2. The government will not be making initial disclosures to plaintiffs, because we do not believe + +Fed.R.Civ.P. 26 applies to this matter. + +3. The CVRA applies to the criminal case which has been filed in district court, where an individual is deemed to be a "victim," not any civil litigation which may be initiated to enforce those claimed rights. We do not believe there is any ht to in this case. Moreover, we do not believe that whatever Kenneth Starr or may have said to this office, or what this office said to Kenneth Starr or Lilly Ann , has any bearing on whether a duty existed under 18 U.S.C. 3771(a) to consult with plaintiffs prior to entering into a non-prosecution agreement, where no charges were filed in the district court. We will respond to your motion seeking access to this information. + +4. As I understand the Magistrate Judge's order in Jane Doe No. 2 v. Jeffrey Epstein (D.E. 226), you must give notice to Epstein, prior to making certain correspondence public by either filing the correspondence in a court file, attaching it to a deposition, releasing it to the media, or publically + +disseminating it in any other fashion. D.E. 226 at 4. Presumably, Epstein will raise any objections he + +believes are appropriate, and the court will resolve the matter. + +The U.S. Attorney's Office has no independent objection to the filing of "an unsealed, unredacted pleading reciting the U.S. Attorney's correspondence." In stating that the U.S. Attorney's Office has no independent objections, we wish to make clear that we are not, and cannot, relieve the plaintiffs of their obligation to comply with the Magistrate Judge's order by giving the appropriate notice to Epstein + +(D.E. 226). Thank you. + +From: Paul Cassell [mailto: + +Sent: Tuesda , March 15, 2011 7:21 PM + +To: USAFLS + +Cc: . (USAFLS); Brad Edwards + +Subject: RE: Government's Position on Several Pending Issues? Still Waiting for Answer + +Dear + +Brad and I have received Mr. letter of today. We are deeply disappointed. We will file our + +court pleadings on Friday. + +Mr. - again. letter still leaves unanswered a number of questions, which I am writing to raise with you - + +1. You still have not provided, as you promised you would, the name of the person coordinating the OPR investigation. As a result we have not been able to obtain any information about the status of the + +investigation. Just to be clear, we intend to include in our filing information that OPR has begun an investigation and to include the information that we currently have about — we assume + +that making that information public will not compromise OPR's work. + +2. We will be making initial disclosures to you under the Federal Rules of Civil Procedure shortly. We have not heard back from you on whether you will be making parallel disclosures. Accordingly, we understand your position to be that you are not obligated to provide to us any documents under Rule + +26. + +3. We understand your position to be that, despite the "best efforts" clause in the CVRA and your obligation to treat victims with fairness, you can withhold evidence from the victims that will help them prove CVRA violations. For example, we understand you to take the position that you can withhold the other half of the U.S. Attorney's correspondence, correspondence between the Department and Ken Starr and Lillian on behalf of Epstein, and information about role in the Epstein case. In short, we understand you to be asserting a blanket position that you can withhold information that will help prove the victims' CVRA case. If this is incorrect, please advise us promptly. If we have misunderstood you and you are willing to provide us relevant information, we will promptly provide you with a list of such information. If we have understood you correctly, we will be filing a motion with the Court shortly to block the Justice Department from suppressing such highly relevant + +information. + +4. You still have not given us your position on the victims' motion to file an unsealed, unredacted pleading reciting the U.S. Attorney's correspondence. What is your position on that motion: We have been asking for your position on this motion for some time now. If we have not heard back from you by c.o.b. Wednesday, March 16, 2011, we will include in our pleadings the following statement: "The Justice Department attorneys handling this case have been contacted several times for their position + +on this issue but have refused to respond to give their position." + +Thanks you in advance for your assistance. Sincerely, Paul Cassell, Co-Counsel for Jane Doe + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law + +S.J. Quinney College of Law at the University of Utah + +Voice: + +Fax: + +Email: + +http://www.law.utah.edu/profiles/defaultasp?PersonID=57&name=Cassell,Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the + +sender by reply electronic mail and delete the original message. Thank you. + +From: (USAFLS) + +Sent: Thursday, March 17, 201112:43 PM To: (USAFLS) + +Cc: (USAFLS); . (USAFLS); + +(USAFLS); (USAFLS) + +Subject: RE: Contact from Vanity Fair re Epstein related to Conflict of Interest + +Thank you. + +From: (USAFLS) Sent: Thursda , March 17, 2011 12:42 PM + +To: (USAFLS) + +(USAFLS); (USAFLS); (USAFLS); (USAFLS); + +(USAFLS) + +Subject: Contact from Vanity Fair re Epstein related to Conflict of Interest + +(USAFLS); + +Hi — I received the following voicemail from Vanity Fair magazine this morning. As per usual, I will + +leave it to you to respond. + +This is a transcription so if it reads strangely, that is why: + +Yes, Assistant U.S. Attorney . This is John Connelly from Vanity Fair Magazine. I think I tried to talk to you a couple years ago about a guy named Jeffrey Epstein. Anyway, ummm I need to speak to you or maybe somebody if you are uncomfortable speaking to me totally on background your public information office because something has come to me which is a bit troubling about the U.S. Attorney's decision to not prosecute Jerry Jeffrey Epstein as long as he took that plea where he was allowed out of his cell 16 hours a day 6 days a week not a bad deal umm but is has to do with the relationship of your former AG and Mr. ummm Epstein's lawyer. It seems as though there was certainly a possible conflict and I need somebody to talk to about that whether it is you or anybody else I don't care. John Connelly. Vanity Fair Magazine. I really + +appreciate your call and off the record I heard you did great work on that case. Thank you so much. + +Assistant U.S. Attorney + +Fax + +Sent: Friday, March 18, 2011 3:31 PM To: . (USAFLS) Subject: Your CourtLink dockets have arrived + +Attachments: CourtLink\_Dockets\_728652\_3.18.2011\_153050541.zip + +Attached is information ordered from CourtLink by ANN on 3/18/2011. + +This information is in PDF format, which you can open with Adobe Acrobat. + +If you do not have Adobe Acrobat, you may download Adobe Acrobat Reader from + +http://www.adobe.com/products/acrobat1readstep2.html. Contact LexisNexis Customer Support or your own IT Department + +for assistance. + +This file is currently zipped and must be unzipped before you will be able to open it. You can use PKUnzip or WinZip to unzip the file. If you do not have either program, you may download Winzip from http://www.winzip.com. Contact + +LexisNexis Customer Support or your own IT Department for assistance. + +If you have difficulty opening or using this file, please contact LexisNexis Customer Support at 1-888-311-1966 or go to + +http://supportlexisnexis.com/courtlinkemail. + +If you would like to monitor additional cases, you can set up a TRACK to notify you of unfolding activity in existing cases. + +Please visit https://CourtLink.LexisNexis.comlTrack/TrackSetup.aspx. + +PLEASE NOTE: If there is no file attached to this email, the attachment may have been blocked by your firm's email system for security reasons. Please contact your email system administrator, IT Department, or LexisNexis Customer + +Support for further assistance. + +This is a send only email. Please do not reply to this email. + +If you are experiencing any issues in using the LexisNexis(r) CourtLink(r) service, please feel free to Contact LexisNexis + +Customer Support. CourtLink(r) 888-311-1966 + +CourtLink Classic(r) 877-430-2990 + +Customer Support team is available 24 hours a day, 7 days a week to assist you. For a web mail form for Customer Support please go to the following page: + +http://supportlexisnexis.com/courtlinkemaiVdefauft.asp?vcForm=Courtlink\_Email\_Form1&61=Continue + +LexisNexis is a trademark and CourtLink and CourtLink Classic are registered trademarks of LexisNexis. + +From: (USAFLS) Sent: Thursday, March 17, 2011 6:24 PM + +To: (USAFLS) Subject: Re: Call from Newsweek + +I don't have it. She left a voicemail + +Original Message ---- From: (USAFLS) + +Sent: Thursda . March 17, 2011 06:22 PM To: . (USAFLS) Subject: Re: Call from Newsweek + +---- Or ir Aessag - + +From: (USAFLS) Sent: Thursda , March 17, 2011 06:13 PM + +To: , USAFLS + +Cc: (USAFLS); <1=1 1.>: + +(USAFLS); 'eis@miamidade.gov' + +Subject: Call from Newsweek + +(USAFLS); + +Hi Received a voicemail from Newsweek (which now includes Conchita Sarnoff) while I was at the doctor's office + +from Akin (sp?) And Samoff saying they wanted comment from me on a letter they received on the Epstein prosecution. My guess is it is either Cassell's letter or response thereto. They are going to print tomorrow. + +From: (USAFLS)< > + +Sent: Friday, March 18, 2011 4:45 PM To: (ODAG) (JMD) Subject: RE: Can you call me? It is urgent + +I will wait for you. There may be a Newsweek story tomorrow about Alex's relationship with Starr and + +Lefkowitz and the special treatment for Epstein. + +Assistant U.S. Attorney + +Fax + +From: (ODAG) (SMO) Sent: Frida March 18, 2011 4:43 PM To: . (USAFLS) Subject: Re: Can you call me? It is urgent + +In meetings with the DAG (and others) until 5:30. Can it wait until then or should I step out? + +Assistant U.S. Attorney + +Fax + +From: (USAFLS) Sent: Tuesday, March 15, 2011 7:37 PM To: (USAFLS) + +Cc: (USAFLS); (USAFLS); (USAFLS); + +(USAFLS) + +Subject: RE: Epstein + +Agreed. Agents will be conducting the interview in Australia tomorrow night our time (Thursday Australia time). After that, I will know what we are really working with and will finish it up as quickly as I can. There is a lot to digest and unfortunately I have a lot of other pressing matters, too, but I am working as fast as I can. + +Assistant U.S. Attorney + +Fax + +From: (USAFLS) Sent: Tuesda March 15 2011 6:51 PM To: . (USAFLS + +Cc: (USAFLS); (USAFLS); (USAFLS); (USAFLS) + +Subject: Epstein + +Hi M, + +I think you mentioned last week that you were preparing a memo addressing some of the legal and strategic issues relating to a potential new investigation into Epstein and/or other targets. Once you've done that, we + +Thanks you in advance for your assistance. Sincerely, Paul Cassell, Co-Counsel for Jane Doe + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law + +S.J. Quinney College of Law at the University of Utah + +Voice: + +Fax: + +Email: + +http://www.law.utah.edu/profiles/defaultasp?PersonID=57&name=Cassell,Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the + +sender by reply electronic mail and delete the original message. Thank you. + +From: (USAFLS) < + +Sent: Tuesday, March 15, 2011 7:40 PM + +To: (USAFLS); (USAFLS) Cc: (USAFLS); (USAFLS) + +Subject: FW: Government's Position on Several Pending Issues? Still Waiting for Answer + +and M, + +Here is Cassell's response to our letter. On March 1, 2010, I sent an e-mail to at OPR, to whom I had referred Cassell's letter asking for an inquiry. I asked if OPR had a policy about complainants having direct contact with investigating attorneys, since I was reluctant to provide name in the absence of consent. has not responded to my e-mail. I intend to provide + +the general phone number for OPR to Cassell. + +Thanks you in advance for your assistance. Sincerely, Paul Cassell, Co-Counsel for Jane Doe + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law + +S.J. Quinney College of Law at the University of Utah + +Voice: + +Fax: + +Email: + +http://www.law.utah.edu/profiles/default.asp?PersonID=57&name=Cassell,Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the + +sender by reply electronic mail and delete the original message. Thank you. + +From: (USAFLS) Sent: Tuesday, March 15, 2011 8:49 PM To: (USAFLS) + +Subject: Re: Epstein + +Thanks - I know you are swamped. No rush, I just figured we should all talk since this case has so + +many moving parts. + +(USAFLS) + +March 15, 2011 07:37 PM (USAFLS) + +(USAFLS); (USAFLS); (USAFLS); + +(USAFLS) Subject: RE: Epstein + +Agreed. Agents will be conducting the interview in Australia tomorrow night our time (Thursday Australia time). After that, I will know what we are really working with and will finish it up as quickly as I can. There is a lot to digest and unfortunately I have a lot of other pressing matters, too, but I am working as fast as I can. + +Assistant U.S. Attorney + +Fax + +From: (USAFLS) Sent: Tuesda March 15 2011 6:51 PM To: .(USAFLS + +Cc: (USAFLS); (USAFLS); (USAFLS); (USAFLS) + +Subject: Epstein + +Hi M, + +I think you mentioned last week that you were preparing a memo addressing some of the legal and strategic issues relating to a potential new investigation into Epstein and/or other targets. Once you've done that, we should probably set aside some time to chat about the case generally. Also, reached out to • + +and me last week and raised some issues that we can discuss as well. Thanks. + +From: (USAFLS) Sent: Tuesday, March 15, 2011 8:40 PM + +To: (USAFLS); (USAFLS) + +Cc: (USAFLS); (USAFLS) + +Subject: Re: Government's Position on Several Pending Issues? Still Waiting for Answer + +At the risk of stating the obvious, Cassell's approach seems to be to ratchet up the attacks against the + +office whenever he doesn't get exactly what he wants. Most of his e-mail deals with his efforts to + +embarrass the Office rather than the legal issue before Judge Marra. + +That being said, his statement that OPR "has begun an investigation" is not only irrelevant, but possibly incorrect. Since there is pending litigation, my guess is that OPR has not yet begun an investigation. My understanding based on another experience as well as on comments from OPR at the NAC is that they specifically do not begin investigations while there is pending litigation on the same subject matter as the referral. The fact that Cassell is the one who wrote the letter that we forwarded to OPR matters here as well. Cassell simply made an accusation and he is now trying to use the fact of an OPR investigation to give the illusion that there must be some merit to the allegation. + +I could be mistaken and it may just be semantics, but he seems wrong on this. + +To: USAFLS); USAFLS) Cc: (USAFLS); . (USAFLS) + +Subject: FW: Government's Position on Several Pending Issues? Still Waiting for Answer + +and M, + +Here is Cassell's response to our letter. On March 1, 2010, I sent an e-mail to at OPR, to whom I had referred Cassell's letter asking for an inquiry. I asked if OPR had a policy about complainants having direct contact with investigating attorneys, since I was reluctant to provide name in the absence of consent. has not responded to my e-mail. I intend to provide + +the general phone number for OPR to Cassell. + +From: Paul Cassell [mailto: + +Sent: Tuesda , March 15, 2011 7:21 PM + +To: USAFLS + +Cc: . (USAFLS); Brad Edwards + +Subject: RE: Government's Position on Several Pending Issues? Still Waiting for Answer + +Dear + +Brad and I have received Mr. letter of today. We are deeply disappointed. We will file our + +court pleadings on Friday. + +Mr. - again. letter still leaves unanswered a number of questions, which I am writing to raise with you - + +1. You still have not provided, as you promised you would, the name of the person coordinating the OPR investigation. As a result we have not been able to obtain any information about the status of the investigation. Just to be clear, we intend to include in our filing information that OPR has begun an investigation and to include the information that we currently have about — we assume + +that making that information public will not compromise OPR's work. + +2. We will be making initial disclosures to you under the Federal Rules of Civil Procedure shortly. We have not heard back from you on whether you will be making parallel disclosures. Accordingly, we understand your position to be that you are not obligated to provide to us any documents under Rule + +26. + +From: Sent: To: Cc: Subject: . (USAFLS) + +Wednesday, March 16, 2011 10:15 AM + +(USAFLS); (USAFLS) (USAFLS); . (USAFLS) RE: Government's Position on Several Pending Issues? Still Waiting for Answer + +Excellent point. Please make OPR aware of this situation so that we can provide guidance. We need + +to clarify this point with Cassell before he files his motion on Friday. is right: this is a classic + +smear campaign in order to distract the court from the legal/statutory issue before it. + +From: (USAFLS) Sent: Tuesda March 15, 2011 8:40 PM + +To: USAFLS); USAFLS + +Cc: (USAFLS); . (USAFLS) + +Subject: Re: Government's Position on Several Pending Issues? Still Waiting for Answer + +At the risk of stating the obvious, Cassell's approach seems to be to ratchet up the attacks against the + +office whenever he doesn't get exactly what he wants. Most of his e-mail deals with his efforts to + +embarrass the Office rather than the legal issue before Judge Marra. + +That being said, his statement that OPR "has begun an investigation" is not only irrelevant, but possibly incorrect. Since there is pending litigation, my guess is that OPR has not yet begun an investigation. My understanding based on another experience as well as on comments from OPR at the NAC is that they specifically do not begin investigations while there is pending litigation on the same subject matter as the referral. The fact that Cassell is the one who wrote the letter that we forwarded to OPR matters here as well. Cassell simply made an accusation and he is now trying to use the fact of an OPR investigation to give the illusion that there must be some merit to the allegation. + +I could be mistaken and it may just be semantics, but he seems wrong on this. + +From: + +Sent: Tuesda + +To: Cc: + +Subject: FW: Government's Position on Several Pending Issues? Still Waiting for Answer + +(USAFLS) + +March 15, 2011 07:39 PM USAFLS); (USAFLS); + +USAFLS) I. (USAFLS) + +and M, + +Here is Cassell's response to our letter. On March 1, 2010, I sent an e-mail to OPR, to whom I had referred Cassell's letter asking for an inquiry. I asked about complainants having direct contact with investigating attorneys, since I was + +name in the absence of consent. has not responded to my e-mail. I + +the general phone number for OPR to Cassell. + +r ad a policy + +at + +reluctant to provide intend to provide + +Thanks you in advance for your assistance. Sincerely, Paul Cassell, Co-Counsel for Jane Doe + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law + +S.J. Quinney College of Law at the University of Utah + +Voice: + +Fax: + +Email: + +http://www.law.utah.edu/profiles/defaultasp?PersonID=57&name=Cassell,Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the + +sender by reply electronic mail and delete the original message. Thank you. + +From: (USAFLS) Sent: Thursday, March 17, 2011 12:17 PM + +To: (USAFLS); (USAFLS); (USAFLS) + +Cc: (USAFLS) + +Subject: RE: Government's Position on Several Pending Issues? Still Waiting for Answer + +Hi — I think that some of these positions may conflict with other positions taken by the + +Department. In particular I believe that the Department's position is that the Federal Rules of Civil + +Procedure do not apply because this is not a civil action. + +As to point number 4, I would recommend that we make clear that the matter should be filed under seal in accordance with Judge Marra's order, however, if the plaintiffs abide by the terms of that order (in terms of providing notice and the opportunity to be heard) and make a motion to unseal, we will not + +oppose the motion to unseal. + +Assistant U.S. Attorney + +Fax + +From: (USAFLS) + +Sent: Thursda March 17, 2011 11:20 AM + +To: USAFLS); USAFLS) Cc: (USAFLS); . (USAFLS) + +Subject: FW: Government's Position on Several Pending Issues? Still Waiting for Answer + +and M, + +I would like to respond to Cassell's requests today. As to paragraph 1, I provided him a phone + +number and contact person yesterday, March 16. + +As to paragraph 2, I would like to tell Cassell we won't be making initial disclosures, because we don't + +believe Fed.R.Civ.P. 26 applies in this hybrid civil matter. + +As to paragraph 3, I would like to tell Cassell that the CVRA applies to the criminal case which has been filed in district court, where an individual is deemed to be a "victim," not any civil litigation which may be initiated to enforce those rights. Any rights to discovery in an action to enforce the CVRA would emanate from the Federal Rules of Civil Procedure, if at all. Moreover, I would like to tell him that whatever Ken Starr said to our office, and what our office said to Ken Starr, has no bearing on whether a legal duty to consult, in the absence of any charge filed in the district court, existed. We + +will respond to any motion he files, claiming he has a right of access to these materials. + +As to paragraph 4, I discern no privilege attaching to e-mail and mail correspondence our office had with Epstein's attorneys. These could be considered plea discussions, but normally, one of the parties to the negotiation is complaining about the other side using information gleaned from such discussions improperly in the merits of the case. We could argue that disclosure to third parties could + +assert a chilling effect, but that seems to be a stretch. In any event, I think we should advise Cassell the U.S. Attorney's Office has no independent objection to the release of this correspondence between our office and Epstein's attorneys. It will be the victims' burden to notify Epstein, and respond to + +whatever objections he lodges. + +Thanks. + +From: Paul Cassell [mailto: + +Sent: Tuesda , March 15, 2011 7:21 PM + +To: USAFLS + +Cc: . (USAFLS); Brad Edwards + +Subject: RE: Government's Position on Several Pending Issues? Still Waiting for Answer + +Dear + +Brad and I have received Mr. letter of today. We are deeply disappointed. We will file our + +court pleadings on Friday. + +Mr. - again. letter still leaves unanswered a number of questions, which I am writing to raise with you - + +1. You still have not provided, as you promised you would, the name of the person coordinating the OPR investigation. As a result we have not been able to obtain any information about the status of the investigation. Just to be clear, we intend to include in our filing information that OPR has begun an investigation and to include the information that we currently have about — we assume + +that making that information public will not compromise OPR's work. + +2. We will be making initial disclosures to you under the Federal Rules of Civil Procedure shortly. We have not heard back from you on whether you will be making parallel disclosures. Accordingly, we understand your position to be that you are not obligated to provide to us any documents under Rule + +26. + +3. We understand your position to be that, despite the "best efforts" clause in the CVRA and your obligation to treat victims with fairness, you can withhold evidence from the victims that will help them prove CVRA violations. For example, we understand you to take the position that you can withhold the other half of the U.S. Attorney's correspondence, correspondence between the Department and Ken Starr and Lillian on behalf of Epstein, and information about role in the Epstein case. In short, we understand you to be asserting a blanket position that you can withhold + +information that will help prove the victims' CVRA case. If this is incorrect, please advise us promptly. If we have misunderstood you and you are willing to provide us relevant information, we will promptly provide you with a list of such information. If we have understood you correctly, we will be filing a motion with the Court shortly to block the Justice Department from suppressing such highly relevant + +information. + +4. You still have not given us your position on the victims' motion to file an unsealed, unredacted pleading reciting the U.S. Attorney's correspondence. What is your position on that motion: We have been asking for your position on this motion for some time now. If we have not heard back from you by c.o.b. Wednesday, March 16, 2011, we will include in our pleadings the following statement: "The Justice Department attorneys handling this case have been contacted several times for their position + +on this issue but have refused to respond to give their position." + +Thanks you in advance for your assistance. Sincerely, Paul Cassell, Co-Counsel for Jane Doe + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law + +S.J. Quinney College of Law at the University of Utah + +Voice: + +Fax: + +Email: + +http://www.law.utah.edu/profiles/defaultasp?PersonID=57&name=Cassell,Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the + +sender by reply electronic mail and delete the original message. Thank you. + +From: (USAFLS) < + +Sent: Thursday, March 17, 2011 11:20 AM + +To: (USAFLS); (USAFLS) Cc: (USAFLS); (USAFLS) + +Mr. - again. letter still leaves unanswered a number of questions, which I am writing to raise with you - + +1. You still have not provided, as you promised you would, the name of the person coordinating the OPR investigation. As a result we have not been able to obtain any information about the status of the investigation. Just to be clear, we intend to include in our filing information that OPR has begun an investigation and to include the information that we currently have about — we assume + +that making that information public will not compromise OPR's work. + +2. We will be making initial disclosures to you under the Federal Rules of Civil Procedure shortly. We have not heard back from you on whether you will be making parallel disclosures. Accordingly, we understand your position to be that you are not obligated to provide to us any documents under Rule + +26. + +3. We understand your position to be that, despite the "best efforts" clause in the CVRA and your obligation to treat victims with fairness, you can withhold evidence from the victims that will help them prove CVRA violations. For example, we understand you to take the position that you can withhold the other half of the U.S. Attorney's correspondence, correspondence between the Department and Ken Starr and Lillian on behalf of Epstein, and information about role in the Epstein case. In short, we understand you to be asserting a blanket position that you can withhold information that will help prove the victims' CVRA case. If this is incorrect, please advise us promptly. If we have misunderstood you and you are willing to provide us relevant information, we will promptly provide you with a list of such information. If we have understood you correctly, we will be filing a motion with the Court shortly to block the Justice Department from suppressing such highly relevant + +information. + +4. You still have not given us your position on the victims' motion to file an unsealed, unredacted pleading reciting the U.S. Attorney's correspondence. What is your position on that motion: We have been asking for your position on this motion for some time now. If we have not heard back from you by c.o.b. Wednesday, March 16, 2011, we will include in our pleadings the following statement: "The Justice Department attorneys handling this case have been contacted several times for their position + +on this issue but have refused to respond to give their position." + +Thanks you in advance for your assistance. Sincerely, Paul Cassell, Co-Counsel for Jane Doe + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law + +S.J. Quinney College of Law at the University of Utah + +Voice: + +Fax: + +Email: + +http://www.law.utah.edu/profiles/defaultasp?PersonID=57&name=Cassell,Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the + +sender by reply electronic mail and delete the original message. Thank you. + +Subject: Epstein Location: oft + +Start: End: + +Fri 3/18/2011 10:30 AM Fri 3/18/2011 11:00 AM + +Recurrence: (none) + +Organizer: + +Required Attendees: + +call in + +. (USAFLS) + +(USAFLS); + +(USAFLS); (USAFLS); (USAFLS); + +(USAFLS); (USAFLS) + +When: Fri March 18, 2011 10:30 AM-11:00 AM (GMT-05:00) Eastern Time (US & Canada). + +Where: IMMI ofci call in + +Note: The GMT offset above does not reflect daylight saving time adjustments. + +From: (USAFLS) Sent: Frida March 18, 2011 9:06 AM To: (USAFLS) + +Hole. Can lease set a conference call for 10:30 this morning in office re: Epstein with + +and and ask for a number we should call in WPB? Thanks. + +From: (USAFLS) Sent: Friday, March 18, 2011 11:44 AM + +«081124 Ltr to Black final.wpd» This was the letter that was sent. + +The message is ready to be sent with the following file or link attachments: + +081124 Ltr to Black final.wpd + +Note: To protect against computer viruses, e-mail programs may prevent sending or receiving certain types of file + +attachments. Check your e-mail security settings to determine how attachments are handled. + +From: (USAFLS) Sent: Monday, March 21, 20115:07 PM + +To: (USAFLS); (USAFLS); (USAFLS) + +Cc: (USAFLS); (USAFLS) + +Subject: Filings from Cassell + +Attachments: DE51\_20110321\_Motion to use correspondence and unseal.pdf; DE49\_20110321\_Motion + +to Have Facts Accepted as True.pdf; DE50\_20110321\_Motn for Brady-type evidence.pdf; DE50-1\_20110321\_Exhibit Edwards Letter.pdf; DESO-2\_20110321\_Proposed Order.pdf; DE48 302.pdf; DE48 Victim notification Itr.pdf; DE48 victim notification Ittpdf; DE48-5\_20110321\_NPA.pdf; DE48-6\_20110321\_Twiler Itr to DE48-7\_20110321\_Twiler Itr to Jim Eisenberg + +for • DE48-8\_20110321\_302 of from Jan 2008.pdf; DE48- + +9\_20110321\_Twiler Itr to DE48\_20110321\_Motn for finding a violation of + +CVRA.pdf + +Here they all are + +<> «DE49\_20110321\_Motion to Have Facts Accepted + +as True.pdf» <> «DE50-2 20110321 Proposed Order.pdf» <> < < «DE48-8 20110321 302 of from Jan 2008.pdf>> «DE48-9\_20110321\_Twiler Itr to + +> < + +Sent: Tuesday, March 22, 2011 1:22 PM To: (USAFLS) + +Subject: Re: Telephone call + +I got it. I am sending him the statement we drafted yesterday. + +From: (USAFLS) Sent: Tuesc March 22, 2011 01:20 PM + +To: ,M (USAFLS) Subject: FW: Telephone call + +FYI. See below. + +Assistant U.S. Attorney + +Fax + +From: Fernandez, Aida I. (USAFLS) Sent: Tuesday, March 22, 2011 12:59 PM To: (USAFLS) + +Subject: Telephone call + +Telephone call fm John Pasanti, Daily Business Review re: Epstein filing of 3/21/2011. I referred + +To: (FBI); R. (MM)(FBI) + +Subject: Epstein suit in the news + +Just FYI — The victims' rights suit is back in the news. or I may be reaching out to you re affidavits + +or hearing dates. + +Assistant U.S. Attorney + +Fax + +From: (USAFLS) < > + +Sent: Monday, March 21, 2011 5:35 PM + +To: (USAFLS); (USAFLS); (USAFLS) Cc: (USAFLS); (USAFLS) + +Subject: RE: Jeffrey Epstein -- pleading is pubic -- PLEASE REVIEW URGENT + +Suggest deleting first sentence (since we are kind of responding) + +(USAFLS); + +The U.S. Attorney's Office will file its response to the instant motion in court. However, as we stated more than two years ago in July 2008 in our response to the plaintiffs' then emergency petition for enforcement of the Crime Victim Rights Act (CVRA), the CVRA was not violated since no federal + +charges were ever filed in the Southern District of Florida. + +From: Michele Dargan [mailto + +Sent: Monc March 21, 2011 4:52 PM + +To: , (USAFLS) Subject: Jeffrey Epstein + +Hi + +There's been a new court filing in West Palm Beach federal court regarding Jeffrey Epstein. In case # + +08-CV-80736, attorneys for Jane Doe #1 and #2 are challenging the validity of the federal NPA, worked out between the USAO and Jeffrey Epstein's criminal attorneys before he pled guilty to his + +state charges. + +Basically, the attorneys for Doe 1 and 2 are saying the USAO did not notify the victims before signing + +the NPA, which violates the Crime Victims Rights Act. They are saying that the NPA should be invalidated because of it. They also allege in the motion that the USAO agreed to keeping the NPA secret (it was originally sealed) because of pressure from Epstein's attorneys and higher ups in the + +Justice Dept. + +I'm reaching out to you for a response to the court filing. I am on deadline with the story. + +Thanks, Michele + +Michele Dargan Staff Writer + +Palm Beach Daily News + +http://www.palmbeachdailynews.com + +Cox Conserves. + +Please consider the environment before printing this e-mail. + +Contents of this e-mail may be confidential and proprietary. + +Use discretion when forwarding. + +From: (USAFLS)< > + +Sent: Thursday, March 24, 2011 5:39 PM To: . (USAFLS) Subject: FW: Epstein -- DOJ letter to defense + +I am waiting to hear back. + +Will let you know. + +From: (SMO) + +Sent: Thuinla, March 24, 2011 5:34 PM + +To: , (USAFLS) + +Subject: RE: Epstein -- DOJ letter to defense + +I think this is going to be a call, but let me check. + +Sent: Thursda + +To: Cc: + +March 24, 2011 5:31 PM + +(SMO); (USAFLS); (USAFLS) Subject: RE: Epstein -- DOJ letter to defense + +SMO); + +. (USAFLS); (USAFLS); + +Here is what we propose to say, but wanted to run this past you: + +As you know from your communications with the DOJ's Office of Public Affairs, the defense in this case asked for an independent DOJ review of all facts, circumstances and allegations surrounding this + +prosecution. The Office of the Deputy Attorney General did in fact review the case, which is not + +uncommon, and determined that no misconduct occurred and that prosecutorial discretion in the case + +appropriately rested with the U.S. Attorney's Office. + +The italicized wording is new but 100% accurate. + +Please advise ASAP - time is of the essence. + +Thanks - + +From: (SMO) + +Sent: Thursda , March 24, 2011 4:49 PM + +To: USAFLS); Cc: (USAFLS); + +Subject: RE: Epstein -- DOJ letter to defense + +SMO); SMO + +. (USAFLS); (USAFLS) + +Adding Tracy and Jess. I think you are correct. + +Here is what I sent to her (per your previous email) + +Thanks for your patience. I checked into your two questions on who was the USA's boss and why the "defense was allowed to negotiate with Main Justice", as you put it. Here's what I have for you — The Office of the Deputy Attorney General did review the case, which is not uncommon, and determined that prosecutorial discretion in the case appropriately rested with the U.S. Attorney's Office. (Off the record, note "review" would be the appropriate word, not "negotiate".) In terms of a boss, the U.S. Attorneys' Offices report through the Office of the Deputy Attorney General (at the time, Mark Filip was + +the DAG.) + +From: (USAFLS) + +Sent: Thursda March 24, 2011 4:45 PM + +Co: (SMO) Cc: (USAFLS); + +Subject: RE: Epstein -- DOJ letter to defense + +. (USAFLS); + +Can we make this letter public? I don't think so, but wanted to check with you. + +This would put to rest some of her questions. + +«080623 DAG Ltr to Lefkowitz and Starr.pdf» + +From: Sent: To: + +Cc: Subject: (USAFLS) ‹ > + +Monday, March 21, 2011 5:52 PM + +(USAFLS); (USAFLS); + +(USAFLS) + +(USAFLS); (USAFLS) + +RE: Jeffrey Epstein -- pleading is pubic -- PLEASE REVIEW URGENT + +Should there be a final sentence such as the following? + +(USAFLS) + +.(USAFLS); + +Because the matter remains pending in court, it would be inappropriate at this time to provide + +additional comment on the merits of the motion. + +Just a thought. + +From: + +Sent: Monda + +To: + +(USAFLS) + +March 21, 2011 5:35 PM + +(USAFLS); (USAFLS); + +(USAFLS); + +Suggest deleting first sentence (since we are kind of responding) + +The U.S. Attorney's Office will file its response to the instant motion in court. However, as we stated more than two years ago in July 2008 in our response to the plaintiffs' then emergency petition for enforcement of the Crime Victim Rights Act (CVRA), the CVRA was not violated since no federal + +charges were ever filed in the Southern District of Florida. + +From: Michele Dargan [mailto + +Sent: Monc March 21, 2011 4:52 PM + +To: , (USAFLS) Subject: Jeffrey Epstein + +Hi + +There's been a new court filing in West Palm Beach federal court regarding Jeffrey Epstein. In case # + +08-CV-80736, attorneys for Jane Doe #1 and #2 are challenging the validity of the federal NPA, worked out between the USAO and Jeffrey Epstein's criminal attorneys before he pled guilty to his + +state charges. + +Basically, the attorneys for Doe 1 and 2 are saying the USAO did not notify the victims before signing + +the NPA, which violates the Crime Victims Rights Act. They are saying that the NPA should be invalidated because of it. They also allege in the motion that the USAO agreed to keeping the NPA secret (it was originally sealed) because of pressure from Epstein's attorneys and higher ups in the + +Justice Dept. + +I'm reaching out to you for a response to the court filing. I am on deadline with the story. + +Thanks, Michele + +Michele Dargan Staff Writer + +Palm Beach Daily News + +http://www.palmbeachdailynews.com + +From: Sent: To: Subject: + +I agree with the revised. + +Assistant U.S. Attorney + +Fax + +From: + +Sent: Monda + +To: + +Cc: + +Subject: RE: + +(USAFLS) ). + +Monday, March 21, 2011 5:36 PM (USAFLS) + +RE: Jeffrey Epstein -- pleading is pubic -- PLEASE REVIEW URGENT + +(USAFLS) + +March 21, 2011 5:33 PM + +(USAFLS); (USAFLS); (USAFLS); + +(USAFLS); . (USAFLS) + +Jeffrey Epstein -- pleading is pubic -- PLEASE REVIEW URGENT + +Revised response: + +It would be inappropriate to comment on the merits of this motion, as the case is pending in court. The U.S. Attorney's Office will file its response to the instant motion in court. However, as we stated more than two years ago in July 2008 in our response to the plaintiffs' then emergency petition for enforcement of the Crime Victim Rights Act (CVRA), the CVRA was not violated since no federal + +charges were ever filed in the Southern District of Florida. + +Hi + +There's been a new court filing in West Palm Beach federal court regarding Jeffrey Epstein. In case # + +08-CV-80736, attorneys for Jane Doe #1 and #2 are challenging the validity of the federal NPA, worked out between the USAO and Jeffrey Epstein's criminal attorneys before he pled guilty to his + +state charges. + +Basically, the attorneys for Doe 1 and 2 are saying the USAO did not notify the victims before signing + +the NPA, which violates the Crime Victims Rights Act. They are saying that the NPA should be invalidated because of it. They also allege in the motion that the USAO agreed to keeping the NPA secret (it was originally sealed) because of pressure from Epstein's attorneys and higher ups in the + +Justice Dept. + +I'm reaching out to you for a response to the court filing. I am on deadline with the story. + +Thanks, Michele + +Michele Dargan Staff Writer + +Palm Beach Daily News + +http://www.palmbeachdailynews.com + +Cox Conserves. + +Please consider the environment before printing this e-mail. + +Contents of this e-mail may be confidential and proprietary. + +Use discretion when forwarding. + +From: (USAFLS)< > + +Sent: Thursday, March 24, 2011 5:19 PM + +To: . (USAFLS); (USAFLS); (USAFLS); (USAFLS) + +Cc: (USAFLS) + +Subject: RE: jeffrey epstein prosecution -CONTACT FROM NEWSWEEK + +Cc: (USAFLS) + +Subject: RE: jeffrey epstein prosecution -CONTACT FROM NEWSWEEK + +How about giving them the letter??? + +Assistant U.S. Attorne + +Fax + +Ori2ir Message From: =. (USAFLS) + +Sent: Thursda . March 24, 2011 5:09 PM + +To: (USAFLS); . (USAFLS); (USAFLS); + +(USAFLS) + +Cc: (USAFLS) + +Subject: RE: Jeffrey epstein prosecution -CONTACT FROM NEWSWEEK + +I understand why you want that, and I would love to include it, but that is beyond the response DOJ gave to Conchita. I will + +have to run this by them. + +Any other thoughts before I send this to DOJ?? + +Ori inal Messa e + +From: . (USAFLS) Sent: Thursda , March 24, 2011 5:07 PM + +To: , (USAFLS); . (USAFLS); (USAFLS); (USAFLS) + +Cc: (USAFLS) + +Subject: RE: jeffrey epstein prosecution -CONTACT FROM NEWSWEEK + +Please add the capitalized language (below). + +I am trying to find letter to them. + +Assistant U.S. Attorne + +Fax + +Ori inal Message From: (USAFLS) + +Sent: Thursda , March 24, 2011 4:57 PM + +To: . (USAFLS), (USAFLS); Cc: (USAFLS); (USAFLS) + +Subject: RE: jeffrey epstein prosecution -CONTACT FROM NEWSWEEK + +Proposed SDFL (non)response: + +(USAFLS) + +As you know from your communications with the DOJ's Office of Public Affairs, the defense in this case asked for an independent DOJ review of all facts, circumstances and allegations surrounding this prosecution. The Office of the Deputy + +Attorney General did in fact review the case, which is not uncommon, and determined that NO MISCONDUCT OCCURRED AND THAT prosecutorial discretion in the case appropriately rested with the U.S. Attorney's Office. + +If you agree, I need to run this by DOJ. DOJ already provided the following comment -- but ours is slightly different (ergo, the need to run it by them) DOJ response: The Office of the Deputy Attorney General did review the case, which is not uncommon, and determined that prosecutorial discretion in the case appropriately rested with the U.S. Attorney's Office. (Off the record, note "review' would be the appropriate word, not "negotiate".) In terms of a boss, the U.S. Attorneys' + +Offices report through the Office of the Deputy Attorney General (at the time, Mark Filip was the DAG.) + +Ori inal Messa e + +From: . (USAFLS) Sent: Thursda . March 24. 2011 4:12 PM + +To: . USAFLS + +Cc: (USAFLS); (USAFLS) + +Subject: FW: jeffrey epstein prosecution -CONTACT FROM NEWSWEEK + +Importance: High + +— This just arrived. Why do they always wait until 2 minutes before their deadline to contact us99999 I did not fail to call her back, I referred the matter to you. Can you please handle this. Making clear that all allegations raised by Epstein's team were investigated by DOJ and found to be completely meritless. You might also add that Epstein had previously + +made false allegations against the Palm Beach Police Chief. + +I would love to know how they got the letter, but they probably will not tell you their source. + +Assistant U.S. Attorne + +Fax + +----Original Message From: Aitken, Lee [mailto + +Sent: Thursda . March 24, 2011 4:07 PM To: . (USAFLS) Subject: jeffrey epstein prosecution + +Dear Ms. + +I am an editor at both Newsweek and the Daily Beast website. I left a phone message last week but have not received a call back. Now we are facing a deadline for posting on the Daily Beast tonight, so I'd like to give you another chance to respond to our query. We have obtained a five-page letter you wrote to attorney Jay Lefkowitz on December 13, 2007 protesting charges of misconduct on your part and laying out several details about your interactions with Jeffrey Epstein's legal team. Your co-signer, Alex Accosta, has already acknowledged the vaiidity of this letter, but I would also like you to confirm that it came from your office. If you have any further comment to make about it or facts to add about this case I would love to hear back from you right away. We plan to post a story about the negotiations behind the Non-Prosecution + +agreement at 8 pm this evening. + +Thank you for your time and prompt attention, Lee Aitken + +From: . (USAFLS) + +Sent: Monday, March 21, 2011 5:53 PM + +To: (USAFLS); (USAFLS); (USAFLS) Cc: (USAFLS); (USAFLS) + +Subject: RE: Jeffrey Epstein -- pleading is pubic -- PLEASE REVIEW URGENT + +(USAFLS); + +From: (USAFLS) Sent: Monc March 21, 2011 5:52 PM + +To: USAFLS , M (USAFLS); (USAFLS); + +Cc: (USAFLS); . (USAFLS) + +Subject: RE: Jeffrey Epstein -- pleading is pubic -- PLEASE REVIEW URGENT + +Should there be a final sentence such as the following? + +. (USAFLS); + +Because the matter remains pending in court, it would be inappropriate at this time to provide + +additional comment on the merits of the motion. + +Just a thought. + +From: + +Sent: Monda + +To: + +Cc: + +Subject: RE: + +(USAFLS) + +March 21, 2011 5:35 PM + +(USAFLS); (USAFLS); + +(USAFLS); . (USAFLS) + +Jeffrey Epstein -- pleading is pubic -- PLEASE REVIEW URGENT + +Suggest deleting first sentence (since we are kind of responding) + +(USAFLS); + +The U.S. Attorney's Office will file its response to the instant motion in court. However, as we stated more than two years ago in July 2008 in our response to the plaintiffs' then emergency petition for enforcement of the Crime Victim Rights Act (CVRA), the CVRA was not violated since no federal + +charges were ever filed in the Southern District of Florida. + +From: Michele Dargan [mailto + +Sent: Monda 21, 2011 4:52 PM + +To: , (USAFLS) Subject: Jeffrey Epstein + +Hi + +08-CV-80736, attorneys for Jane Doe #1 and #2 are challenging the validity of the federal NPA, worked out between the USAO and Jeffrey Epstein's criminal attorneys before he pled guilty to his + +Basically, the attorneys for Doe 1 and 2 are saying the USAO did not notify the victims before signing + +the NPA, which violates the Crime Victims Rights Act. They are saying that the NPA should be invalidated because of it. They also allege in the motion that the USAO agreed to keeping the NPA secret (it was originally sealed) because of pressure from Epstein's attorneys and higher ups in the + +Justice Dept. + +I'm reaching out to you for a response to the court filing. I am on deadline with the story. + +Thanks, Michele + +Michele Dargan Staff Writer + +Palm Beach Daily News + +http://www.palmbeachdailynews.com + +Cox Conserves. + +Please consider the environment before printing this e-mail. + +Contents of this e-mail may be confidential and proprietary. + +Use discretion when forwarding. + +From: (USAFLS) Sent: Thursday, March 24, 2011 7:02 PM + +To: (USAFLS) + +Subject: RE: Jeffrey epstein prosecution + +Have you heard anything? + +Assistant U.S. Attorne + +Fax + +Original Message From: =. (USAFLS) + +Sent: Thursda March 24. 2011 5:41 PM + +To: + +Subject: RE: Jeffrey epstein prosecution + +a-- + +----Original Message From: Aitken, Lee [mailto: + +Sent: Thursda March 24. 2011 4:07 PM To: . (USAFLS) Subject: Jeffrey epstein prosecution + +Dear Ms. + +I am an editor at both Newsweek and the Daily Beast website. I left a phone message last week but have not received a call back. Now we are facing a deadline for posting on the Daily Beast tonight, so I'd like to give you another chance to respond to our query. We have obtained a five-page letter you wrote to attorney Jay Lefkowitz on December 13, 2007 protesting charges of misconduct on your part and laying out several details about your interactions with Jeffrey Epstein's legal team. Your co-signer, Alex Accosta, has already acknowledged the vaiidity of this letter, but I would also like you to confirm that it came from your office. If you have any further comment to make about it or facts to add about this case I would love to hear back from you right away. We plan to post a story about the negotiations behind the Non-Prosecution + +agreement at 8 pm this evening. + +Thank you for your time and prompt attention, Lee Aitken + +From: (USAFLS) < > + +Sent: Monday, March 21, 2011 5:53 PM + +To: (USAFLS); (USAFLS); (USAFLS); + +(USAFLS) Cc: (USAFLS); (USAFLS) + +Subject: RE: Jeffrey Epstein -- pleading is pubic -- PLEASE REVIEW URGENT + +Sure. I will add and send out. + +Ok with everyone? + +From: (USAFLS) Sent: Monc March 21, 2011 5:52 PM + +To: , (USAFLS); (USAFLS); . (USAFLS); + +USAFLS + +Cc: (USAFLS); . (USAFLS) + +Subject: RE: Jeffrey Epstein -- pleading is pubic -- PLEASE REVIEW URGENT + +Should there be a final sentence such as the following? + +Just a thought. + +From: + +Sent: Monda + +To: + +Cc: + +Subject: RE: + +(USAFLS) + +March 21, 2011 5:35 PM + +(USAFLS); (USAFLS); + +(USAFLS); . (USAFLS) + +Jeffrey Epstein -- pleading is pubic -- PLEASE REVIEW URGENT + +Suggest deleting first sentence (since we are kind of responding) + +(USAFLS); + +The U.S. Attorney's Office will file its response to the instant motion in court. However, as we stated more than two years ago in July 2008 in our response to the plaintiffs' then emergency petition for enforcement of the Crime Victim Rights Act (CVRA), the CVRA was not violated since no federal + +charges were ever filed in the Southern District of Florida. + +From: Michele Dargan [mailto + +Sent: Monda 21, 2011 4:52 PM + +To: , (USAFLS) Subject: Jeffrey Epstein + +Hi + +There's been a new court filing in West Palm Beach federal court regarding Jeffrey Epstein. In case # + +08-CV-80736, attorneys for Jane Doe #1 and #2 are challenging the validity of the federal NPA, worked out between the USAO and Jeffrey Epstein's criminal attorneys before he pled guilty to his + +state charges. + +Basically, the attorneys for Doe 1 and 2 are saying the USAO did not notify the victims before signing + +the NPA, which violates the Crime Victims Rights Act. They are saying that the NPA should be invalidated because of it. They also allege in the motion that the USAO agreed to keeping the NPA secret (it was originally sealed) because of pressure from Epstein's attorneys and higher ups in the + +Justice Dept. + +I'm reaching out to you for a response to the court filing. I am on deadline with the story. + +Thanks, Michele + +voice: fax: Toll-free: + +http://www.palmbeachdailynews.com + +Cox Conserves. + +Please consider the environment before printing this e-mail. + +Contents of this e-mail may be confidential and proprietary. + +Use discretion when forwarding. + +From: (USAFLS)< I> + +Sent: Tuesday, March 22, 20119:09 AM + +To: . (USAFLS) + +Subject: Fw: Filings from Cassell + +Attachments: DE51\_20110321\_Motion to use correspondence and unseal.pdf; DE49\_20110321\_Motion + +to Have Facts Accepted as True.pdf; DE50\_20110321\_Motn for Brady-type evidence.pdf; DE50-1\_20110321\_Exhibit Edwards Letter.pdf; DE50-2\_20110321\_Proposed 0rder.pdf; DE48 302.pdf; DE48- Victim notification Itr.pdf; DE48 victim notification Itcpdf; DE48-5\_20110321\_NPA.pdf; DE48-6\_20110321\_Twiler Itr to DE48-7\_20110321\_Twiler Itr to Jim Eisenberg + +for • 0E48-8\_20110321 302 of from Jan 2008.pdf; DE48- + +9\_20110321\_Twiler Itr to DE48\_20110321\_Motn for finding a violation of + +CVRA.pdf + +Mr. Rotker, + +This is what Cassell filed yesterday. + +From: (USAFLS) Sent: Monda March 21, 2011 05:06 PM + +To: . (USAFLS ; + +Cc: (USAFLS); Subject: Filings from Cassell + +Here they all are + +(USAFLS) + +(USAFLS); (USAFLS) + +<> «DE49\_20110321\_Motion to Have Facts Accepted + +as True.pdf» <> «DE50-2 20110321 Proposed Order.pdf» <> < < «DE48-8 20110321 302 of from Jan 2008.pdf>> «DE48-9\_20110321\_Twiler Itr to + +Assistant U.S. Attorney + +Fax + +From: (USAFLS) < M> Sent: Thursday, March 24, 2011 7:51 PM To: . (USAFLS) + +Subject: Fw: Statement re Epstein + +Sorry. Here it is + +Original Message -- + +From: csamoff (mailta ) Sent: Thursda March 24, 2011 06:56 PM + +To: =,= (USAFLS); Janet Aitken ‹ > + +Subject: Re: Statement re Epstein + +Thank you Best, Conchita + +Message----- + +From: == To: Janet Aitken + +Cc: + +Subject: Statement re Epstein Sent: 24 Mar 2011 18:40 + +After reviewing the U.S. Attorneya€TMs handling of this matter, including allegations of misconduct, the office of the deputy attorney general determined there was no basis to intervene in the matter. We will not be making additional comments. + +Thanks for checking with us. + +Special Counsel to the US Attorney + +Sent from my Verizon Wireless BlackBerry + +From: (USAFLS) + +Sent: Thursday, March 24, 2011 7:02 PM To: . (USAFLS) + +Subject: Automatic reply: jeffrey epstein prosecution + +I will be out of the office on Friday, March 25. 2011. + +For press matters, please contact AUSA by e-mail at or by phone at + +Estare fuera de la oficina el viemes, 25 de marzo. Si se trata de un asunto de prensa, favor de comunicarse con el fiscal + +anotado anteriormente. Gracias y que tenga muy buen dia. + +From: (USAFLS) Sent: Thursday, March 24, 2011 7:57 PM + +To: (USAFLS) + +Cc: (USAFLS); (USAFLS) + +Subject: RE: Statement re Epstein + +And it has already been filed with the court! + +Assistant U.S. Attorne + +Fax + +-----OrigirS Message + +From: =, (USAFLS) + +Sent: Thursda , March 24, 2011 7:51 PM To: . (USAFLS) Subject: Fw: Statement re Epstein + +Sorry. Here it is + +Original Message --- From: csarnoff (rnailto: + +Sent: The, March 24, 2011 06:56 PM + +To: =,=I (USAFLS); Janet Aitken •: .> + +Subject: Re: Statement re Epstein + +Thank you Best, Conchita + +Message---- + +From: == To: Janet Aitken + +Cc: + +Subject: Statement re Epstein Sent: 24 Mar 2011 18:40 + +After reviewing the U.S. Attorneyaems handling of this matter, including allegations of misconduct, the office of the deputy attorney general determined there was no basis to intervene in the matter. We will not be making additional comments. + +Thanks for checking with us. + +Special Counsel to the US Attorney + +Sent from my Verizon Wireless BlackBerry + +Cc: (USAFLS); + +Subject: RE: Statement re Epstein + +(USAFLS) + +Why do you make it so hard for the good guys to follow the rules? Just release the letter. It isn't a privileged + +communication. It was sent to opposing counsel. + +Assistant U.S. Attorne + +Fax + +Original Message From: =, (USAFLS) + +Sent: Thursda , March 24, 2011 7:51 PM To: . (USAFLS) Subject: Fw: Statement re Epstein + +Sorry. Here it is + +Original Message ---- + +From: csamoff [mailto: + +Sent: Thurnla , March 24, 2011 06:56 PM + +To: =,= (USAFLS); Janet Aitken ‹ > + +Subject: Re: Statement re Epstein + +Thank you Best, Conchita + +Original Message-- + +From: == To: Janet Aitken + +Cc: + +Subject: Statement re Epstein Sent: 24 Mar 2011 18:40 + +After reviewing the U.S. Attorneyaems handling of this matter, including allegations of misconduct, the office of the deputy attorney general determined there was no basis to intervene in the matter. We will not be making additional comments. + +Thanks for checking with us. + +Special Counsel to the US Attorney + +Sent from my Verizon Wireless BlackBerry + +From: Aitken, Lee + +Sent: Thursday, March 24, 2011 4:07 PM To: . (USAFLS) Subject: jeffrey epstein prosecution + +I am an editor at both Newsweek and the Daily Beast website. I left a phone message last week but have not received a call back. Now we are facing a deadline for posting on the Daily Beast tonight, so I'd like to give you another chance to respond to our query. We have obtained a five-page letter you wrote to attorney Jay Lefkowitz on December 13, 2007 + +protesting charges of misconduct on your part and laying out several details about your interactions with Jeffrey Epstein's legal team. Your co-signer, Alex Accosta, has already acknowledged the vaiidity of this letter, but I would also like you to confirm that it came from your office. If you have any further comment to make about it or facts to add about this case I would love to hear back from you right away. We plan to post a story about the negotiations behind the Non-Prosecution + +agreement at 8 pm this evening. + +Thank you for your time and prompt attention, Lee Aitken + +From: (USAFLS) Sent: Thursday, March 24, 2011 5:07 PM + +To: (USAFLS); (USAFLS); + +(USAFLS) + +Cc: (USAFLS) + +Subject: RE: Jeffrey epstein prosecution -CONTACT FROM NEWSWEEK + +Attachments: Letter from CEOS.TIF + +Please add the capitalized language (below). + +I am trying to find letter to them. + +Assistant U.S. Attorne + +Fax + +Ori inal Message From: (USAFLS) + +Sent: Thursda March 24, 2011 4:57 PM + +To: . (USAFLS)• (USAFLS); Cc: (USAFLS); (USAFLS) + +Subject: RE: Jeffrey epstein prosecution -CONTACT FROM NEWSWEEK + +Proposed SDFL (non)response: + +(USAFLS) + +(USAFLS); + +As you know from your communications with the DOJ's Office of Public Affairs, the defense in this case asked for an independent DOJ review of all facts, circumstances and allegations surrounding this prosecution. The Office of the Deputy + +Attorney General did in fact review the case, which is not uncommon, and determined that NO MISCONDUCT OCCURRED AND THAT prosecutorial discretion in the case appropriately rested with the U.S. Attorney's Office. + +If you agree, I need to run this by DOJ. DOJ already provided the following comment -- but ours is slightly different (ergo, + +the need to run it by them) + +DOJ response: The Office of the Deputy Attorney General did review the case, which is not uncommon, and determined that prosecutorial discretion in the case appropriately rested with the U.S. Attorney's Office. (Off the record, note 'review" would be the appropriate word, not "negotiate".) In terms of a boss, the U.S. Attorneys' Offices report through the Office of + +the Deputy Attorney General (at the time, Mark Filip was the DAG.) + +Ori inal Messa e + +From: . (USAFLS) Sent: Thursda , March 24, 2011 4:12 PM + +To: . USAFLS + +Cc: (USAFLS); (USAFLS) + +— This just arrived. Why do they always wait until 2 minutes before their deadline to contact us99999 I did not fail to call her back, I referred the matter to you. Can you please handle this. Making clear that all allegations raised by Epstein's team were investigated by DOJ and found to be completely meritless. You might also add that Epstein had previously + +made false allegations against the Palm Beach Police Chief. + +I would love to know how they got the letter, but they probably will not tell you their source. + +Assistant U.S. Attorne + +Fax + +Original Message From: Aitken, Lee (mailto• + +Sent: Thursda , March 24, 2011 4:07 PM To: . (USAFLS) Subject: jeffrey epstein prosecution + +Dear Ms. + +I am an editor at both Newsweek and the Daily Beast website. I left a phone message last week but have not received a call back. Now we are facing a deadline for posting on the Daily Beast tonight, so I'd like to give you another chance to respond to our query. We have obtained a five-page letter you wrote to attorney Jay Lefkowitz on December 13, 2007 protesting charges of misconduct on your part and laying out several details about your interactions with Jeffrey Epstein's legal team. Your co-signer, Alex Accosta, has already acknowledged the vaiidity of this letter, but I would also like you to confirm that it came from your office. If you have any further comment to make about it or facts to add about this case I would love to hear back from you right away. We plan to post a story about the negotiations behind the Non-Prosecution + +agreement at 8 pm this evening. + +Thank you for your time and prompt attention, Lee Aitken + +From: (USAFLS) < > + +Sent: Monday, March 21, 2011 5:58 PM + +To: (USAFLS); (USAFLS); + +(USAFLS); . (USAFLS) + +Cc: (USAFLS) + +Subject: FW: Jeffrey Epstein + +Here is our response. + +Although technically incorrect, using the term plaintiff does make it easier to follow. + +Let me know if you want me to change for future use. + +From: (USAFLS) + +Sent: Monday, March 21, 2011 5:55 PM + +To: Michele Dar an + +Cc: (USAFLS) Subject: RE: Jeffrey Epstein + +(USAFLS); + +The U.S. Attorney's Office will file its response to the instant motion in court. However, as we stated more than two years ago in July 2008 in our response to the plaintiffs' then-emergency petition for enforcement of the Crime Victim Rights Act (CVRA), the CVRA was not violated because no federal charges were ever filed in the Southern District of Florida. Because the matter remains pending in court, it would be inappropriate at this time to provide additional comment on the merits of the current + +motion. + +Special Counsel to the U.S. Attorney + +From: Michele Dargan + +Sent: Monda 21, 2011 4:52 PM + +To: , (USAFLS) Subject: Jeffrey Epstein + +Hi + +There's been a new court filing in West Palm Beach federal court regarding Jeffrey Epstein. In case # + +08-CV-80736, attorneys for Jane Doe #1 and #2 are challenging the validity of the federal NPA, worked out between the USAO and Jeffrey Epstein's criminal attorneys before he pled guilty to his + +state charges. + +Basically, the attorneys for Doe 1 and 2 are saying the USAO did not notify the victims before signing + +the NPA, which violates the Crime Victims Rights Act. They are saying that the NPA should be invalidated because of it. They also allege in the motion that the USAO agreed to keeping the NPA secret (it was originally sealed) because of pressure from Epstein's attorneys and higher ups in the + +Justice Dept. + +I'm reaching out to you for a response to the court filing. I am on deadline with the story. + +Thanks, Michele + +Michele Dargan Staff Writer + +Palm Beach Dail News + +voice: fax: Toll-free: + +Cox Conserves. + +Please consider the environment before printing this e-mail. + +Contents of this e-mail may be confidential and proprietary. + +Use discretion when forwarding. + +From: (USAFLS) ‹ > + +Sent: Monday, March 21, 2011 5:57 PM + +To: (USAFLS); (USAFLS); (USAFLS) Cc: (USAFLS); (USAFLS) + +Subject: RE: Jeffrey Epstein -- pleading is pubic -- PLEASE REVIEW URGENT + +No, although I might feel different if it were a pleading. And then again, I might not. + +From: (USAFLS) + +Sent: Monda March 21, 2011 5:56 PM + +To: (USAFLS); (USAFLS); + +USAFLS) + +Cc: (USAFLS); . (USAFLS) + +Subject: RE: Jeffrey Epstein -- pleading is pubic -- PLEASE REVIEW URGENT + +. (USAFLS);IMI + +. (USAFLS); + +Too late.... Went out. I don't think it's worth resending, do you? I will correct for future use. + +From: (USAFLS) Sent: Monc March 21, 2011 5:54 PM + +To: ,M (USAFLS); (USAFLS); . (USAFLS); + +USAFLS + +Cc: (USAFLS); . (USAFLS) + +Subject: RE: Jeffrey Epstein -- pleading is pubic -- PLEASE REVIEW URGENT + +It just occurred to me that perhaps we should not refer to the Jane Does as plaintiffs since there is no + +independent civil action, just a motion in a miscellaneous proceeding. + +From: (USAFLS) + +Sent: Monda , March 21, 2011 5:53 PM + +Sure. I will add and send out. + +Ok with everyone? + +From: (USAFLS) Sent: Monc March 21, 2011 5:52 PM + +To: , (USAFLS); (USAFLS); + +USAFLS + +Cc: (USAFLS); . (USAFLS) + +Subject: RE: Jeffrey Epstein -- pleading is pubic -- PLEASE REVIEW URGENT + +Should there be a final sentence such as the following? + +. (USAFLS); + +Because the matter remains pending in court, it would be inappropriate at this time to provide + +additional comment on the merits of the motion. + +Just a thought. + +From: + +Sent: Monda + +To: + +Cc: + +Subject: RE: + +(USAFLS) + +March 21, 2011 5:35 PM + +(USAFLS); (USAFLS); (USAFLS); + +(USAFLS); . (USAFLS) + +Jeffrey Epstein -- pleading is pubic -- PLEASE REVIEW URGENT + +Suggest deleting first sentence (since we are kind of responding) + +The U.S. Attorney's Office will file its response to the instant motion in court. However, as we stated more than two years ago in July 2008 in our response to the plaintiffs' then emergency petition for enforcement of the Crime Victim Rights Act (CVRA), the CVRA was not violated since no federal + +charges were ever filed in the Southern District of Florida. + +From: Michele Dargan [mailto + +Sent: Monda 21, 2011 4:52 PM + +To: , (USAFLS) Subject: Jeffrey Epstein + +Hi + +There's been a new court filing in West Palm Beach federal court regarding Jeffrey Epstein. In case # + +08-CV-80736, attorneys for Jane Doe #1 and #2 are challenging the validity of the federal NPA, worked out between the USAO and Jeffrey Epstein's criminal attorneys before he pled guilty to his + +state charges. + +Basically, the attorneys for Doe 1 and 2 are saying the USAO did not notify the victims before signing + +the NPA, which violates the Crime Victims Rights Act. They are saying that the NPA should be invalidated because of it. They also allege in the motion that the USAO agreed to keeping the NPA secret (it was originally sealed) because of pressure from Epstein's attorneys and higher ups in the + +Justice Dept. + +I'm reaching out to you for a response to the court filing. I am on deadline with the story. + +Thanks, Michele + +Michele Dargan Staff Writer + +Palm Beach Daily News + +http://www.palmbeachdailynews.com + +Cox Conserves. + +Please consider the environment before printing this e-mail. + +Contents of this e-mail may be confidential and proprietary. + +Use discretion when forwarding. + +From: (USAFLS) < > + +Sent: Monday, March 21, 2011 5:56 PM + +To: (USAFLS); (USAFLS); (USAFLS) Cc: (USAFLS); (USAFLS) + +(USAFLS); + +From: (USAFLS) Sent: Monc March 21, 2011 5:54 PM + +To: ,M (USAFLS); (USAFLS); . (USAFLS); MI + +USAFLS + +Cc: (USAFLS); . (USAFLS) + +Subject: RE: Jeffrey Epstein -- pleading is pubic -- PLEASE REVIEW URGENT + +It just occurred to me that perhaps we should not refer to the Jane Does as plaintiffs since there is no + +independent civil action, just a motion in a miscellaneous proceeding. + +From: (USAFLS) + +Sent: Monda March 21, 2011 5:53 PM + +To: (USAFLS); (USAFLS); + +USAFLS) + +Cc: r + +(USAFLS); . (USAFLS) + +Subject: RE: Jeffrey Epstein -- pleading is pubic -- PLEASE REVIEW URGENT + +Sure. I will add and send out. + +Ok with everyone? + +. (USAFLS); + +From: (USAFLS) Sent: Monc March 21, 2011 5:52 PM + +To: ,M (USAFLS); (USAFLS); . (USAFLS); + +USAFLS + +Cc: (USAFLS); . (USAFLS) + +Subject: RE: Jeffrey Epstein -- pleading is pubic -- PLEASE REVIEW URGENT + +Should there be a final sentence such as the following? + +Because the matter remains pending in court, it would be inappropriate at this time to provide + +additional comment on the merits of the motion. + +From: + +Sent: Monda + +To: + +Cc: + +Subject: RE: + +(USAFLS) + +March 21, 2011 5:35 PM + +(USAFLS); (USAFLS); (USAFLS); + +(USAFLS); . (USAFLS) + +Jeffrey Epstein -- pleading is pubic -- PLEASE REVIEW URGENT + +Suggest deleting first sentence (since we are kind of responding) + +The U.S. Attorney's Office will file its response to the instant motion in court. However, as we stated more than two years ago in July 2008 in our response to the plaintiffs' then emergency petition for enforcement of the Crime Victim Rights Act (CVRA), the CVRA was not violated since no federal + +charges were ever filed in the Southern District of Florida. + +From: Michele Dargan [mailto + +Sent: Monc March 21, 2011 4:52 PM + +To: , (USAFLS) Subject: Jeffrey Epstein + +Hi + +There's been a new court filing in West Palm Beach federal court regarding Jeffrey Epstein. In case # + +08-CV-80736, attorneys for Jane Doe #1 and #2 are challenging the validity of the federal NPA, worked out between the USAO and Jeffrey Epstein's criminal attorneys before he pled guilty to his + +state charges. + +Basically, the attorneys for Doe 1 and 2 are saying the USAO did not notify the victims before signing + +the NPA, which violates the Crime Victims Rights Act. They are saying that the NPA should be invalidated because of it. They also allege in the motion that the USAO agreed to keeping the NPA secret (it was originally sealed) because of pressure from Epstein's attorneys and higher ups in the + +Justice Dept. + +I'm reaching out to you for a response to the court filing. I am on deadline with the story. + +Thanks, Michele + +Michele Dargan Staff Writer + +http://www.palmbeachdailynews.com + +Cox Conserves. + +Please consider the environment before printing this e-mail. + +Contents of this e-mail may be confidential and proprietary. + +Use discretion when forwarding. + +From: (USAFLS)c Sent: Monday, March 21, 2011 5:54 PM + +To: (USAFLS); (USAFLS); (USAFLS) Cc: (USAFLS); (USAFLS) + +Subject: RE: Jeffrey Epstein -- pleading is pubic -- PLEASE REVIEW URGENT + +.(USAFLS); + +It just occurred to me that perhaps we should not refer to the Jane Does as plaintiffs since there is no + +independent civil action, just a motion in a miscellaneous proceeding. + +From: (USAFLS) + +Sent: Monda March 21, 2011 5:53 PM + +To: (USAFLS); (USAFLS); + +USAFLS) + +Cc: r + +(USAFLS); . (USAFLS) + +Subject: RE: Jeffrey Epstein -- pleading is pubic -- PLEASE REVIEW URGENT + +Sure. I will add and send out. + +Ok with everyone? + +. (USAFLS); + +From: (USAFLS) Sent: Monc March 21, 2011 5:52 PM + +To: ,M (USAFLS); (USAFLS); . (USAFLS); + +USAFLS + +Cc: (USAFLS); . (USAFLS) + +Subject: RE: Jeffrey Epstein -- pleading is pubic -- PLEASE REVIEW URGENT + +Because the matter remains pending in court, it would be inappropriate at this time to provide + +additional comment on the merits of the motion. + +Just a thought. + +From: + +Sent: Monda + +To: + +Cc: + +Subject: RE: + +(USAFLS) + +March 21, 2011 5:35 PM + +(USAFLS); (USAFLS); + +(USAFLS); . (USAFLS) + +Jeffrey Epstein -- pleading is pubic -- PLEASE REVIEW URGENT + +Suggest deleting first sentence (since we are kind of responding) + +(USAFLS); + +The U.S. Attorney's Office will file its response to the instant motion in court. However, as we stated more than two years ago in July 2008 in our response to the plaintiffs' then emergency petition for enforcement of the Crime Victim Rights Act (CVRA), the CVRA was not violated since no federal + +charges were ever filed in the Southern District of Florida. + +From: Michele Dargan [mailto + +Sent: Monc March 21, 2011 4:52 PM + +To: , (USAFLS) Subject: Jeffrey Epstein + +Hi + +There's been a new court filing in West Palm Beach federal court regarding Jeffrey Epstein. In case # + +08-CV-80736, attorneys for Jane Doe #1 and #2 are challenging the validity of the federal NPA, worked out between the USAO and Jeffrey Epstein's criminal attorneys before he pled guilty to his + +state charges. + +Basically, the attorneys for Doe 1 and 2 are saying the USAO did not notify the victims before signing + +the NPA, which violates the Crime Victims Rights Act. They are saying that the NPA should be invalidated because of it. They also allege in the motion that the USAO agreed to keeping the NPA secret (it was originally sealed) because of pressure from Epstein's attorneys and higher ups in the + +Justice Dept. + +Michele Dargan Staff Writer + +Palm Beach Daily News + +http://www.palmbeachdailynews.com + +Cox Conserves. + +Please consider the environment before printing this e-mail. + +Contents of this e-mail may be confidential and proprietary. + +Use discretion when forwarding. + +From: Sent: To: + +Cc: Subject: + +Ok - will send out now. + +From: + +Sent: Monda + +To: + +(USAFLS) < > + +Monday, March 21, 2011 5:54 PM + +(USAFLS); + +(USAFLS) + +(USAFLS); + +RE: Jeffrey Epstein -- pleading is pubic -- PLEASE REVIEW URGENT + +(USAFLS); + +(USAFLS) + +. (USAFLS) March 21, 2011 5:53 PM + +(USAFLS); (USAFLS); + +Cc: (USAFLS); . (USAFLS) + +Subject: RE: Jeffrey Epstein -- pleading is pubic -- PLEASE REVIEW URGENT + +That's fine with me. + +From: (USAFLS) Sent: Monc March 21, 2011 5:52 PM + +To: , (USAFLS); (USAFLS); + +USAFLS + +(USAFLS); + +. (USAFLS); + +(USAFLS); + +Should there be a final sentence such as the following? + +Because the matter remains pending in court, it would be inappropriate at this time to provide + +additional comment on the merits of the motion. + +Just a thought. + +From: + +Sent: Monda + +To: + +Cc: + +Subject: RE: + +(USAFLS) + +March 21, 2011 5:35 PM + +(USAFLS); (USAFLS); (USAFLS); + +(USAFLS); . (USAFLS) + +Jeffrey Epstein -- pleading is pubic -- PLEASE REVIEW URGENT + +Suggest deleting first sentence (since we are kind of responding) + +The U.S. Attorney's Office will file its response to the instant motion in court. However, as we stated more than two years ago in July 2008 in our response to the plaintiffs' then emergency petition for enforcement of the Crime Victim Rights Act (CVRA), the CVRA was not violated since no federal + +charges were ever filed in the Southern District of Florida. + +From: Michele Dargan [mailto + +Sent: Monc March 21, 2011 4:52 PM + +To: , (USAFLS) Subject: Jeffrey Epstein + +Hi + +There's been a new court filing in West Palm Beach federal court regarding Jeffrey Epstein. In case # + +08-CV-80736, attorneys for Jane Doe #1 and #2 are challenging the validity of the federal NPA, worked out between the USAO and Jeffrey Epstein's criminal attorneys before he pled guilty to his + +state charges. + +Basically, the attorneys for Doe 1 and 2 are saying the USAO did not notify the victims before signing + +the NPA, which violates the Crime Victims Rights Act. They are saying that the NPA should be invalidated because of it. They also allege in the motion that the USAO agreed to keeping the NPA secret (it was originally sealed) because of pressure from Epstein's attorneys and higher ups in the + +Thanks, Michele + +Michele Dargan Staff Writer + +Palm Beach Daily News + +http://www.palmbeachdailynews.com + +Cox Conserves. + +Please consider the environment before printing this e-mail. + +Contents of this e-mail may be confidential and proprietary. + +Use discretion when forwarding. + +From: Sent: To: Subject: (USAFLS)< > + +Thursday, March 24, 2011 4:13 PM + +FW: jeffrey epstein prosecution -CONTACT FROM NEWSWEEK + +Importance: High + +Hi — This is why I don't want to ask for more time. The only way that I have to defend myself is through the court + +system. + +Assistant U.S. Attorne + +Fax + +Ori inal Messa e + +From: . (USAFLS) Sent: Thursda , March 24, 2011 4:12 PM + +To: USAFLS + +Cc: (USAFLS); (USAFLS) + +Subject: FW: jeffrey epstein prosecution -CONTACT FROM NEWSWEEK + +Importance: High + +— This just arrived. Why do they always wait until 2 minutes before their deadline to contact us99999 I did not fail to call her back, I referred the matter to you. Can you please handle this. Making clear that all allegations raised by Epstein's team were investigated by DOJ and found to be completely meritless. You might also add that Epstein had previously + +made false allegations against the Palm Beach Police Chief. + +Assistant U.S. Attorne + +Fax + +----Original Message From: Aitken, Lee (mailto + +Sent: Thursda , March 24, 2011 4:07 PM To: . (USAFLS) Subject: jeffrey epstein prosecution + +Dear Ms. + +I am an editor at both Newsweek and the Daily Beast website. I left a phone message last week but have not received a call back. Now we are facing a deadline for posting on the Daily Beast tonight, so I'd like to give you another chance to respond to our query. We have obtained a five-page letter you wrote to attorney Jay Lefkowitz on December 13, 2007 protesting charges of misconduct on your part and laying out several details about your interactions with Jeffrey Epstein's legal team. Your co-signer, Alex Accosta, has already acknowledged the vaiidity of this letter, but I would also like you to confirm that it came from your office. If you have any further comment to make about it or facts to add about this case I would love to hear back from you right away. We plan to post a story about the negotiations behind the Non-Prosecution + +agreement at 8 pm this evening. + +Thank you for your time and prompt attention, Lee Aitken + +From: (USAFLS) Sent: Thursday, March 24, 2011 4:16 PM + +To: Brad Edwards + +Subject: FW: jeffrey epstein prosecution + +FYI + +Assistant U.S. Attorne + +Fax + +Original Message From: Aitken, Lee (mailto + +Sent: Thursda , March 24, 2011 4:07 PM To: . (USAFLS) Subject: jeffrey epstein prosecution + +Dear Ms. + +I am an editor at both Newsweek and the Daily Beast website. I left a phone message last week but have not received a call back. Now we are facing a deadline for posting on the Daily Beast tonight, so I'd like to give you another chance to respond to our query. We have obtained a five-page letter you wrote to attorney Jay Lefkowitz on December 13, 2007 protesting charges of misconduct on your part and laying out several details about your interactions with Jeffrey Epstein's legal team. Your co-signer, Alex Accosta, has already acknowledged the vaiidity of this letter, but I would also like you to confirm that it came from your office. If you have any further comment to make about it or facts to add about this case I would love to hear back from you right away. We plan to post a story about the negotiations behind the Non-Prosecution + +agreement at 8 pm this evening. + +From: (USAFLS) Sent: Thursday, March 24, 2011 4:12 PM + +To: (USAFLS) + +Cc: (USAFLS); (USAFLS) + +Subject: FW: jeffrey epstein prosecution -CONTACT FROM NEWSWEEK + +Importance: High + +-- This just arrived. Why do they always wait until 2 minutes before their deadline to contact us99999 I did not fail to call her back, I referred the matter to you. Can you please handle this. Making clear that all allegations raised by Epstein's team were investigated by DOJ and found to be completely meritless. You might also add that Epstein had previously + +made false allegations against the Palm Beach Police Chief. + +I would love to know how they got the letter, but they probably will not tell you their source. + +Assistant U.S. Attorne + +Fax + +Original Message From: Aitken, Lee (mailto + +Sent: Thursda , March 24, 2011 4:07 PM To: . (USAFLS) Subject: jeffrey epstein prosecution + +Dear Ms. + +I am an editor at both Newsweek and the Daily Beast website. I left a phone message last week but have not received a call back. Now we are facing a deadline for posting on the Daily Beast tonight, so I'd like to give you another chance to respond to our query. We have obtained a five-page letter you wrote to attorney Jay Lefkowitz on December 13, 2007 protesting charges of misconduct on your part and laying out several details about your interactions with Jeffrey Epstein's legal team. Your co-signer, Alex Accosta, has already acknowledged the vaiidity of this letter, but I would also like you to confirm that it came from your office. If you have any further comment to make about it or facts to add about this case I would love to hear back from you right away. We plan to post a story about the negotiations behind the Non-Prosecution + +agreement at 8 pm this evening. + +Thank you for your time and prompt attention, Lee Aitken + +From: (USAFLS) Sent: Tuesday, March 22, 2011 10:11 AM + +To: + +Subject: FW: Filings from Cassell + +Attachments: DE51\_20110321\_Motion to use correspondence and unseal.pdf; DE49\_20110321\_Motion + +to Have Facts Accepted as True.pdf; DE50\_20110321\_Motn for Brady-type evidence.pdf; DE50-1\_20110321\_Exhibit Edwards Letter.pdf; DE50-2\_20110321\_Proposed Order.pdf; DE48 302.pdf; DE48 Victim notification Itr.pdf; DE48 victim notification Itrpdf; DE48-5\_20110321\_NPA.pdf; DE48-6\_20110321\_Twiler Itr to DE48-7\_20110321\_Twiler Itr to Jim Eisenberg + +I am back from the doctor. Here they all are (see below). After you have had a chance to look, can we discuss? I think that we need you on the team now. We made a few missteps early on, like conceding that this should be + +treated as a civil matter, which we tried to fix later, but it would help a lot if we had some guidance. + +Assistant U.S. Attorney + +Fax + +From: (USAFLS) Sent: Monda March 21, 2011 5:07 PM + +To: (USAFLS Cc: (USAFLS); Subject: Filings from Cassell + +Here they all are + +(USAFLS) + +(USAFLS); (USAFLS) + +«DE51\_20110321\_Motion to use correspondence and unseal.pdf>> «DE49\_20110321\_Motion to Have Facts Accepted + +as True.pdf>> <> «DE50-1 20110321 Exhibit Edwards Letter.pdf>> < «DE48-6\_20110321\_Twiler Rr to » «DE48-7\_20110321\_Twiler Itr to Jim Eisenbe for > «DE48-8 20110321 302 of from Jan 2008.pdf>> «DE48-9\_20110321\_Twiler lb.to + +> < + +Sent: Tuesday, March 22, 2011 12:59 PM To: . (USAFLS) + +Subject: Telephone call + +Telephone call fm John Pasanti, Daily Business Review re: Epstein filing of 3/21/2011. I referred + +him to + +From: (USAFLS)< > + +Sent: Thursday, March 24, 2011 5:09 PM + +To: . (USAFLS); (USAFLS); (USAFLS); (USAFLS) + +Cc: (USAFLS) + +----Ori inal Messa e--- + +From: . (USAFLS) Sent: Thursda , March 24, 2011 5:07 PM + +To: , (USAFLS); . (USAFLS); (USAFLS); (USAFLS) + +Cc: (USAFLS) + +Subject: RE: Jeffrey epstein prosecution -CONTACT FROM NEWSWEEK + +Please add the capitalized language (below). + +I am trying to find letter to them. + +Assistant U.S. Attorne + +Fax + +-----Ori inal Message + +From: , (USAFLS) + +Sent: Thursda , March 24, 2011 4:57 PM + +To: . (USAFLS), (USAFLS); Cc: (USAFLS); (USAFLS) + +Subject: RE: Jeffrey epstein prosecution -CONTACT FROM NEWSWEEK + +Proposed SDFL (non)response: + +(USAFLS) + +As you know from your communications with the DOJ's Office of Public Affairs, the defense in this case asked for an independent DOJ review of all facts, circumstances and allegations surrounding this prosecution. The Office of the Deputy + +Attorney General did in fact review the case, which is not uncommon, and determined that NO MISCONDUCT OCCURRED AND THAT prosecutorial discretion in the case appropriately rested with the U.S. Attorney's Office. + +If you agree, I need to run this by DOJ. DOJ already provided the following comment -- but ours is slightly different (ergo, the need to run it by them) DOJ response: The Office of the Deputy Attorney General did review the case, which is not uncommon, and determined that prosecutorial discretion in the case appropriately rested with the U.S. Attorney's Office. (Off the record, note "review' would be the appropriate word, not "negotiate".) In terms of a boss, the U.S. Attorneys' + +Offices report through the Office of the Deputy Attorney General (at the time, Mark Filip was the DAG.) + +Ori inal Messa e-- + +From: . (USAFLS) Sent: Thursda , March 24, 2011 4:12 PM + +To: USAFLS + +Cc: (USAFLS); (USAFLS) + +Subject: FW: jeffrey epstein prosecution -CONTACT FROM NEWSWEEK + +Importance: High + +— This just arrived. Why do they always wait until 2 minutes before their deadline to contact us99999 I did not fail to call her back, I referred the matter to you. Can you please handle this. Making clear that all allegations raised by Epstein's team were investigated by DOJ and found to be completely meritless. You might also add that Epstein had previously + +made false allegations against the Palm Beach Police Chief. + +I would love to know how they got the letter, but they probably will not tell you their source. + +----Original Message From: Aitken, Lee [mailto + +Sent: Thursda , March 24, 2011 4:07 PM To: .(USAFLS) Subject: Jeffrey epstein prosecution + +Dear Ms. + +I am an editor at both Newsweek and the Daily Beast website. I left a phone message last week but have not received a call back. Now we are facing a deadline for posting on the Daily Beast tonight, so I'd like to give you another chance to respond to our query. We have obtained a five-page letter you wrote to attorney Jay Lefkowitz on December 13, 2007 protesting charges of misconduct on your part and laying out several details about your interactions with Jeffrey Epstein's legal team. Your co-signer, Alex Accosta, has already acknowledged the vaiidity of this letter, but I would also like you to confirm that it came from your office. If you have any further comment to make about it or facts to add about this case I would love to hear back from you right away. We plan to post a story about the negotiations behind the Non-Prosecution + +agreement at 8 pm this evening. + +Thank you for your time and prompt attention, Lee Aitken + +From: (USAFLS) ‹ > + +Sent: Thursday, March 24, 2011 5:13 PM + +To: (USAFLS); (USAFLS); + +(USAFLS) + +Cc: (USAFLS) + +Subject: RE: jeffrey epstein prosecution -CONTACT FROM NEWSWEEK + +How about giving them the letter??? + +Assistant U.S. Attorne + +Fax + +----OrigirS Message + +From: MI, (USAFLS) + +Sent Thursda , March 24, 2011 5:09 PM + +To: (USAFLS); . (USAFLS); (USAFLS); + +(USAFLS) + +Cc: (USAFLS) + +Subject: RE: Jeffrey epstein prosecution -CONTACT FROM NEWSWEEK + +(USAFLS); + +I understand why you want that, and I would love to include it, but that is beyond the response DOJ gave to Conchita. I will + +have to run this by them. + +Any other thoughts before I send this to DOJ?? + +----Ori inal Messa e--- + +From: . (USAFLS) Sent: Thursda , March 24, 2011 5:07 PM + +To: , (USAFLS); . (USAFLS); (USAFLS); (USAFLS) + +I am trying to find letter to them. + +Assistant U.S. Attorne + +Fax + +Original Message + +(USAFLS) + +March 24, 2011 4:57 PM + +.(USAFLS): (USAFLS); + +(USAFLS); (USAFLS) Subject: RE: jeffrey epstein prosecution -CONTACT FROM NEWSWEEK + +Proposed SDFL (non)response: + +(USAFLS) + +As you know from your communications with the DOJ's Office of Public Affairs, the defense in this case asked for an independent DOJ review of all facts, circumstances and allegations surrounding this prosecution. The Office of the Deputy + +Attorney General did in fact review the case, which is not uncommon, and determined that NO MISCONDUCT OCCURRED AND THAT prosecutorial discretion in the case appropriately rested with the U.S. Attorney's Office. + +If you agree, I need to run this by DOJ. DOJ already provided the following comment -- but ours is slightly different (ergo, the need to run it by them) DOJ response: The Office of the Deputy Attorney General did review the case, which is not uncommon, and determined that prosecutorial discretion in the case appropriately rested with the U.S. Attorney's Office. (Off the record, note "review' would be the appropriate word, not "negotiate".) In terms of a boss, the U.S. Attorneys' + +Offices report through the Office of the Deputy Attorney General (at the time, Mark Filip was the DAG.) + +Ori inal Messa e + +From: . (USAFLS) Sent: Thursda , March 24, 2011 4:12 PM + +To: . USAFLS + +Cc: (USAFLS); (USAFLS) + +Subject: FW: jeffrey epstein prosecution -CONTACT FROM NEWSWEEK + +Importance: High + +-- This just arrived. Why do they always wait until 2 minutes before their deadline to contact us99999 I did not fail to call her back, I referred the matter to you. Can you please handle this. Making clear that all allegations raised by Epstein's team were investigated by DOJ and found to be completely meritless. You might also add that Epstein had previously + +made false allegations against the Palm Beach Police Chief. + +I would love to know how they got the letter, but they probably will not tell you their source. + +Assistant U.S. Attorne + +Fax + +----Original Message From: Aitken, Lee [mailto + +Sent: Thursda March 24. 2011 4:07 PM To: . (USAFLS) Subject: jeffrey epstein prosecution + +Dear Ms. -- + +I am an editor at both Newsweek and the Daily Beast website. I left a phone message last week but have not received a call back. Now we are facing a deadline for posting on the Daily Beast tonight, so I'd like to give you another chance to respond to our query. We have obtained a five-page letter you wrote to attorney Jay Lefkowitz on December 13, 2007 protesting charges of misconduct on your part and laying out several details about your interactions with Jeffrey Epstein's legal team. Your co-signer, Alex Accosta, has already acknowledged the vaiidity of this letter, but I would also like you to confirm that it came from your office. If you have any further comment to make about it or facts to add about this case I would love to hear back from you right away. We plan to post a story about the negotiations behind the Non-Prosecution + +agreement at 8 pm this evening. + +Thank you for your time and prompt attention, Lee Aitken + +From: + +Sent: Monday, March 28, 2011 9:43 AM To: . (USAFLS); + +Subject: RE: Emailing: CVRA Omnibus Response.wpd + +Let me know when you want to chat and I'll make myself available. + +United States Department of Justice Criminal Division. Appellate Section + +tel: fax: + +Ori inal Messa e + +From: . (USAFLS) [mailto: + +Sent: Monda March 28. 2011 9:36 AM To: (USAFLS) + +Subject: RE: Emailing: CVRA Omnibus Response.wpd + +Hi MI and -- Just read all of your emails from yesterday. + +(USAFLS) + +-- I think that, having read more cases, and then re-read the Department's guidance, that our position should be that + +the petitioners are not entitled to file a civil cause of action, even for a declaratory judgment. The statute provides them with a remedy, which is a referral of DOJ attomeys for disciplinary sanctions, and specifies that "the Attorney General, or the designee of the Attorney General, shall be the final arbiter of the complaint, and that there shall be no judicial review of + +the final decision of the Attorney General by the complainant." (18 USC 3771(f)(2)(D)) "Where a statute expressly provides a particular remedy or remedies, a court must be chary of reading others into it." U.S. v. Aguirre-Gonzalez, 597 + +F.3d 46, 54 (1st Cir. 2010) (quoting TAMA v. Lewis, 444 U.S. 11, 19 (1979)). + +Why don't we get together tomorrow face-to-face and talk it through? I can come down to Miami. + +-- maybe we can steal you for 30 minutes just to bounce some ideas off of you? + +Assistant U.S. Attorne + +---Ori inal Mess e— + +From: + +Sent: Monde March 28, 2011 8:18 AM + +To: (USAFLS); (USAFLS) Subject: RE: Emailing: CVRA Omnibus Response.wpd + +All, + +This is going to be a rou h week for me work-wise so here's a suggestion. If, as email says, the due date is 4/7, perhaps you can work up whatever you want me to look at this week and then I can make some comments as of next Monday, 4/4. If you don't think that will + +work or if you need comments earlier, I can try to work on it next weekend. I am just inundated right now and have an Eleventh Circuit argument on Friday, so I am going to be out of pocket much of this week. + +Let me know your thoughts. + +••••••••••••••••••••••••••.•••••••••••• + +United States Department of Justice Criminal Division. ellate Section + +tel: fax: + +Ori inal Message + +From: (USAFLS) [main° Sent: Sunda , March 27, 2011 1:44 PM To: . (USAFLS). + +Subject: RE: Emailing: CVRA Omnibus Response.wpd + +I am working on our response to their material "facts," which really aren't facts at all. I should have these done by today. I will then move on to the legal argument. I was considering responding to each + +motion separately, to make it easier for the court. + +P.S. Our deadline is April 7, 2011. + +----Ori inal Messa e-- + +From: . (USAFLS) Sent: Sunda , March 27, 2011 1:31 PM + +To: (USAFLS); + +Subject: Emailing: CVRA Omnibus Response.wpd + +the CVRA in a habeas/Rule 35 type claim. I think that is a good example of how the CVRA, as Cassell sees it, could be abused. Since every assault on a federal prisoner is a federal crime, federal defendants could demand meetings with AUSAs claiming that they were assaulted (whether or not the assaults actually occurred) and, even if the USAO decided to defer to administrative authorities, i.e., the Bureau of + +Prisons, according to Cassell, we would be forced to go meet with them. + +I also have found good language in several cases that suggest that the Petitioners' failure to prosecute the case will end up being a second reason to dismiss the petition. Cassell will, no doubt, try to pin the blame on us, but they had no contact with us for over a year while they were pursuing their civil claims against Epstein. In the meantime, Epstein finished serving his entire criminal sentence. And now they want to try to attack the "plea" agreement. There is good language about the need for finality in criminal proceedings that should help + +with that. + +Talk to you all on Monday. + +Thanks. + +The message is ready to be sent with the following file or link + +attachments: + +CVRA Omnibus Response.wpd + +Note: To protect against computer viruses, e-mail programs may prevent sending or receiving certain types of file attachments. Check your e-mail security settings to determine how attachments are handled. + +From: (USAFLS) < + +Sent: Monday, March 28, 2011 10:10 AM To: . (USAFLS); + +Cc: (USAFLS) + +Subject: RE: Emailing: CVRA Omnibus Response.wpd + +I will be here tomorrow. The argument you suggest has a number of problems. First, there is a presumption in favor of judicial review of administrative action. McNary v. Haitian Refugee Center, Inc., 498 U.S. 479, 498 (1986). Second, since Congress establishes the subject matter jurisdiction of the lower federal courts, we would have to demonstrate that it intended section 3771(f) to be the exclusive remedy for a putative victim claiming a violation of the CVRA. There is nothing explicit in the text of section 3771 that supports that proposition. Moreover, arguing that an aggrieved person can only file an administrative complaint with the federal agency that allegedly deprived him or her of his rights under the CVRA is an + +argument that is likely to be viewed with much judicial skepticism. + +Section 3771(d)(3) expressly provides that the rights in section 3771(a) can be asserted in the criminal case, or in the district where the crime occurred if no prosecution is underway. We would have to argue that, where there is no + +prosecution underway, the only remedy is to file an administrative complaint with the DOJ. That conflicts with the language of section 3771(d)(3), which permits a putative victim to file a motion in the district where the crime occurred. I recognize the DOJ has a view on what that provision means, but that argument is not based upon the existence of an exclusive + +administrative remedy. + +Hi and -- Just read all of your emails from yesterday. + +-- I think that, having read more cases, and then re-read the Department's guidance, that our position should be that + +the petitioners are not entitled to file a civil cause of action, even for a declaratory judgment. The statute provides them with a remedy, which is a referral of DOJ attorneys for disciplinary sanctions, and specifies that "the Attorney General, or the designee of the Attorney General, shall be the final arbiter of the complaint, and that there shall be no judicial review of + +the final decision of the Attorney General by the complainant." (18 USC 3771(f)(2)(D)) "Where a statute expressly provides a particular remedy or remedies, a court must be chary of reading others into it." U.S. v. Aguirre-Gonzalez, 597 + +F.3d 46, 54 (1st Cir. 2010) (quoting TAMA v. Lewis, 444 U.S. 11, 19 (1979)). + +Why don't we get together tomorrow face-to-face and talk it through? I can come down to Miami. + +-- maybe we can steal you for 30 minutes just to bounce some ideas off of you? + +Assistant U.S. Attorne + +Fax + +Ori inal Messa e From: ) + +Sent: Monda March 28, 2011 8:18 AM + +To: (USAFLS); . (USAFLS) Subject: RE: Emailing: CVRA Omnibus Response.wpd + +All, + +This is going to becalh week for me work-wise so here's a suggestion. If, as email says, the due date is 4/7, perhaps you can work up whatever you want me to look at this week and then I can make some comments as of next Monday, 4/4. If you don't think that will + +work or if you need comments earlier, I can try to work on it next weekend. I am just inundated right now and have an Eleventh Circuit argument on Friday, so I am going to be out of pocket much of this week. + +Let me know your thoughts. + +United States Department of Justice Criminal Division. Appellate Section + +tel: fax: + +I am working on our response to their material "facts," which really aren't facts at all. I should have these done by today. I will then move on to the legal argument. I was considering responding to each + +motion separately, to make it easier for the court. + +P.S. Our deadline is April 7, 2011. + +Ori inal Messa e + +From: . (USAFLS) Sent: Sunda . March 27. 2011 1:31 PM + +To: (USAFLS); + +Subject: Emailing: CVRA Omnibus Response.wpd + +Hi and MI + +Obviously, this is just a rough draft of an introduction. I have been side-tracked by research. I found a case where a prisoner tried to use the CVRA in a habeas/Rule 35 type claim. I think that is a good example of how the CVRA, as Cassell sees it, could be abused. Since every assault on a federal prisoner is a federal crime, federal defendants could demand meetings with AUSAs claiming that they were assaulted (whether or not the assaults actually occurred) and, even if the USAO decided to defer to administrative authorities, i.e., the Bureau of + +Prisons, according to Cassell, we would be forced to go meet with them. + +I also have found good language in several cases that suggest that the Petitioners' failure to prosecute the case will end up being a second reason to dismiss the petition. Cassell will, no doubt, try to pin the blame on us, but they had no contact with us for over a year while they were pursuing their civil claims against Epstein. In the meantime, Epstein finished serving his entire criminal sentence. And now they want to try to attack the "plea" agreement. There is good language about the need for finality in criminal proceedings that should help + +with that. + +Talk to you all on Monday. + +Thanks. + +The message is ready to be sent with the following file or link + +attachments: + +CVRA Omnibus Response.wpd + +Note: To protect against computer viruses, e-mail programs may prevent sending or receiving certain types of file attachments. Check your e-mail security settings to determine how attachments are handled. + +All, + +This is going to be a rough week for me work-wise so here's a suggestion. If, as email says, the due date is 4/7, perhaps you can work up whatever you want me to look at this week and then I can make some comments as of next Monday, 4/4. If you don't think that will work or if you need comments earlier, I can try to work on it next weekend. I am just inundated right now and have an Eleventh Circuit argument on Friday, so I am going to be out of pocket much of this + +week. + +Let me know your thoughts. + +United States Department of Justice Criminal Division, Appellate Section + +tel: fax: + +----Ori inal Message + +From: (USAFLS) (mailto Sent: Sunda , March 27, 2011 1:44 PM To: . (USAFLS); + +Subject: RE: Emailing: CVRA Omnibus Response.wpd + +I am working on our response to their material "facts," which really aren't facts at all. I should have these done by today. I will then move on to the legal argument. I was considering responding to each + +motion separately, to make it easier for the court. + +P.S. Our deadline is April 7, 2011. + +----Ori inal Messa e-- + +From: . (USAFLS) Sent: Sunda , March 27, 2011 1:31 PM + +To: (USAFLS); + +Subject: Emailing: CVRA Omnibus Response.wpd + +Hi and MI + +Obviously, this is just a rough draft of an introduction. I have been side-tracked by research. I found a case where a prisoner tried to use the CVRA in a habeas/Rule 35 type claim. I think that is a good example of how the CVRA, as Cassell sees it, could be abused. Since every assault on a federal prisoner is a federal crime, federal defendants could demand meetings with AUSAs claiming that they were assaulted (whether or not the assaults actually occurred) and, even if the USAO decided to defer to administrative authorities, i.e., the Bureau of + +Prisons, according to Cassell, we would be forced to go meet with them. + +I also have found good language in several cases that suggest that the Petitioners' failure to prosecute the case will end up being a second reason to dismiss the petition. Cassell will, no doubt, try to pin the blame on us, but they had no contact with us for over a year while they were pursuing their civil claims against Epstein. In the meantime, Epstein finished serving his entire criminal sentence. And now they want to try to attack the "plea" agreement. There is good language about the need for finality in criminal proceedings that should help + +with that. + +Talk to you all on Monday. + +Thanks. + +The message is ready to be sent with the following file or link + +attachments: + +CVRA Omnibus Response.wpd + +Note: To protect against computer viruses, e-mail programs may prevent sending or receiving certain types of file attachments. Check your e-mail security settings to determine how attachments are handled. + +From: + +Sent: Sunday, March 27, 2011 3:15 PM + +To: (USAFLS); . (USAFLS) + +Subject: RE: Emailing: CVRA Omnibus Response.wpd + +Good points. + +•••••••••••••••••••••••••••••••••••••• + +United States Department of Justice Criminal Division, Appellate Section + +tel: fax: + +----Ori inal Message + +From: (USAFLS) (mailto Sent: Sunda , March 27, 2011 2:50 PM + +To: (USAFLS) Subject: RE: Emailing: CVRA Omnibus Response.wpd + +Another point is that the non-prosecution agreement would not be subject to any judicial approval, absent a claim by one of the parties to the agreement that a breach had occurred. Unlike Dean, the government never contemplated any charge being filed in the district court, nor did it seek a dispensation from the court to limit the number of victims it would contact. In Dean, there was ultimately a charge and a plea agreement for the court to review. In our case, there was neither. + +United States Department of Justice Criminal Division, Appellate Section + +tel: fax: + +Ori inal Message + +From: (USAFLS) [mailto + +To: + +Sent: Sunda . March 27. 2011 1:58 PM + +(USAFLS) + +Subject: RE: Emailing: CVRA Omnibus Response.wpd + +and + +18 U.S.C. 3771(d)(6) provides there is no cause of action for damages. From a civil attomey's viewpoint, damages means money damages. Therefore, a victim cannot sue the United States Government, or an official of the U.S. Government, for money damages, based on a claim + +that their rights under the CVRA were violated. + +Not having a cause of action for damages does not mean you cannot assert + +that your CVRA rights were violated, and you are entitled to non-monetary relief. Also, 18 U.S.C. 3771(d)(3) provides that, in cases where a criminal case has not been filed ("if no prosecution is underway"), the victim can file a motion for relief in the district court in the district in which the crime occurred. This plainly + +suggests that Congress intended a putative victim to have a forum where he could address his claim that his/her CVRA rights have been violated + +by the Government + +---Ori inal Messa e + +From: ) + +Sent: Sunda . March 27, 2011 1:49 PM + +To: . (USAFLS); (USAFLS) Subject: RE: Emailing: CVRA Omnibus Response.wpd + +PS - Real quick, but the CVRA says it doesn't create a cause of action + +"for damages? My instinct is that we should emphasize the + +prosecutorial discretion angle over the "no cause of action" language of + +the CVRA, but I will do a little more digging. + +United States Department of Justice Criminal Division. Appellate Section + +Assistant U.S. Attorne + +Fax + +Ori inal Messa e From: ) + +Sent: Monda , March 28, 2011 8:18 AM + +To: (USAFLS); . (USAFLS) Subject: RE: Emailing: CVRA Omnibus Response.wpd + +All, + +This is going to be a rou h week for me work-wise so here's a suggestion. If, as email says, the due date is 4/7, perhaps you can work up whatever you want me to look at this week and then I can make some comments as of next Monday, 4/4. If you don't think that will + +work or if you need comments earlier, I can try to work on it next weekend. I am just inundated right now and have an Eleventh Circuit argument on Friday, so I am going to be out of pocket much of this week. + +Let me know your thoughts. + +MN + +United States Department of Justice Criminal Division, Appellate Section + +tel: fax: + +Ori inal Message + +From: (USAFLS) [mailto Sent: Sunda . March 27. 2011 1:44 PM To: . (USAFLS); + +Subject: RE: Emailing: CVRA Omnibus Response.wpd + +I am working on our response to their material "facts," which really aren't facts at all. I should have these done by today. I will then move on to the legal argument. I was considering responding to each + +motion separately, to make it easier for the court. + +From: . (USAFLS) Sent: Sunda . March 27. 2011 1:31 PM + +To: (USAFLS); + +Subject: Emailing: CVRA Omnibus Response.wpd + +Hi and MI + +Obviously, this is just a rough draft of an introduction. I have been side-tracked by research. I found a case where a prisoner tried to use the CVRA in a habeas/Rule 35 type claim. I think that is a good example of how the CVRA, as Cassell sees it, could be abused. Since every assault on a federal prisoner is a federal crime, federal defendants could demand meetings with AUSAs claiming that they were assaulted (whether or not the assaults actually occurred) and, even if the USAO decided to defer to administrative authorities, i.e., the Bureau of + +Prisons, according to Cassell, we would be forced to go meet with them. + +I also have found good language in several cases that suggest that the Petitioners' failure to prosecute the case will end up being a second reason to dismiss the petition. Cassell will, no doubt, try to pin the blame on us, but they had no contact with us for over a year while they were pursuing their civil claims against Epstein. In the meantime, Epstein finished serving his entire criminal sentence. And now they want to try to attack the "plea" agreement. There is good language about the need for finality in criminal proceedings that should help + +with that. + +Talk to you all on Monday. + +Thanks. + +The message is ready to be sent with the following file or link + +attachments: + +CVRA Omnibus Response.wpd + +Note: To protect against computer viruses, e-mail programs may prevent sending or receiving certain types of file attachments. Check your e-mail security settings to determine how attachments are handled. + +From: (USAFLS) < + +Sent: Monday, March 28, 20119:23 AM + +To: ); + +Subject: RE: Emailing: CVRA Omnibus Response.wpd + +. (USAFLS) + +I believe we can deliver to you a near-finished product by Saturday, April 2. I will be working on our response the next two + +days, but have to go to the NAC on Wednesday and Thursday. + +Ori inal Messa e From: ) + +Sent: Monda March 28, 2011 8:18 AM + +All, + +This is going to be a rough week for me work-wise so here's a suggestion. If, as email says, the due date is 4/7, perhaps you can work up whatever you want me to look at this week and then I can make some comments as of next Monday, 4/4. If you don't think that will work or if you need comments earlier, I can try to work on it next weekend. I am just inundated right now and have an Eleventh Circuit argument on Friday, so I am going to be out of pocket much of this + +week. + +Let me know your thoughts. + +••••••••••••••••••••••••• + +United States Department of Justice Criminal Division, Appellate Section + +tel: fax: + +-----Ori inal Message + +From: (USAFLS) (mailto Sent: Sunda , March 27, 2011 1:44 PM To: . (USAFLS); + +Subject: RE: Emailing: CVRA Omnibus Response.wpd + +I am working on our response to their material "facts," which really aren't facts at all. I should have these done by today. I will then move on to the legal argument. I was considering responding to each + +motion separately, to make it easier for the court. + +P.S. Our deadline is April 7, 2011. + +----Ori inal Messa e + +From: . (USAFLS) Sent: Sunda March 27, 2011 1:31 PM + +To: (USAFLS); + +Subject: Emailing: CVRA Omnibus Response.wpd + +Hi and + +Obviously, this is just a rough draft of an introduction. I have been side-tracked by research. I found a case where a prisoner tried to use the CVRA in a habeas/Rule 35 type claim. I think that is a good example of how the CVRA, as Cassell sees it, could be abused. Since every assault on a federal prisoner is a federal crime, federal defendants could demand meetings with AUSAs claiming that they were assaulted (whether or not the assaults actually occurred) and, even if the USAO decided to defer to administrative authorities, i.e., the Bureau of + +Prisons, according to Cassell, we would be forced to go meet with them. + +I also have found good language in several cases that suggest that the Petitioners' failure to prosecute the case will end up being a second reason to dismiss the petition. Cassell will, no doubt, try to pin the blame on us, but they had no contact with us for over a year while they were pursuing their civil claims against Epstein. In the meantime, Epstein finished serving his entire criminal sentence. And now they want to try to attack the "plea" agreement. There is good language about the need for finality in criminal proceedings that should help + +with that. + +Talk to you all on Monday. + +Thanks. + +The message is ready to be sent with the following file or link + +attachments: + +CVRA Omnibus Response.wpd + +Note: To protect against computer viruses, e-mail programs may prevent sending or receiving certain types of file attachments. Check your e-mail security settings to determine how attachments are handled. + +From: (USAFLS) Sent: Wednesday, March 30, 2011 2:09 PM + +To: (CRT) + +Subject: RE: + +Ohhhh — Tell Hill!!! I adore her too! I only worked one case with her and she is super-smart + +and + +rt + +dedicated. I have known for around 15 years. + +Tell that I am still working on an Epstein motion now. She will know what I mean. + +EJ is still in temporary housing. But we will both stay in touch. + +Assistant U.S. Attorney + +From: (CRT) + +Sent: Wednesda March 30, 2011 2:06 PM + +To: . (USAFLS) + +Subject: RE: + +I know of but have never met her. I believe she is in appellate. I was talking about + +Braden! Am happy to speak with any of your friends about DC. We love it and it's a cool town....but + +not great for single women as my single girlfriends have told me :-) + +I am so sorry to hear about your torn cartilage. How did you manage to do that? Is the surgery laser + +or invasive? That really stinks. + +Well, EJ better be taking good care of you! You are the best thing that's ever happened to him besides + +my friendship (joke). Seriously, I hope he is not too stressed and taking good care of you. Is he + +enjoying Colombia? How are his living quarters? + +Stay in touch! + +From: (USAFLS) Sent: Wednesda , March 30, 2011 2:01 PM + +To: (CRT) + +Subject: RE: + +Well, I hope it was , whom I adore. She is one of the finest people I know. A good + +heart and honest through and through. + +I hope that you are doing well, I have another friend who is talking about going to DC and if + +she does, I will definitely put her in touch with you. + +These budget cuts and everything are working havoc with for us and I just found out that I have torn cartilage in my hip and have to have surgery. So, yes, I am doing the split time, but luckily EJ has had to be here in Miami for the past week and has been home so I haven't had to sit in an uncomfortable + +airplane seat for 31/2 hours each way. + +Fax + +From: (CRT) + +Sent: Wednesda March 30, 2011 1:57 PM + +To: . (USAFLS) + +Subject: + +Hi + +Just wanted to say hi and see how you were doing? EJ told me that you guys are sort of doing the split + +time in US/Colombia. How is that working out? I was talking with one of my favorite people in the office and she mentioned your name. We got to talking and came to the conclusion that we both + +thought you were terrific. Any idea who it was I was talking to here in my office? + +MI, Trial Attorney + +Civil Rights Division, Criminal Section + +- direct + +- fax + +From: (USAFLS) < Sent: Wednesday, March 30, 2011 1:09 PM + +To: (USAFLS); (USAFLS); (USAFLS); + +(USAFLS) + +Cc: (USAFLS); (USAFLS) + +Subject: Article in today's Palm Beach Daily News + +Attachments: jeffrey-epstein-attorney.pdf + +A response by Roy Black to Alex's letter. I note that this is an extrajudicial statement by Roy Black where he says, without any qualifying statement that it was their opinion or belief, that "We did point out misconduct and over-reaching by certain people involved in the investigation. . . . There will always be people who abuse the + +From: + +Sent: Wednesday, March 30, 2011 2:34 PM To: (USAFLS) + +Subject: RE: Article in today's Palm Beach Daily News + +"Finally Mr. Acosta mentions we looked for personal peccadilloes of prosecutors," Black said. "I am not + +sure what he refers to but this never happened. We did point out misconduct and over-reaching by + +certain people involved in the investigation. Not only is there nothing wrong with this but it is a + +necessary + +part of the process. There will always be people who abuse the great power of the government and we + +cannot stand by silently when it occurs." + +Hmmm. I sure wish I had the correspondence claiming that I should be recused because of my + +daughter's case. + +Esq. + +The Ferraro Law Firm + +4000 Ponce de Leon Blvd. + +Suite 700 + +Miami, FL 33146 + +Website: w-ww.ferrarolaw.com + +Toll-Free 800-275-3332 + +Tel: (305) 375-0111 + +Fax: (305) 379-6222 + +jhs@ferrarolaw.com + +Confidentiality Notice: The information contained in this transmittal, including any attachment, is + +privileged and confidential and is intended only for the person or entity to whom it is addressed. If you are neither the intended recipient nor the employee or agent responsible for delivering this message to the intended recipient, you are hereby notified that any disclosure, copying or distribution or the taking of any action in reliance on the contents of this transmittal is strictly prohibited. If you have received this transmittal in error, please contact the sender immediately and delete this transmittal from any + +computer or other data bank. + +From: (USAFLS) [mailto: Sent: Wednesci.Aarch 30, 2011 2:26 PM + +To: + +Subject: FW: Article in today's Palm Beach Daily News + +Hi - The slander is against you and (mainly) me. + +Assistant U.S. Attorney + +Fax + +From: (USAFLS) Sent: Wednesda March 30, 2011 1:09 PM + +To: . (USAFLS); (USAFLS); (USAFLS); + +Cc: (USAFLS); (USAFLS) Subject: Article in today's Palm Beach Daily News + +A response by Roy Black to Alex's letter. I note that this is an extrajudicial statement by Roy Black where he says, without any qualifying statement that it was their opinion or belief, that "We did point out misconduct and over-reaching by certain people involved in the investigation. . . . There will + +always be people who abuse the great power of the government . . ." + +«jeffrey-epstein-attorney.pdf» + +From: Sent: To: Subject: (USAFLS) + +Wednesday, March 30, 2011 2:26 PM + +FW: Article in today's Palm Beach Daily News + +I I i The slander is against you and (mainly) me. + +Assistant U.S. Attorney + +Fax + +From: (USAFLS) Sent: Wednesda March 30, 2011 1:09 PM + +To: . (USAFLS + +Cc: (USAFLS); (USAFLS) Subject: Article in today's Palm Beach Daily News + +(USAFLS); (USAFLS); (USAFLS) + +A response by Roy Black to Alex's letter. I note that this is an extrajudicial statement by Roy Black where he says, without any qualifying statement that it was their opinion or belief, that "We did point out misconduct and over-reaching by certain people involved in the investigation. . . . There will always be people who abuse the + +great power of the government . . ." + +> + +From: Sent: To: Subject: Attachments: (USAFLS) + +Wednesday, March 30, 2011 10:01 PM (USAFLS); Emailing: Mootness section.wpd + +Mootness section.wpd + +«Mootness section.wpd» Hi a and + +Here is a section addressing the failure to prosecute/"mootness" issue. + +1 + +-- One issue for you. I think that we need to provide evidence on two things: (1) for this section, we need to put in + +the dates that Epstein was released from jail and from community control and (2) for the section on "hey, we didn't violate the CVRA, we went above and beyond" I want to put in my letter to PBSO asking them to tell me when he was released so I could do victim notifications. We should be able to get all of that information from PBSO. We can get it either by a + +subpoena or a public records request. Which would you prefer to do? And who do you want to issue the + +riast/subpoena? Please let me know and I can draft it and get it out tomorrow. I don't think it should come from me, but or someone else here can do it for purposes of speed. FBI thinks that a subpoena would be better than a public + +records request in this instance. + +Thanks. + +To: (USAFIS); Cc: (USAFIS) + +Subject: RE: Emailing: CVRA Omnibus Response.wpd + +(USAFLS) + +Maybe the way to split the difference is to say that Ws his burden to show that there's a cause of action, and he hasn't done + +so, and that there are a number of good reasons, both textual and policy-wise, not to interpret the CVRA to create a freestanding cause of action, and that such a conclusion would not leave dissatisfied victims without any recourse because + +of the grievance process - or something along those lines. + +Textually, by the way, I'd say that the no prosecution Is underway" language does not open the courts to CVRA claims + +whenever no charges are brought but only applies post-complaint, pre-indictment, as the OLC memo says. + +United States Department of Justice Criminal Division, Appellate Section + +tel: fax: + +--Ori inal Message— + +From: (USAFLS) (mailto Sent: Monde , March 28, 2011 10:10AM To: . (USAFLS); Cc: (USAFLS) + +Subject: RE: Emailing: CVRA Omnibus Response.wpd + +I will be here tomorrow. The argument you suggest has a number of problems. First, there is a presumption in favor of judicial review of administrative action. McNary v. Haitian Refugee Center, Inc., 498 U.S. 479, 498 (1986). Second, since Congress establishes the subject matter jurisdiction of the lower federal courts, we would have to demonstrate that it intended section 3771(t) to be the exclusive remedy for a putative victim claiming a violation of the CVRA. There is nothing explicit in the text of section 3771 that supports that proposition. Moreover, arguing that an aggrieved person can only file an administrative complaint with the federal agency that allegedly deprived him or her of his rights under the CVRA is an + +argument that is likely to be viewed with much judicial skepticism. + +Section 3771(d)(3) expressly provides that the rights in section 3771(a) can be asserted in the criminal case, or in the district where the crime occurred if no prosecution is underway. We would have to argue that, where there is no + +prosecution underway, the only remedy is to file an administrative complaint with the DOJ. That conflicts with the language of section 3771(d)(3), which permits a putative victim to file a motion in the district where the crime occurred. I recognize the DOJ has a view on what that provision means, but that argument is not based upon the existence of an exclusive + +administrative remedy. + +On inal Messa e + +From: . (USAFLS) Sent: Monde March 28, 2011 9:36 AM + +To: ); (USAFLS) Subject: RE: Emailing: CVRA Omnibus Response.wpd + +-- I think that, having read more cases, and then re-read the Department's guidance, that our position should be that + +the petitioners are not entitled to file a civil cause of action, even for a declaratory judgment. The statute provides them with a remedy, which is a referral of DOJ attorneys for disciplinary sanctions, and specifies that "the Attorney General, or the designee of the Attorney General, shall be the final arbiter of the complaint, and that there shall be no judicial review of + +the final decision of the Attorney General by the complainant." (18 USC 3771(f)(2)(D)) "Where a statute expressly provides a particular remedy or remedies, a court must be chary of reading others into it." U.S. v. Aguirre-Gonzalez, 597 + +F.3d 46, 54 (1st Cir. 2010) (quoting TAMA v. Lewis, 444 U.S. 11, 19 (1979)). + +Why don't we get together tomorrow face-to-face and talk it through? I can come down to Miami. + +-- maybe we can steal you for 30 minutes just to bounce some ideas off of you? + +Assistant U.S. Attorne + +Fax + +Ori inal Messa e From: ) + +Sent: Monda . March 28, 2011 8:18 AM + +To: (USAFLS); . (USAFLS) Subject: RE: Emailing: CVRA Omnibus Response.wpd + +All, + +This is going to be a rau h week for me work-wise so here's a suggestion. If, as email says, the due date is 4/7, perhaps you can work up whatever you want me to look at this week and then I can make some comments as of next Monday, 4/4. If you don't think that will + +work or if you need comments earlier, I can try to work on it next weekend. I am just inundated right now and have an Eleventh Circuit argument on Friday, so I am going to be out of pocket much of this week. + +Let me know your thoughts. + +United States Department of Justice Criminal Division, Appellate Section + +tel: fax: + +Ori inal Message + +From: (USAFLS) (mailto Sent: Sunda . March 27. 2011 1:44 PM To: . (USAFLS); + +Subject: RE: Emailing: CVRA Omnibus Response.wpd + +I am working on our response to their material "facts," which really aren't facts at all. I should have these done by today. I will then move on to the legal argument. I was considering responding to each + +motion separately, to make it easier for the court. + +P.S. Our deadline is April 7, 2011. + +Ori inal Messa e + +From: . (USAFLS) Sent: Sunda . March 27. 2011 1:31 PM + +To: (USAFLS); + +Subject: Emailing: CVRA Omnibus Response.wpd + +Hi and MI + +Obviously, this is just a rough draft of an introduction. I have been side-tracked by research. I found a case where a prisoner tried to use the CVRA in a habeas/Rule 35 type claim. I think that is a good example of how the CVRA, as Cassell sees it, could be abused. Since every assault on a federal prisoner is a federal crime, federal defendants could demand meetings with AUSAs claiming that they were assaulted (whether or not the assaults actually occurred) and, even if the USAO decided to defer to administrative authorities, i.e., the Bureau of + +Prisons, according to Cassell, we would be forced to go meet with them. + +I also have found good language in several cases that suggest that the Petitioners' failure to prosecute the case will end up being a second reason to dismiss the petition. Cassell will, no doubt, try to pin the blame on us, but they had no contact with us for over a year while they were pursuing their civil claims against Epstein. In the meantime, Epstein finished serving his entire criminal sentence. And now they want to try to attack the "plea" agreement. There is good language about the need for finality in criminal proceedings that should help + +with that. + +Talk to you all on Monday. + +Thanks. + +The message is ready to be sent with the following file or link + +attachments: + +CVRA Omnibus Response.wpd + +Note: To protect against computer viruses, e-mail programs may prevent sending or receiving certain types of file attachments. Check your e-mail security settings to determine how attachments are handled. + +From: (USAFLS) ). + +Sent: Monday, March 28, 2011 10:10 AM + +To: + +Fax + +----Ori inal Messa e + +From: ) + +Sent: Monda , March 28, 2011 9:44 AM To: . (USAFLS) + +Subject: RE: Emailing: CVRA Omnibus Response.wpd + +Hey - Aguirre-Gonzalez that was my case!! + +United States Department of Justice Criminal Division. Appellate Section + +tel: fax: + +Ori inal Messa e + +From: . (USAFLS) [mailto: + +Sent: Monda March 28.2011 9:36 AM To: (USAFLS) + +Subject: RE: Emailing: CVRA Omnibus Response.wpd + +Hi MI and -- Just read all of your emails from yesterday. + +-- I think that, having read more cases, and then re-read the Department's guidance, that our position should be that + +the petitioners are not entitled to file a civil cause of action, even for a declaratory judgment. The statute provides them with a remedy, which is a referral of DOJ attorneys for disciplinary sanctions, and specifies that "the Attorney General, or the designee of the Attorney General, shall be the final arbiter of the complaint, and that there shall be no judicial review of + +the final decision of the Attorney General by the complainant." (18 USC 3771(f)(2)(D)) "Where a statute expressly provides a particular remedy or remedies, a court must be chary of reading others into it." U.S. v. Aguirre-Gonzalez, 597 + +F.3d 46, 54 (1st Cir. 2010) (quoting TAMA v. Lewis, 444 U.S. 11, 19 (1979)). + +Why don't we get together tomorrow face-to-face and talk it through? I can come down to Miami. + +-- maybe we can steal you for 30 minutes just to bounce some ideas off of you? + +Assistant U.S. Attorne + +Fax + +Ori inal Messa e From: ) + +Sent: Monda March 28, 2011 8:18 AM + +I also have found good language in several cases that suggest that the Petitioners' failure to prosecute the case will end up being a second reason to dismiss the petition. Cassell will, no doubt, try to pin the blame on us, but they had no contact with us for over a year while they were pursuing their civil claims against Epstein. In the meantime, Epstein finished serving his entire criminal sentence. And now they want to try to attack the "plea" agreement. There is good language about the need for finality in criminal proceedings that should help + +with that. + +Talk to you all on Monday. + +Thanks. + +The message is ready to be sent with the following file or link + +attachments: + +CVRA Omnibus Response.wpd + +Note: To protect against computer viruses, e-mail programs may prevent sending or receiving certain types of file attachments. Check your e-mail security settings to determine how attachments are handled. + +From: Jackie Perczek + +Sent: Friday, April 01, 2011 4:58 PM To: . (USAFLS); + +Cc: Roy BLACK Subject: Doe v. USAO + +Attachments: WordPerfect 6.1.WPD + +Good afternoon and Ann + +(USAFLS) + +Consistent with the conversation Roy and I had with this week, attached is a working draft of the motion to intervene and the objections we intend to lodge to the recent filings of Doe 1 and Doe 2 concerning discovery and disclosure of plea negotiation letters and emails. Please let us know your + +position. + +Have a good weekend, + +Jackie + +From: (USAFLS) < + +Sent: Monday, March 28, 2011 10:45 AM + +To: . (USAFLS); (USAFLS) Cc: (USAFLS); (USAFLS) + +Subject: Conversation with Roy Black - Redacted Materials + +Colleagues, + +I just spoke with Roy Black regarding the U.S. Attorney's Correspondence materials the victims seek to have unredacted. I told him we advised Cassell we had no independent objection to the public filing of the + +Black told me they intended to file a notice today advising the court that Epstein intended to object, and would be filing a detailed legal memo by next Monday. Black said they would send us a courtesy copy by the end of this week. Black will assert three grounds: (1) some of the correspondence contains material covered by Fed.R.Crim.P. 6(e); (2) the correspondence included plea negotiations; and (3) victims' counsel could not be trusted to keep material from the press. Black advised he believed the five-page letter had been leaked to the + +Daily Beast by the victims' lawyers. + +Black said he understood the DOJ had policies about public disclosure, but he wanted to know if the + +government would join in their motion. + +From: + +Sent: Sunday, March 27, 2011 2:03 PM + +To: (USAFLS); + +Subject: RE: Emailing: CVRA Omnibus Response.wpd + +> + +.(USAFLS) + +The "no prosecution is underway" language has a specific meaning addressed in the OLC opinion I sent earlier. It does not mean that it creates a forum for victims to bring a non-monetary cause of action when (as here) that cause of action is divorced from a criminal case. (What relief is being sought in this case, by the way? If it's a declaratory judgment that we + +bring charges, then he's barred by prosecutorial discretion - we're the govt, not him) + +The CVRA does not create any independent causes of action - the money damages clause was belts and suspenders, to make clear that sovereign immunity wasn't being waived. If a victim believes their rights were violated, they can, in theory, bring a cause of action under some other federal law, cf. 42 USC 1983, but the CVRA itself doesn't create a recoverable + +cause of action. + +United States Department of Justice Criminal Division. Appellate Section + +tel: fax: + +Ori inal Message + +From: (USAFLS) (mailto + +To: + +Sent: Sunda . March 27. 2011 1:58 PM + +. (USAFLS) + +Subject: RE: Emailing: CVRA Omnibus Response.wpd + +and + +18 U.S.C. 3771(d)(6) provides there is no cause of action for damages. From a civil attorney's viewpoint, damages means money damages. Therefore, a victim cannot sue the United States Government, or an + +I also have found good language in several cases that suggest that the Petitioners' failure to prosecute the case will end up being a second reason to dismiss the petition. Cassell will, no doubt, try to pin the blame on us, but they had no contact with us for over a year while they were pursuing their civil claims against Epstein. In the meantime, Epstein finished serving his entire criminal sentence. And now they want to try to attack the "plea" agreement. There is good language about the need for finality in criminal proceedings that should help + +with that. + +Talk to you all on Monday. + +Thanks. + +The message is ready to be sent with the following file or link + +attachments: + +CVRA Omnibus Response.wpd + +Note: To protect against computer viruses, e-mail programs may prevent sending or receiving certain types of file attachments. Check your e-mail security settings to determine how attachments are handled. + +From: (USAFLS) < + +Sent: Sunday, March 27, 2011 1:58 PM + +To: ); + +Subject: RE: Emailing: CVRA Omnibus Response.wpd + +and + +. (USAFLS) + +18 U.S.C. 3771(d)(6) provides there is no cause of action for damages. From a civil attorneys viewpoint, damages means money damages. Therefore, a victim cannot sue the United States Government, or an official of the U.S. Government, for + +money damages, based on a claim that their rights under the CVRA were violated. + +Not having a cause of action for damages does not mean you cannot assert that your CVRA rights were violated, and you are entitled to non-monetary relief. Also, 18 U.S.C. 3771(d)(3) provides that, in cases where a criminal case has not been filed ("if no prosecution is underway"), the victim can file a motion for relief in the district court in the district in which the crime occurred. This plainly suggests that Congress intended a putative victim to have a forum where he could address + +his claim that his/her CVRA rights have been violated by the Government. + +Ori inal Messa e From: ) + +Sent: Sunda . March 27. 2011 1:49 PM + +To: . (USAFLS); (USAFLS) Subject: RE: Emailing: CVRA Omnibus Response.wpd + +PS - Real quick, but the CVRA says it doesn't create a cause of action + +"for damages." My instinct is that we should emphasize the + +prosecutorial discretion angle over the "no cause of action" language of + +the CVRA, but I will do a little more digging. + +United States Department of Justice Criminal Division, Appellate Section + +tel: fax: + +----Original Messa e-- + +From: [mailto: + +Sent: Sunda , March 27, 2011 1:31 PM + +To: (USAFLS); + +Subject: Emailing: CVRA Omnibus Response.wpd + +«CVRA Omnibus Response.wpd>> Hi and + +Obviously, this is just a rough draft of an introduction. I have been side-tracked by research. I found a case where a prisoner tried to use the CVRA in a habeas/Rule 35 type claim. I think that is a good example of how the CVRA, as Cassell sees it, could be abused. Since every assault on a federal prisoner is a federal crime, federal defendants could demand meetings with AUSAs claiming that they were assaulted (whether or not the assaults actually occurred) and, even if the USAO decided to defer to administrative authorities, i.e., the Bureau of + +Prisons, according to Cassell, we would be forced to go meet with them. + +I also have found good language in several cases that suggest that the Petitioners' failure to prosecute the case will end up being a second reason to dismiss the petition. Cassell will, no doubt, try to pin the blame on us, but they had no contact with us for over a year while they were pursuing their civil claims against Epstein. In the meantime, Epstein finished serving his entire criminal sentence. And now they want to try to attack the "plea" agreement. There is good language about the need for finality in criminal proceedings that should help + +with that. + +Talk to you all on Monday. + +Thanks. + +The message is ready to be sent with the following file or link + +attachments: + +CVRA Omnibus Response.wpd + +Note: To protect against computer viruses, e-mail programs may prevent sending or receiving certain types of file attachments. Check your e-mail security settings to determine how attachments are handled. + +From: + +United States Department of Justice Criminal Division. Appellate Section + +tel: fax: + +Ori inal Messa e + +From: . (USAFLS) [mailto: + +Sent: Sunda . March 27. 2011 1:31 PM + +To: (USAFLS); + +Subject: Emailing: CVRA Omnibus Response.wpd + +«CVRA Omnibus Response.wpd» Hi and + +Obviously, this is just a rough draft of an introduction. I have been side-tracked by research. I found a case where a prisoner tried to use the CVRA in a habeas/Rule 35 type claim. I think that is a good example of how the CVRA, as Cassell sees it, could be abused. Since every assault on a federal prisoner is a federal crime, federal defendants could demand meetings with AUSAs claiming that they were assaulted (whether or not the assaults actually occurred) and, even if the USAO decided to defer to administrative authorities, i.e., the Bureau of Prisons, according to Cassell, we would be forced + +to go meet with them. + +I also have found good language in several cases that suggest that the Petitioners' failure to prosecute the case will end up being a second reason to dismiss the petition. Cassell will, no doubt, try to pin the blame on us, but they had no contact with us for over a year while they were pursuing their civil claims against Epstein. In the meantime, Epstein finished serving his entire criminal sentence. And now they want to try to attack the "plea" agreement. There is good language + +about the need for finality in criminal proceedings that should help with that. + +Talk to you all on Monday. + +Thanks. + +The message is ready to be sent with the following file or link + +attachments: + +CVRA Omnibus Response.wpd + +Note: To protect against computer viruses, e-mail programs may prevent sending or receiving certain types of file + +attachments. Check your e-mail security settings to determine how attachments are handled. + +From: + +The message is ready to be sent with the following file or link + +attachments: + +CVRA Omnibus Response.wpd + +Note: To protect against computer viruses, e-mail programs may prevent sending or receiving certain types of file attachments. Check your e-mail security settings to determine how attachments are handled. + +From: (USAFLS) < + +Sent: Sunday, March 27, 2011 1:44 PM To: . (USAFLS); + +Subject: RE: Emailing: CVRA Omnibus Response.wpd + +I am working on our response to their material "facts," which really aren't facts at all. I should have these done by today. I will then move on to the legal argument. I was considering responding to each motion separately, to make it easier for the + +court. + +P.S. Our deadline is April 7, 2011. + +Ori inal Messa e + +From: . (USAFLS) Sent: Sunda . March 27, 2011 1:31 PM + +To: (USAFLS); + +Subject: Emailing: CVRA Omnibus Response.wpd + +Hi and MI + +Obviously, this is just a rough draft of an introduction. I have been side-tracked by research. I found a case where a prisoner tried to use the CVRA in a habeas/Rule 35 type claim. I think that is a good example of how the CVRA, as Cassell sees it, could be abused. Since every assault on a federal prisoner is a federal crime, federal defendants could demand meetings with AUSAs claiming that they were assaulted (whether or not the assaults actually occurred) and, even if the USAO decided to defer to administrative authorities, i.e., the Bureau of Prisons, according to Cassell, we would be forced + +to go meet with them. + +I also have found good language in several cases that suggest that the Petitioners' failure to prosecute the case will end up being a second reason to dismiss the petition. Cassell will, no doubt, try to pin the blame on us, but they had no contact with us for over a year while they were pursuing their civil claims against Epstein. In the meantime, Epstein finished serving his entire criminal sentence. And now they want to try to attack the "plea" agreement. There is good language + +about the need for finality in criminal proceedings that should help with that. + +Talk to you all on Monday. + +Thanks. + +The message is ready to be sent with the following file or link attachments: + +From: + +Sent: Sunday, March 27, 2011 1:42 PM + +To: . (USAFLS); (USAFLS) + +Subject: RE: Emailing: CVRA Omnibus Response.wpd + +What's our deadline here again? Thanks + +United States Department of Justice Criminal Division, Appellate Section + +tel: fax: + +Ori inal Messa e + +From: . (USAFLS) [mailto: + +Sent: Sunda . March 27. 2011 1:31 PM + +To: (USAFLS); + +Subject: Emailing: CVRA Omnibus Response.wpd + +«CVRA Omnibus Response.wpd>> Hi and + +Obviously, this is just a rough draft of an introduction. I have been side-tracked by research. I found a case where a prisoner tried to use the CVRA in a habeas/Rule 35 type claim. I think that is a good example of how the CVRA, as Cassell sees it, could be abused. Since every assault on a federal prisoner is a federal crime, federal defendants could demand meetings with AUSAs claiming that they were assaulted (whether or not the assaults actually occurred) and, even if the USAO decided to defer to administrative authorities, i.e., the Bureau of Prisons, according to Cassell, we would be forced + +to go meet with them. + +I also have found good language in several cases that suggest that the Petitioners' failure to prosecute the case will end up being a second reason to dismiss the petition. Cassell will, no doubt, try to pin the blame on us, but they had no contact with us for over a year while they were pursuing their civil claims against Epstein. In the meantime, Epstein finished serving his entire criminal sentence. And now they want to try to attack the "plea" agreement. There is good language + +about the need for finality in criminal proceedings that should help with that. + +Talk to you all on Monday. + +Thanks. + +The message is ready to be sent with the following file or link + +attachments: + +CVRA Omnibus Response.wpd + +From: (USAFLS) Sent: Thursday, March 24, 2011 8:28 PM To: . (USAFLS) + +Subject: Re: Statement re Epstein + +I'm at this AUSA reception thing. Can I call you later if it's not too late? + +Ori inal Messa e + +From: . (USAFLS) Sent: Thursda , March 24, 2011 07:56 PM + +To: USAFLS + +Cc: (USAFLS); Subject: RE: Statement re Epstein + +(USAFLS) + +Why do you make it so hard for the good guys to follow the rules? Just release the letter. It isn't a privileged + +communication. It was sent to opposing counsel. + +Assistant U.S. Attorne + +Fax + +Ori\_girS Message From: =, (USAFLS) + +Sent: Thursda , March 24, 2011 7:51 PM To: . (USAFLS) Subject: Fw: Statement re Epstein + +Sorry. Here it is + +---- Original Message — From: csamoff [mailto: + +Sent: ThuS, March 24, 2011 06:56 PM To: MI, I= (USAFLS); Janet Aitken Subject: Re: Statement re Epstein + +Thank you Best, Conchita + +Message----- + +From: == To: Janet Aitken + +Cc: + +Subject: Statement re Epstein Sent: 24 Mar 2011 18:40 + +After reviewing the U.S. Attorneyaes handling of this matter, including allegations of misconduct, the office of the deputy attorney general determined there was no basis to intervene in the matter. We will not be making additional comments. + +Thanks for checking with us. + +Special Counsel to the US Attorney + +From: Sent: To: Subject: (USAFLS) < > + +Sunday, March 27, 2011 2:50 PM + +RE: Emailing: CVRA Omnibus Response.wpd + +.(USAFLS) + +Another point is that the non-prosecution agreement would not be subject to any judicial approval, absent a claim by one of the parties to the agreement that a breach had occurred. Unlike Dean, the government never contemplated any charge being filed in the district court, nor did it seek a dispensation from the court to limit the number of victims it would contact. In Dean, there was ultimately a charge and a plea agreement for the court to review. In our case, there was neither. + +----Ori inal Messa e— From: ) + +Sent: Sunda , March 27, 2011 2:44 PM + +To: (USAFLS); . (USAFLS) Subject: RE: Emailing: CVRA Omnibus Response.wpd + +I must really be clueless here, but why would we have to consult with them if no charges have been brought. That's the OLC opinion. That doesn't mean we couldn't consult with them as a courtesy, but we have no legal compulsion to do so + +under the CVRA because no charges were ever brought. + +United States Department of Justice Criminal Division. ellate Section + +tel: fax: + +----Ori inal Message + +From: (USAFLS) [main° Sent: Sunda , March 27, 2011 2:06 PM + +To: (USAFLS) Subject: RE: Emailing: CVRA Omnibus Response.wpd + +The remedy they seek is a vacatur of the non-prosecution agreement. Presumably, we would then have to consult with them pursuant to 18 U.S.C. 3771(a)(5). Cassell did agree that the district court had no + +authority to compel the government to prosecute Epstein. + +----Ori inal Messa e-- From: ) + +Sent: Sunda , March 27, 2011 2:03 PM + +To: (USAFLS); . (USAFLS) Subject: RE: Emailing: CVRA Omnibus Response.wpd + +The "no prosecution is underway" language has a specific meaning addressed in the OLC opinion I sent earlier. It does not mean that it creates a forum for victims to bring a non-monetary cause of action when (as here) that cause of action is divorced from a criminal case. (What relief is being sought in this case, by the way? If it's a declaratory judgment that we bring charges, then he's barred by prosecutorial + +discretion - we're the govt, not him) + +United States Department of Justice Criminal Division, Appellate Section + +tel: fax: + +Ori inal Message + +From: [mailto: + +Sent: Sunda . March 27. 2011 1:31 PM + +To: (USAFLS): + +Subject: Emailing: CVRA Omnibus Response.wpd + +USAFLS + +«CVRA Omnibus Response.wpd>> Hi and + +Obviously, this is just a rough draft of an introduction. I have been side-tracked by research. I found a case where a prisoner tried to use the CVRA in a habeas/Rule 35 type claim. I think that is a good example of how the CVRA, as Cassell sees it, could be abused. Since every assault on a federal prisoner is a federal crime, federal defendants could demand meetings with AUSAs claiming that they were assaulted (whether or not the assaults actually occurred) and, even if the USAO decided to defer to administrative authorities, i.e., the Bureau of + +Prisons, according to Cassell, we would be forced to go meet with them. + +I also have found good language in several cases that suggest that the Petitioners' failure to prosecute the case will end up being a second reason to dismiss the petition. Cassell will, no doubt, try to pin the blame on us, but they had no contact with us for over a year while they were pursuing their civil claims against Epstein. In the meantime, Epstein finished serving his entire criminal sentence. And now they want to try to attack the "plea" agreement. There is good language about the need for finality in criminal proceedings that should help + +with that. + +Talk to you all on Monday. + +Thanks. + +The message is ready to be sent with the following file or link + +attachments: + +CVRA Omnibus Response.wpd + +Note: To protect against computer viruses, e-mail programs may prevent sending or receiving certain types of file attachments. Check your e-mail security settings to determine how attachments are handled. + +From: + +> + +I must really be clueless here, but why would we have to consult with them if no charges have been brought. That's the OLC opinion. That doesn't mean we couldn't consult with them as a courtesy, but we have no legal compulsion to do so + +under the CVRA because no charges were ever brought. + +••••••••••••••••••••••••••.•••••••••••• + +United States Department of Justice Criminal Division. Appellate Section + +tel: fax: + +-----Ori inal Message + +From: (USAFLS) [mailto Sent: Sunda , March 27 2011 2:06 PM + +To: (USAFLS) Subject: RE: Emailing: CVRA Omnibus Response.wpd + +The remedy they seek is a vacatur of the non-prosecution agreement. Presumably, we would then have to consult with them pursuant to 18 U.S.C. 3771(a)(5). Cassell did agree that the district court had no + +authority to compel the government to prosecute Epstein. + +Ori inal Messa e-- From: ) + +Sent: Sunda March 27, 2011 2:03 PM + +To: (USAFLS); . (USAFLS) Subject: RE: Emailing: CVRA Omnibus Response.wpd + +The "no prosecution is underway" language has a specific meaning addressed in the OLC opinion I sent earlier. It does not mean that it creates a forum for victims to bring a non-monetary cause of action when (as here) that cause of action is divorced from a criminal case. (What relief is being sought in this case, by the way? If it's a declaratory judgment that we bring charges, then he's barred by prosecutorial + +discretion - we're the govt, not him) + +The CVRA does not create any independent causes of action - the money damages clause was belts and suspenders, to make clear that sovereign immunity wasn't being waived. If a victim believes their rights were violated, they can, in theory, bring a cause of action under some other federal law, cf. 42 USC 1983, but the CVRA itself doesn't create a + +recoverable cause of action. + +United States Department of Justice Criminal Division, Appellate Section + +Obviously, this is just a rough draft of an introduction. I have been side-tracked by research. I found a case where a prisoner tried to use the CVRA in a habeas/Rule 35 type claim. I think that is a good example of how the CVRA, as Cassell sees it, could be abused. Since every assault on a federal prisoner is a federal crime, federal defendants could demand meetings with AUSAs claiming that they were assaulted (whether or not the assaults actually occurred) and, even if the USAO decided to defer to administrative authorities, i.e., the Bureau of + +Prisons, according to Cassell, we would be forced to go meet with them. + +I also have found good language in several cases that suggest that the Petitioners' failure to prosecute the case will end up being a second reason to dismiss the petition. Cassell will, no doubt, try to pin the blame on us, but they had no contact with us for over a year while they were pursuing their civil claims against Epstein. In the meantime, Epstein finished serving his entire criminal sentence. And now they want to try to attack the "plea" agreement. There is good language about the need for finality in criminal proceedings that should help + +with that. + +Talk to you all on Monday. + +Thanks. + +The message is ready to be sent with the following file or link + +attachments: + +CVRA Omnibus Response.wpd + +Note: To protect against computer viruses, e-mail programs may prevent sending or receiving certain types of file attachments. Check your e-mail security settings to determine how attachments are handled. + +From: (USAFLS) < + +Sent: Sunday, March 27, 2011 2:06 PM + +To: ); + +Subject: RE: Emailing: CVRA Omnibus Response.wpd + +. (USAFLS) + +The remedy they seek is a vacatur of the non-prosecution agreement. Presumably, we would then have to consult with + +them pursuant to 18 U.S.C. 3771(a)(5). Cassell did agree that the district court had no authority to compel the + +government to prosecute Epstein. + +Ori inal Messa e From: ) + +Sent: Sunda . March 27. 2011 2:03 PM + +To: (USAFLS); . (USAFLS) Subject: RE: Emailing: CVRA Omnibus Response.wpd + +The "no prosecution is underway" language has a specific meaning addressed in the OLC opinion I sent earlier. It does not mean that it creates a forum for victims to bring a non-monetary cause of action when (as here) that cause of action is divorced from a criminal case. (What relief is being sought in this case, by the way? If it's a declaratory judgment that we + +tel: fax: + +Original Message + +From: [mailto: + +Sent: Sunda . March 27, 2011 1:31 PM + +To: (USAFLS); + +Subject: Emailing: CVRA Omnibus Response.wpd + +USAFLS + +«CVRA Omnibus Response.wpd>> Hi and MI -- + +Obviously, this is just a rough draft of an introduction. I have been side-tracked by research. I found a case where a prisoner tried to use the CVRA in a habeas/Rule 35 type claim. I think that is a good example of how the CVRA, as Cassell sees it, could be abused. Since every assault on a federal prisoner is a federal crime, federal defendants could demand meetings with AUSAs claiming that they were assaulted (whether or not the assaults actually occurred) and, even if the USAO decided to defer to administrative authorities, i.e., the Bureau of + +Prisons, according to Cassell, we would be forced to go meet with them. + +I also have found good language in several cases that suggest that the Petitioners' failure to prosecute the case will end up being a second reason to dismiss the petition. Cassell will, no doubt, try to pin the blame on us, but they had no contact with us for over a year while they were pursuing their civil claims against Epstein. In the meantime, Epstein finished serving his entire criminal sentence. And now they want to try to attack the "plea" agreement. There is good language about the need for finality in criminal proceedings that should help + +with that. + +Talk to you all on Monday. + +Thanks. + +The message is ready to be sent with the following file or link + +attachments: + +CVRA Omnibus Response.wpd + +Note: To protect against computer viruses, e-mail programs may prevent sending or receiving certain types of file attachments. Check your e-mail security settings to determine how attachments are handled. + +From: (USAFLS) e > + +Sent: Tuesday, March 29, 2011 10:13 AM + +To: ); (USAFLS) Subject: Emailing: CVRA Omnibus Response.wpd + +CVRA Omnibus Response.wpd + +Note: To protect against computer viruses, e-mail programs may prevent sending or receiving certain types of file + +attachments. Check your e-mail security settings to determine how attachments are handled. + +From: (USAFLS) ‹ > + +Sent: Wednesday, March 30, 2011 11:55 AM + +To: (USAFLS); (USAFLS); (USAFLS); + +(USAFLS) + +Cc: (USAFLS) + +Subject: RE: Please click on link below + +Just FYI — The blog is, for the most part, completely nuts, but the link to William Riley is real. William Riley is the person who removed the computers from Mr. Epstein's house after Epstein or Roy Black somehow found out that a state search warrant was coming. (It was suspected that a court reporter at the state courthouse was the source of the leak, but never + +confirmed.) He also was one of the private investigators who investigated the agents and probably me during the + +investigation. + +Special Agent accent). + +See how much fun this is! + +Assistant U.S. Attorne + +Fax + +was followed to her home this past weekend, but it is believed that it was a reporter (British + +Ori inal Message From: (USAFLS) + +Sent: Wednesda March 30, 2011 10:51 AM + +To: . (USAFLS); (USAFLS); Cc: (USAFLS); (USAFLS) + +Subject: FW: Please click on link below + +This is wackiest thing I have ever read. + +----Original Message + +From: csamoff (mailto:csamoff@bellsouth.net] Sent: Wednesday, March 30, 2011 7:55 AM + +To: MI, (USAFLS); + +Subject: Please click on link below + +Good morning, + +(USAFLS) + +(USAFLS) + +Off The Record- Please can you comment on this piece? Just received and fitting pieces together. Call when you can. + +Thank you, Conchita + +From: (USAFLS) Sent: Thursday, March 24, 2011 8:20 PM + +To: (USAFLS) Subject: Re: Statement re Epstein + +It is supposedly part of the 350 pages of correspondence that the Jane Does filed on Monday. I am trying to check now. It + +was filed under seal and I just got it at 4:00 today + +Origiia + +. + +l Message ---- + +From: (USAFLS) + +Sent: Thurscla , March 24, 2011 08:16 PM To: . (USAFLS) Subject: Re: Statement re Epstein + +When and where was the Itr filed? That is news to me + +From: (USAFLS) Sent: Thursda , March 24, 2011 07:57 PM + +To: USAFLS + +Cc: (USAFLS); Subject: RE: Statement re Epstein + +And it has already been filed with the court! + +Assistant U.S. Attorne + +Fax + +----Ori\_guS Message + +From: =, (USAFLS) + +Sent: Thursda , March 24, 2011 7:51 PM To: . (USAFLS) Subject: Fw: Statement re Epstein + +Sorry. Here it is + +---- Original Message — From: csamoff (mailto: + +Sent: Thursday, March 24, 2011 06:56 PM To: =, (USAFLS); Janet Aitken Subject: Re: Statement re Epstein + +Thank you Best, Conchita + +Message----- + +From: == To: Janet Aitken + +Cc: + +Subject: Statement re Epstein Sent: 24 Mar 2011 18:40 + +(USAFLS) + +After reviewing the U.S. Attorneyaes handling of this matter, including allegations of misconduct, the office of the deputy attorney general determined there was no basis to intervene in the matter. We will not be making additional comments. + +Special Counsel to the US Attorney + +Sent from my Verizon Wireless BlackBerry + +From: (USAFLS) + +Sent: Thursday, March 24, 2011 8:17 PM To: . (USAFLS) + +Subject: Re: Statement re Epstein + +When and where was the Itr filed? That is news to me + +---- Ono inal Messa e + +From: (USAFLS) Sent: Thursda , March 24, 2011 07:57 PM + +To: USAFLS + +Cc: (USAFLS); Subject: RE: Statement re Epstein + +And it has already been filed with the court! + +Assistant U.S. Attorne + +Fax + +OrigirS Message From: =, (USAFLS) + +Sent: Thursda , March 24, 2011 7:51 PM To: . (USAFLS) Subject: Fw: Statement re Epstein + +Sorry. Here it is + +(USAFLS) + +Original Message --- + +From: csamoff + +Sent: Thursday, March 24, 2011 06:56 PM + +To: =,= (USAFLS); Janet Aitken e > + +Subject: Re: Statement re Epstein + +Thank you Best, Conchita + +Message----- + +From: == To: Janet Aitken + +Cc: + +Subject: Statement re Epstein Sent: 24 Mar 2011 18:40 + +After reviewing the U.S. Attorneyaems handling of this matter, including allegations of misconduct, the office of the deputy attorney general determined there was no basis to intervene in the matter. We will not be making additional comments. + +Special Counsel to the US Attorney + +Sent from my Verizon Wireless BlackBerry + +From: (USAFLS) Sent: Thursday, March 24, 2011 8:29 PM To: (USAFLS) Subject: RE: Statement re Epstein + +Sure. I am still at the office but leaving soon. + +Assistant U.S. Attorne + +Fax + +----Ori inal Messa e-- + +From: (USAFLS) Sent: Thursda , March 24, 2011 8:28 PM To: . (USAFLS) Subject: Re: Statement re Epstein + +I'm at this AUSA reception thing. Can I call you later if it's not too late? + +---- Ori inWtiesm— + +From: (USAFLS) Sent: Thursda , March 24, 2011 07:56 PM + +To: USAFLS + +Cc: (USAFLS): Subject: RE: Statement re Epstein + +(USAFLS) + +Why do you make it so hard for the good guys to follow the rules? Just release the letter. It isn't a privileged + +communication. It was sent to opposing counsel. + +Assistant U.S. Attorne + +Fax + +Origial Message From: =. (USAFLS) + +Sent: Thursda , March 24, 2011 7:51 PM To: . (USAFLS) Subject: Fw: Statement re Epstein + +Original Message From: csamoff [mailto: + +Sent: Thursday, March 24, 2011 06:56 PM To: 'MI= (USAFLS); Janet Aitken Subject: Re: Statement re Epstein + +Thank you Best, Conchita + +Message------ + +From: == To: Janet Aitken + +Cc: + +Subject: Statement re Epstein Sent: 24 Mar 2011 18:40 + +After reviewing the U.S. Attorneya€Tms handling of this matter, including allegations of misconduct, the office of the deputy attorney general determined there was no basis to intervene in the matter. We will not be making additional comments. + +Thanks for checking with us. + +Special Counsel to the US Attorney + +Sent from my Verizon Wireless BlackBerry + +From: (USAFLS) < + +Sent: Friday, March 25, 2011 9:15 AM + +To: (USAFLS); (USAFLS); + +(USAFLS); (USAFLS); (USAFLS); + +Cc: (USAFLS) + +Subject: Fw: published today, The Daily Beast/Newsweek + +FYI + +From: [mailto: Sent: Fridl arch 25, 2011 09:08 AM + +To: , (USAFLS) + +Subject: published today, The Daily Beast/Newsweek + +(USAFLS) + +http://www.thedailybeast.com/blogs-and-stories/2011-03-25/jeffrey-epstein-how-the-billionaire- + +pedophile-got-off-easy/?cid=hp:mainpromo1 + +Conchita SarnoffThe message and any attachment may be confidential or privileged and isintended only for the individual or entity identified above as theaddressee. If you are not the addressee, or if this message has beenaddressed to you in error, you are not authorized to read, copy ordistribute this message or any attachments and we ask that you please deletethis message and any attachments and notify the sender by return email.Delivery of this message and any attachments to any person (s) + +is notintended in any way to waive confidentially or a privilege. + +From: Sent: To: + +http://www.thedailybeast.com/blogs-and-stories/2011-03-25/jeffrey-epstein-how-the-billionaire-pedophile-got-off-easy/2/ + +A. + +From: (USAFLS)< > + +Sent: Friday, March 25, 2011 5:41 PM To: . (USAFLS) + +Attachments: Facts response.wpd + +< + +Sent: Friday, March 25, 2011 9:24 AM + +To: (USAFLS); Waters, Robert (USAFLS) Subject: FW: published today, The Daily Beast/Newsweek + +Assistant U.S. Attorney + +Fax + +Sent: Frida March 25, 2011 9:15 AM + +To: . (USAFLS (USAFLS; (USAFLS); USAFLS); (USAFLS); (USAFLS) + +Cc: (USAFLS) + +Subject: Fw: published today, The Daily Beast/Newsweek + +FYI + +From: [mailto: Sent: Fridly arch 25, 2011 09:08 AM + +To: , (USAFLS) + +Subject: published today, The Daily Beast/Newsweek + +http://www.thedailybeast.com/blogs-and-stories/2011-03-25/jeffrey-epstein-how-the-billionaire- + +pedophile-got-off-easy/?cid=hp:mainpromo1 + +Conchita SarnoffThe message and any attachment may be confidential or privileged and isintended only for the individual or entity identified above as theaddressee. If you are not the addressee, or if this message has beenaddressed to you in error, you are not authorized to read, copy ordistribute this message or any attachments and we ask that you please deletethis message and any attachments and notify the sender by return email.Delivery of this message and any attachments to any person (s) + +is notintended in any way to waive confidentially or a privilege. + +From: (USAFLS)< > + +Sent: Monday, March 28, 2011 2:45 PM + +To: (USAFLS); (USAFLS); Cc: (USAFLS); . (USAFLS) Subject: John Connolly Vanity Fair magazine -- Proposed responses + +(USAFLS) + +Hi guys — + +Below please find my proposed answers [in red ink] to John Conolly of Vanity Fair. + +Let's discuss ASAP so I can send him a response. + +After we agree on a proposed response, I need to run this by DOJ-Public Affairs before sending out. + +Thanks + +From: john1885c [mailto: + +Sent: Frid larch 18, 2011 1:51 PM + +AUSA + +It was a pleasure speaking with you this morning. As per your request here are questions I would like to have answered for a piece I am researching on Jeffrey Epstein. As life would have it I am going to be on a busman's holiday this coming week on Singer Island, FL. I would like to meet you + +and whomever else you think I should speak with. If not, I understand perfectly. + +Let me preface these questions by saying that AUSA who was in charge of the investigation of Jeffrey Epstein has a remarkably record as a prosecutor. I also know that an AUSA does not have the authority to grant a potential defendant a non -prosecution agreement without the + +permission of higher ups in the Justice Department. + +Not quite three years ago, the US Attorney for the Southern District of Florida, granted Jeffrey Epstein + +a non-prosecution agreement in return for his accepting a FL State plea deal for his illegal acts regarding sex with minor females. The state case was handled by the West Palm Beach State + +Prosecutor who has since left office. + +Re terms and conditions of imprisonment: + +--Was your office aware of the extraordinary sweet deal that Mr. Epstein was granted by that state + +prosecutor? + +--Was your office at the time of the agreement aware that Mr. Epstein would not be sent to a state prison facility as almost all defendants who are sentenced to more that a year in prison are required to + +do? + +--Was your office aware that Mr. Epstein would serve his sentence in the local WPB jail? + +--Was your office aware that Mr. Epstein would be allowed, what most FL law enforcement officials describe as "beyond a sweetheart deal", in that six days a week at 7:00 AM Mr. Epstein would leave the the WPB jail with a corrections officer he was personally paying for, and be escorted to the office of attorney Jack Goldberger where he would be allowed to stay until 11:00 PM and then be returned to + +jail for the evening? + +Ostensibly this was so that Mr. Epstein could work on a new charity he had formed. This despite the fact that just prior to beginning his jail sentence, Mr. Epstein liquidated his charity and gave \$18 million + +to a charity run by the wife of his former patron. + +--Does the US Attorney believe that Mr. Epstein was working on a charity? + +--Was Mr. Epstein doing work as a Confidential Informer for the federal government as he has in the + +past? + +Mr. Eptein was Victim # 1 in the federal indictment of two Bear Stears executives on fraud charges stemming from a mortgage backed fund that went under. Mr. Epstein lost almost \$70 million in that + +fund. + +--Was your office aware that in return for Mr. Goldberger's help, Mr. Epstein purchased for him a top of the line black BMW? (Sadly for Goldberger he was in an accident and totaled the vehicle three weeks + +later.) + +The USAO reached a NPA with Mr. Epstein in good faith. The Agreement speaks for itself about the + +expectations of the USAO regarding the length and conditions of punishment. Ultimately, the + +sentence was imposed by the State Court Judge who presided over the matter. + +At this time, we cannot comment further on your questions regarding any possible cooperation by Mr. + +Epstein, or what the USAO might have known or not known at the time of the negotiations. + +Re Alex Acosta alleged Conflict/Recusal Issue: + +It has come to my attention that the R. Alexander Acos to former Attorney General for the Southern District of Florida during the investigation and non-prosecution agreement with Mr. Epstein had been a + +law partner and friend of two Mr. Epstein's lawyers. Both Ken Star and Jay Lefkowitz had been partners with Mr. Acosta at the law firm of Kirkland & Ellis prior to his being appointed by President + +Bush. + +I have been told by sources that Mr. Acosta was the person responsible for the decision not to + +prosecute Mr. Epstein. + +I have also been told that during Mr. Starr's trip to FL to speak with federal prosecutors he complained to Mr. Acosta that the press coverage of his trips to FL on Mr. Epstein's private jets were being leaked + +by FBI agents. ( I can assure you that was not true.) + +--Did Mr. Acosta recuse himself from any discussions about the Epstein case so as to avoid even the + +appearance of impropriety? + +--Was the possibility of his removing himself from the case ever discussed by officials in the Justice + +Department? + +--Are there any memos regarding that? + +--Is there currently an Office of Professional Responsibility investigation into the facts surrounding the + +handling of this case and Mr. Acosta actions in it? + +Mr. Acosta recused from the matter in November 2008. That recusal was reviewed and approved by + +the Department of Justice, as is the standard procedure in all recusal matters. + +DOJ policy and the Privacy Act prohibit comment on the existence or non-existence of OPR investigations. However, please note that, at the request of the defense, the office of the deputy attorney general reviewed the U.S. Attorney's handling of this matter, including allegations of misconduct, and determined there was no basis to intervene in the matter. We will not be making + +additional comments. Thanks for checking with us. + +Thanks so much for your help, John Connolly + +From: (USAFLS) Sent: Monday, March 28, 2011 3:05 PM + +To: (USAFLS); (USAFLS); + +(USAFLS) + +Cc: (USAFLS) + +Subject: RE: John Connolly Vanity Fair magazine -- Proposed responses + +I am here at my desk. + +Assistant U.S. Attorney + +Fax + +From: (USAFLS) + +Sent: Monda March 28, 2011 2:45 PM + +To: . (USAFLS); (USAFLS); Cc: (USAFLS); . (USAFLS) + +Subject: John Connolly Vanity Fair magazine -- Proposed responses + +(USAFLS); + +(USAFLS) + +Hi guys — + +Below please find my proposed answers [in red ink] to John Conolly of Vanity Fair. + +Let's discuss ASAP so I can send him a response. + +From: john1885c [mailto: + +Sent: Frid larch 18, 2011 1:51 PM + +To: , (USAFLS) + +Subject: From: John Connolly Vanity Fair magazine Please confirm receipt. + +AUSA + +It was a pleasure speaking with you this morning. As per your request here are questions I would like to have answered for a piece I am researching on Jeffrey Epstein. As life would have it I am going to be on a busman's holiday this coming week on Singer Island, FL. I would like to meet you + +and whomever else you think I should speak with. If not, I understand perfectly. + +Let me preface these questions by saying that AUSA who was in charge of the investigation of Jeffrey Epstein has a remarkably record as a prosecutor. I also know that an AUSA does not have the authority to grant a potential defendant a non -prosecution agreement without the + +permission of higher ups in the Justice Department. + +Not quite three years ago, the US Attorney for the Southern District of Florida, granted Jeffrey Epstein + +a non-prosecution agreement in return for his accepting a FL State plea deal for his illegal acts regarding sex with minor females. The state case was handled by the West Palm Beach State + +Prosecutor who has since left office. + +Re terms and conditions of imprisonment: + +--Was your office aware of the extraordinary sweet deal that Mr. Epstein was granted by that state + +prosecutor? + +--Was your office at the time of the agreement aware that Mr. Epstein would not be sent to a state prison facility as almost all defendants who are sentenced to more that a year in prison are required to + +do? + +--Was your office aware that Mr. Epstein would serve his sentence in the local WPB jail? + +--Was your office aware that Mr. Epstein would be allowed, what most FL law enforcement officials describe as "beyond a sweetheart deal", in that six days a week at 7:00 AM Mr. Epstein would leave the the WPB jail with a corrections officer he was personally paying for, and be escorted to the office of attorney Jack Goldberger where he would be allowed to stay until 11:00 PM and then be returned to + +jail for the evening? + +Ostensibly this was so that Mr. Epstein could work on a new charity he had formed. This despite the fact that just prior to beginning his jail sentence, Mr. Epstein liquidated his charity and gave \$18 million + +--Does the US Attorney believe that Mr. Epstein was working on a charity? + +--Was Mr. Epstein doing work as a Confidential Informer for the federal government as he has in the + +past? + +Mr. Eptein was Victim # 1 in the federal indictment of two Bear Stears executives on fraud charges stemming from a mortgage backed fund that went under. Mr. Epstein lost almost \$70 million in that + +fund. + +--Was Mr. Epstein working on the government case while working on "His Charity"? + +--Has your office ever agreed to any allow any other prisoner the same or similar sweet deal? + +--Was your office aware that in return for Mr. Goldberger's help, Mr. Epstein purchased for him a top of the line black BMW? (Sadly for Goldberger he was in an accident and totaled the vehicle three weeks + +later.) + +The USAO reached a NPA with Mr. Epstein in good faith. The Agreement speaks for itself about the + +expectations of the USAO regarding the length and conditions of punishment. Ultimately, the + +sentence was imposed by the State Court Judge who presided over the matter. + +At this time, we cannot comment further on your questions regarding any possible cooperation by Mr. + +Epstein, or what the USAO might have known or not known at the time of the negotiations. + +Re Alex Acosta alleged Conflict/Recusal Issue: + +It has come to my attention that the R. Alexander Acos to former Attorney General for the Southern District of Florida during the investigation and non-prosecution agreement with Mr. Epstein had been a + +law partner and friend of two Mr. Epstein's lawyers. Both Ken Star and Jay Lefkowitz had been partners with Mr. Acosta at the law firm of Kirkland & Ellis prior to his being appointed by President + +Bush. + +I have been told by sources that Mr. Acosta was the person responsible for the decision not to + +prosecute Mr. Epstein. + +I have also been told that during Mr. Starr's trip to FL to speak with federal prosecutors he complained to Mr. Acosta that the press coverage of his trips to FL on Mr. Epstein's private jets were being leaked + +by FBI agents. ( I can assure you that was not true.) + +--Did Mr. Acosta recuse himself from any discussions about the Epstein case so as to avoid even the + +appearance of impropriety? + +--Was the possibility of his removing himself from the case ever discussed by officials in the Justice + +Department? + +Mr. Acosta recused from the matter in November 2008. That recusal was reviewed and approved by + +the Department of Justice, as is the standard procedure in all recusal matters. + +DOJ policy and the Privacy Act prohibit comment on the existence or non-existence of OPR investigations. However, please note that, at the request of the defense, the office of the deputy attorney general reviewed the U.S. Attorney's handling of this matter, including allegations of misconduct, and determined there was no basis to intervene in the matter. We will not be making + +additional comments. Thanks for checking with us. + +Thanks so much for your help, John Connolly + +From: (USAFLS)< > + +Sent: Sunday, March 27, 2011 1:31 PM + +To: (USAFLS); + +Subject: Emailing: CVRA Omnibus Response.wpd + +Attachments: CVRA Omnibus Response.wpd + +«CVRA Omnibus Response.wpd» Hi and MI -- + +Obviously, this is just a rough draft of an introduction. I have been side-tracked by research. I found a case where a prisoner tried to use the CVRA in a habeas/Rule 35 type claim. I think that is a good example of how the CVRA, as Cassell sees it, could be abused. Since every assault on a federal prisoner is a federal crime, federal defendants could demand meetings with AUSAs claiming that they were assaulted (whether or not the assaults actually occurred) and, even if the USAO decided to defer to administrative authorities, i.e., the Bureau of Prisons, according to Cassell, we would be forced + +to go meet with them. + +I also have found good language in several cases that suggest that the Petitioners' failure to prosecute the case will end up being a second reason to dismiss the petition. Cassell will, no doubt, try to pin the blame on us, but they had no contact with us for over a year while they were pursuing their civil claims against Epstein. In the meantime, Epstein finished serving his entire criminal sentence. And now they want to try to attack the "plea" agreement. There is good language + +about the need for finality in criminal proceedings that should help with that. + +Talk to you all on Monday. + +Thanks. + +The message is ready to be sent with the following file or link attachments: + +CVRA Omnibus Response.wpd + +Note: To protect against computer viruses, e-mail programs may prevent sending or receiving certain types of file + +attachments. Check your e-mail security settings to determine how attachments are handled. + +New article online re: letter from Acosta. Your mentioned. + +From: USAFLS) To: R. + +Sent: Tue Mar 22 13:27:21 2011 Subject: Epstein suit in the news + +Just FYI — The victims' rights suit is back in the news. or I may be reaching out to you re affidavits + +or hearing dates. + +Assistant U.S. Attorney + +Fax + +From: Sent: To: Subject: Attachments: (USAFLS) + +Monday, March 28, 2011 11:57 PM + +Emailing: CVRA Omnibus Response.wpd + +CVRA Omnibus Response.wpd + +<> + +Assistant U.S. Attorney + +Fax + +From: (USAFLS) + +Sent: Monday, March 28, 2011 10:45 AM + +To: 1 (USAFLS)• (USAFLS) Cc: (USAFLS); . (USAFLS) Subject: Conversation with Roy Black - Redacted Materials + +Colleagues, + +I just spoke with Roy Black regarding the U.S. Attorney's Correspondence materials the victims seek to have unredacted. I told him we advised Cassell we had no independent objection to the public filing of the + +correspondence. + +Black told me they intended to file a notice today advising the court that Epstein intended to object, and would be filing a detailed legal memo by next Monday. Black said they would send us a courtesy copy by the end of this week. Black will assert three grounds: (1) some of the correspondence contains material covered by Fed.R.Crim.P. 6(e); (2) the correspondence included plea negotiations; and (3) victims' counsel could not be trusted to keep material from the press. Black advised he believed the five-page letter had been leaked to the + +From: (USAFLS)< > + +Sent: Monday, March 28, 2011 3:33 PM + +To: (USAFLS); (USAFLS); Cc: (USAFLS); . (USAFLS) + +Subject: RE: John Connolly Vanity Fair magazine -- Proposed responses + +is an individual's recusal and the basis thereof Privacy Act protected? + +After discussing with M, I am ok leaving that out. + +From: (USAFLS) Sent: Monda March 28, 2011 3:31 PM + +To: (USAFLS ; USAFLS); Cc: (USAFLS); . (USAFLS) + +Subject: Re: John Connolly Vanity Fair magazine -- Proposed responses + +. (USAFLS) + +(USAFLS) + +Would the recusal request also be governed by the Privacy Act? While I do not like commenting on the 2008 recusal in a vacuum because of the erroneous inferences to which it could lead, it also seems to me that we might want to say something about why we're not responding to the recusal question. It also seems to me that an individual's recusal and the basis thereof might potentially fall under the + +Privacy Act. + +From: (USAFLS) Sent: Monda March 28, 2011 03:16 PM + +To: (USAFLS); USAFLS); Cc: (USAFLS); (USAFLS) + +Subject: RE: John Connolly Vanity Fair magazine -- Proposed responses + +(USAFLS) + +I think we should delete the line "Mr. Acosta recused from the matter in November 2008. That recusal was reviewed and approved by the Department of Justice, as is the standard procedure in all recusal matters." We simply shouldn't comment on 2008 Alex's recusal. I am comfortable with the rest with one caveat. If (and only if) the Roth letter has in fact been publicly filed, we could send that as well. + +Make sense? + +From: (USAFLS) + +Sent: Monda March 28, 2011 2:45 PM + +To: . (USAFLS); (USAFLS); Cc: (USAFLS); . (USAFLS) + +Subject: John Connolly Vanity Fair magazine -- Proposed responses + +(USAFLS) + +Hi guys — + +Below please find my proposed answers [in red ink] to John Conolly of Vanity Fair. + +Let's discuss ASAP so I can send him a response. + +After we agree on a proposed response, I need to run this by DOJ-Public Affairs before sending out. + +Thanks + +From: john1885c [mailto: + +Sent: Fridl larch 18, 2011 1:51 PM + +To: ,M (USAFLS) + +Subject: From: John Connolly Vanity Fair magazine Please confirm receipt. + +AUSA + +It was a pleasure speaking with you this morning. As per your request here are questions I would like to have answered for a piece I am researching on Jeffrey Epstein. As life would have it I am going to be on a busman's holiday this coming week on Singer Island, FL. I would like to meet you + +and whomever else you think I should speak with. If not, I understand perfectly. + +Let me preface these questions by saying that AUSA who was in charge of the investigation of Jeffrey Epstein has a remarkably record as a prosecutor. I also know that an AUSA does not have the authority to grant a potential defendant a non -prosecution agreement without the + +permission of higher ups in the Justice Department. + +Not quite three years ago, the US Attorney for the Southern District of Florida, granted Jeffrey Epstein + +a non-prosecution agreement in return for his accepting a FL State plea deal for his illegal acts regarding sex with minor females. The state case was handled by the West Palm Beach State + +Prosecutor who has since left office. + +--Was your office at the time of the agreement aware that Mr. Epstein would not be sent to a state prison facility as almost all defendants who are sentenced to more that a year in prison are required to + +do? + +--Was your office aware that Mr. Epstein would serve his sentence in the local WPB jail? + +--Was your office aware that Mr. Epstein would be allowed, what most FL law enforcement officials describe as "beyond a sweetheart deal", in that six days a week at 7:00 AM Mr. Epstein would leave the the WPB jail with a corrections officer he was personally paying for, and be escorted to the office of attorney Jack Goldberger where he would be allowed to stay until 11:00 PM and then be returned to + +jail for the evening? + +Ostensibly this was so that Mr. Epstein could work on a new charity he had formed. This despite the fact that just prior to beginning his jail sentence, Mr. Epstein liquidated his charity and gave \$18 million + +to a charity run by the wife of his former patron. + +--Does the US Attorney believe that Mr. Epstein was working on a charity? + +--Was Mr. Epstein doing work as a Confidential Informer for the federal government as he has in the + +past? + +Mr. Eptein was Victim # 1 in the federal indictment of two Bear Stears executives on fraud charges stemming from a mortgage backed fund that went under. Mr. Epstein lost almost \$70 million in that + +fund. + +--Was Mr. Epstein working on the government case while working on "His Charity"? + +--Has your office ever agreed to any allow any other prisoner the same or similar sweet deal? + +--Was your office aware that in return for Mr. Goldberger's help, Mr. Epstein purchased for him a top of the line black BMW? (Sadly for Goldberger he was in an accident and totaled the vehicle three weeks + +later.) + +The USAO reached a NPA with Mr. Epstein in good faith. The Agreement speaks for itself about the + +expectations of the USAO regarding the length and conditions of punishment. Ultimately, the + +sentence was imposed by the State Court Judge who presided over the matter. + +At this time, we cannot comment further on your questions regarding any possible cooperation by Mr. + +Epstein, or what the USAO might have known or not known at the time of the negotiations. + +Re Alex Acosta alleged Conflict/Recusal Issue: + +It has come to my attention that the R. Alexander Acos to former Attorney General for the Southern District of Florida during the investigation and non-prosecution agreement with Mr. Epstein had been a + +law partner and friend of two Mr. Epstein's lawyers. Both Ken Star and Jay Lefkowitz had been partners with Mr. Acosta at the law firm of Kirkland & Ellis prior to his being appointed by President + +Bush. + +I have been told by sources that Mr. Acosta was the person responsible for the decision not to + +prosecute Mr. Epstein. + +I have also been told that during Mr. Starr's trip to FL to speak with federal prosecutors he complained to Mr. Acosta that the press coverage of his trips to FL on Mr. Epstein's private jets were being leaked + +by FBI agents. ( I can assure you that was not true.) + +--Did Mr. Acosta recuse himself from any discussions about the Epstein case so as to avoid even the + +appearance of impropriety? + +--Was the possibility of his removing himself from the case ever discussed by officials in the Justice + +Department? + +--Are there any memos regarding that? + +--Is there currently an Office of Professional Responsibility investigation into the facts surrounding the + +handling of this case and Mr. Acosta actions in it? + +Mr. Acosta recused from the matter in November 2008. That recusal was reviewed and approved by + +the Department of Justice, as is the standard procedure in all recusal matters. + +DOJ policy and the Privacy Act prohibit comment on the existence or non-existence of OPR investigations. However, please note that, at the request of the defense, the office of the deputy attorney general reviewed the U.S. Attorney's handling of this matter, including allegations of misconduct, and determined there was no basis to intervene in the matter. We will not be making + +additional comments. Thanks for checking with us. + +Thanks so much for your help, John Connolly + +From: (USAFLS) < + +Sent: Monday, March 28, 2011 4:33 PM + +To: (USAFLS); (USAFLS); (USAFLS); + +(USAFLS) + +Cc: Subject: + +(USAFLS) RE: John Connolly Vanity Fair magazine -- Proposed responses + +Information that is contained in a "system of records" is protected by the Privacy Act. Disclosure could only occur if the disclosure was pursuant to a routine use (law enforcement agencies); upon the + +consent of the individual; or pursuant to a court order of a court of competent jurisdiction. I do + +From: + +Sent: Monda + +To: Cc: + +Subject: John Connolly Vanity Fair magazine -- Proposed responses + +(USAFLS) + +March 28, 2011 2:45 PM . (USAFLS ; + +(USAFLS); + +(USAFLS); (USAFLS) + +. (USAFLS) + +Hi guys — + +Below please find my proposed answers [in red ink] to John Conolly of Vanity Fair. + +Let's discuss ASAP so I can send him a response. + +After we agree on a proposed response, I need to run this by DOJ-Public Affairs before sending out. + +Thanks + +From: john1885c [mailto: + +Sent: Frid larch 18, 2011 1:51 PM + +To: ,M (USAFLS) + +Subject: From: John Connolly Vanity Fair magazine Please confirm receipt. + +AUSA + +It was a pleasure speaking with you this morning. As per your request here are questions I would like to have answered for a piece I am researching on Jeffrey Epstein. As life would have it I am going to be on a busman's holiday this coming week on Singer Island, FL. I would like to meet you + +and whomever else you think I should speak with. If not, I understand perfectly. + +Let me preface these questions by saying that AUSA who was in charge of the investigation of Jeffrey Epstein has a remarkably record as a prosecutor. I also know that an AUSA does not have the authority to grant a potential defendant a non -prosecution agreement without the + +permission of higher ups in the Justice Department. + +Not quite three years ago, the US Attorney for the Southern District of Florida, granted Jeffrey Epstein + +a non-prosecution agreement in return for his accepting a FL State plea deal for his illegal acts regarding sex with minor females. The state case was handled by the West Palm Beach State + +Prosecutor who has since left office. + +--Was your office aware of the extraordinary sweet deal that Mr. Epstein was granted by that state + +prosecutor? + +--Was your office at the time of the agreement aware that Mr. Epstein would not be sent to a state prison facility as almost all defendants who are sentenced to more that a year in prison are required to + +do? + +--Was your office aware that Mr. Epstein would serve his sentence in the local WPB jail? + +--Was your office aware that Mr. Epstein would be allowed, what most FL law enforcement officials describe as "beyond a sweetheart deal", in that six days a week at 7:00 AM Mr. Epstein would leave the the WPB jail with a corrections officer he was personally paying for, and be escorted to the office of attorney Jack Goldberger where he would be allowed to stay until 11:00 PM and then be returned to + +jail for the evening? + +Ostensibly this was so that Mr. Epstein could work on a new charity he had formed. This despite the fact that just prior to beginning his jail sentence, Mr. Epstein liquidated his charity and gave \$18 million + +to a charity run by the wife of his former patron. + +--Does the US Attorney believe that Mr. Epstein was working on a charity? + +--Was Mr. Epstein doing work as a Confidential Informer for the federal government as he has in the + +past? + +Mr. Eptein was Victim # 1 in the federal indictment of two Bear Stears executives on fraud charges stemming from a mortgage backed fund that went under. Mr. Epstein lost almost \$70 million in that + +fund. + +--Was Mr. Epstein working on the government case while working on "His Charity"? + +--Has your office ever agreed to any allow any other prisoner the same or similar sweet deal? + +--Was your office aware that in return for Mr. Goldberger's help, Mr. Epstein purchased for him a top of the line black BMW? (Sadly for Goldberger he was in an accident and totaled the vehicle three weeks + +later.) + +The USAO reached a NPA with Mr. Epstein in good faith. The Agreement speaks for itself about the + +expectations of the USAO regarding the length and conditions of punishment. Ultimately, the + +sentence was imposed by the State Court Judge who presided over the matter. + +At this time, we cannot comment further on your questions regarding any possible cooperation by Mr. + +Epstein, or what the USAO might have known or not known at the time of the negotiations. + +Re Alex Acosta alleged Conflict/Recusal Issue: + +It has come to my attention that the R. Alexander Acos to former Attorney General for the Southern District of Florida during the investigation and non-prosecution agreement with Mr. Epstein had been a + +law partner and friend of two Mr. Epstein's lawyers. Both Ken Star and Jay Lefkowitz had been partners with Mr. Acosta at the law firm of Kirkland & Ellis prior to his being appointed by President + +Bush. + +I have been told by sources that Mr. Acosta was the person responsible for the decision not to + +prosecute Mr. Epstein. + +I have also been told that during Mr. Starr's trip to FL to speak with federal prosecutors he complained to Mr. Acosta that the press coverage of his trips to FL on Mr. Epstein's private jets were being leaked + +by FBI agents. ( I can assure you that was not true.) + +--Did Mr. Acosta recuse himself from any discussions about the Epstein case so as to avoid even the + +appearance of impropriety? + +--Was the possibility of his removing himself from the case ever discussed by officials in the Justice + +Department? + +--Are there any memos regarding that? + +--Is there currently an Office of Professional Responsibility investigation into the facts surrounding the + +handling of this case and Mr. Acosta actions in it? + +Mr. Acosta recused from the matter in November 2008. That recusal was reviewed and approved by + +the Department of Justice, as is the standard procedure in all recusal matters. + +DOJ policy and the Privacy Act prohibit comment on the existence or non-existence of OPR investigations. However, please note that, at the request of the defense, the office of the deputy attorney general reviewed the U.S. Attorney's handling of this matter, including allegations of misconduct, and determined there was no basis to intervene in the matter. We will not be making + +additional comments. Thanks for checking with us. + +Thanks so much for your help, John Connolly + +From: (USAFLS) Sent: Monday, March 28, 2011 3:17 PM + +To: (USAFLS); (USAFLS); Cc: (USAFLS); . (USAFLS) + +Subject: RE: John Connolly Vanity Fair magazine -- Proposed responses + +(USAFLS) + +I think we should delete the line "Mr. Acosta recused from the matter in November 2008. That recusal was reviewed and approved by the Department of Justice, as is the standard procedure in all recusal matters." We simply shouldn't comment on 2008 Alex's recusal. I am comfortable with the rest with one caveat. If (and only if) the Roth letter has in fact been publicly filed, we could send that as well. + +Make sense? + +From: + +Sent: Monda + +To: Cc: + +Subject: John Connolly Vanity Fair magazine -- Proposed responses + +(USAFLS) + +March 28, 2011 2:45 PM . (USAFLS ; + +(USAFLS); + +(USAFLS); (USAFLS) + +. (USAFLS) + +Hi guys — + +Below please find my proposed answers [in red ink] to John Conolly of Vanity Fair. + +Let's discuss ASAP so I can send him a response. + +After we agree on a proposed response, I need to run this by DOJ-Public Affairs before sending out. + +Thanks + +From: john1885c [mailto: + +Sent: Frid larch 18, 2011 1:51 PM + +To: ,M (USAFLS) + +Subject: From: John Connolly Vanity Fair magazine Please confirm receipt. + +AUSA + +It was a pleasure speaking with you this morning. As per your request here are questions I would like to have answered for a piece I am researching on Jeffrey Epstein. As life would have it I am going to be on a busman's holiday this coming week on Singer Island, FL. I would like to meet you + +and whomever else you think I should speak with. If not, I understand perfectly. + +Let me preface these questions by saying that AUSA who was in charge of the investigation of Jeffrey Epstein has a remarkably record as a prosecutor. I also know that an AUSA does not have the authority to grant a potential defendant a non -prosecution agreement without the + +permission of higher ups in the Justice Department. + +Not quite three years ago, the US Attorney for the Southern District of Florida, granted Jeffrey Epstein + +a non-prosecution agreement in return for his accepting a FL State plea deal for his illegal acts regarding sex with minor females. The state case was handled by the West Palm Beach State + +Prosecutor who has since left office. + +--Was your office at the time of the agreement aware that Mr. Epstein would not be sent to a state prison facility as almost all defendants who are sentenced to more that a year in prison are required to + +do? + +--Was your office aware that Mr. Epstein would serve his sentence in the local WPB jail? + +--Was your office aware that Mr. Epstein would be allowed, what most FL law enforcement officials describe as "beyond a sweetheart deal", in that six days a week at 7:00 AM Mr. Epstein would leave the the WPB jail with a corrections officer he was personally paying for, and be escorted to the office of attorney Jack Goldberger where he would be allowed to stay until 11:00 PM and then be returned to + +jail for the evening? + +Ostensibly this was so that Mr. Epstein could work on a new charity he had formed. This despite the fact that just prior to beginning his jail sentence, Mr. Epstein liquidated his charity and gave \$18 million + +to a charity run by the wife of his former patron. + +--Does the US Attorney believe that Mr. Epstein was working on a charity? + +--Was Mr. Epstein doing work as a Confidential Informer for the federal government as he has in the + +past? + +Mr. Eptein was Victim # 1 in the federal indictment of two Bear Stears executives on fraud charges stemming from a mortgage backed fund that went under. Mr. Epstein lost almost \$70 million in that + +fund. + +--Was Mr. Epstein working on the government case while working on "His Charity"? + +--Has your office ever agreed to any allow any other prisoner the same or similar sweet deal? + +--Was your office aware that in return for Mr. Goldberger's help, Mr. Epstein purchased for him a top of the line black BMW? (Sadly for Goldberger he was in an accident and totaled the vehicle three weeks + +later.) + +The USAO reached a NPA with Mr. Epstein in good faith. The Agreement speaks for itself about the + +expectations of the USAO regarding the length and conditions of punishment. Ultimately, the + +sentence was imposed by the State Court Judge who presided over the matter. + +At this time, we cannot comment further on your questions regarding any possible cooperation by Mr. + +Epstein, or what the USAO might have known or not known at the time of the negotiations. + +Re Alex Acosta alleged Conflict/Recusal Issue: + +It has come to my attention that the R. Alexander Acos to former Attorney General for the Southern District of Florida during the investigation and non-prosecution agreement with Mr. Epstein had been a + +law partner and friend of two Mr. Epstein's lawyers. Both Ken Star and Jay Lefkowitz had been partners with Mr. Acosta at the law firm of Kirkland & Ellis prior to his being appointed by President + +Bush. + +I have been told by sources that Mr. Acosta was the person responsible for the decision not to + +prosecute Mr. Epstein. + +I have also been told that during Mr. Starr's trip to FL to speak with federal prosecutors he complained to Mr. Acosta that the press coverage of his trips to FL on Mr. Epstein's private jets were being leaked + +by FBI agents. ( I can assure you that was not true.) + +--Did Mr. Acosta recuse himself from any discussions about the Epstein case so as to avoid even the + +appearance of impropriety? + +--Was the possibility of his removing himself from the case ever discussed by officials in the Justice + +Department? + +--Are there any memos regarding that? + +--Is there currently an Office of Professional Responsibility investigation into the facts surrounding the + +handling of this case and Mr. Acosta actions in it? + +Mr. Acosta recused from the matter in November 2008. That recusal was reviewed and approved by + +the Department of Justice, as is the standard procedure in all recusal matters. + +DOJ policy and the Privacy Act prohibit comment on the existence or non-existence of OPR investigations. However, please note that, at the request of the defense, the office of the deputy attorney general reviewed the U.S. Attorney's handling of this matter, including allegations of misconduct, and determined there was no basis to intervene in the matter. We will not be making + +additional comments. Thanks for checking with us. + +Thanks so much for your help, John Connolly + +From: (USAFLS) < Sent: Monday, March 28, 2011 3:31 PM + +To: (USAFLS); (USAFLS); Cc: (USAFLS); . (USAFLS) + +Subject: Re: John Connolly Vanity Fair magazine -- Proposed responses + +.(USAFLS) + +Would the recusal request also be governed by the Privacy Act? While I do not like commenting on the 2008 recusal in a vacuum because of the erroneous inferences to which it could lead, it also seems to me that we might want to say something about why we're not responding to the recusal question. It also seems to me that an individual's recusal and the basis thereof might potentially fall under the + +Privacy Act. + +From: (USAFLS) Sent: Monda March 28, 2011 03:16 PM + +To: (USAFLS); USAFLS); (USAFLS) + +Cc: (USAFLS); (USAFLS) + +Subject: RE: John Connolly Vanity Fair magazine -- Proposed responses + +I think we should delete the line "Mr. Acosta recused from the matter in November 2008. That recusal was reviewed and approved by the Department of Justice, as is the standard procedure in all recusal matters." We simply shouldn't comment on 2008 Alex's recusal. I am comfortable with the rest with one caveat. If (and only if) the Roth letter has in fact been publicly filed, we could send that as well. + +Make sense? + +From: (USAFLS) + +Sent: Monda March 28, 2011 2:45 PM + +To: . (USAFLS); (USAFLS); Cc: (USAFLS); . (USAFLS) + +Subject: John Connolly Vanity Fair magazine -- Proposed responses + +(USAFLS) + +Hi guys — + +Below please find my proposed answers [in red ink] to John Conolly of Vanity Fair. + +Let's discuss ASAP so I can send him a response. + +After we agree on a proposed response, I need to run this by DOJ-Public Affairs before sending out. + +Thanks + +From: john1885c [mailto: + +Sent: Fridl larch 18, 2011 1:51 PM + +To: ,M (USAFLS) + +Subject: From: John Connolly Vanity Fair magazine Please confirm receipt. + +AUSA + +It was a pleasure speaking with you this morning. As per your request here are questions I would like to have answered for a piece I am researching on Jeffrey Epstein. As life would have it I am going to be on a busman's holiday this coming week on Singer Island, FL. I would like to meet you + +and whomever else you think I should speak with. If not, I understand perfectly. + +Let me preface these questions by saying that AUSA who was in charge of the investigation of Jeffrey Epstein has a remarkably record as a prosecutor. I also know that an AUSA does not have the authority to grant a potential defendant a non -prosecution agreement without the + +permission of higher ups in the Justice Department. + +Not quite three years ago, the US Attorney for the Southern District of Florida, granted Jeffrey Epstein + +a non-prosecution agreement in return for his accepting a FL State plea deal for his illegal acts regarding sex with minor females. The state case was handled by the West Palm Beach State + +Prosecutor who has since left office. + +Re terms and conditions of imprisonment: + +--Was your office aware of the extraordinary sweet deal that Mr. Epstein was granted by that state + +prosecutor? + +--Was your office at the time of the agreement aware that Mr. Epstein would not be sent to a state prison facility as almost all defendants who are sentenced to more that a year in prison are required to + +do? + +--Was your office aware that Mr. Epstein would serve his sentence in the local WPB jail? + +--Was your office aware that Mr. Epstein would be allowed, what most FL law enforcement officials describe as "beyond a sweetheart deal", in that six days a week at 7:00 AM Mr. Epstein would leave the the WPB jail with a corrections officer he was personally paying for, and be escorted to the office of attorney Jack Goldberger where he would be allowed to stay until 11:00 PM and then be returned to + +jail for the evening? + +Ostensibly this was so that Mr. Epstein could work on a new charity he had formed. This despite the fact that just prior to beginning his jail sentence, Mr. Epstein liquidated his charity and gave \$18 million + +to a charity run by the wife of his former patron. + +--Does the US Attorney believe that Mr. Epstein was working on a charity? + +--Was Mr. Epstein doing work as a Confidential Informer for the federal government as he has in the + +past? + +Mr. Eptein was Victim # 1 in the federal indictment of two Bear Stears executives on fraud charges stemming from a mortgage backed fund that went under. Mr. Epstein lost almost \$70 million in that + +fund. + +--Was Mr. Epstein working on the government case while working on "His Charity"? + +--Has your office ever agreed to any allow any other prisoner the same or similar sweet deal? + +--Was your office aware that in return for Mr. Goldberger's help, Mr. Epstein purchased for him a top of the line black BMW? (Sadly for Goldberger he was in an accident and totaled the vehicle three weeks + +later.) + +The USAO reached a NPA with Mr. Epstein in good faith. The Agreement speaks for itself about the + +expectations of the USAO regarding the length and conditions of punishment. Ultimately, the + +sentence was imposed by the State Court Judge who presided over the matter. + +Re Alex Acosta alleged Conflict/Recusal Issue: + +It has come to my attention that the R. Alexander Acos to former Attorney General for the Southern District of Florida during the investigation and non-prosecution agreement with Mr. Epstein had been a + +law partner and friend of two Mr. Epstein's lawyers. Both Ken Star and Jay Lefkowitz had been partners with Mr. Acosta at the law firm of Kirkland & Ellis prior to his being appointed by President + +Bush. + +I have been told by sources that Mr. Acosta was the person responsible for the decision not to + +prosecute Mr. Epstein. + +I have also been told that during Mr. Starr's trip to FL to speak with federal prosecutors he complained to Mr. Acosta that the press coverage of his trips to FL on Mr. Epstein's private jets were being leaked + +by FBI agents. ( I can assure you that was not true.) + +--Did Mr. Acosta recuse himself from any discussions about the Epstein case so as to avoid even the + +appearance of impropriety? + +--Was the possibility of his removing himself from the case ever discussed by officials in the Justice + +Department? + +--Are there any memos regarding that? + +--Is there currently an Office of Professional Responsibility investigation into the facts surrounding the + +handling of this case and Mr. Acosta actions in it? + +Mr. Acosta recused from the matter in November 2008. That recusal was reviewed and approved by + +the Department of Justice, as is the standard procedure in all recusal matters. + +DOJ policy and the Privacy Act prohibit comment on the existence or non-existence of OPR investigations. However, please note that, at the request of the defense, the office of the deputy attorney general reviewed the U.S. Attorney's handling of this matter, including allegations of misconduct, and determined there was no basis to intervene in the matter. We will not be making + +additional comments. Thanks for checking with us. + +Thanks so much for your help, John Connolly + +To: (USAFLS); (USAFLS); + +Cc: (USAFLS) + +Subject: FW: Doe v. USAO Attachments: WordPerfect 6.1.WPD (USAFLS) + +Hi everyone — This is a draft of Epstein's motion to intervene. One strategic issue. I just took a quick glance and noticed that some of the cases and arguments that I have in my draft (which I am about to send to you) are raised in Epstein's motion. I think that we should file before Epstein does. I don't + +want there to be a suggestion that we "copied" from them. + +Assistant U.S. Attorney + +Fax + +From: Jackie Perczek [mailto:JPerczek@royblack.com] + +Sent: Frida , A ril 01, 2011 4:58 PM + +To: . (USAFLS); (USAFLS) + +Cc: Roy BLACK + +Subject: Doe v. USAO + +Good afternoon and Ann + +Consistent with the conversation Roy and I had with this week, attached is a working draft of the motion to intervene and the objections we intend to lodge to the recent filings of Doe 1 and Doe 2 concerning discovery and disclosure of plea negotiation letters and emails. Please let us know your + +position. + +Have a good weekend, + +Jackie + +From: (USAFLS) ‹ > + +Sent: Tuesday, April 05, 2011 9:39 AM + +Assistant U.S. Attorney + +Fax + +Ori inal intment + +From: (USAFLS) On Behalf Of (USAFLS) + +Sent: Tuesda Aril 05, 2011 9:18 AM + +To: (USAFLS); (USAFLS); (USAFLS) + +Subject: Epstein + +When: Tuesday, April 05, 2011 4:00 PM-4:30 PM (GMT-05:00) Eastern Time (US & Canada). + +Where: = ofcl= by phone + +----- Subject: Location: + +Epstein + +ofc./M by phone + +Start: Tue 4/5/2011 4:00 PM End: Tue 4/5/2011 4:30 PM + +Show Time As: Tentative + +Recurrence: (none) + +Organizer: (USAFLS) + +Required Attendees: (USAFLS); (USAFLS); . (USAFLS) + +When: Tuesday, A ril 05, 2011 4:00 PM-4:30 PM (GMT-05:00) Eastern Time (US & Canada). + +Where: ()kJ= by phone + +Note: The GMT offset above does not reflect daylight saving time adjustments. + +From: (USAFLS) < + +Sent: Saturday, April 02, 2011 5:20 PM + +Colleagues, + +Attached please find my draft opposition to the petitioners' motion for finding of violations of the CVRA. I have responded to the arguments in Cassell's motion, and also argued that the court lacks authority to set aside the + +non-prosecution agreement, assuming arguendo it found a violation of section 3771(a)(5). As to the + +statement of uncontroverted facts, I admitted those facts which we believe to be true, but denied as irrelevant those which have no bearing on the statutory interpretation issue. We could actually contend that all the "facts" alleged by Cassell are irrelevant, but I wanted to demonstrate good faith in agreeing to certain of the + +facts. + +I welcome your comments and suggestions. Our response is due on Thursday, April 7, 2011. I will begin + +working on the other two motions filed by Cassell. + +Thanks for your assistance. If you have any questions, please call me at + +• + +«victims\_govt\_opp\_motion\_enforce.wpd» + +From: (USAFLS) Sent: Tuesday, April 05, 2011 9:42 AM + +To: (USAFLS); (USAFLS); (USAFLS) + +Subject: RE: Epstein + +As soon as I am back in the office I will email all of you. + +Assistant U.S. Attorney + +Fax + +From: (USAFLS) Sent: Tuesda , A ril 05, 2011 9:41 AM + +To: . (USAFLS); (USAFLS); (USAFLS) + +Ok with me (I need to leave here by 5:00 for yet another going away party but that should give is + +enough time). + +From: (USAFLS) Sent: Tuesda , A ril 05, 2011 09:39 AM + +To: (USAFLS); (USAFLS); (USAFLS) + +Subject: RE: Epstein + +Is there any chance that we could start at 4:30? I have an appointment at 3:45 just to have a quick + +blood test down the street, but I don't want to cut it too close. + +Assistant U.S. Attorney + +Fax + +Ori inal A ointment + +From: (USAFLS) On Behalf Of (USAFLS) + +Sent: Tuesda , A ril 05, 2011 9:18 AM + +To: (USAFLS); (USAFLS); . (USAFLS) + +Subject: Epstein + +When: Tuesday, A. ril 05, 2011 4:00 PM-4:30 PM (GMT-05:00) Eastern Time (US & Canada). + +Where: ofc./M by phone + +From: Sent: To: Subject: (USAFLS) '( .> + +Tuesday, April 05, 2011 9:41 AM + +. (USAFLS); (LISAFL5); (LISAFLS) + +Re: Epstein + +Ok with me (I need to leave here by 5:00 for yet another going away party but that should give is + +enough time). + +From: (USAFLS) Sent: Tuesda , A ril 05, 2011 09:39 AM + +To: (USAFLS); (USAFLS); (USAFLS) + +Subject: RE: Epstein + +Assistant U.S. Attorney + +Fax + +Ori inal intment + +From: (USAFLS) On Behalf Of (USAFLS) + +Sent: Tuesda Aril 05, 2011 9:18 AM + +To: (USAFLS); (USAFLS); (USAFLS) + +Subject: Epstein + +When: Tuesday, April 05, 2011 4:00 PM-4:30 PM (GMT-05:00) Eastern Time (US & Canada). + +Where: = ofc.M by phone + +From: (USAFLS) Sent: Sunday, April 03, 2011 2:40 PM + +To: (USAFLS); (USAFLS); + +(USAFLS); ); (USAFLS) + +Cc: (OLP) (JMD); (USAEO); Subject: RE: Draft Opposition to Victims' Motion for Finding of Violations + +Attachments: Response to Summary Judgment Motn 4-3-2011.wpd + +Good afternoon, everyone. + +Here is my attempt at addressing the same topics. I will work with + +<> + +(USAFLS); + +(USAEO) + +tomorrow to meld the two into one. + +One thought on the "statement of undisputed facts," I would not respond to it at all in this response, I would only discuss it in the response to Docket Entry 49 ("Jane Does Motion to Have Their Facts Accepted Because of the + +Government's Failure to Contest Any of the Facts.") + +First I would hammer the fact that they told the court that there was no need for any more facts at the last hearing on this case. Then, I would not agree to many of their "facts" that has listed as admitted. In my start of a + +draft response to DE 49, which I have sent to I included the following: + +We note the Justice Department's policy not to comment on the guilt or innocence of an unconvicted person. The ABA's Model Rules of Professional Conduct on the Special Responsibilities of a Prosecutor contains similar + +defendant Jeffrey Epstein (a billionaire with significant with significant political connections) sexually abused more than 30 minor girls at his mansion in West Palm Beach (sic), Florida, and elsewhere. Epstein + +performed repeated lewd, lascivious, and sexual acts on them, including (but not limited to) + +. Because Epstein used a means of interstate commerce and + +knowingly traveled in interstate commerce to engage in abuse of Jane Doe #1 and Jane Doe #2 (and the other victims), he committed violations of federal law, including repeated violations of 18 U.S.C. § 2422. + +(DE48 at 3-4 ¶ 1.) Jane Does No. 1 and No. 2 had the opportunity to prove these allegations at trial but elected to sign confidential settlement agreements where, presumably, there was no acknowledgement of criminal or civil liability. Respectfully, the U.S. Attorney's Office will leave the final determinations of what, if any, crimes Mr. Epstein committed (other than those to which he pled guilty in Palm Beach County Circuit Court), to any + +judge and/or jury who are called upon to see and hear the evidence against Mr. Epstein. + +My concern is that if we agree to statements like these, on behalf of the Department of Justice, it can be used + +against another USAO that may try to prosecute Epstein in the future. + +Assistant U.S. Attorney + +From: (USAFLS) + +Sent: Saturda Aril 02 2011 5:20 PM + +To: (USAFLS); -. (USAFLS); + +(USAFLS + +Cc: . (SMO); (USAEO); + +Subject: Draft Opposition to Victims' Motion for Finding of Violations + +Colleagues, + +(USAEO) + +(USAFLS); + +Attached please find my draft opposition to the petitioners' motion for finding of violations of the CVRA. I have responded to the arguments in Cassell's motion, and also argued that the court lacks authority to set aside the + +non-prosecution agreement, assuming arguendo it found a violation of section 3771(a)(5). As to the + +statement of uncontroverted facts, I admitted those facts which we believe to be true, but denied as irrelevant those which have no bearing on the statutory interpretation issue. We could actually contend that all the "facts" alleged by Cassell are irrelevant, but I wanted to demonstrate good faith in agreeing to certain of the + +facts. + +I welcome your comments and suggestions. Our response is due on Thursday, April 7, 2011. I will begin + +working on the other two motions filed by Cassell. + +Thanks for your assistance. If you have any questions, please call me at + +From: Sent: To: Subject: (USAFLS) + +Thursday, April 07, 2011 8:12 AM + +Fw: Blended Opposition to Motion for Finding of Violations + +Hi . Since you will most likely have to defend on appeal, can you make sure everything is ok? + +From: (USAFLS) + +Sent: Wednesda A ril 06, 2011 04:52 PM To: . (USAFLS); + +USAFLS) + +Cc: (USAFLS) + +Subject: Blended Opposition to Motion for Finding of Violations + +Colleagues, + +. (USAFLS); (USAFLS); + +Attached please find a document integrating the draft oppositions that and I prepared. I deleted the following: (1) lack of standing argument; (2) no case or controversy argument (mootness); and (3) victims' + +exclusive remedy is to file an administrative complaint with the Attorney General. + +From draft, I included the procedural history, the analysis of all 8 rights and how the government either complied, or the right did not attach, and the analysis on separation of powers and prosecutorial discretion. + +Please let me know what you think. If you wish to discuss the revisions, please let me know. Thanks. + +< + +Subject: RE: Question re Preservation of Electronically Stored Information re Epstein/Jane Does + +Date: Thu, 06 Jan 2011 14:33:54 +0000 + +Importance: Normal + +w ill be contacting you. We made copies of the documents on your N and .PST. That will be what you need to review, not the originals. + +Sent: Wednesda January 05 2011 6:02 PM + +u j : : ue on re reserva ion oElectronically o n omm on re ein ane + +Thanks for your caution with this. + +Please have IT do this. They can capture the information. As a Lit Hold is already in place, I would suggest contacting as perhaps the information has already been captured. I am copying Jacquie on this email so that she or another IT person can assist you. + +Best wishes for the new year. + +Sent: wednesda January 05 2011 5:50 PM + +Good evening, everyone. The Justice Department has made an inquiry of Dexter, that he has passed along to me, to review our records and gather some information for them to review. This is going to require me to search and + +retrieve emails and electronic documents (Word Perfect documents) to give to Dexter, so that he can send them to Washington. Obviously I will not be altering the documents or emails in any way, but I know that just opening the documents can change the data. Is there a way for me to do this safely? + +Thank you. + +![](_page_1_Picture_2.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00206513/EFTA00206513.metadata.json b/marker2/ds9/EFTA00206513/EFTA00206513.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..eac1f66a6247d809d2bc8baa9034e233c0724ca7 --- /dev/null +++ b/marker2/ds9/EFTA00206513/EFTA00206513.metadata.json @@ -0,0 +1,90 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206513.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1374, + "elapsed_seconds": 0.7, + "image_assets": [ + "_page_1_Picture_2.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 39 + ], + [ + "Line", + 18 + ], + [ + "Text", + 13 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 9 + ], + [ + "Line", + 5 + ], + [ + "Text", + 2 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206513" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206513/_page_1_Picture_2.jpeg b/marker2/ds9/EFTA00206513/_page_1_Picture_2.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..cb9053629c50e900124ed5f174e3622e92620ff5 --- /dev/null +++ b/marker2/ds9/EFTA00206513/_page_1_Picture_2.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:c676c62cd655bca91591c4be2a9b2c67ef73cc878639c63310bbf2bf1597e883 +size 8790 diff --git a/marker2/ds9/EFTA00206515/EFTA00206515.md b/marker2/ds9/EFTA00206515/EFTA00206515.md new file mode 100644 index 0000000000000000000000000000000000000000..1a1e9f8e68be69402d1a7062354f0efba3315f2c --- /dev/null +++ b/marker2/ds9/EFTA00206515/EFTA00206515.md @@ -0,0 +1,45 @@ +![](_page_0_Picture_72.jpeg) + +**Subject:** RE: Question re Preservation of Electronically Stored Information re Epstein/Jane Does + +**Date:** Thu, 06 Jan 2011 14:36:20 +0000 + +**Importance:** Normal + +--- + +Other people involved on the Lit. Hold you mean ? + +![](_page_0_Picture_77.jpeg) + +**Subject:** RE: Question re Preservation of Electronically Stored Information re Epstein/Jane Does + +Great. Do you have copies of other people's emails, too? + +![](_page_0_Picture_80.jpeg) + +![](_page_0_Picture_81.jpeg) + +**Subject:** RE: Question re Preservation of Electronically Stored Information re Epstein/Jane Does + +Ann Marie: + +Damaris will be contacting you. We made copies of the documents on your N and .PST. That will be what you need to review, not the originals. + +![](_page_0_Picture_85.jpeg) + +S) + +**Subject:** RE: Question re Preservation of Electronically Stored Information re Epstein/Jane Does + +Thanks for your caution with this. + +Please have IT do this. They can capture the information. As a Lit Hold is already in place, I would suggest contacting J [REDACTED] as perhaps the information has already been captured. I am copying [REDACTED] on this email so that she or another IT person can assist you. + +ey + +Subject: Question re Preservation of Electronically Stored Information re Epstein/Jane Does • + +Good evening, everyone. The Justice Department has made an inquiry of Mthat he has passed along to me, to review our records and gather some information for them to review. This is o require me to search and retrieve emails and electronic documents (Word Perfect documents) to give to so that he can send them to Washington. Obviously I will not be altering the documents or emails in any way, but I know that just opening the documents can change the data. Is there a way for me to do this safely? + +Thank you. \ No newline at end of file diff --git a/marker2/ds9/EFTA00206515/EFTA00206515.metadata.json b/marker2/ds9/EFTA00206515/EFTA00206515.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..edc3db853e07e5485a4a811d5ae367699e265a0d --- /dev/null +++ b/marker2/ds9/EFTA00206515/EFTA00206515.metadata.json @@ -0,0 +1,94 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206515.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1813, + "elapsed_seconds": 4.66, + "image_assets": [ + "_page_0_Picture_72.jpeg", + "_page_0_Picture_77.jpeg", + "_page_0_Picture_80.jpeg", + "_page_0_Picture_81.jpeg", + "_page_0_Picture_85.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 36 + ], + [ + "Text", + 31 + ], + [ + "Line", + 17 + ], + [ + "Picture", + 5 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 19 + ], + [ + "Line", + 10 + ], + [ + "Text", + 5 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206515" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206515/_page_0_Picture_72.jpeg b/marker2/ds9/EFTA00206515/_page_0_Picture_72.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..59c1f3a31274b2da4a773ee60c74fd7d6e19147e --- /dev/null +++ b/marker2/ds9/EFTA00206515/_page_0_Picture_72.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:762a58bd19019874461a96aed53f3bafbf842201ed075e9a4f681a6aa8e30245 +size 5624 diff --git a/marker2/ds9/EFTA00206515/_page_0_Picture_77.jpeg b/marker2/ds9/EFTA00206515/_page_0_Picture_77.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..ac9ccb37077100411b3e2675e79790a1cdab76a3 --- /dev/null +++ b/marker2/ds9/EFTA00206515/_page_0_Picture_77.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:ed20e7a4b5840817305315278d72cdcdefbe6061d8cc9eb27e2d4f050f7d5816 +size 2852 diff --git a/marker2/ds9/EFTA00206515/_page_0_Picture_80.jpeg b/marker2/ds9/EFTA00206515/_page_0_Picture_80.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..78bb39cbd2631e6c5af316eb062cdcc03a881132 --- /dev/null +++ b/marker2/ds9/EFTA00206515/_page_0_Picture_80.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:9d0dde089b58a5fe80e0477cf089f059f36f599b282e2ad1e97bafb395761a82 +size 5197 diff --git a/marker2/ds9/EFTA00206515/_page_0_Picture_81.jpeg b/marker2/ds9/EFTA00206515/_page_0_Picture_81.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..9a52a7d3c47406ac1f5ae5330cbd8139eadce7ff --- /dev/null +++ b/marker2/ds9/EFTA00206515/_page_0_Picture_81.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:f0ff64bf7b71707e3019b7d3d5d95cf0c0fbd174a89785b8696da33fe782645c +size 6750 diff --git a/marker2/ds9/EFTA00206515/_page_0_Picture_85.jpeg b/marker2/ds9/EFTA00206515/_page_0_Picture_85.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..b4590358a6bd37c61627c0efbbbfda5c22634605 --- /dev/null +++ b/marker2/ds9/EFTA00206515/_page_0_Picture_85.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:8ab8995a9d46b17f3f76d8eca1282627f8198077bd43e153ca916a2a39ab41df +size 5121 diff --git a/marker2/ds9/EFTA00206517/EFTA00206517.md b/marker2/ds9/EFTA00206517/EFTA00206517.md new file mode 100644 index 0000000000000000000000000000000000000000..8d0d131b0bf65d1f5b2baaa6b5e456a5f77ec731 --- /dev/null +++ b/marker2/ds9/EFTA00206517/EFTA00206517.md @@ -0,0 +1,67 @@ +To: ' , . (USAFLS)" + +Subject: RE: Setting up a conference call + +Date: Tue, 08 Feb 2011 15:01:06 +0000 + +Importance: Normal + +I have to set it up with the service first. Thanks. + +From: . I. (USAFLS) + +Sent: TuescSFebruary 08, 2011 9:57 AM + +To: M, MI (USAFLS) + +Subject: RE: Setting up a conference call + +Hi — What is the call-in number and the other info they need? I will send out the info today. Thanks. + +![](_page_0_Picture_11.jpeg) + +Fro + +Sent 42 PM + +To: S) + +Subject: RE: Setting up a conference call + +Great, thanks. + +From: , M U. (USAFLS) + +Sent 41 PM + +T + +Should only be 4, so say 4-6 + +![](_page_0_Picture_22.jpeg) + +nce call + +From Sent: Fr aly, Febru 4, 2011 3:41 PM To: (USAFLS) Subject: RE: Setting up a conference call + +6-8 participants? + +From: U. (USAFLS) Sent: Friday, February 04, 2011 3:39 PM Subject: RE: Setting up a conference call + +They can join at any time. + +![](_page_1_Picture_5.jpeg) + +From Sent: ay, February 04, 2011 3:37 PM To: (USAFLS) Subject: RE: Setting up a conference call + +Do you want them to be "announced" or free to join at any time? + +From: I. (USAFLS) Sent: Fri ebruary 04, 2011 3:30 PM To: M, (USAFLS) Subject: Setting up a conference call + +Hi — Can you set up another one of those "official" conference calls? For Thursday at 10:30? It is with the Epstein lawyers. I guess I will be the "organizer." 10:30 to 12:00 should be plenty of time. + +Thanks. + +![](_page_1_Picture_11.jpeg) + +Fax \ No newline at end of file diff --git a/marker2/ds9/EFTA00206517/EFTA00206517.metadata.json b/marker2/ds9/EFTA00206517/EFTA00206517.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..ca66652dc606259a80c352e5519bc012103cdaab --- /dev/null +++ b/marker2/ds9/EFTA00206517/EFTA00206517.metadata.json @@ -0,0 +1,127 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206517.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 1417, + "elapsed_seconds": 1.16, + "image_assets": [ + "_page_0_Picture_11.jpeg", + "_page_0_Picture_22.jpeg", + "_page_1_Picture_5.jpeg", + "_page_1_Picture_11.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 44 + ], + [ + "Line", + 22 + ], + [ + "Text", + 21 + ], + [ + "Picture", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 60 + ], + [ + "Line", + 24 + ], + [ + "Text", + 10 + ], + [ + "Picture", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 3 + ], + [ + "Line", + 2 + ], + [ + "Text", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206517" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206517/_page_0_Picture_11.jpeg b/marker2/ds9/EFTA00206517/_page_0_Picture_11.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..8f6df964713b0459052b5e83542e5e0170f79e35 --- /dev/null +++ b/marker2/ds9/EFTA00206517/_page_0_Picture_11.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:e2a42e3446a4753bf133ae1f5e10f1da12a9cf8c56c5e2091f58f261dc0c4bd4 +size 8410 diff --git a/marker2/ds9/EFTA00206517/_page_0_Picture_22.jpeg b/marker2/ds9/EFTA00206517/_page_0_Picture_22.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..5bbeed96fa79415c8cd1d63d1af33c3970ab3e69 --- /dev/null +++ b/marker2/ds9/EFTA00206517/_page_0_Picture_22.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:e390e58c0a44508302998b9425873194b9e13e5a4596b65a73f4db914562772f +size 7268 diff --git a/marker2/ds9/EFTA00206517/_page_1_Picture_11.jpeg b/marker2/ds9/EFTA00206517/_page_1_Picture_11.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..a6ba3de47b8077740cb90fd7947574937c3a0bfb --- /dev/null +++ b/marker2/ds9/EFTA00206517/_page_1_Picture_11.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:8ba7fa469e2d47451a29cb38043744bbe5faa9317c04d45cf89782176f398243 +size 7488 diff --git a/marker2/ds9/EFTA00206517/_page_1_Picture_5.jpeg b/marker2/ds9/EFTA00206517/_page_1_Picture_5.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..11059e167cbcd181ec2389719230661bebd4c538 --- /dev/null +++ b/marker2/ds9/EFTA00206517/_page_1_Picture_5.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:9b969f12c9833c325de12ed0493076c6ea1bc7dd831422b653acbf3100cf3e0c +size 7318 diff --git a/marker2/ds9/EFTA00206520/EFTA00206520.md b/marker2/ds9/EFTA00206520/EFTA00206520.md new file mode 100644 index 0000000000000000000000000000000000000000..259e221e77353b8563cb354b915b98d72c36b8ce --- /dev/null +++ b/marker2/ds9/EFTA00206520/EFTA00206520.md @@ -0,0 +1,57 @@ +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA + +#### CASE NO. 08-CIV-80893-MARRA/JOHNSON + +JANE DOE NO. 2, + +Plaintiff, + +vs. + +JEFFREY EPSTEIN, + +Defendant. + +Related cases: + +08-80232, 08-80380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80119, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 + +### ORDER + +THIS CAUSE is before the Court on Defendant Jeffrey Epstein's Motion for Protective Order and Objection to Disclosure of Certain Documents (D.E. #214). For the following reasons said Motion is granted in part and denied in part accordance with the terms herein. + +## BACKGROUND + +On July 20, 2010 the United States District Court entered a Final Order in the above-captioned case dismissing the action with prejudice and closing the case. (D.E. #211). In said Order, Judge Marra stated "[t]he Court shall retain jurisdiction to enforce the terms of the parties' settlement and the joint stipulation (D.E. #207) and Order thereon." Id. The Joint Stipulation (D.E. #207) referred to, which was ultimately adopted by the District Court by way of Order (D.E. #209), puts into place a mechanism for dealing with future efforts of Plaintiffs or Plaintiffs' counsel to disclose or make public certain discovery that Plaintiffs were provided in the underlying Doe I. Epstein case. + +Specifically, the Joint Stipulation provides that Counsel for Jane Doe and Counsel for Epstein disagree whether certain correspondence, defined by the parties as "correspondence and documents (including content thereof) between Epstein's attorneys/agents and federal prosecutors [received through discovery]" is confidential.(D.E. #207, p.1). In light of said disagreement, the parties jointly stipulated that to the extent Plaintiffs' Counsel "or Mr. Edwards as a Defendant in the Epstein I. Rothstein case" wished to file, disclose or make available to anyone else the subject Correspondence, said Counsel or Mr. Edwards must first provide Epstein's Counsel with seven (7) days notice of an intent to so use the material or alternatively file the material under seal. Epstein's Counsel would thereafter be given seven (7) days from the date of any such notice or filing under seal within which to file any objection. Once Epstein's Counsel files an objection, the material is not to be disclosed until the Court has ruled on the objection. Id. at pp. 1-2. + +On August 26, 2010, Plaintiffs' Counsel served Notice of its intent to use the Correspondence in two separate court proceedings, an internal Justice Department Complaint procedure (and in connection with this procedure disseminate the material to the media), and in a pending state court proceeding styled Epsteinil. Edwards, No. 502009 CA040800XXXXMB AG, that Epstein initiated against Plaintiffs' Counsel Edwards, among others, alleging a conspiracy to use Epstein's case as a lure in an illegal Ponzi scheme. + +Epstein's Counsel filed a timely objection to the attempt to use such Correspondence, and in said Objection argued the Correspondence is privileged and inadmissible under the Federal Rules of Evidence and the Florida Rules of Evidence. Counsel for Plaintiffs, for their part, argued the State Court is in the best position to determine whether the evidence is admissible in the state proceeding and that insofar as the internal Justice Department Complaint procedure, because Epstein is not a party to that suit, without moving for and obtaining leave to intervene, Epstein has no standing to raise objections to use of the Correspondence in that case.' The instant Motion for Protective Order followed. + +# ANALYSIS + +To the extent Epstein's Counsel asks the Court to find the subject correspondence privileged and on that basis prohibit Plaintiffs' Counsel from disclosing it in either of the two proceedings, said request is denied. However, to the extent Epstein requests entry of a protective order requiring Plaintiffs' Counsel to file the subject Correspondence he wishes to make public under seal with the appropriate institution (e.g. the State Court proceeding and the Justice Department), said Motion is granted. + +In this regard, the Court agrees with Plaintiffs' Counsel that the judge presiding over the state court case and the appropriate decision maker in the Internal Justice Department Complaint procedure are the ones best suited to make the determination of admissibility as it relates to their respective cases. In so ruling the Court is specifically not holding that it is without jurisdiction to enforce the terms of the Joint Stipulation. On the contrary, the Court recognizes that by virtue of the Joint Stipulation (D.E. #207), which was adopted by + +&#x27; Plaintiffs' Counsel also contends that these arguments were previously raised and rejected by the undersigned, but the Court finds this argument without merit as the admissibility of these documents in the State Court and internal Justice Department Proceeding were never before the Court. + +the Court (D.E. #209), and by virtue of the Final Judgment in which the District Court specifically retained jurisdiction to enforce the terms of the parties' settlement and Joint Stipulation (D.E. #211), the Court has jurisdiction to enforce the stated wishes of the parties as set forth in the Joint Stipulation. See American Disability Assn., Inc. ff. Chmielarz, 289 F.3d 1315, 1321 (11th Cir. 2002). + +The stated wishes of the parties as set forth in the Joint Stipulation and as approved by the District Court in its Final Judgment are clear: As part of the settlement the parties agreed to keep the subject correspondence confidential until notice of intended use was given, an opportunity for objection to such use by Epstein could be made, and a ruling was entered by the Court. In other words, the Final Judgment entered in this case requires the parties to seek a ruling on use of the subject Correspondence before its use in other proceedings. As Epstein correctly observes, Plaintiffs' Counsel's apparent belief that it may proceed to file the subject correspondence in a court file or make use the subject correspondence in the media or as exhibits to depositions without first seeking leave of Court is flawed, as it leaves Epstein without an opportunity to prevent disclosure of the correspondence in contravention of the stated intent of the Joint Stipulation. Thus, to the extent Plaintiffs' Counsel wishes to make the subject Correspondence public by either filing the Correspondence in a court file, attaching it to a deposition, releasing it to the media, or publically disseminating it in any other fashion, before allowing Epstein an opportunity to object to its disclosure, Counsel's request is denied. + +## CONCLUSION + +In the instant case, Epstein is objecting to use of the subject Correspondence in one + +court proceeding and in one internal Justice Department proceeding. Because each of these institutions have their own internal proceedings and rules regulating the discoverability and/or admissibility of documents, it is these proceedings to which the ultimate question of the Correspondence's admissibility and/or public disclosure should be directed. Accordingly, to the extent Epstein requests entry of a protective order requiring Plaintiffs' Counsel to file the subject Correspondence he wishes to make public under seal with the appropriate institution (e.g. the State Court proceeding and the Justice Department), and obtain a ruling from that institution on the use to which such Correspondence can be put, said Motion is granted. However, to the extent Epstein's Counsel asks the Court to enter a protective order finding the subject correspondence privileged and on that basis prohibit Plaintiffs' Counsel from disclosing it in either of the two proceedings, said request is denied. In all events, however, Plaintiffs' Counsel is reminded that the subject Correspondence must be filed under seal and a ruling obtained on the use to which such Correspondence may be put before the Correspondence may be disclosed or in any way made public. In accordance with the above and foregoing, it is hereby, + +ORDERED AND ADJUDGED that Defendant Jeffrey Epstein's Motion for Protective Order and Objection to Disclosure of Certain Documents (D.E. #214) is GRANTED IN PART AND DENIED IN PART in accordance with the terms herein. + +DONE AND ORDERED this January 5, 2011, in Chambers, at West Palm Beach, Florida. + +> LINNEA R. JOHN UNITED STATES MAGISTRATE JUDGE N + +CC: The Honorable Kenneth A. 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+ ], + "debug_data_path": "debug_data/EFTA00206520" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206526/EFTA00206526.md b/marker2/ds9/EFTA00206526/EFTA00206526.md new file mode 100644 index 0000000000000000000000000000000000000000..e508411167947a05e5763a0ce0014a9ee2cc2aff --- /dev/null +++ b/marker2/ds9/EFTA00206526/EFTA00206526.md @@ -0,0 +1,59 @@ +From: ' To: ' ' < + +Subject: Activity in Case 9:08-cv-80893-KAM Doe 1 Epstein Order + +Date: Wed, 05 Jan 2011 21:44:56 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered on 1/5/2011 at 4:44 PM EST and filed on 1/5/2011 + +Case Name: Doe I Epstein + +Case Number: 9:08-cv-80893-KAM + +Filer: + +WARNING: CASE CLOSED on 07/20/2010 + +Document Number: 226 + +## Docket Text: + +ORDER Granting In Part and Denying In Part [214] Defendant's MOTION for Protective Order and Objection to Disclosure of Certain Documents with Integrated Memorandum of Law filed by Jeffrey Epstein. Signed by Magistrate Judge Linnea R. Johnson on 1/5/2011. (sa) + +9:08-cv-80893-KAM Notice has been electronically mailed to: + +IN I + +Bradley James Edwards + +Jack Alan Goldberger + +Joseph Laurence Ackerman , Jr WHITE.COM NTROMPET@FOWLER- + +Katherine Warthen Ezell + +Lilly - + +9:08-cv-80893-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1 + +The following document(s) are associated with this transaction: + +Document description:Main Document + +Original filename:n/a + +Electronic document Stamp: + +[STAMP dcecpamp\_1D=1105629215 Wate=1/5/2011.1 IFileNumber=8357417-0.1 11146j8ffil6b43d2j87d2d2d9le455ffa9de60110be676f669e83827d5580691c7ael d48c7b0c04468416311da6adj2183710eeac9130.1321637ddbe740f47d7bil \ No newline at end of file diff --git a/marker2/ds9/EFTA00206526/EFTA00206526.metadata.json b/marker2/ds9/EFTA00206526/EFTA00206526.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..26c9ca65d2e058babe6cee89f0e52c1a85fcb47f --- /dev/null +++ b/marker2/ds9/EFTA00206526/EFTA00206526.metadata.json @@ -0,0 +1,135 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206526.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2127, + "elapsed_seconds": 1.18, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 31.212, + 309.42 + ], + [ + 184.74722290039062, + 309.42 + ], + [ + 184.74722290039062, + 324.6035461425781 + ], + [ + 31.212, + 324.6035461425781 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 31.212, + 439.02 + ], + [ + 101.52233123779297, + 439.02 + ], + [ + 101.52233123779297, + 453.3170471191406 + ], + [ + 31.212, + 453.3170471191406 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 78 + ], + [ + "Line", + 37 + ], + [ + "Text", + 24 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 23 + ], + [ + "Line", + 11 + ], + [ + "Text", + 7 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206526" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206528/EFTA00206528.md b/marker2/ds9/EFTA00206528/EFTA00206528.md new file mode 100644 index 0000000000000000000000000000000000000000..82f3cc139f4c9498dfb7b46cdbe2fc7e6653f082 --- /dev/null +++ b/marker2/ds9/EFTA00206528/EFTA00206528.md @@ -0,0 +1,17 @@ +To: + +Cc: + +Subject: Call from OPR + +Date: Tue, 04 Jan 2011 20:27:16 +0000 + +Importance: Normal + +I've just spoken witl at OPR, regarding the request for investigation submitted by Paul Cassell. She is in the preliminary stages of determining whether the matter should be opened into an investigation. To assist her in this process, she asked if we could produce the following: + +(1) documents such as memos or e-mails which show the decisional process for determining whether this Office should enter into the Non-Prosecution Agreement with Epstein. This would include opposing views within the office, as well as supporting views; and + +(2) documents showing whether the FBI was, or was not, made aware of the negotiations with Epstein regarding the Non-Prosecution Agreement. Cassell claims the FBI was kept completely out of the process. + +Can you canvass your files and find out whether responsive documents exist? Thanks. \ No newline at end of file diff --git a/marker2/ds9/EFTA00206528/EFTA00206528.metadata.json b/marker2/ds9/EFTA00206528/EFTA00206528.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..a8e8896106f8be2c2525b94f61ad86da208f76ae --- /dev/null +++ b/marker2/ds9/EFTA00206528/EFTA00206528.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206528.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 919, + "elapsed_seconds": 0.63, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 35 + ], + [ + "Line", + 18 + ], + [ + "Text", + 12 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206528" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206529/EFTA00206529.md b/marker2/ds9/EFTA00206529/EFTA00206529.md new file mode 100644 index 0000000000000000000000000000000000000000..50d2834e352c6519676309f5345d2e927c4d1d1b --- /dev/null +++ b/marker2/ds9/EFTA00206529/EFTA00206529.md @@ -0,0 +1,25 @@ +Subject: RE: Detailed to Miami + +Date: Sat, 08 Jan 2011 01:16:34 +0000 + +Importance: Normal + +You, too. Thanks. + +Sent: Friday, January 07, 2011 8:14 PM + +Subject: Re: Detailed to Miami + +Stop by the IT dept. I'll be conducting training, but you may be able to catch me on a break. If not, Jacquie will also be around. + +Have a good weekend. + +Sent: Friday, January 07, 2011 08:11 PM + +Subject: RE: Detailed to Miami + +I am going to be in Miami on Tuesday. Can we meet then to go through how I search for the saved emails and memos on the Epstein thing? + +Ricky and I will be at the Miami USAO the week of January 10th. We will have limited access to email; however, we will be checking them periodically. If you require immediate assistance with Computer, ALS, Graphics support or VTC scheduling, please contact Lourdes at + +Thanks and wish us luck! \ No newline at end of file diff --git a/marker2/ds9/EFTA00206529/EFTA00206529.metadata.json b/marker2/ds9/EFTA00206529/EFTA00206529.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..373e915e665c02f2d5dfb4e2e48c85b55e5edb08 --- /dev/null +++ b/marker2/ds9/EFTA00206529/EFTA00206529.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206529.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 838, + "elapsed_seconds": 0.81, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 34 + ], + [ + "Text", + 16 + ], + [ + "Line", + 15 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 9 + ], + [ + "Line", + 5 + ], + [ + "Text", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206529" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206531/EFTA00206531.md b/marker2/ds9/EFTA00206531/EFTA00206531.md new file mode 100644 index 0000000000000000000000000000000000000000..e3e96ffad6383517d36125203354e229e6df0f0d --- /dev/null +++ b/marker2/ds9/EFTA00206531/EFTA00206531.md @@ -0,0 +1,23 @@ +Subject: RE: Is everything ok? + +Date: Thu, 03 Feb 2011 13:45:43 +0000 + +Importance: Normal + +Jeff, can I tell you how wonderful you are? Life has not been good. I had to file my final appeal of the OPR thing yesterday, which, as usual, has sent me to the depths of depression. I was just putting it into final form and I got three emails regarding Epstein. Knowing that you are out there thinking of me has really helped, and I have a big note on my desk to call you today. + +I am running over to grand jury, but will call you when I get back. + +Thank you so much for thinking of me. + +sent: I nurstlay, YeDruary /:4S AM + +Subject: Is everything ok? + +Marie: + +Just checking in to see how you are. I hope everything is ok. + +Jeffrey H. Sloman, Esq. + +Confidentiality Notice: The information contained in this transmittal, including any attachment, is privileged and confidential and is intended only for the person or entity to whom it is addressed. If you are neither the intended recipient nor the employee or agent responsible for delivering this message to the intended recipient, you are hereby notified that any disclosure, copying or distribution or the taking of any action in reliance on the contents of this transmittal is strictly prohibited. If you have received this transmittal in error, please contact the sender immediately and delete this transmittal from any computer or other data bank. \ No newline at end of file diff --git a/marker2/ds9/EFTA00206531/EFTA00206531.metadata.json b/marker2/ds9/EFTA00206531/EFTA00206531.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..17196c1c9cd2b89efe90d7a1b4dc790096efd5f7 --- /dev/null +++ b/marker2/ds9/EFTA00206531/EFTA00206531.metadata.json @@ -0,0 +1,80 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206531.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1395, + "elapsed_seconds": 0.64, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 53 + ], + [ + "Line", + 23 + ], + [ + "Text", + 12 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "PageFooter", + 1 + ], + [ + "Line", + 1 + ], + [ + "Span", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206531" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206533/EFTA00206533.md b/marker2/ds9/EFTA00206533/EFTA00206533.md new file mode 100644 index 0000000000000000000000000000000000000000..d0053aef4ad0ffa0140f6d3cd6d07de842aa35d0 --- /dev/null +++ b/marker2/ds9/EFTA00206533/EFTA00206533.md @@ -0,0 +1,45 @@ +From: ' (USAFLS)" + +To: (USAFLS)" ctl + +Subject: RE: Jane Does + +Date: Wed, 05 Jan 2011 22:39:29 +0000 + +Importance: Normal + +I will check with and the computer gurus. I think the computer folks told me that opening emails, even to look at them, would change the data. + +Assistant U.S. Attorney + +Fax + +From: (USAFLS) + +Sent: Wednesday, Imam 05, 2011 5:37 PM + +To: . (USAFLS) + +Subject: RE: Jane Does + +Judge Johnson's ruling should put an end to Cassell's insistence that we agree to his undisputed facts as part of the victims' summary judgment motion. He can file the e-mails under seal. + +As to searching your earlier e-mails and documents, the letter you are referring to is the preservation of electronically stored information letter which sent you? Is there a way to retrieve the information OPR has requested without altering the electronic data? Thanks. + +From: (USAFLS) + +Sent: Wednesday, January 05, 2011 5:13 PM + +To: (USAFLS) + +Subject: Jane Does + +Hi — Just got this from CM/ECF. According to this, counsel for Jane Does cannot quote from any of the emails in a public court filing and must file any emails under seal. + +« File: DE226\_20110105\_Order re Releasing USAO Epstein emails.pdf » + +Also, re your earlier request, am I allowed to search my earlier emails and documents? I don't want to mess up my electronic data in violation of the letter that I signed. + +Assistant U.S. Attorney + +Fax \ No newline at end of file diff --git a/marker2/ds9/EFTA00206533/EFTA00206533.metadata.json b/marker2/ds9/EFTA00206533/EFTA00206533.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..61c62a1fc2a66686cde4632c282d0868cf48b691 --- /dev/null +++ b/marker2/ds9/EFTA00206533/EFTA00206533.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206533.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1389, + "elapsed_seconds": 1.09, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 67 + ], + [ + "Line", + 29 + ], + [ + "Text", + 23 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Text", + 6 + ], + [ + "Span", + 5 + ], + [ + "Line", + 3 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206533" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206535/EFTA00206535.md b/marker2/ds9/EFTA00206535/EFTA00206535.md new file mode 100644 index 0000000000000000000000000000000000000000..a7164389b799111deab7145accf36cff1b466734 --- /dev/null +++ b/marker2/ds9/EFTA00206535/EFTA00206535.md @@ -0,0 +1,49 @@ +**To:** [REDACTED] + +**Subject:** RE: Setting up a conference call + +**Date:** Fri, 04 Feb 2011 20:38:39 +0000 + +**Importance:** Normal + +--- + +They can join at any time. + +[REDACTED] + +Assistant U.S. Attorney + +500 S. Australian Ave, Suite 400 + +West Palm Beach, FL 33401 + +[REDACTED] + +--- + +**Sent:** Friday, February 04, 2011 3:37 PM + +**Subject:** RE: Setting up a conference call + +Do you want them to be "announced" or free to join at any time? + +--- + +**Sent:** Friday, February 04, 2011 3:30 PM + +**Subject:** Setting up a conference call + +Hi Shawn – Can you set up another one of those "official" conference calls? For Thursday at 10:30? It is with the Epstein lawyers. I guess I will be the "organizer." 10:30 to 12:00 should be plenty of time. + +Thanks. + +[REDACTED] + +Assistant U.S. Attorney + +500 S. Australian Ave, Suite 400 + +West Palm Beach, FL 33401 + +[REDACTED] \ No newline at end of file diff --git a/marker2/ds9/EFTA00206535/EFTA00206535.metadata.json b/marker2/ds9/EFTA00206535/EFTA00206535.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..df10d59d3f57b1988d496fe4177e7aa77df80ce4 --- /dev/null +++ b/marker2/ds9/EFTA00206535/EFTA00206535.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206535.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 857, + "elapsed_seconds": 4.54, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 46 + ], + [ + "Span", + 40 + ], + [ + "Line", + 20 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206535" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206536/EFTA00206536.md b/marker2/ds9/EFTA00206536/EFTA00206536.md new file mode 100644 index 0000000000000000000000000000000000000000..42e43ed8192cc1c23c72ede30a30147ae99db512 --- /dev/null +++ b/marker2/ds9/EFTA00206536/EFTA00206536.md @@ -0,0 +1,59 @@ +To: "flsd\_cmecf notice@flsd.uscourts.gov" + +Subject: Activity in Case 9:08-cv-80893-KAM Doe 1 Epstein Order on Motion for Miscellaneous Relief + +Date: Thu, 01 Jul 2010 19:28:21 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered on 7/1/2010 at 3:28 PM EDT and filed on 7/1/2010 + +Case Name: Doe I Epstein + +Case Number: 9:08-cv-80893-KAM + +Filer: + +Document Number: 193 + +## Docket Text: + +ORDER on Plaintiffs Motion for Modification of Sr. Magistrate Judge Palermo's Order Scheduling Settlement Conference. Signed by Sr. Magistrate Judge Peter R. Palermo on 7/1/2010. (ds) + +9:08-cv-80893-KAM Notice has been electronically mailed to: + +Ann Marie C. Villafana ann.marie.c.villafana@usdoj.gov, fran.prager@usdoj.gov + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Jack Alan Goldberger jagesq@bellsouth.net, nalanis®agwpa.com + +Katherine Warthen Ezell KEzell@podhurst.com, mestrada@podhurst.com + +Michael James Pike MPike@bciclaw.com, bobbie@bciclaw.com, jcadwell@bciclaw.com + +Paul G. Cassell cassellp@law.utah.edu + +9:08-cv-80893-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +Document description:Main Document + +Original filename:n/a + +Electronic document Stamp: + +[STAMP dceciStamp\_11: 1105629215 [Date=7/1/2010] [FileNumber=7747060-0) + +[4d3e0524400ba66d80476fec432cf69bbab544b21a20ff2983e3dfc3693adfa40a9c + +3 f8b060e011841cc22a8c9984a9299 f8ffaa2a229 f3f27bb1026602b3a54]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00206536/EFTA00206536.metadata.json b/marker2/ds9/EFTA00206536/EFTA00206536.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..abd989d372b7ea8019d9c2a56e7c82096da1002e --- /dev/null +++ b/marker2/ds9/EFTA00206536/EFTA00206536.metadata.json @@ -0,0 +1,135 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206536.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2323, + "elapsed_seconds": 1.19, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 321.57000000000005 + ], + [ + 184.37722778320312, + 321.57000000000005 + ], + [ + 184.37722778320312, + 338.10357666015625 + ], + [ + 30.6, + 338.10357666015625 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 436.59000000000003 + ], + [ + 101.52233123779297, + 436.59000000000003 + ], + [ + 101.52233123779297, + 452.1035461425781 + ], + [ + 30.6, + 452.1035461425781 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 74 + ], + [ + "Line", + 36 + ], + [ + "Text", + 24 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 15 + ], + [ + "Line", + 8 + ], + [ + "Text", + 7 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206536" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206538/EFTA00206538.md b/marker2/ds9/EFTA00206538/EFTA00206538.md new file mode 100644 index 0000000000000000000000000000000000000000..dafb491885a42065b1c67f85cb37462ec557ea33 --- /dev/null +++ b/marker2/ds9/EFTA00206538/EFTA00206538.md @@ -0,0 +1,49 @@ +To: "flsd\_cmecf notice@flsd.uscourts.gov" + +Subject: Activity in Case 9:08-cv-80893-KAM Doe 1 Epstein Endorsed Order + +Date: Thu, 01 Jul 2010 18:05:20 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the C1VUECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered on 7/1/2010 at 2:05 PM EDT and filed on 7/1/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80893-KAM + +Filer: + +Document Number: 192(No document attached) + +## Docket Text: + +\*Endorsed Order DENYING AS AN EMERGENCY Plaintiff's Motion for Contempt and Sanctions (DE 190). Defendant shall respond to the motion by 12:00 noon on July 8, 2010.. Signed by Judge Kenneth A. Marra on 7/1/2010. (mkz) + +9:08-cv-80893-KAM Notice has been electronically mailed to: + +Ann Marie C. Villafana ann.marie.c.villafana@usdoj.gov, fran.prager@usdoj.gov + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Jack Alan Goldberger jagesq@bellsouth.net, nalanis®agwpa.com + +Katherine Warthen Ezell KEzell@podhurst.com, mestrada@podhurst.com + +Michael James Pike MPike@bciclaw.com, bobbie@bciclaw.com, jcadwell&ciclaw.com + +Paul G. Cassell cassellp@law.utah.edu + +Robert Deweese Critton , Jr rcrit@bciclaw.com, bobbie@bciclaw.com + +9:08-cv-80893-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. 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Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered on 7/2/2010 at 11:01 AM EDT and filed on 7/1/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80893-ICAM + +Filer: + +Document Number: No document attached + +## Docket Text: + +Set/Reset Deadlines per Order at DE [192] as to [190] Plaintiff's MOTION for Contempt, Plaintiff's MOTION for Sanctions. Responses due by 7/8/2010 (bb) + +9:08-cv-80893-KAM Notice has been electronically mailed to: + +![](_page_0_Picture_18.jpeg) + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Jack Alan Goldberger jagesq@bellsouth.net, nalanis®agwpa.com + +Katherine Warthen Ezell ICEzell@podhurst.com, mestrada@podhurst.com + +Michael James Pike MPike@bcIclaw.com, bobbie@bciclaw.com, jcadwell@bciclaw.com + +Paul G. Cassell cassellp@law.utah.edu + +Robert Deweese Critton , Jr rcrit@bciclaw.com, bobbie@bciclaw.com + +9:08-cv-80893-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. 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Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered on 7/2/2010 at 2:11 PM EDT and filed on 7/2/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80893-KAM + +Filer: + +Document Number: 194(No document attached) + +Docket Text: + +Sealed Document (ots) + +9:08-cv-80893-KAM Notice has been electronically mailed to: + +![](_page_0_Picture_18.jpeg) + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Jack Alan Goldberger jagesq@bellsouth.net, nalanis®agwpa.com + +Katherine Warthen Ezell KEzell@podhurst.com, mestrada@podhurst.com + +Michael James Pike MPike@bciclaw.com, bobbie@bciclaw.com, jcadwell@bciclaw.com + +Paul G. Cassell cassellp@law.utah.edu + +Robert Deweese Critton , Jr rcrit@bciclaw.com, bobbie@bciclaw.com + +9:08-cv-80893-ICAM Notice has not been delivered electronically to those listed below and will be provided by other means. 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Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered by Edwards, Bradley on 7/1/2010 at 11:09 AM EDT and filed on 7/1/2010 + +Case Name: Doe Epstein + +Case Number: 9:08-cv-80893-KAM + +Filer: Jane Doe + +Document Number: 190 + +## Docket Text: + +Plaintiffs MOTION for Contempt ( Responses due by 7/19/2010), Plaintiffs MOTION for Sanctions by Jane Doe. (Edwards, Bradley) + +9:08-cv-80893-lKAM Notice has been electronically mailed to: + +Ann Marie C. Villafana ann.marie.c.villafana@usdoj.gov, fran.prager@usdoj.gov + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Jack Alan Goldberger jagesq@bellsouth.net, nalanis®agwpa.com + +Katherine Warthen Ezell ICEzell@podhurst.com, mestrada@podhurst.com + +Michael James Pike MPike@bciclaw.com, bobbie@bciclaw.com, jcadwell@bciclaw.com + +Paul G. Cassell cassellp@law.utah.edu + +Robert Deweese Critton , Jr rcrit@bciclaw.com, bobbie@bciclaw.com + +9:08-cv-80893-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. 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Epstein et al Response to Order to Show Cause +Date: Fri, 02 Jul 2010 17:57:05 +0000 + +Importance: Normal + +**This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended.** + +**\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\*** Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +### Notice of Electronic Filing + +The following transaction was entered by Garcia, Isidro on 7/2/2010 at 1:57 PM EDT and filed on 7/2/2010 + +Case Name: Doe II [REDACTED] Epstein et al + +Case Number: [9:09-cv-80469-KAM](#) + +Filer: Jane Doe II + +Document Number: [81](#) + +#### Docket Text: + +**RESPONSE TO ORDER TO SHOW CAUSE by Jane Doe II. (Garcia, Isidro)** + +9:09-cv-80469-KAM Notice has been electronically mailed to: + +[REDACTED] + +Bradley James Edwards [brad@pathtojustice.com](mailto:brad@pathtojustice.com), [beth@pathtojustice.com](mailto:beth@pathtojustice.com) + +Bruce Reinhart [e-\[REDACTED\]](#) + +Denise Kalland [d-\[REDACTED\]](#) + +Isidro Manuel Garcia [REDACTED] + +Jack Alan Goldberger [REDACTED] + +Michael James Pike [M-\[REDACTED\]](#) + +Robert Deweese Critton , Jr [r-\[REDACTED\]](#) + +9:09-cv-80469-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. 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Please DO NOT RESPOND to this e-mail because the mail box is unattended.** + +**\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\*** Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court +Southern District of Florida + +**Notice of Electronic Filing** + +The following transaction was entered by Pike, Michael on 7/1/2010 at 12:38 PM EDT and filed on 7/1/2010 + +Case Name: Doe [REDACTED] Epstein +Case Number: [9:08-cv-80893-KAM](#) +Filer: Jeffrey Epstein +Document Number: [191](#) + +**Docket Text:** +**RESPONSE to Motion re [187] Plaintiff's MOTION No Contact Order at Settlement Conference filed by Jeffrey Epstein. Replies due by 7/12/2010. (Pike, Michael)** + +**9:08-cv-80893-KAM Notice has been electronically mailed to:** + +[REDACTED] + +Bradley James Edwards [REDACTED] + +Jack Alan Goldberger [REDACTED] + +Katherine Warthen Ezell [REDACTED] + +Michael James Pike [REDACTED] + +Paul G. Cassell [REDACTED] + +Robert Deweese Critton , Jr [REDACTED] + +**9:08-cv-80893-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. 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Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered on 7/2/2010 at 2:50 PM EDT and filed on 7/2/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80893-KAM + +Filer: + +Document Number: 196(No document attached) + +## Docket Text: + +\*Endorsed Order DENYING AS AN EMERGENCY Plaintiff's Motion for a Hearing and Contempt (DE 195). This motion shall be addressed in the normal course.. Signed by Judge Kenneth A. Marra on 7/2/2010. (mkz) + +9:08-cv-80893-KAM Notice has been electronically mailed to: + +![](_page_0_Picture_18.jpeg) + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Jack Alan Goldberger jagesq®bellsouth.net, nalanis®agwpa.com + +Katherine Warthen Ezell KEzell®podhurst.com, mestrada@podhurst.com + +Michael James Pike MPike@bciclaw.com, bobbie@bciclaw.com, jcadwell@bciclaw.com + +Paul G. Cassell cassellp@law.utah.edu + +Robert Deweese Critton , Jr rcrit@bciclaw.com, bobbie@bciclaw.com + +9:08-cv-80893-ICAM Notice has not been delivered electronically to those listed below and will be provided by other means. 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Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered on 7/1/2010 at 10:55 AM EDT and filed on 7/1/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80893-KAM + +Filer: + +Document Number: 188(No document attached) + +## Docket Text: + +\*Endorsed Order requiring expedited response to (DE 187) Plaintiff's Motion for Modification of Magistrate Judge Palermo's Order Scheduling Settlement Conference. Defendant shall file a response no later than 5:00 p.m. on Thursday, July 1, 2010.. Signed by Judge Kenneth A. Marra on 7/1/2010. (mkz) + +9:08-cv-80893-KAM Notice has been electronically mailed to: + +• I. + +Bradley James Edwards + +Jack Alan Goldberger + +Katherine Warthen Ezell + +Michael James Pike + +Paul G. Cassell + +Robert Deweese Critton , Jr + +9:08-cv-80893-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. 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Please DO NOT RESPOND to this e-mail because the mail box is unattended.** + +**\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\*** Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court +Southern District of Florida + +**Notice of Electronic Filing** + +The following transaction was entered on 7/2/2010 at 2:13 PM EDT and filed on 7/2/2010 +Case Name: Doe [REDACTED] Epstein +Case Number: [9:08-cv-80893-KAM](#) +Filer: +Document Number: 195(No document attached) + +**Docket Text:** +**Sealed Document (ots)** + +9:08-cv-80893-KAM Notice has been electronically mailed to: + +[REDACTED] + +Bradley James Edwards [REDACTED] + +Jack Alan Goldberger [REDACTED] + +Katherine Warthen Ezell [REDACTED] + +Michael James Pike [REDACTED] + +Paul G. Cassell [REDACTED] + +Robert Deweese Critton , Jr [REDACTED] + +9:08-cv-80893-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. 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Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered on 7/1/2010 at 10:59 AM EDT and filed on 7/1/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80893-ICAM + +Filer: + +Document Number: 189(No document attached) + +## Docket Text: + +\*Endorsed Order requiring expedited response to (DE 185) Defendant Epstein's Motion to Continue Trial. Plaintiff shall file a response by July 7, 2010.. Signed by Judge Kenneth A. Marra on 7/1/2010. (mkz) + +9:08-cv-80893-KAM Notice has been electronically mailed to: + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Jack Alan Goldberger jagesq@bellsouth.net, nalanis®agwpa.com + +Katherine Warthen Ezell KEzell@podhurst.com, mestrada@podhurst.com + +Michael James Pike MPike@bciclaw.com, bobbie@bciclaw.com, jcadwell@bciclaw.com + +Paul G. Cassell cassellp@law.utah.edu + +Robert Deweese Critton , Jr rcrit@bcIclaw.com, bobbie@bciclaw.com + +9:08-cv-80893-ICAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: \ No newline at end of file diff --git a/marker2/ds9/EFTA00206551/EFTA00206551.metadata.json b/marker2/ds9/EFTA00206551/EFTA00206551.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..7d46b3d93440e41412168d8737108864963ef08f --- /dev/null +++ b/marker2/ds9/EFTA00206551/EFTA00206551.metadata.json @@ -0,0 +1,105 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206551.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 2034, + "elapsed_seconds": 1.12, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 308.61 + ], + [ + 184.3336639404297, + 308.61 + ], + [ + 184.3336639404297, + 324.23358154296875 + ], + [ + 30.6, + 324.23358154296875 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 422.82 + ], + [ + 101.52233123779297, + 422.82 + ], + [ + 101.52233123779297, + 438.3170471191406 + ], + [ + 30.6, + 438.3170471191406 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 69 + ], + [ + "Line", + 34 + ], + [ + "Text", + 23 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206551" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206552/EFTA00206552.md b/marker2/ds9/EFTA00206552/EFTA00206552.md new file mode 100644 index 0000000000000000000000000000000000000000..d3da4c3325bcb42f10b066f2e90eb4da92503770 --- /dev/null +++ b/marker2/ds9/EFTA00206552/EFTA00206552.md @@ -0,0 +1,55 @@ +To: + +Cc: + +Subject: RE: Jane Doe v. Jeffrey Epstein + +Date: Thu, 01 Jul 2010 18:36:16 +0000 + +Importance: High + +Priority: Urgent + +The FD515 is an accomplishment report. I spoke with and the FBI does not have an objection to releasing the two FD302's Dertainino to Jane Doe's interviews. + +iscuss with AUSA and let me know if we are still in objection to releasing information regarding the criminal investigation of Jeffrey Epstein. Also please let me know if you want me to forward you a copy of the FD302's for Jane Doe. + +Thanks. + +From: + +Sent: way, + +To: + +Subject: FW: Jane Doe v. Jeffrey Epstein + +Attached please find response on the new subpoena. What is the FD515? Thanks. + +From + +Sent: Wednesday, June 30, 2010 1:44 PM + +To: + +Subject: RE: Jane Doe v. Jeffrey Epstein + +HiM- When it rains, it pours. I am dealing with another Epstein issue now. The investigation is sort of re-opened, we are trying to track down new victims. But, in light of waiver, if the items she requests relate only to. if FBI has no objection, then it seems alright to me. + +The FBI has received a subpoena seeking documents relating to Jane Doe. There is a Privacy Act waiver attached which was signed by The return date for the subpoena is July 8, 2010. I understand from the FBI that there are two FBI 302's responsive to the request. There is also an FD515, which the FBI believes is not responsive. + +Since has executed a Privacy Act waiver, permitting disclosure to there's no Privacy Act issue. Does the government have any privilege to assert regarding the responsive documents, e.g. law enforcement investigatory records, etc.? Thanks. + +From: Sent: Monday, June 28, 2010 9:59 AM To: Cc: Sub ect: ane e rey Epstein + +Good morning + +I faxed over a new subpoena that we received on another Jane Doe v. Jeffrey Epstein case. I faxed it t' and asked her if she could assign it to you, since you were the one assigned this matter in the past. + +I spoke with SAS he advised me that we do have two FD302's of Jane Doe's interviews, and an FD515. 5 would not be pertinent to their request. However, he suggested to have you contact the criminal AUSA and see what position is on releasing the information requested. + +can be reached at any assistance. f you need additional information. Please call me if you need + +Thank you. + +Parale al FBI \ No newline at end of file diff --git a/marker2/ds9/EFTA00206552/EFTA00206552.metadata.json b/marker2/ds9/EFTA00206552/EFTA00206552.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..2db3b8ad228fd6646db954b2c8b2357a2b1da9cd --- /dev/null +++ b/marker2/ds9/EFTA00206552/EFTA00206552.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206552.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2304, + "elapsed_seconds": 1.22, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 61 + ], + [ + "Line", + 30 + ], + [ + "Text", + 26 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 51 + ], + [ + "Line", + 25 + ], + [ + "Text", + 9 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206552" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206554/EFTA00206554.md b/marker2/ds9/EFTA00206554/EFTA00206554.md new file mode 100644 index 0000000000000000000000000000000000000000..7231b51a278d203f82dffcc0375af28e82fc2de8 --- /dev/null +++ b/marker2/ds9/EFTA00206554/EFTA00206554.md @@ -0,0 +1,41 @@ +Subject: FLORIDA OFFENDER ALERT MESSAGE + +Date: Sat, 10 Jul 2010 19:12:08 +0000 + +Importanc Normal + +e: + +![](_page_0_Picture_4.jpeg) + +La.:Florida Offender Alert System 07/10/2010 + +You have subscribed with the Florida Offender Alert System to receive e-mail notifications when a registered Florida sexual offender or predator reports an address within the following subscribed address of interest: + +Radius: one mile Subscribed Address: 358 El Brillo Way, Palm Beach, FL 33480 + +This e-mail is to inform you that the following updated address information was reported to the Florida Sexual Offender Registry and falls within the specified radius: + +| Offender Name:
JEFFREY E EPSTEIN | DOB:
01/20/1953 | Reported Offender Address: 358
EL BRILLO WAY, PALM BEACH, FL | View
Offender
Flyer | +|--------------------------------------------|---------------------------|------------------------------------------------------------------------|---------------------------------------------------------------------------| +|--------------------------------------------|---------------------------|------------------------------------------------------------------------|---------------------------------------------------------------------------| + +To change your subscription information, go to FloridaOffenderAlert.com and select "Tracking Addresses." + +It is unlawful to misuse public records information regarding a sexual offender or predator as defined by Florida Statute Section 775.21(10)-(c).. + +Opt-Out of Notifications + +Assistance with Technical Issues + +Safety Tips and Victim Information + +Frequently Asked Questions + +Thank you, + +The Florida Offender Alert System + +The Florida Offender Alert System is being provided in partnership between the Florida Sheriffs Association, Florida Police Chiefs Association and Florida Department of Law Enforcement. + +Please do not respond to this e-mail. This is an unmonitored e-mail location. \ No newline at end of file diff --git a/marker2/ds9/EFTA00206554/EFTA00206554.metadata.json b/marker2/ds9/EFTA00206554/EFTA00206554.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..2c15f7e48b864ca8ae479a6da3c82bd5d4c60ae3 --- /dev/null +++ b/marker2/ds9/EFTA00206554/EFTA00206554.metadata.json @@ -0,0 +1,64 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206554.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 2004, + "elapsed_seconds": 1.42, + "image_assets": [ + "_page_0_Picture_4.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 59 + ], + [ + "Line", + 27 + ], + [ + "Text", + 18 + ], + [ + "Picture", + 1 + ], + [ + "Table", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206554" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206554/_page_0_Picture_4.jpeg b/marker2/ds9/EFTA00206554/_page_0_Picture_4.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..f834953a0e0c77b14e6e8a3f25b7a54694b8277d --- /dev/null +++ b/marker2/ds9/EFTA00206554/_page_0_Picture_4.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:47c4941e5004bc0af4e11af64c3d21ba7dcd41428044ae40cccc4bd50a2e7f9d +size 1057 diff --git a/marker2/ds9/EFTA00206555/EFTA00206555.md b/marker2/ds9/EFTA00206555/EFTA00206555.md new file mode 100644 index 0000000000000000000000000000000000000000..e378cb48eb04b46a90a7b263791828eff1d15854 --- /dev/null +++ b/marker2/ds9/EFTA00206555/EFTA00206555.md @@ -0,0 +1,145 @@ +To: ' (USAFLS)" + +Subject: Re: Alfredo Rodriguez/Jeffrey Epstein + +Date: Thu, 08 Jul 2010 21:50:50 +0000 + +Importance: Normal + +Sounds good. Have a good weekend. + +From: (USAFLS) + +To: + +Sent: Thu Jul 08 17:36:52 2010 + +Subject: RE: Alfredo Rodriguez/Jeffrey Epstein + +Thanks, . I will talk to you next week after you talk to Brad. Good luck in California! + +Assistant U.S. Attorney + +West Palm Beach, FL 33401 + +MEM + +From: (FBI) + +Sent: Thursday, July 08, 2010 5:35 PM + +To: . (USAFLS) + +Subject: Re: Alfredo Rodriguez/Jeffrey Epstein + +From: (USAFLS) + +To: + +Sent: Thu Jul 08 17:23:20 2010 + +Subject: RE: Alfredo Rodriguez/Jeffrey Epstein + +Hi — What is your cell phone so I can call? + +Assistant U.S. Attorney + +West Palm Beach, FL 33401 + +From: (FBI) + +Sent: Thursday, July 08, 2010 4:58 PM + +To: . (USAFLS) + +Subject: Re: Alfredo Rodriguez/Jeffrey Epstein + +**From:** [REDACTED]. (USAFLS) <[REDACTED]> +**To:** [REDACTED] +**Sent:** Thu Jul 08 16:37:17 2010 +**Subject:** RE: Alfredo Rodriguez/Jeffrey Epstein +That would be great. Thanks. + +[REDACTED] +Assistant U.S. Attorney +[REDACTED] +West Palm Beach, FL 33401 +[REDACTED] +[REDACTED] + +--- + +**From:** [REDACTED] (FBI) +**Sent:** Thursday, July 08, 2010 4:33 PM +**To:** [REDACTED]. (USAFLS) +**Subject:** RE: Alfredo Rodriguez/Jeffrey Epstein + +We just landed, taxing. Should I call your office a couple minutes before 5? + +--- + +**From:** [REDACTED]. (USAFLS) <[REDACTED]> +**To:** Brad Edwards <[REDACTED]> +**Cc:** [REDACTED] +**Sent:** Thu Jul 08 12:43:43 2010 +**Subject:** RE: Alfredo Rodriguez/Jeffrey Epstein + +Thank you, [REDACTED]. [REDACTED] is on a flight right now, which is due to land around 4:00. If her flight is delayed, I will let you know. Otherwise, I will plan to call you at your office at 5:00. + +Thanks. + +[REDACTED] +Assistant U.S. Attorney +[REDACTED] +West Palm Beach, FL 33401 +[REDACTED] +[REDACTED] + +--- + +**From:** Brad Edwards [mailto:[REDACTED]] +**Sent:** Thursday, July 08, 2010 12:01 PM +**To:** [REDACTED]. (USAFLS) +**Subject:** RE: Alfredo Rodriguez/Jeffrey Epstein + +No, all of my cases are not settled. I am available at 5. + +**Brad Edwards** +Civil Justice Attorney +**Farmer, Jaffe, Weissing,** +**Edwards, Fistos & Lehrman, P.L.** +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +![](_page_2_Picture_1.jpeg) + +siA Please consider the environment before printing this e-mail. + +IRS Circular 230 Disclosure: Please note that the views expressed herein or in any attachments hereto are not intended to constitute a "reliance opinion" under applicable Treasury Regulations, and accordingly are not intended or written to be used, and may not be used or relied upon, for the purpose of (i) avoiding tax-related penalties that may be imposed by the Internal Revenue Service, or (ii) promoting, marketing or recommending to another party any tax-related matters addressed herein. + +NOTICE: THE INFORMATION CONTAINED IN THIS TRANSMISSION IS ATTORNEY PRIVILEGED AND CONFIDENTIAL. IT IS INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY NAMED ABOVE. IF THE READER OF THIS MESSAGE IS NOT THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION, DISTRIBUTION OR COPY OF THIS COMMUNICATION IS STRICTLY PROHIBITED. IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONE TOLL FREE (800) 400-1098 AND DELETE THE MATERIAL FROM ANY COMPUTER. THANK YOU. + +From: (USAFLS) [mallto + +Sent: Thursday, July 08, 2010 11:31 AM + +To: Brad Edwards + +Cc: (FBI) + +Subject: Alfredo Rodriguez/Jeffrey Epstein + +Good morning, Brad: + +Are you free to speak this afternoon at around 5:00? the Alfredo Rodriguez case. and I want to follow up on some items related to + +Can you also confirm that all of your cases are settled? + +Thank you. + +Assistant U.S. Attorney + +West Palm Beach, FL 33401 \ No newline at end of file diff --git a/marker2/ds9/EFTA00206555/EFTA00206555.metadata.json b/marker2/ds9/EFTA00206555/EFTA00206555.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..9c71a0cbafb35eaafb1380f07183365be8d7f834 --- /dev/null +++ b/marker2/ds9/EFTA00206555/EFTA00206555.metadata.json @@ -0,0 +1,124 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206555.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 3811, + "elapsed_seconds": 6.07, + "image_assets": [ + "_page_2_Picture_1.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 67 + ], + [ + "Text", + 35 + ], + [ + "Line", + 31 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 71 + ], + [ + "Text", + 42 + ], + [ + "Line", + 32 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 49 + ], + [ + "Line", + 25 + ], + [ + "Text", + 14 + ], + [ + "PageHeader", + 1 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206555" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206555/_page_2_Picture_1.jpeg b/marker2/ds9/EFTA00206555/_page_2_Picture_1.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..dd5e6952629f9f46d5364e5da8aaef5a3fdfe987 --- /dev/null +++ b/marker2/ds9/EFTA00206555/_page_2_Picture_1.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:bd60ec0ccfc82a6f9c3722d72d8a7475e1047bfc3fa43b4dd70870a27816a40c +size 1236 diff --git a/marker2/ds9/EFTA00206558/EFTA00206558.md b/marker2/ds9/EFTA00206558/EFTA00206558.md new file mode 100644 index 0000000000000000000000000000000000000000..082b2c8cde703777a4185709fe0991de99061476 --- /dev/null +++ b/marker2/ds9/EFTA00206558/EFTA00206558.md @@ -0,0 +1,59 @@ +From: ' To:' ' < + +Subject: Activity in Case 9:08-cv-80893-KAM Doe 1 Epstein Motion in Limine + +Date: Fri, 02 Jul 2010 21:11:12 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the C1VUECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +# U.S. District Court + +### Southern District of Florida + +# Notice of Electronic Filing + +The following transaction was entered by Pike, Michael on 7/2/2010 at 5:11 PM EDT and filed on 7/2/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80893-KAM + +Filer: Jeffrey Epstein + +Document Number: 198 + +Docket Text: + +Defendant's MOTION in Limine Pertaining to Evidence of Other Females and Similar Fact Evidence with Incorporated Supporting Memorandumof Law by Jeffrey Epstein. (Pike, Michael) + +9:08-cv-80893-ICAM Notice has been electronically mailed to: + +• I. + +Bradley James Edwards + +Jack Alan Goldberger + +Katherine Warthen Ezell + +Michael James Pike + +Paul G. Cassell + +Robert Deweese Critton , Jr + +9:08-cv-80893-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. 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Epstein Sealed Document + +Date: Mon, 12 Jul 2010 19:45:18 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CMIECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered on 7/12/2010 at 3:45 PM EDT and filed on 7/12/2010 + +Case Name: Doe v. Epstein + +Case Number: 9:08-cv-80893-KAM + +Filer: + +Document Number: 206(No document attached) + +Docket Text: + +Sealed Document (ir) + +9:08-cv-80893-KAM Notice has been electronically mailed to: + +Bradley James Edwards Jack Alan Goldberger Katherine Warthen Ezel Michael James Pike Paul G. Cassell Robert Deweese Critton , r + +9:08-cv-80893-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. 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Epstein Notice of Compliance + +Date: Fri, 02 Jul 2010 20:51:39 +0000 + +Importance: Normal + +--- + +**This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended.** + +**\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\*** Judicial Conference of the United States policy permits attorneys of record and parties in a case (including prose litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +### Notice of Electronic Filing + +The following transaction was entered by Edwards, Bradley on 7/2/2010 at 4:51 PM EDT and filed on 7/2/2010 + +Case Name: Doe [REDACTED] Epstein + +Case Number: [9:08-cv-80893-KAM](#) + +Filer: Jane Doe + +Document Number: [197](#) + +#### Docket Text: + +**NOTICE of Compliance Fed. R. Evid. 145(b) by Jane Doe (Attachments: # (1) Exhibit A) (Edwards, Bradley)** + +9:08-cv-80893-KAM Notice has been electronically mailed to: + +[REDACTED] +Bradley James Edwards + +Jack Alan Goldberger j + +Katherine Warthen Ezell + +Michael James Pike M + +Paul G. Cassell [REDACTED] + +Robert Deweese Critton , [REDACTED] + +9:08-cv-80893-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. 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Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered by Pike, Michael on 7/5/2010 at 3:16 PM EDT and filed on 7/5/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80893-ICAM + +Filer: Jeffrey Epstein + +Document Number:200 + +## Docket Text: + +RESPONSE in Opposition re [190] Plaintiffs MOTION for ContemptPlaintiff's MOTION for Sanctions and Defendant's Motion for Sanctions and Incorporated Memorandum of Law filed by Jeffrey Epstein. (Attachments: # (1) Exhibit A, # (2) Exhibit B, # (3) Exhibit C, # (4) Exhibit D) (Pike, Michael) + +A A non, + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Jack Alan Goldberger jagesq@bellsouth.net, nalanis®agwpa.com + +Katherine Warthen Ezell KEzell@podhurst.com, mestrada@podhurst.com + +Michael James Pike MPike@bciclaw.com, bobbie@bciclaw.com, jcadwell@bciclaw.com + +Paul G. Cassell cassellp@law.utah.edu + +9:08-cv-80893-ICAM Notice has not been delivered electronically to those listed below and ill be pros Wed by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +**Document description:**Main Document + +**Original filename:**n/a + +**Electronic document Stamp:** + +[STAMP dcecfStamp\_ID=1105629215 [Date=7/5/2010] [FileNumber=7754608-0] +[69cb126d79493d1cb078e29a90a99e3fc4f195f7bb768401306d06f2ac795a4a408e +86aa84b376d2722601c0e83b58c07eb214b22026d538fad0d8f50f648f62]] + +**Document description:**Exhibit A + +**Original filename:**n/a + +**Electronic document Stamp:** + +[STAMP dcecfStamp\_ID=1105629215 [Date=7/5/2010] [FileNumber=7754608-1] +[8285ccd03254e5a189efcd75416c31c9322041faaff1db49b54215fd67710f192e79 +23eb0d985384399cb49082db2f2d32ad6eafb35114a5c4faf38422b000dc]] + +**Document description:**Exhibit B + +**Original filename:**n/a + +**Electronic document Stamp:** + +[STAMP dcecfStamp\_ID=1105629215 [Date=7/5/2010] [FileNumber=7754608-2] +[220ec657516b17b3215ed2b03fb1f791b466c886882ddf8c3fe2c6bbeb459d94196a +eaaa39852798135e55f7afac3fb648678931e495acc876cc9b4b98e9c65b]] + +**Document description:**Exhibit C + +**Original filename:**n/a + +**Electronic document Stamp:** + +[STAMP dcecfStamp\_ID=1105629215 [Date=7/5/2010] [FileNumber=7754608-3] +[3c7330a1d4d848d0f8b2fa17fe1a947c4e61e96f4c7435e35eec9f10e4c248f55dc8 +404dbfda7a525e765a7bad0636d32357ff6333df96be0273055059e3c81d]] + +**Document description:**Exhibit D + +**Original filename:**n/a + +**Electronic document Stamp:** + +[STAMP dcecfStamp\_ID=1105629215 [Date=7/5/2010] [FileNumber=7754608-4] +[650b9a980388ee5437ee005dfec410425cf7a0e4b59a25b5b0dd67a67882251b05e1 +13320c3ca123e8cbe6bc000727c9fa5195a32f27f7bd324a48cbf6e14c62]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00206563/EFTA00206563.metadata.json b/marker2/ds9/EFTA00206563/EFTA00206563.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..68aff098dbf9ac1d4e29242c23d94ff80ee0094a --- /dev/null +++ b/marker2/ds9/EFTA00206563/EFTA00206563.metadata.json @@ -0,0 +1,127 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206563.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 3556, + "elapsed_seconds": 6.44, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 308.61 + ], + [ + 184.3336639404297, + 308.61 + ], + [ + 184.3336639404297, + 324.23358154296875 + ], + [ + 30.6, + 324.23358154296875 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 422.82 + ], + [ + 101.52233123779297, + 422.82 + ], + [ + 101.52233123779297, + 438.3170471191406 + ], + [ + 30.6, + 438.3170471191406 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 73 + ], + [ + "Line", + 35 + ], + [ + "Text", + 23 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 42 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206563" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206565/EFTA00206565.md b/marker2/ds9/EFTA00206565/EFTA00206565.md new file mode 100644 index 0000000000000000000000000000000000000000..4500fe68e1ce2d058e4c4c28360bd63c80ce757b --- /dev/null +++ b/marker2/ds9/EFTA00206565/EFTA00206565.md @@ -0,0 +1,57 @@ +To: ' + +Subject: Activity in Case 9:08-cv-80893-KAM Doe v. Epstein Motion in Limine + +Date: Mon, 05 Jul 2010 17:18:29 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered by Pike, Michael on 7/5/2010 at 1:18 PM EDT and filed on 7/5/2010 + +Case Name: Doe v. Epstein + +Case Number: 9:08-cv-80893-KAM + +Filer: Jeffrey Epstein + +Document Number: 199 + +## Docket Text: + +Defendant's MOTION in Limine to Exclude Certain Testimony and Opinions of Jane Doe's Expert Witness by Jeffrey Epstein. (Pike, Michael) + +9:08-cv-80893-KAM Notice has been electronically mailed to: + +Bradley James Edwards + +Jack Alan Goldberger + +Katherine Warthen Ezel + +Michael James Pike + +Paul G. Cassell + +Robert Deweese Critton , Jr + +9:08-cv-80893-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. 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Miami Beach, FL 33169 + + Testimony: YOU ARE COMMANDED to appear at the time, date, and place set forth below to testify at a deposition to be taken in this civil action. If you are an organization that is not a party in this case, you must designate one or more officers, directors, or managing agents, or designate other persons who consent to testify on your behalf about the following matters, or those set forth in an attachment: + +| Place: Farmer, Jaffe, Weissing, et al.
425 North Andrews Avenue, Suite 2
Ft. Lauderdale, FL 33301 | Date and Time:
07/08/2010 2:00 pm | +|---------------------------------------------------------------------------------------------------------|--------------------------------------| +|---------------------------------------------------------------------------------------------------------|--------------------------------------| + +The deposition will be recorded by this method: + + Production: You, or your representatives, must also bring with you to the deposition the following documents, electronically stored information, or objects, and permit their inspection, copying, testing, or sampling of the material: + +Any and All documents, photographs, videos, memos, or any other objects or items that reference, depict, or in any way relate directly to Jane Doe (Jane Doe's name and DOB are in cover letter to protect her identity), including but not limited to all things obtained during any criminal investigation of Jeffrey Epstein, his co-conspirators or his former employee. + +The provisions of Fed. R. Civ. P. 45(c), relating to your protection as a person subject to a subpoena, and Rule 45 (d) and (e), relating to your duty to respond to this subpoena and the potential consequences of not doing so, are attached. + +Date: 06/25/2010 + +CLERK OF COURT + +OR + +![]()Signature of Clerk or Deputy Clerk + +Attorney's signature + +The name, address, c-mail, and telephone number of the attorney representing (name of party) Jane Doe, who issues or requests this subpoena, are: +Bradley Edwards, Esq., Farmer, Jaffe, Weissing, et al., 425 North Andrews Avenue, Suite 2, Ft. Lauderdale, FL 33301 +(954) 524-2820, brad@pathtojustice.com + +AO 88A (Rev. 01/09) Subpoena to Testify at a Depotition or to Produce Documents in a Civil Action (Page 2) + +Civil Action No. 08-80893CIV-MARRA/JOHNSO + +PROOF OF SERVICE + +(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.) + +This subpoena for (name of individual and title, if any) \_\_\_\_\_ +was received by me on (date) \_\_\_\_\_ + + I personally served the subpoena on the individual at (place) \_\_\_\_\_ +on (date) \_\_\_\_\_; or + + I left the subpoena at the individual's residence or usual place of abode with (name) \_\_\_\_\_, +a person of suitable age and discretion who resides there. +on (date) \_\_\_\_\_, and mailed a copy to the individual's last known address; or + + I served the subpoena on (name of individual) \_\_\_\_\_, who is +designated by law to accept service of process on behalf of (name of organization) \_\_\_\_\_ +on (date) \_\_\_\_\_; or + + I returned the subpoena unexecuted because \_\_\_\_\_; or + + Other (specify): + +Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also +tendered to the witness fees for one day's attendance, and the mileage allowed by law, in the amount of +\$ \_\_\_\_\_. + +My fees are \$ \_\_\_\_\_ for travel and \$ \_\_\_\_\_ for services, for a total of \$ \_\_\_\_\_ 0.00 + +I declare under penalty of perjury that this information is true. + +Date: \_\_\_\_\_ +\_\_\_\_\_ Server's signature +\_\_\_\_\_ +Printed name and title +\_\_\_\_\_ +\_\_\_\_\_ Server's address + +Additional information regarding attempted service, etc: + +### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA + +JANE DOE, CASE NO. 08-CV-80893-CIWMARRNJOHNSON + +Plaintiff, + +Vs. + +JEFFREY EPSTEIN, et al. + +Defendant. + +Related Cases: + +08-80119, 08-80232, 08-80380, 08-80381. 08-80994, 08-80811, 08-80893, 0940469, 09-80591, 09-80656. 09-80802, 09-81092 + +#### PRIVACY WAIVER + +Ma ne Doe), hereby consent to release of information that the FBI is maintaining about me in connection with its criminal investigation of Jeffrey Epstein and specifically consent to release of the information under the Privacy Act, Title 5, United States code, Section 552a. I hereby authorize disclosure to my attorney in the civil action against Jeffrey Epstein. My attorney is Bradley Edwards, Esq. + +You can send the materials to Mr. Edwards at Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L., 425 North Andrews Avenue. Suite 2, Ft. Lauderdale, FL, 33301. + +STATE OF FLORIDA COUNTY OF Re; + +CASE NO: 08-CV-80119-MARRA/JOHNSON + +The foregoing instrument was acknowledged before me this 11th day of +March, 2010 by [redacted] who is personally known to me or who has +produced \_\_\_\_\_ as identification and who did/did +not take an oath. + +![]()Notary Public + +![](_page_3_Picture_86.jpeg) + +![](_page_4_Picture_3.jpeg) + +# Farmer, Jaffe, Weissing, Edwards, Fistos a Lehrman, P.L. + +June 25, 2010 + +vl F OSIMU\_E (305) 787-6124 (5 Pays/ + +FBI - Miami Field Office Legal Dept. 16320 NW 2nd Ave. N. Miami Beach, FL 33169 + +Re: Jane Doe'. Epstein / Case Number 08-cv-80893-MARRA/JOHNSON Subpoena for Documents + +Dear al + +Iam writing with regard to the subpoena referenced above to provide astatement which describes the nature of the litigation in which the subpoena is issued. My client has brought an action for damages because of sexual abuse inflicted on her by defendant Jeffrey Epstein while she was aminor. The records sought go directly to proving her claims. + +Attached please find a copy of the subpoena and a Privacy Waiver executed by my client. + +Jane Does real name is: her dare of birth is and her partial social security number is 593-70-xxxx. + +if l can provide any further information, please do not hesitate to call. + +Very truly yours, + +Bradley Edwards + +BJE/bw Attachments as stated + +> 425North Andrews Avenue, Suite 2, Fort Lauderdale, Florida 33301 954.524.2820 office 954.524.2822 fax \ No newline at end of file diff --git a/marker2/ds9/EFTA00206567/EFTA00206567.metadata.json b/marker2/ds9/EFTA00206567/EFTA00206567.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f03ab7f65efa9b825793ff146a71fbc60bb09fca --- /dev/null +++ b/marker2/ds9/EFTA00206567/EFTA00206567.metadata.json @@ -0,0 +1,360 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206567.pdf", + "engine": { + "marker_major": "2", + "marker_version": 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Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered by Pike, Michael on 7/6/2010 at 11:13 AM EDT and filed on 7/6/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80893-KAM + +Filer: Jeffrey Epstein + +Document Number:201 + +## Docket Text: + +RESPONSE in Opposition re [175] Plaintiffs MOTION for Writ of Habeas Corpus ad testificandum Alfredo Rodriguez filed by Jeffrey Epstein. (Pike, Michael) + +9:08-cv-80893-KAM Notice has been electronically mailed to: + +Ann Marie C. Villafana ann.marie.c.villafana@usdoj.gov, fran.prager@usdoj.gov + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Jack Alan Goldberger jagesq@bellsouth.net, nalanis®agwpa.com + +Katherine Warthen Ezell KEzell@podhurst.com, mestrada@podhurst.com + +Michael James Pike MPike@bciclaw.com, bobbie@bciclaw.com, jcadwell@bciclaw.com + +Paul G. Cassell cassellp@law.utah.edu + +Robert Deweese Critton , Jr rcrit@bciclaw.com, bobbie@bciclaw.com + +9:08-cv-80893-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. 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After months of reporting, The Daily Beast's reveals exclusive details of the investigation and the legal wrangling that saved him from a long prison term. She reports: + +- Palm Beach's police chief objected to Epstein's "special treatment" and gave The Daily Beast an exclusive look at his nine-hour deposition about the investigation. +- Earlier versions of the U.S attorney's charges, including a sealed 53-page indictment, could have landed Epstein in prison for 20 years. +- Victims alleged that Epstein molested underage girls from South America. Europe. and the former Soviet republics. including three 12-year-old girls brought over from France as a birthday gift. +- The victims also alleged trips out of state and abroad on Epstein's private jets. which would be evidence of sex trafficking—a much more serious federal crime than the state charges Epstein was convicted of. +- Epstein's attorneys investigated members of the Palm Beach Police Department, while others ordered private investigators to follow and intimidate the victims' families: one even posed as a police officer. +- Then-Attorney General Alberto Gonzales told The Daily Beast that he "would have instructed the Justice Department to pursue justice without making a political mess." + +Film director Roman Polanski is not the only convicted pedophile to walk free this month and return to a life of privilege. On Wednesday, hedge fund manager Jeffrey Epstein completes his one-year house arrest in Palm Beach, which has been even less arduous than Polanski's time at a Swiss ski chalet. + +During Epstein's term of 'house arrest: he made several trips each month to his New York home and his private Caribbean island. In the earlier stage of his sentence for soliciting prostitution with a minor-13 months in the Palm Beach Stockade—he was allowed out to his office each day. Meanwhile, Epstein has settled more than a dozen lawsuits brought by the underage girls who were recruited to perform "massages" at his Palm Beach mansion. Seven victims reached a last-minute deal last week, days before a scheduled trial; each received well over \$1 million—an amount that will hardly dent Epstein's \$2 billion net worth. + +With that, the known victims of Epstein's sexual compulsion have been officially silenced, and the case against him is closed unless new ones come forward. According to banking sources, he has been moving assets out of the U.S. and may well follow Polanski into a luxurious exile. + +Watch Jeffrey Epstein Storm Out of a Deposition When Asked About His Penis + +But the question remains: Did Epstein's wealth and social connections—former President Bill Clinton; Prince Andrew; former Israeli Prime Minister Ehud Barak; New Mexico Gov. Bill Richardson; and former Treasury Secretary Larry Summers were just a few of the prominent passengers on his private jets—allow him to receive only a slap on the wrist for crimes that carry a mandatory 20-year sentence? Was he able, with his limitless assets and heavy-hitting lawyers—Alan Dershowitz, Gerald Lefcourt, Roy Black, Kenneth Starr, Guy Lewis, and Martin Weinberger among them—to escape equal justice? + +the former Palm Beach police chief, certainly thinks so. He gave The Daily Beast exclusive access to the transcript of his nine-hour deposition for the victims' civil suits, in which he explained how the case against Epstein was minimized by the State Attorney's Office, then bargained down by the U.S. Department of Justice, all in an atmosphere of hardball legal tactics and social pressures so intense that became estranged from several colleagues. At the time, , who retired in 2009 and now runs his own security firm, objected both to Epstein's plea agreement and to the flexible terms of his incarceration in the county jail rather than state prison. Asked during the deposition whether he thought Epstein received special treatment, he answered "yes: + +In March 2005, department, acting on a complaint from the Florida parents of a 14-year-old girl, launched an investigation that would eventually uncover a pattern of predatory behavior stretching back years and spanning several continents, knowingly enabled by Epstein's associates and employees. Two or three times a day, whenever Epstein was in Palm Beach, a teenage girl would be brought to the mansion on El Brillo Way. ("The younger the better," he instructed a, a local teenager who was paid to bring other girls to the house, and who declared, on a police tape, that she was like a Heidi Reiss," the infamous California madam.) Advised that she would be giving a -massage: the girl was then pressured to remove her clothes, submit to fondling and a large vibrator, and sometimes lured into more invasive sexual contact. Each girl was paid \$200 or more, depending on how far things went, by house manager Alfredo Rodriguez, who was instructed always to have \$2,000 cash on hand. + +The Palm Beach Police Department identified 17 local girls who had contact with Epstein before the age of consent; the youngest was 14, and many were younger than 16. And that was just at one of Epstein's many homes around the world—he also owns properly in New York, Santa Fe, Paris, London, and the Caribbean. Subsequent investigation by the FBI, reaching as far back as 2001, indentified roughly 40 victims, not counting , whom Epstein referred to as his -Yugoslavian sex slave" because he had imported her from the Balkans at age 14. Now 24, + +became a member of the household and is alleged to have participated in the sexual contact with underage girls. + +Epstein quickly got wind of the investigation. and progress on the case got messy very quickly. He hired a squad of lawyers and private investigators and dispatched influential friends to pressure the police into backing off. Instead, local detectives pressed on and brought the matter to the attention of the FBI. The detectives asked their federal colleagues whether the fact that some victims appeared to have traveled out of state on Epstein's planes—plus the use of interstate phone service to arrange assignations—might be violations of the federal 2000 Trafficking Victims Protection Act, which carries a minimum sentence of 20 years. (Florida enacted the federal TVPA in 2002.) + +So when State Attorney , who also ran Florida's Crimes Against Children Unit, proved reluctant to mount a vigorous prosecution of Epstein. saying the local victims were not credible witnesses, Chief wrote the attorney a letter complaining of the state's -highly unusual" conduct and asking him to remove himself from the case. He did not. and the evidence his office presented to a state grand jury produced only a single count of soliciting prostitution. (Krischer has since retired and would not comment for this article.) The day after that indictment was returned, was relieved to have the FBI step in and take over the investigation. + +The details that eventually emerged were often shocking and occasionally bizarre. For Epstein's birthday one year, according to allegations in a civil suit. he was presented with three 12-year-old girls from France. who were molested then flown back to Europe the next day. These same civil complaints allege that young girls from South America, Europe, and the former Soviet republics, few of whom spoke English, were recruited for Esptein's sexual pleasure. According to a former bookkeeper. a number of the girls worked for MC2. the modeling agency owned by Jean Luc Brunel, a longtime acquaintance and frequent guest of Epstein's. Brunel received \$1 million from the billionaire around the time he started the agency. + +The non-prosecution agreement executed between Epstein and the Department of Justice states that Epstein and four members of his staff were investigated for -knowingly, in affecting interstate and foreign commerce. recruiting enticing and obtaining by any means a person. knowing that person has not yet obtained the age of 18 years and would be caused to engage in commercial sex act"—that is. child sex trafficking. Yet the agreement allowed Epstein to plead guilty to only two lower-level state crimes, soliciting prostitution and soliciting a minor child for prostitution. + +Although the police investigation was officially closed. Chief tried to stay abreast of the federal case against Epstein. He was particularly concerned that Epstein be registered as a sex offender, which was part of the final deal. and that a fund be set up to compensate his victims—which was not, although Epstein agreed to bankroll their civil lawsuits. Attorney Dershowitz says Epstein's agreement to pay attorney fees for the victims and agree to civil damage claims—without admitting guilt—amounted to "extortion under threat of criminal prosecution." + +But exactly which crimes did the Department of Justice threaten to prosecute? The Daily Beast has learned that there were several earlier versions of the U.S Attorney's charges. including a 53-page indictment that, had he been convicted. could have landed Epstein in prison for 20 years. Brad Edwards. attorney for seven of the victims, confirms the existence of an earlier draft of the non-prosecution agreement. officially under seal, in which it appears that Epstein "committed, at some point. to a 10-year federal sentence." But in the end Epstein's legal team refused that deal and threatened to proceed to trial. And that's where the question of whether the case was "winnable" before a jury again came into play, according to a source in the U.S Attorney's Office. which shared the state attorney's view that the prosecution was far from a slam dunk. + +For one, it was clear from the start that Epstein would spare no legal expense and that his team of veteran lawyers. whose cases ranged from O.J. Simpson to the investigation of Clinton's relationship with an intern. would play rough. When the Palm Beach police started to identify victims, according to Detective report. Dershowitz began sending the detective Facebook and MySpace posts to demonstrate that some of these girls were no angels. deposition also states that he heard from local private investigators that Dershowitz had launched background checks on both the police chief and . Dershowitz denies all of that. According to . both he and also became aware that they were under surveillance for several months, without knowing who ordered it. And the Florida victims began to complain that they and family members were being followed and intimidated by + +private investigators who were then linked to local attorneys in Epstein's employ. In one reported instance. the private investigator claimed to be a police officer. and considered filing witness-tampering charges. + +The credibility of the victims was also an issue: they had never complained of their treatment by Epstein until they were contacted by police, and they may have voluntarily returned to the Palm Beach mansion several times. Many of the girls came from disadvantaged backgrounds or broken homes, and they were susceptible to Epstein's cash. intimidation, and charm. Those who were 16 when they went to El Britlo Way would have been in their 20s by the time they took the stand, and Epstein's investigators had dredged up every instance of bad behavior in their pasts. According to an exchange in the deposition. a few of the victims had worked in West Palm Beach at massage parlors known as "jack shacks.' Each new compromising detail was immediately forwarded to the State Attorney's Office, where staff met frequently with Epstein's lawyers. + +The Florida statutes are clear: Any person older than 24 who engages in sexual contact with someone under the age of 18 commits a felony of the second degree. The victim's prior sexual conduct is not relevant: ignorance of her age is no defense. She needn't resist physically to cast doubt on the issue of "consent." For a child under 16, even lewd behavior short of touching is a felony of the second degree. But convincing a jury that a sexual encounter is a heinous crime is difficult if the victim can be made to appear willing and unharmed, not to mention vulgar and mercenary. It wasn't hard to imagine some of the victims quickly being discredited in court by Epstein's crack legal team, who repeatedly noted that the age of consent is lower in many other states. + +But that doesn't quite explain why the Department of Justice would forgo the child-trafficking charges, which pertain regardless of a girl's attitude or character. Epstein's final sentence is so out of line with the statutory guidelines for that crime that it appears the department may have been influenced by the existence of his many powerful friends and attorneys. A highly intelligent man who once taught math at the Dalton School in New York without a bachelor's degree, Epstein has been a serious and respected player in the highest reaches of politics and philanthropy. He has made substantial contributions to political candidates, served on the Council on Foreign Relations, and donated \$30 million to Harvard University. + +Moreover. many of his high-powered acquaintances availed themselves of Epstein's private jets. for which the pilot logs, obtained by discovery in the civil suits, sometimes showed that bold-face names were on the same flights as underage girls. A high-profile trial threatened to splash mud over all sorts of big players, just as both Gov. Richardson and Bill Clinton's wife were running for president. Also, a hedge fund prosecution in which Epstein offered to give evidence was heating up. Alberto Gonzales, who was U.S. attorney general throughout most of the Epstein investigation and resigned just before the non-prosecution agreement was signed, told The Daily Beast that he 'would have instructed the Justice Department to pursue justice without making a political mess.' But that may have been an impossible mandate. given the players involved. + +Instead. said attorney Brad Edwards, "Epstein committed crimes that should have jailed him for most of his life...he was jailed for only a few months." And this week he walks through his door a free man. + +has developed multimedia communication programs for Fortune 500 companies and has produced three current events debate television programs. The Americas Forum. From Beirut to Kabul. and a segment for The Oppenheimer Report. She is a contributor to The Huffington Post and is writing a book about child trafficking in America. + +Get a head start with the Morning Scoop email. It's your Cheat Sheet with must reads from across the Web. 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Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered on 7/7/2010 at 5:16 PM EDT and filed on 7/7/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80893-KAM + +Filer: + +Document Number:203(No document attached) + +## Docket Text: + +\*Endorsed Order directing Clerk to restrict Doc No. 202 from public view due to confidental information. Signed by Sr. Magistrate Judge Peter R. Palermo on 7/7/2010. (ds) + +![](_page_0_Picture_18.jpeg) + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Jack Alan Goldberger jagesq@bellsouth.net, nalanis®agwpa.com + +Katherine Warthen Ezell ICEzell@podhurst.com, mestrada@podhurst.com + +Michael James Pike MPike@bciclaw.com, bobbie@bciclaw.com, jcadwell@bciclaw.com + +Paul G. Cassell cassellp@law.utah.edu + +Robert Deweese Critton , Jr rcrit@bciclaw.com, bobbie@bciclaw.com + +9:08-cv-80893-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: \ No newline at end of file diff --git a/marker2/ds9/EFTA00206578/EFTA00206578.metadata.json b/marker2/ds9/EFTA00206578/EFTA00206578.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..2559f40ba15ea3f16cc008dece9ecf1e2acb39c0 --- /dev/null +++ b/marker2/ds9/EFTA00206578/EFTA00206578.metadata.json @@ -0,0 +1,111 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206578.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1966, + "elapsed_seconds": 1.19, + "image_assets": [ + "_page_0_Picture_18.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 308.61 + ], + [ + 184.3336639404297, + 308.61 + ], + [ + 184.3336639404297, + 324.23358154296875 + ], + [ + 30.6, + 324.23358154296875 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 422.82 + ], + [ + 101.52233123779297, + 422.82 + ], + [ + 101.52233123779297, + 438.3170471191406 + ], + [ + 30.6, + 438.3170471191406 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 64 + ], + [ + "Line", + 32 + ], + [ + "Text", + 23 + ], + [ + "SectionHeader", + 2 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206578" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206578/_page_0_Picture_18.jpeg b/marker2/ds9/EFTA00206578/_page_0_Picture_18.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..3b0e6a5c3cdcd8c74d4ab6645e5eca61c96cb4ee --- /dev/null +++ b/marker2/ds9/EFTA00206578/_page_0_Picture_18.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:7086c3a5da21f1896b26f39bbdc6e701b3d0062076e7c832def1d666f4e51844 +size 7064 diff --git a/marker2/ds9/EFTA00206579/EFTA00206579.md b/marker2/ds9/EFTA00206579/EFTA00206579.md new file mode 100644 index 0000000000000000000000000000000000000000..07df33e4259cec8f20666f698510879ff5b1c984 --- /dev/null +++ b/marker2/ds9/EFTA00206579/EFTA00206579.md @@ -0,0 +1,57 @@ +To: "flsd\_cmecf notice®flsd.uscourts.gov" + +Subject: Activity in Case 9:08-cv-80893-KAM Doe 1 Epstein Settlement Conference + +Date: Wed, 07 Jul 2010 20:41:16 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered on 7/7/2010 at 4:41 PM EDT and filed on 7/6/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80893-KAM + +Filer: + +Document Number:202 + +## Docket Text: + +Minute Order for proceedings held before Sr. Magistrate Judge Peter R. Palermo: Settlement Conference held on 7/6/2010.CASE SETTLED. (ds) + +9:08-cv-80893-KAM Notice has been electronically mailed to: + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Jack Alan Goldberger jagesq@bellsouth.net, nalanis®agwpa.com + +Katherine Warthen Ezell ICEzell@podhurst.com, mestrada@podhurst.com + +Michael James Pike MPike@bciclaw.com, bobbie@bciclaw.com, jcadwell@bciclaw.com + +Paul G. Cassell cassellp@law.utah.edu + +Robert Deweese Critton , Jr rcrit@bciclaw.com, bobbie@bciclaw.com + +9:08-cv-80893-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. 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Thanks. + +Sent: Friday, July 23, 2010 3:23 PM + +Subject: RE: Request for Press Comment re Epstein + +She called me also. I will send her an email and tell her we will not be commenting or speaking about this matter. She is persistent, that's for sure. + +Sent: Friday, July 23, 2010 3:15 PM + +To: Valle, Alicia (USAFLS) + +Subject: Request for Press Comment re Epstein + +onchita Samoff has called me again. She told me to read her two intemet articles and then asked me to call her to "discuss" them. Her number is + +Here are the articles. I don't have any comment. + +Confidential background information: The investigation stemming from the seizure of the evidence from Epstein's former butler (who is referenced in the articles), is continuing. + +Please let me know if you would like me to do anything. 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I bcc'd you on my email to her. + +--- + +**From:** [REDACTED] + +**Sent:** Friday, July 23, 2010 3:25 PM + +**To:** [REDACTED] + +**Subject:** RE: Request for Press Comment re Epstein + +Thank you, Alicia. Can you just let her know that you are responding on my behalf as well (i.e., she should really stop calling me!). Thanks. + +[REDACTED] +Assistant U.S. Attorney + +500 S. Australian Ave, Suite 400 + +West Palm Beach, FL 33401 + +--- + +**From:** [REDACTED] + +**Sent:** Friday, July 23, 2010 3:23 PM + +**To:** [REDACTED] + +**Subject:** RE: Request for Press Comment re Epstein + +She called me also. I will send her an email and tell her we will not be commenting or speaking about this matter. She is persistent, that's for sure. + +--- + +**From:** [REDACTED] + +**Sent:** Friday, July 23, 2010 3:15 PM + +**To:** [REDACTED] + +**Subject:** Request for Press Comment re Epstein + +Hi Alicia – [REDACTED] has called me again. She told me to read her two internet articles and then asked me to call her to “discuss” them. Her number is [REDACTED] + +Confidential background information: The investigation stemming from the seizure of the evidence from Epstein's former butler (who is referenced in the articles), is continuing. + +Please let me know if you would like me to do anything. Thanks. + +« File: Sarnoff Article.pdf » + +« File: 2nd Sarnoff Article.pdf » + +Assistant U.S. Attorney + +500 S. 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JEFFREY E EPSTEIN | DOB:
01/20/1953 | Reported Offender Address: 358
EL BRILLO WAY, PALM BEACH, FL | View
Offender
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Australian Ave, Suite 400 + +West Palm Beach, FL 33401 + +561-209-1047 + +Fax 561-802-1787 \ No newline at end of file diff --git a/marker2/ds9/EFTA00206586/EFTA00206586.metadata.json b/marker2/ds9/EFTA00206586/EFTA00206586.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..02d987d70177a8200d81d96459b74197ecf88515 --- /dev/null +++ b/marker2/ds9/EFTA00206586/EFTA00206586.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206586.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 504, + "elapsed_seconds": 0.75, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 33 + ], + [ + "Line", + 17 + ], + [ + "Text", + 16 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206586" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206587/EFTA00206587.md b/marker2/ds9/EFTA00206587/EFTA00206587.md new file mode 100644 index 0000000000000000000000000000000000000000..60e21cd0113f00a682d2faf3dec6dba9278ebbba --- /dev/null +++ b/marker2/ds9/EFTA00206587/EFTA00206587.md @@ -0,0 +1,67 @@ +To: [REDACTED] v> + +Subject: Activity in Case 9:09-cv-80469-KAM Doe II [REDACTED]. Epstein et al Order Dismissing Case + +Date: Thu, 08 Jul 2010 14:54:01 +0000 + +Importance: Normal + +--- + +**This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended.** + +**\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\*** Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +**Notice of Electronic Filing** + +The following transaction was entered on 7/8/2010 at 10:54 AM EDT and filed on 7/8/2010 + +Case Name: Doe II [REDACTED] Epstein et al + +Case Number: [9:09-cv-80469-KAM](#) + +Filer: + +WARNING: CASE CLOSED on 07/08/2010 + +Document Number: [82](#) + +Docket Text: + +**ORDER DISMISSING CASE with prejudice. All pending motions are denied as moot. This case is CLOSED. Signed by Judge Kenneth A. Marra on 7/7/2010. (ir)** + +9:09-cv-80469-KAM Notice has been electronically mailed to: + +[REDACTED] + +Bradley James Edwards [REDACTED] + +Bruce Reinhart [REDACTED] + +Denise Kalland [REDACTED] + +Isidro Manuel Garcia [REDACTED] + +Jack Alan Goldberger [REDACTED] + +Michael James Pike [REDACTED] + +9:09-cv-80469-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +The following document(s) are associated with this transaction: + +Document description:Main Document + +Original filenamem/a + +Electronic document Stamp: + +[STAMP dcecfStamp\_1E 1105629215 [Date=7/8/2010] [FileNumber=7765437-0] + +[243a4462c17c3d0c06bfbad6cae2b8c4a34319d328762156e5ef38630573091ed2d2 + +Mbl4b56e4761e3b2df99801b9b3813b29a93a8f23946c4988154fa5fad3]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00206587/EFTA00206587.metadata.json b/marker2/ds9/EFTA00206587/EFTA00206587.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..eed1b67a99db9d1d01f739f66650bb67f1ec8d15 --- /dev/null +++ b/marker2/ds9/EFTA00206587/EFTA00206587.metadata.json @@ -0,0 +1,112 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206587.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2162, + "elapsed_seconds": 7.61, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 308.61 + ], + [ + 182.37599999999998, + 308.61 + ], + [ + 182.37599999999998, + 323.19 + ], + [ + 30.6, + 323.19 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 65 + ], + [ + "Text", + 52 + ], + [ + "Line", + 33 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 20 + ], + [ + "Line", + 10 + ], + [ + "Text", + 8 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206587" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206589/EFTA00206589.md b/marker2/ds9/EFTA00206589/EFTA00206589.md new file mode 100644 index 0000000000000000000000000000000000000000..d9d153798262cfb307a3fb3372435b84fba15281 --- /dev/null +++ b/marker2/ds9/EFTA00206589/EFTA00206589.md @@ -0,0 +1,57 @@ +**From:** "cmecfautosender@flsd.uscourts.gov" +**To:** "flsd\_cmecf\_notice@flsd.uscourts.gov" +**Subject:** Activity in Case 9:08-cv-80893-KAM Doe █ Epstein Stipulation +**Date:** Mon, 19 Jul 2010 20:59:36 +0000 +**Importance:** Normal + +--- + +**This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended.** + +**\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\*** Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +### Notice of Electronic Filing + +The following transaction was entered by Pike, Michael on 7/19/2010 at 4:59 PM EDT and filed on 7/19/2010 +**Case Name:** Doe █ Epstein +**Case Number:** [9:08-cv-80893-KAM](#) +**Filer:** Jeffrey Epstein +**Document Number:** [207](#) + +#### Docket Text: + +**STIPULATION *Joint Stipulation* by Jeffrey Epstein (Attachments: # (1) Text of Proposed Order Proposed Order)(Pike, Michael)** + +9:08-cv-80893-KAM Notice has been electronically mailed to: + +[REDACTED] [REDACTED] +Bradley James Edwards [REDACTED] +Jack Alan Goldberger [REDACTED] +Katherine Warthen Ezell [REDACTED] +Michael James Pike [REDACTED] +Paul G. Cassell [REDACTED] +Robert Deweese Critton , Jr [REDACTED] + +9:08-cv-80893-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +**Original filename:**n/a + +**Electronic document Stamp:** + +[STAMP dcecfStamp\_ID=1105629215 [Date=7/19/2010] [FileNumber=7801968-0 +] [7929e0fd0cb350991fc7e081b729816d4614f24e7849c97aa4d6ebba6a483af4b1e +a20d4cca4fcbb95b97c600da89dc4d40a287956f63074e2f668b5e187ee9a]] + +**Document description:**Text of Proposed Order Proposed Order + +**Original filename:**n/a + +**Electronic document Stamp:** + +[STAMP dcecfStamp\_ID=1105629215 [Date=7/19/2010] [FileNumber=7801968-1 +] [3638a94ec2d3f24e3012404c669e5dfd74d47a4a05ae9e55cfc459164247d2f5670 +b1d0c10d156872c3b89a831a5e347586e09a8ec40730b62418d312bd553dc]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00206589/EFTA00206589.metadata.json b/marker2/ds9/EFTA00206589/EFTA00206589.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..14897ab9756c657afceec48126d52b8c3debd4bf --- /dev/null +++ b/marker2/ds9/EFTA00206589/EFTA00206589.metadata.json @@ -0,0 +1,131 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206589.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2565, + "elapsed_seconds": 7.74, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 308.61 + ], + [ + 182.37599999999998, + 308.61 + ], + [ + 182.37599999999998, + 323.19 + ], + [ + 30.6, + 323.19 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 422.82 + ], + [ + 99.756, + 422.82 + ], + [ + 99.756, + 436.59000000000003 + ], + [ + 30.6, + 436.59000000000003 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 67 + ], + [ + "Text", + 37 + ], + [ + "Line", + 34 + ], + [ + "SectionHeader", + 3 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 10 + ], + [ + "SectionHeader", + 6 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206589" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206591/EFTA00206591.md b/marker2/ds9/EFTA00206591/EFTA00206591.md new file mode 100644 index 0000000000000000000000000000000000000000..e685a12abfea581bd881e92554c79c822c234884 --- /dev/null +++ b/marker2/ds9/EFTA00206591/EFTA00206591.md @@ -0,0 +1,65 @@ +To + +Subject: Activity in Case 9:08-cv-80893-KAM Doe v. Epstein Notice (Other) + +Date: Tue, 20 Jul 2010 15:26:40 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered by Pike, Michael on 7/20/2010 at 11:26 AM EDT and filed on 7/20/2010 + +Case Name: Doe v. Epstein + +Case Number: 9:08-cv-80893-KAM + +Filer: Jeffrey Epstein + +Document Number:208 + +Docket Text: + +NOTICE by Jeffrey Epstein re [207] Stipulation Notice of Filing Amended Proposed Order (Attachments: # (1) Text of Proposed Order Proposed Order)(Pike, Michael) + +9:08-cv-80893-KAM Notice has been electronically mailed to: + +Bradley James Edwards + +Jack Alan Goldberger + +Katherine Warthen Ezel + +Michael James Pike + +Paul G. Cassell + +Robert Deweese Critton , J + +9:08-cv-80893-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +**Original filename:**n/a + +**Electronic document Stamp:** + +[STAMP dcecfStamp\_ID=1105629215 [Date=7/20/2010] [FileNumber=7804075-0 +] [3df57d606e08f731afe2c12bcb92a50c755ff7813110313d68e16b7053deeaa6185 +ff876977ad0e272448b4c36ba3eb93310b2e1be05c92a47ae2a567768cdbb]] + +**Document description:**Text of Proposed Order Proposed Order + +**Original filename:**n/a + +**Electronic document Stamp:** + +[STAMP dcecfStamp\_ID=1105629215 [Date=7/20/2010] [FileNumber=7804075-1 +] [8e408808a5ca09e44581199af555d7eb5faac0bbea3c8f8231d6fe4161ea370311e +e89a1bba0f0a0fae48ae5a6e8e3cf04264e23f4587c95470fa86263b0631a]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00206591/EFTA00206591.metadata.json b/marker2/ds9/EFTA00206591/EFTA00206591.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..50a603dcdcf54beb9a07a545c4116c213457691f --- /dev/null +++ b/marker2/ds9/EFTA00206591/EFTA00206591.metadata.json @@ -0,0 +1,108 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206591.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2272, + "elapsed_seconds": 3.68, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 308.61 + ], + [ + 184.3336639404297, + 308.61 + ], + [ + 184.3336639404297, + 324.23358154296875 + ], + [ + 30.6, + 324.23358154296875 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 71 + ], + [ + "Line", + 34 + ], + [ + "Text", + 25 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 14 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206591" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206593/EFTA00206593.md b/marker2/ds9/EFTA00206593/EFTA00206593.md new file mode 100644 index 0000000000000000000000000000000000000000..4502a57353caf4489dad5311c34fc05a9dcea60d --- /dev/null +++ b/marker2/ds9/EFTA00206593/EFTA00206593.md @@ -0,0 +1,111 @@ +To + +Subject: FW: Alfredo Rodriguez/Jeffrey Epstein + +Date: Mon, 19 Jul 2010 20:30:38 +0000 + +Importance: Normal + +Hi + +I wanted to touch base with you on this. I spoke with Brad's firm's investigator today and have a meeting next Tuesday in Ft. Lauderdale with him to review some things. If you get a chance, can you give me a call? + +Thanks, + +From + +Sent: Thursda Jul 08 2010 5:51 PM + +To: + +Subje : e: re o o nguez e ey Epstein + +Sounds good. Have a good weekend. + +Fro II + +To: + +Sent: Thu Jul 08 17:36:52 2010 + +Subject: RE: Alfredo Rodriguez/Jeffrey Epstein + +Thanks, I will talk to you next week after you talk to Brad. Good luck in California! + +Assistant U.S. Attorney + +From + +Sent: Thursda Jul 08 2010 5:35 PM + +To + +Subject: Re: Alfredo Rodriguez/Jeffrey Epstein + +From: + +To: + +Sent: Thu Jul 08 17:23:20 2010 + +Subject: RE: Alfredo Rodriguez/Jeffrey Epstein + +From Sent: Thursday, July 08, 2010 4:58 PM To: Subject: Re: Alfredo RodHay gr Epstein + +Maybe few minutes past 5 waiting on luggage. + +From To: Sent: Thu Jul 08 16:37:17 2010 Subject: RE: Alfredo Rodriguez/Jeffrey Epstein + +That would be great. Thanks. + +Assistant U.S. Attorney + +From Sent: Thursday, July 08, 2010 4:33 PM To: Subject: Re: Alfredo Rodriguez/Jeffrey Epstein + +We just landed, taxing. Should I call your office a couple minutes before 5? + +From To: Brad Edwards Cc Sent: Thu Jul 08 12:43:43 2010 Subject: RE: Alfredo Rodriguez/Jeffrey Epstein + +Thank you, Brad. is on a flight right now, which is due to land around 4:00. If her flight is delayed, I will let you know. Ot erwrse, I will plan to call you at your office at 5:00. + +Thanks. + +Assistant U.S. Attorney + +From: Brad Edwards Sent: Thursday, July ummilmo + +No, all of my cases are not settled. I am available at S. + +Brad Edwards Civil Justice Attorney Farmer, Jaffe, Weissing, + +![](_page_2_Picture_3.jpeg) + +mil Please consider the environment before printing this e-mail. + +IRS Circular 230 Disclosure: Please note that the views expressed herein or in any attachments hereto are not intended to constitute a "reliance opinion" under applicable Treasury Regulations, and accordingly are not intended or written to be used, and may not be used or relied upon, for the purpose of (i) avoiding tax-related penalties that may be imposed by the Internal Revenue Service, or (ii) promoting, marketing or recommending to another party any tax-related matters addressed herein. + +NOTICE: THE INFORMATION CONTAINED IN THIS TRANSMISSION IS ATTORNEY PRIVILEGED AND CONFIDENTIAL. IT IS INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY NAMED ABOVE. IF THE READER OF THIS MESSAGE IS NOT THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION, DISTRIBUTION OR COPY OF THIS COMMUNICATION IS STRICTLY PROHIBITED. IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONE TOLL FREE (800) 400.1098 AND DELETE THE MATERIAL FROM ANY COMPUTER. THANK YOU. + +From: + +Sent: ursday, July 08, 2010 11:31 AM + +To: Brad Edwards + +Cc: + +Subject: Alfredo Rodriguez/Jeffrey Epstein + +Good morning, Brad: + +Are you free to speak this afternoon at around 5:00? the Alfredo Rodriguez case. and I want to follow up on some items related to + +Can you also confirm that all of your cases are settled? + +Thank you. + +![](_page_2_Picture_16.jpeg) + +Assistant U.S. Attorney + +![](_page_2_Picture_18.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00206593/EFTA00206593.metadata.json b/marker2/ds9/EFTA00206593/EFTA00206593.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1fc79fd24047bb5ad1b6f8678e3b615e87767e7a --- /dev/null +++ b/marker2/ds9/EFTA00206593/EFTA00206593.metadata.json @@ -0,0 +1,122 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206593.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 3315, + "elapsed_seconds": 1.36, + "image_assets": [ + "_page_2_Picture_3.jpeg", + "_page_2_Picture_16.jpeg", + "_page_2_Picture_18.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 64 + ], + [ + "Line", + 31 + ], + [ + "Text", + 28 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 60 + ], + [ + "Line", + 29 + ], + [ + "Text", + 13 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 57 + ], + [ + "Line", + 29 + ], + [ + "Text", + 16 + ], + [ + "Picture", + 3 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206593" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206593/_page_2_Picture_16.jpeg b/marker2/ds9/EFTA00206593/_page_2_Picture_16.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..a7ba89ca8541b7f55da2a30c2bf940cf4c44dcb5 --- /dev/null +++ b/marker2/ds9/EFTA00206593/_page_2_Picture_16.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:63bdc602477fe9cc51293e3913742b71a6bbab252bedc4fb489e396109499258 +size 1699 diff --git a/marker2/ds9/EFTA00206593/_page_2_Picture_18.jpeg b/marker2/ds9/EFTA00206593/_page_2_Picture_18.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..a063287ca92c9c7a3c7bbcef7490d443101588e9 --- /dev/null +++ b/marker2/ds9/EFTA00206593/_page_2_Picture_18.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:595ef0e3d5cf7164803e9ed5b663717727cd96e784eac53d4fb612c7ae219c52 +size 5636 diff --git a/marker2/ds9/EFTA00206593/_page_2_Picture_3.jpeg b/marker2/ds9/EFTA00206593/_page_2_Picture_3.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..647e04b3c371a9121fc2cf5dad79d24f57493613 --- /dev/null +++ b/marker2/ds9/EFTA00206593/_page_2_Picture_3.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:7995cdaf173bf97a8d60aea130871e7cc2ae51fcf14f120f8918921fd61e44fe +size 1292 diff --git a/marker2/ds9/EFTA00206596/EFTA00206596.md b/marker2/ds9/EFTA00206596/EFTA00206596.md new file mode 100644 index 0000000000000000000000000000000000000000..df66ff25e429c155dc339ec8c7632ddaca27d6c0 --- /dev/null +++ b/marker2/ds9/EFTA00206596/EFTA00206596.md @@ -0,0 +1,67 @@ +To: "flsd\_cmecf notice®flsd.uscourts.gov" + +Subject: Activity in Case 9:08-cv-80893-KAM Doe 1 Epstein Stipulation of Dismissal + +Date: Tue, 20 Jul 2010 18:07:59 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered by Pike, Michael on 7/20/2010 at 2:07 PM EDT and filed on 7/20/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80893-KAM + +Filer: Jeffrey Epstein + +Document Number: 210 + +## Docket Text: + +STIPULATION of Dismissal with Prejudice by Jeffrey Epstein (Attachments: # (1) Text of Proposed Order Proposed Order)(Pike, Michael) + +9:08-cv-80893-KAM Notice has been electronically mailed to: + +![](_page_0_Picture_18.jpeg) + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Jack Alan Goldberger jagesq@bellsouth.net, nalanis®agwpa.com + +Katherine Warthen Ezell KEzell@podhurst.com, mestrada@podhurst.com + +Michael James Pike MPike@bciclaw.com, bobbie@bciclaw.com, jcadwell@bciclaw.com + +Paul G. Cassell cassellp@law.utah.edu + +Robert Deweese Critton , Jr rcrit@bciclaw.com, bobbie@bciclaw.com + +9:08-cv-80893-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. 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Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered on 7/20/2010 at 2:54 PM EDT and filed on 7/20/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80893-KAM + +Filer: + +WARNING: CASE CLOSED on 07/20/2010 + +Document Number: 211 + +Docket Text: + +ORDER DISMISSING CASE with prejudice. All pending motions are denied as moot. This case is CLOSED. Signed by Judge Kenneth A. Marra on 7/20/2010. (ir) + +9:08-cv-80893-ICAM Notice has been electronically mailed to: + +Ann Marie C. Villafana ann.marie.c.villafana@usdoj.gov, shawn.ball®usdoj.gov + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Jack Alan Goldberger jagesq@bellsouth.net, nalanis®agwpa.com + +Katherine Warthen Ezell KEzell@podhurst.com, mestrada@podhurst.com + +Michael James Pike MPike@bciclaw.com, bobbie@bc1claw.com, jcadwell&ciclaw.com + +Paul G. Cassell cassellp@law.utah.edu + +Robert Deweese Critton , Jr rcrit@bciclaw.com, bobbie@bciclaw.com + +9:08-cv-80893-ICAM Notice has not been delivered electronically to those listed below and will be provided by other means. 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Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered on 7/8/2010 at 4:42 PM EDT and filed on 7/8/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80893-ICAM + +Filer: + +Document Number: 204(No document attached) + +Docket Text: + +Sealed Document (ots) + +9:08-cv-80893-KAM Notice has been electronically mailed to: + +Bradley James Edwards + +Jack Alan Goldberger + +Katherine Warthen Ezell + +Michael James Pike + +Paul G. Cassell + +Robert Deweese Critton , Jr + +9:08-cv-80893-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. 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Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered on 7/20/2010 at 1:56 PM EDT and filed on 7/20/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80893-KAM + +Filer: + +Document Number:209 + +Docket Text: + +ORDER ADOPTING AND ENTERING JOINT STIPULATION re [207] Stipulation filed by Jeffrey Epstein. Signed by Judge Kenneth A. Marra on 7/20/2010. (ir) + +9:08-cv-80893-KAM Notice has been electronically mailed to: + +Ann Marie C. Villafana ann.marie.c.villafana@usdoj.gov, shawn.ball®usdoj.gov + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Jack Alan Goldberger jagesq@bellsouth.net, nalanis®agwpa.com + +Katherine Warthen Ezell KEzell@podhurst.com, mestrada@podhurst.com + +Michael James Pike MPike@bciclaw.com, bobbie@bciclaw.com, jcadwell@bciclaw.com + +Paul G. Cassell cassellp@law.utah.edu + +Robert Deweese Critton , Jr rcrit@bciclaw.com, bobbie@bciclaw.com + +9:08-cv-80893-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +Original ffiename:n/a + +## Electronic document Stamp: + +[STAMP dcecfStamp\_11: 1105629215 [Date=7/20/2010] [FileNumber=7805241-0 ] [71b2dcd7c0b28b3cb8f18dd I ec08e55fdel5f36adlbfa0b7f6b05aeb6fd0aea0ed8 166f64cf3Idafdb83aalf1d562ddf6e36debb02cf4a714888b0546c836294]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00206601/EFTA00206601.metadata.json b/marker2/ds9/EFTA00206601/EFTA00206601.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..6be3b2e3da3ce4db941d6f1c2160d11e3ec3a0cc --- /dev/null +++ b/marker2/ds9/EFTA00206601/EFTA00206601.metadata.json @@ -0,0 +1,162 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206601.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2281, + "elapsed_seconds": 1.19, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 308.61 + ], + [ + 184.3336639404297, + 308.61 + ], + [ + 184.3336639404297, + 324.23358154296875 + ], + [ + 30.6, + 324.23358154296875 + ] + ] + }, + { + "title": "Document description:Main Document", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 29.988, + 25.92 + ], + [ + 232.20684814453125, + 25.92 + ], + [ + 232.20684814453125, + 40.8170166015625 + ], + [ + 29.988, + 40.8170166015625 + ] + ] + }, + { + "title": "Electronic document Stamp:", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 29.988, + 52.650000000000006 + ], + [ + 183.31948852539062, + 52.650000000000006 + ], + [ + 183.31948852539062, + 67.8170166015625 + ], + [ + 29.988, + 67.8170166015625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 69 + ], + [ + "Line", + 35 + ], + [ + "Text", + 26 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 13 + ], + [ + "Line", + 7 + ], + [ + "SectionHeader", + 2 + ], + [ + "Text", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206601" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206603/EFTA00206603.md b/marker2/ds9/EFTA00206603/EFTA00206603.md new file mode 100644 index 0000000000000000000000000000000000000000..74f1a99fb24ffbcb0027aff3488ac875bed11cb1 --- /dev/null +++ b/marker2/ds9/EFTA00206603/EFTA00206603.md @@ -0,0 +1,55 @@ +**To:** The Daily Beast + +**Subject:** [REDACTED] sent you an article from The Daily Beast + +**Date:** Fri, 23 Jul 2010 13:58:25 +0000 + +**Importance:** Normal + +Hi [REDACTED] – It is so good to hear from you. I hope that things are going well. I still can't believe it either. And I have been getting more and more depressed as the time has drawn near. Yesterday I was home with a migraine. We sort of “found” a list with more names on it, and we are investigating those, too, but I have no faith that it will ever go anywhere. And I have no doubt that the pattern of abuse will continue. + +[REDACTED] + +Assistant U.S. Attorney + +[REDACTED] + +**From:** [REDACTED] + +**Sent:** Thursday, July 22, 2010 7:25 PM + +**To:** [REDACTED] + +**Subject:** [REDACTED] sent you an article from The Daily Beast + +[REDACTED] has shared an article from The Daily Beast with you! [Click here](#) to subscribe to The Daily Beast's morning email and breaking news alerts. + +**Message from sender:** I am just as upset about this today as I was then. The lawsuit settlements are a good thing, but jail would have been better. + +**Today:** July 22, 2010 + +![](_page_0_Picture_142.jpeg) + +![](_page_0_Picture_143.jpeg) + +![](_page_0_Picture_144.jpeg) + +[Billionaire](#) +[Pedophile](#) +[Goes](#) +[Free](#) +by + +Hedge fund mogul Jeffrey Epstein became a free man Wednesday, five years after he was first accused of sexually abusing underage girls. After months of reporting, The Daily Beast's [REDACTED] eveals exclusive details of the investigation and the legal wrangling that saved him from a long prison term. She reports: + +- • Palm Beach's police chief objected to Epstein's "special treatment" and gave The Daily Beast an exclusive look at his nine-hour deposition about the investigation. + +![](_page_0_Picture_148.jpeg) + +SACK TO TOP + +![](_page_1_Picture_2.jpeg) + +![](_page_1_Picture_3.jpeg) + +![A small green and white icon in the top right corner of the page.]()July 20. 2010 l 11:05 PM \ No newline at end of file diff --git a/marker2/ds9/EFTA00206603/EFTA00206603.metadata.json b/marker2/ds9/EFTA00206603/EFTA00206603.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..673867ad9f6e0405371e0181120306542318c9b6 --- /dev/null +++ b/marker2/ds9/EFTA00206603/EFTA00206603.metadata.json @@ -0,0 +1,107 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206603.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": 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[Click here](#) to subscribe to The Daily Beast's morning email and breaking news alerts. + +![](_page_0_Picture_116.jpeg) + +Sent you an article from The Daily Beast + +**Date:** Thu, 22 Jul 2010 23:24:44 +0000 + +**Importance:** Normal + +![](_page_0_Picture_120.jpeg) + +She shared an article from The Daily Beast with you! [Click here](#) to subscribe to The Daily Beast's morning email and breaking news alerts. + +**Message from sender:** I am just as upset about this today as I was then. The lawsuit settlements are a good thing, but jail would have been better. + +**Today:** July 22, 2010 + +![](_page_0_Picture_124.jpeg) + +![](_page_0_Picture_125.jpeg) + +**Conchita Sarnoff** + +![](_page_0_Picture_127.jpeg) + +Billionaire +Pedophile +Goes +Free +by +*Conchita +Sarnoff* + +**Hedge fund mogul Jeffrey Epstein became a free man** +**Wednesday, five years after he was first accused of sexually abusing underage girls. After months of reporting, The Daily Beast's Conchita Sarnoff reveals exclusive details of the investigation and the legal wrangling that saved him from a long prison term. She reports:** + +• Palm Beach's police chief objected to Epstein's "special treatment" and gave The Daily Beast an exclusive look at his nine-hour deposition about the investigation. + +[Read Full Article »](#) + +![](_page_0_Picture_132.jpeg) + +[BACK TO TOP](#) + +July 20, 2010 | 11:05 PM + +![](_page_0_Picture_135.jpeg) + +![](_page_0_Picture_136.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00206605/EFTA00206605.metadata.json b/marker2/ds9/EFTA00206605/EFTA00206605.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..5511a04e50682930d1557e82dbb4c7116d180135 --- /dev/null +++ b/marker2/ds9/EFTA00206605/EFTA00206605.metadata.json @@ -0,0 +1,76 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206605.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": 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Ray, Judge +United States Bankruptcy Court + +**UNITED STATES BANKRUPTCY COURT +SOUTHERN DISTRICT OF FLORIDA +FORT LAUDERDALE DIVISION** +[www.flsb.uscourts.gov](http://www.flsb.uscourts.gov) + +IN RE: + +CASE NO.: 09-34791-RBR + +ROTHSTEIN ROSENFELDT ADLER, P.A., CHAPTER 11 + +Debtor. + +**ORDER RESPECTING PRODUCTION OF +DOCUMENTS REGARDING JEFFREY EPSTEIN** + +THIS CAUSE came before the Court for hearing on August 4, 2010 upon (i) Motion to Compel Production of Documents from Trustee Pursuant to Document Production Protocol, as established by D.E. #672 (D.E. #807); (ii) Motion for Protective Order filed by Interested Party Farmer, Jaffe, Weissing, Edwards, Fistos and Lehrman, P.L. ("Farmer, Jaffe") (D.E. #818) and its related amendment (D.E. #819). The Court heard argument of all counsel present at the hearing, and being otherwise duly advised in the premises, + +![](_page_0_Picture_231.jpeg) + +Case 09-34791-RBR Doc 888 Filed 08/13/10 Page 2 of 3 + +### DOES HEREBY ORDER: + +f. The Court appoints former Broward County Circuit Judge Robert Carney as Special Master who shall work with counsel for the Trustee to obtain documents responsive to the subpoena served upon the Trustee by Jeffrey Epstein to: (i) review all electronically stored information ("ESI") and other documents in the Trustee's possession, including Qtask data for purposes of determining the applicability of the attorney/client and work product privileges that may inure to the benefit of L.M., Brad Edwards, and other current or former clients of Fanner, Jaffe; (ii) segregate any such privileged documents; and (iii) prepare aprivilege log in accordance with standard practice and law. + +2. Prior to engaging in this document review, the Special Master shall meet with counsel for Epstein, counsel for Fanner, Jaffe and counsel for the Trustee to hear their respective positions concerning these matters. Upon completion of the review by the Special Master, the Special Muster shall prepare and file a privilege log with the Court. No documents or ESI shall be released to anyone until such time as the Special Master has notified the Court that he has concluded his review of the responsive documents and is in a position to report to the Court Ins findings and to obtain further instruction. Upon the filing of such notice by the Special Master, the Court shall set acontinued hearing on the pending motions identified above. All legal fees and costs incurred by the Special Master shall be paid by Epstein, who has agreed to pay directly all such fees and costs. + +## + +Case 09-34791-RBR Doc 888 Filed 08/13/10 Page 3 of 3 + +## Submitted by; + +Charles H. Lichtman, Esq. + +BERGER SINGERMAN, + +350 East Las Olas Boulevard, Suite 1000 + +Port Lauderdale, FL 33301 + +Telephone: (954) 525-9900 + +Facsimile: (954) 523-2872 + +plichunanCbergersinaennan.com + +## Cony himished to• + +Charles H. Lichtman, Esq. + +(Chat H. 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b/marker2/ds9/EFTA00206609/EFTA00206609.md @@ -0,0 +1,133 @@ +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA + +# FT. LAUDERDALE DIVISION + +Case No. 08-CIV-80893-MARRA/JOHNSON + +JANE DOE, + +Plaintiff, + +v. + +JEFFREY EPSTEIN, + +Defendant. + +DEFENDANT, JEFFREY EPSTEIN'S MOTION FOR PROTECTIVE ORDER AND OBJECTION TO DISCLOSURE OF CERTAIN DOCUMENTS WITH INTEGRATED MEMORANDUM OF LAW + +Defendant, Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to a Joint Stipulation Regarding Certain Documentation files this his Motion for Protective Order and Objection to Disclosure of Certain Correspondence and Discovery for the reasons set forth below: + +### I. PRELIMINARY STATEMENT + +During the underlying litigation, Epstein vigorously sought protection from the Court that these and other documents produced would be used for purposes other than those contemplated by the Federal Rules of Civil Procedure for discovery; i.e., dissemination in the media. His rights to contest this type of use were preserved as part of the settlement of these proceedings, which provided for confidentiality of the settlement as well as provisions to bring these matters to a close. Now, the fears that led to Epstein's efforts to seek protection from the court have now come to pass. The intended use of these documents is now leading to more litigation that the settlement of these cases was designed to end. Epstein requests that the court grant protection so that this does not occur. + +#### II. STATEMENT OF PROCEEDINGS + +I. In July 2010, the Defendant, pursuant to certain discovery orders (D.E. 462 and 572) entered by this court produced correspondence and documentation between Epstein's attorneys/agents and federal prosecutors ("Correspondence"). + +2. Shortly thereafter, the parties entered into settlement agreements in the above-styled matter and in matters of L.M. v. Epstein, Case No. 502008 CA028051 XXXXMB AB in the Fifteenth Judicial Circuit in and for Palm Beach County and in E. W. vs. Epstein, Case No. 502008 CA028058 XXXXMB AB, filed in the Fifteenth Judicial Circuit in and for Palm Beach County, Florida. + +3. The parties entered into a Joint Stipulation, a copy of which is attached hereto as Exhibit "1" to govern the use of public disclosure of discovery of the Correspondence. The Court reserved jurisdiction to enforce the Stipulation. + +4. On August 26, 2010, counsel for the Plaintiff served notice of its intent to use the Correspondence in two court proceedings, an internal Justice Department Complaint procedure, and other, essentially public matters. It is also anticipated that the documents will be released to the media. A copy of the Notice of Intent to Use is attached hereto as Exhibit "2". + +5. The Joint Stipulation provides that if Epstein chooses to serve an objection, the Correspondence will remain confidential until the court has had an adequate opportunity to review the materials and enter a ruling. + +6. On August 30, 2010, the undersigned's firm requested counsel for the Plaintiff to identify the documents they intend to use so that Epstein would be in a position to prepare an appropriate response, which was rejected. The undersigned's law firm understands that the correspondence in question is in excess of 100 documents. In general, the documents consist of communications between Mr. Epstein's defense counsel and the United States Attorney's Office regarding the investigation, negotiation and settlement of potential criminal charges against Mr. Epstein. + +# DESCRIPTION OF INTENDED USE + +Epstein respectfully submits that a brief description of the proceedings that counsel for the Plaintiff has stated that they intend to use the Correspondence will be helpful to the court: + +# A. Epstein v. Edwards. Case No. 502009 CA040800XXXXMB AG + +The Plaintiff Epstein commenced an action on December 7, 2009 seeking damages against Defendants, Scott Rothstein, Bradley J. Edwards, and LM,' based on an alleged illegal Ponzi scheme by the Defendants, and the Plaintiff believes others as well, to market investments to outside investors in lawsuits brought against Epstein by a number of Plaintiffs, represented by the now defunct Law Firm of Rothstein, Rosenfeldt & Adler, P.A. ("RRA"). Some of the lawsuits were transferred to a newly formed firm of Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL ("Farmer Jaffe"). Epstein has alleged and believes that the Defendants and perhaps other former employees of RRA conspired to use the Epstein/LM litigation before this court and perhaps other + +The claim against LM was dismissed pursuant to a settlement agreement. + +litigation to lure investors in to making approximately \$13 million dollars worth of investments into phoney settlements by using pending real cases. + +Counsel for those investors, William Scherer, whose is also a member of the Creditor's Committee in the RRA bankruptcy, represented to the bankruptcy court that a number of his clients and their lawyer went into the RRA conference room and were allowed to go through the LM case file boxes, approximately 10 of them, and concluded that the Epstein case was a real case and ultimately invested money. A copy of the transcript of this hearing is attached hereto as Exhibit "3". Mr. Scherer's remarks appear on pages 17-22.2 + +On August 13, 2010, Bankruptcy Judge Raymond Ray ordered in response to a subpoena from Epstein the appointment of a special master to review in excess of 6,000 electronically stored documents of RRA that relate to Epstein and other litigation to prepare a privilege log in anticipation of production of relevant non-privileged documents. A copy of that Order is attached hereto as Exhibit "4". + +#### B. In Re: Jane Doe, Case No. 08-80736-Marra/Johnson + +In 2008, Jane Doe filed an action under the Crime Victims Rights Act ("CVRA"), 18 U.S. Code § 3771 on behalf of two alleged victims of the alleged sexual assault by Epstein. Since 2008 there has been little if any activity on that file. The articulated purpose of the use of these documents is in an effort to set aside the "Non Prosecution Agreement" which Epstein entered into + +&#x27;It is difficult to believe that if what Mr. Scherer has stated is true, that Mr. Edwards was not aware that his case files were being shown to outside investors. + +with the federal government. Neither victim has met the requirements of 18 U.S. Code § 377I(dX5)(A-C), which requires the court to assert her rights before and during the proceeding and to petition the court of appeals for a writ of mandamus if such right is denied.(See: Docket Entries for Doe v. U.S, 9:08-80736-KAM). It is hard to believe that a case that has been languishing in excess of two years will be revived to invalidate an agreement that the U.S. Attorneys Office entered into with Epstein after the agreement has been fully performed. + +### C. Justice Department Ombudsman and other uses + +The Code of Federal Regulations has set out the procedures to promote compliance with crime victims' rights. 28 C.F.R. § 45.10. In order to take advantage of this complaint process, the Code of Federal Regulations requires that complaints must be submitted within ninety (90) days of the victim's knowledge of a violation, but not more than one (1) year after the actual violation. 28 C.F.R. § 45.10(c)(3). + +It is obvious from the inaction of these proceedings and earlier filed pleading that this time frame has expired. Therefore the articulated intended use of the documents in this complaint proceeding is suspect on its face, thus leaving the only other articulated purposes which essentially is to allow the documents to go into the public domain. + +#### IV. MEMORANDUM OF LAW + +The policies behind FRE 408, and 410 provide this court for basis of sustaining Epstein's objections to the production of these documents. The intended use contravenes a critical public policy of encouraging resolution of criminal prosecutions without trial. Defendants are considerably + +more likely to engage in full and frank discussions with the government if they do not fear that statements they or their counsel make to government prosecutors will be used against them to their detriment in other proceedings. More specifically, Rule 408 prohibits the use of any evidence offered to prove liability for, invalidity of, or the amount of any claim that was disputed. Rule 410 makes inadmissible pleas, plea discussions and related statements. The exceptions under each of these rules do not apply. + +Evidence of statements made during plea negotiations are also not admissible under Florida Rules of Criminal Procedure 3.172(i). They are not admissible in any civil or criminal proceeding against the person who made the plea or offer or who conducted the negotiations. Similar provisions in Florida Evidence Code exist. Statements made as part of settlement negotiations are inadmissible. The exception under each of these rules also do not apply. See: §§ 90.408 and 90.410, Fla. Stat (1976). + +The Florida Rule, like its Federal Rule Counterpart, was adopted to promote plea bargaining by allowing a defendant to negotiate without waiving Fifth Amendment protection. The most significant factor in the rules of adoption was the need for free and open discussion between the prosecution and defense during attempts to reach a compromise United States v. Davis, 617 F. 2d 677, 683 (DC Cir. 1979), cited in Nunes v State of Florida, 988 So. 2d 636 (Fla. 2d DCA 2008). + +It would obviously present a chilling effect on any settlement discussions if such discussions could later be used as admissions of liability at trial or in any other proceeding. Bank Card America, Inc. v. Universal Bank Card Systems, Inc., 203 F. 3d 477, 483 (7°Cir. 2000). One court in the + +federal court system has held that communications falling within the parameters of Rule 408 are covered by settlement privilege which insulates them not just from admission into evidence but from discovery as well. Goodyear Tire & Rubber Company v. Chiles Power Supply, Inc., 332 F. 3d 976, 979-983 (6th Cir. 2003). The court specifically stated: + +> There exists a strong public interest in favor of secrecy of matters discussed by parties during settlement negotiations...the ability to negotiate and settle a case without trial fosters a more efficient, more cost effective, and significantly less burden to the judicial system...parties must be able to abandon their adversarial tendencies to some degree. They must be able to make hypothetical concessions, offer creative quid pro quos, and generally make statements that would otherwise belie their litigation efforts. Goodyear Tire, Id. at 980. + +The same is no less true in the plea negotiation context particularly where a central component of the discussions and negotiations between counsel for Epstein and counsel for the United States Attorney was to reach an agreement on conditions relating to compensation for his alleged victims. + +The court ordered discovery of this Correspondence so the Plaintiff could determine if' it contained any admissible information that would advance a stand-alone federal civil action. Instead, Epstein submits that the real use of this Correspondence will be to further counsel for the Plaintiffs legislative, political and philosophical mission to expand victim rights. This kind of extrinsic use of such discovery chills and compromises the presumptive confidentiality of written and often frank discussions between counsel. Epstein intended his communications with United States Attorney's Office to be private and protected by FRE 410. The communications from the U.S. + +Attorney to Epstein's counsel reflect these discussions and were also intended to be private. Now, after the fact to allow it to be disseminated to victim's rights advocates to change legislation totally defeats the public policy consideration of encouraging the resolution of criminal prosecutions without trial. + +### V. RELIEF REQUESTED + +Epstein requests that this Court grant the Motion for Protective Order by preventing disclosure and order Plaintiffs' counsel to return, without keeping copies, the Correspondence to counsel for Epstein. + +Alternatively, there are in excess of 100 documents of Correspondence; and as noted, counsel for Plaintiff has refused to agree to designate which they intend to use. Therefore, in the event this court is inclined to order the release of said correspondence, then Epstein requests an in-camera inspection of which documents Plaintiff intends to use to determine what, if any, documents are related to the foregoing pleas and what documents are not. Along the same lines, Epstein requests an in-camera inspection in an effort redact any information that may violate third party privacy rights or information that would implicate Epstein's Fifth Amendment rights and to further brief these issues. + +### VI. LOCAL RULE 7.1 STATEMENT + +Pursuant to the above Rule, the undersigned counsel and Plaintiff's counsel have conferred and are unable to resolve this matter. + +**VII. CERTIFICATE OF SERVICE** + +**I HEREBY CERTIFY** that a true and correct copy of the foregoing was electronically filed with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of record identified on the following service list in the manner specified via transmission of Notices of Electronic Filing generated by CM/ECF on this 2nd day of September, 2010. + +![]()![]()Paul G. Cassell, Esq. +*Pro Hac Vice* +33 + +2 South 1400 E. Room 101 + +![](_page_9_Picture_93.jpeg) + +*Co-Counsel for Defendant* + +*Respectfully submitted,* + +/s/ Joseph L. Ackerman, Jr. + +Joseph L. Ackerman, Jr. +Fla. Bar No. 235954 +Lilly Ann Sanchez +Fla. Bar No. 195677 + +FOWLER WHITE BURNETT P.A. + +~~901 Phillips Point West~~ +~~777 South Flagler Drive~~ + +![](_page_9_Picture_100.jpeg) + +*Co-Counsel for Defendant Jeffrey Epstein* + +[nat] W:\80743\MTNPR007-Motion for Protection Order USDC Doe v Epstein.JLA(9/2/10-15:59) \ No newline at end of file diff --git a/marker2/ds9/EFTA00206609/EFTA00206609.metadata.json b/marker2/ds9/EFTA00206609/EFTA00206609.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..016878bab661f12ecbf5dfffdbb7a0399cc1612a --- /dev/null +++ b/marker2/ds9/EFTA00206609/EFTA00206609.metadata.json @@ -0,0 +1,684 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206609.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 10, + "chars": 13945, + "elapsed_seconds": 5.58, + "image_assets": [ + "_page_9_Picture_93.jpeg", + "_page_9_Picture_100.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF FLORIDA", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 209.916, + 94.77000000000001 + ], + [ + 399.42828369140625, + 94.77000000000001 + ], + [ + 399.42828369140625, + 125.0985107421875 + ], + [ + 209.916, + 125.0985107421875 + ] + ] + }, + { + "title": "FT. 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Joint Stipulation Regarding Certain Correspondence Obtained By Jane Doe's attorneys during discovery, and each state: + +I. In July 2010, the law firm of Farmer, Jaffe, Weissing, Edwards, Fistos and Lehrman, PL. (the "Law Finn"), Paul G. Cassell, Esq. and Jay Howell, Esq. ("Counsel") received through discovery certain correspondence and documents (including content thereof) between Epstein's attomeys/agents and federal prosecutors (the "Correspondence"). + +2. Counsel for Jane Doe and Counsel for Epstein disagree whether the Correspondence is confidential. + +3. Without in any way altering the obligations set forth in the Addenda to Settlement Agreements entered into in the above-styled matter and in the matters of L,M. vs. Epstein,CASE NO. 502008 CA028051 JODOCMB AB and E.W. vs. Epstein, CASE NO. 502008 CA028058 XXXXMB AB, Counsel may wish to use the Correspondence in pending cases of Epstein v, Rothstein, CASE NO. 502009CA040800/OOOCMB AO and In Re: Jane Does 1 and 2, CASE + +![](_page_0_Picture_16.jpeg) + +NO. 08-80736-CIV-MARRA/JOHNSON. If Counsel (or Mr. Edwards as a Defendant in the Epstein v. Rothstein case) desires to file, use or disclose the Correspondence or contents thereof to anyone, Counsel agrees that prior to using any of the Correspondence in these proceedings or prior to providing or making the Correspondence available to anyone else, that they will provide seven (7) days notice to Epstein's counsel (Robert D. Critton, Jr. at rerit@bc1claw.com and Michael J. Pike at inpike@bc1claw.com) of their intent to use or provide the Correspondence or in the alternative, file the Correspondence under seal. If Epstein chooses to serve an objection based on a claim that the Correspondence should remain confidential, his objection must be served within seven (7) days from the date of the notice. If Epstein does serve an objection, Counsel (or Mr. Edwards as a defendant) will not file (unless filed under seal) nor disclose the Correspondence to the public or third parties until the court has ruled on the objection. However, Counsel (or Mr. Edwards as a defendant) may file the Correspondence under seal or provide the Correspondence to the court for an in camera inspection if any objection is made such that the court is in a position to rule on the objection. + +WHEREFORE, Plaintiff and Defendant requests that the Court enter an order on the above stipulation and grant any additional relief the Court deems just and proper. + +## Local Rule 7.1 Statement + +Pursuant to the above rule, the undersigned counsel and Plaintiff's counsel have conferred and have agreed to same. + +Respectfully submitted, + +By: /s/ Robert D. Critton. Jr. ROBERT D. CRITFON, JR., ESQ. Florida Bar No. 224162 + +**Certificate of Service** + +I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of record identified on the following service list in the manner specified via transmission of Notices of Electronic Filing generated by CM/ECF on this 19th day of July, 2010: + +Brad Edwards, Esq. +Farmer, Jaffe, Weissing, Edwards, Fistos +& Lehrman, PL +425-21 Andrews Ave + +![](_page_2_Picture_98.jpeg) + +Jack Alan Goldberger, Esq. +Atterbury Goldberger & Weiss, P.A. + +![](_page_2_Picture_100.jpeg) + +Paul G. Cassell, Esq. +*Pro Hac Vice* + +![](_page_2_Picture_102.jpeg) + +*Co-counsel for Plaintiff* + +By: /s/ Robert D. Critton, Jr. +ROBERT D. CRITTON, JR., ESQ. +Florida Bar No. 224162 +rcrit@bclclaw.com +MICHAEL J. PIKE, ESQ. +Florida Bar #617296 +mpike@bclclaw.com +BURMAN, CRITTON, LUTTIER & COLEMAN, LLP +303 Banyan Boulevard, Suite 400 + +![](_page_2_Picture_105.jpeg) + +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA + +CASE NO.: 08-CIV- 80893 — MARRA/JOHNSON + +JANE DOE, + +Plaintiff, + +v. + +JEFFREY EPSTEIN, + +Defendants. + +### Order Adopting and Entering Joint Stint\*'teflon + +This matter came before the Court on Plaintiff; Jane Doe, and Defendant, Jeffrey Epstein's Joint Stipulation, and counsel being in agreement with the entry of the Stipulation, it is HEREBY ORDERED and ADJUDGED that + +- 1. The Joint Stipulation is hereby Adopted and Entered. +- 2. Without in any way altering the obligations set forth in the Addenda to Settlement Agreements entered into in the above-styled matter and in the matters of L.M. vs. Epstein, CASE NO. 502008 CA028051 )OOCXMB AB and E.W. vs. Epstein CASE NO. 502008 CA028058 XXXXMB AB, Counsel may wish to use the Correspondence in pending cases of Epstein v. Rothstein, CASE NO. 502009CA040800XXXXMB AG and In Re: Jane Does 1 and 2, CASE NO. 08-80736-CIV-MARRA/JOHNSON. If Counsel (or Mr. Edwards as a Defendant in the Epstein v. Rothstein case) desires to file, use or disclose the Correspondence or contents thereof to anyone, Counsel agrees that prior to using any of the Conewondence in these proceedings or prior to providing or making the Correspondence available to anyone else, that they will provide seven (7) days notice to + +Epstein's counsel (Robert D. Critton, Jr. at rcrit@belclaw,cont and Michael J. Pike at moike@bc1claw.com) of their intent to use or provide the Correspondence or in the alternative, file the Correspondence under seal. + +3. If Epstein chooses to serve an objection based on a claim that the Correspondence should remain confidential, his objection must be served within seven (7) days from the date of the notice. If Epstein does serve an objection, Counsel (or Mr. Edwards as a defendant) will not file (unless filed under seal) nor disclose the Correspondence to the public or third parties until the court has ruled on the objection. However, Counsel (or Mr. Edwards as a defendant) may file the Correspondence under seal or provide the Correspondence to the court for an in camera inspection if any objection is made such that the court is in a position to rule on the objection. + +DONE and ORDERED this day of , 2010. + +Limns R. 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1 UNITED STATES BANKRUPTCY COURT
SOUTHERN DISTRICT OF FLORIDA

2

3

4

5

6 CASE NO.: 09-34791-BKC-RBR

7 In Re:
ROTHSTEIN ROSENFELDT ADLER, P.A.,
Debtor.

8 _____/

9

10

11 MOTION TO COMPEL PRODUCTION OF DOCUMENTS FROM TRUSTEE
12 PURSUANT TO DOCUMENT PRODUCTION PROTOCOL ESTABLISHED
BY DE#672 (807); AMENDED MOTION FOR PROTECTIVE ORDER
(819)

13

14

15 August 4, 2010

16

17 The above-entitled cause came on for
18 hearing before the HONORABLE RAYMOND B. RAY,
19 one of the Judges of the UNITED STATES BANKRUPTCY
20 COURT, in and for the SOUTHERN DISTRICT OF FLORIDA,
21 at 299 East Broward Blvd., Fort Lauderdale, Broward
22 County, Florida, on Tuesday, August 4, 2010,
23 commencing at or about 9:30 a.m., and the following
24 proceedings were held:
25 Reported By: Margaret Franzen

|

1 THE COURT: Rothstein Rosenfeldt & Adler.
2 All right. May I have appearances, please?
3 MR. LICHTMAN: Good morning, Judge.
4 Chuck Lichtman, Berger Singerman, for the trustee.
5 MR. NEIWIRTH: Good morning, your Honor.
6 Ronald Neiwirth, Fowler White Burnett, on behalf of
7 the movant, Epstein, and with me today are two of my
8 partners, Chris Knight and Lilly Ann Sanchez --
9 MS. SANCHEZ: Good morning, your Honor.
10 MR. KNIGHT: Good morning, your Honor.
11 MR. NEIWIRTH: -- both of whom are more
12 familiar with the State Court angle on this than I
13 am, so they came along to be able to elucidate that
14 end of it.
15 MR. FARMER: Good morning, your Honor.
16 Gary Farmer on behalf of LM, Brad Edwards, and
17 the Farmer Jaffe Weissing law firm. We are an
18 interested party and have filed a motion for
19 protective order as to the subpoena that is at
20 issue here today.
21 THE COURT: All right. Insofar as the
22 TD Bank motion, Docket Entry 780, that has been the
23 subject matter of an agreed order that was submitted
24 to me.
25 MR. LICHTMAN: Correct, Judge.

|

Page 3

Page 4

| +|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------| +|

1 APPEARANCES:

2

3 BERGER SINGERMAN, by
CHARLES H. LICHTMAN, ESQUIRE
on behalf of the Trustee

4

5

6 CONRAD & SCHERER, by
WILLIAM R. SCHERER, ESQUIRE
on behalf of victims

7

8

9 FOWLER WHITE BURNETT, by
RONALD G. NEIWIRTH, ESQUIRE
10 LILLY ANN SANCHEZ, ATTORNEY-AT-LAW
11 CHRISTOPHER E. KNIGHT, ESQUIRE
JOSEPH L. ACKERMAN, ESQUIRE
on behalf of Jeffrey Epstein

12

13 FARMER JAFFE WEISSING EDWARDS FISTOS & LEHRMAN, by
GARY FARMER, ESQUIRE
14 BRAD EDWARDS, ESQUIRE
on behalf of LM, Brad Edwards and
Farmer Jaffe Weissing Edwards Fistos & Lehrman

15

16 -----

17

18

19

20

21

22

23

24

25

|

1 THE COURT: Mr. Scherer.
2 MR. SCHERER: Yes, sir, your Honor.
3 I'm William Scherer and I'm here on behalf of a
4 number of victims in the State Court action, as
5 well as the chairman of the creditors' committee
6 in the bankruptcy.
7 THE COURT: All right. That leaves us with
8 Docket Entry 807 and 819. 807 is Jeffrey Epstein's
9 motion.
10 MR. NEIWIRTH: Thank you, your Honor, and
11 again, good morning. We represent Jeffrey Epstein.
12 He has a civil claim pending in State Court in
13 Palm Beach County. He had served a subpoena on
14 Mr. Stettin requesting documents from the RRA estate,
15 That was back in April.
16 While this was still in process, in
17 May, under Docket Entry 672, your Honor entered
18 an order standardizing procedures for obtaining
19 discovery from Mr. Stettin and the RRA estate,
20 and at least on the face of it, it takes
21 jurisdiction over all discovery efforts against
22 the trustee. That left us in a quandary.
23 We had a subpoena pending in State
24 Court. We had correspondence from Berger
25 Singerman on behalf of the trustee that they had

|

Page 4

| + +°UM-LEITH & MAULDIN COURT REPORTERS, (305) 3584875 + +![](_page_0_Picture_4.jpeg) + +Page 5 + +1 identified information and they were processing + 2 it, including vetting for attorney/client + 3 privilege issues, but then in the meantime came + 4 your Honor's order on May 18th, so we had to go + 5 back and reinvent the wheel and go through the + 6 necessary hoops in order to comply with that. + 7 In the meantime, as we sit here now, we + 8 still have no production. We have a trial date + 9 coming up in October, and we have a motion for + 10 protective order coming from a party who's + 11 already settled out, the LM party. They no + 12 longer have anything directly to do with this. + 13 Further, we are advised by the + 14 creditors' committee that in addition to what was + 15 proffered to us, that at some point in time there + 16 had been something like ten boxes of records + 17 pertaining to these particular issues and someone + 18 on behalf of the victims had been given, or + 19 several someones, had been given access to those + 20 ten boxes and had viewed them, which would + 21 vitiate any attorney/client privilege in any + 22 event. + 23 So what we are trying to do is fashion + 24 a mechanism so we can comply with your order, + 25 Docket 672, about standardized means of getting + +Page 6 + +1 production from the trustee, allow for the + 2 appropriate vetting of the materials for + 3 attorney/client privilege, and we must bear in + 4 mind that this is one objector, there's a lot + 5 more documents than that. + 6 To the best of our knowledge, the + 7 documents that pertain to the LM party, who is + 8 settled anyway, may be 15 percent of those which + 9 are responsive to the inquiry that we made of the + 10 trustee, but in any event, someone has to vet + 11 them for attorney/client privilege and do a + 12 privilege log. + 13 Now, Mr. Farmer's office on behalf of + 14 LM wants to do that. We don't think that's + 15 appropriate. We think the privilege at this + 16 point, since the case is settled, lies with RRA + 17 and, therefore, the trustee, rather than + 18 Mr. Farmer and his client, because as to them the + 19 case is over. + 20 Furthermore, we don't think there is + 21 any privilege because the boxes have been vetted + 22 before and we'll hear more about that from + 23 Mr. Scherer, I assume, because he was the one + 24 that was aware of that. + 25 And last, but not least, your Honor has + +Page 7 + +1 taken jurisdiction over these discovery matters + 2 and attempted to standardize discovery efforts + 3 for the trustee. There's a lot of people that + 4 want things from the trustee. + 5 The trustee is overseeing an estate + 6 which involved somewhere in excess of 70 lawyers + 7 and lots of cases and lots of problems, and + 8 literally millions of documents, and we have + 9 absolutely no problem with the standardized + 10 order, but that means that somehow or other we + 11 have to be able to deal with it in a standardized + 12 manner, instead of Mr. Farmer's suggestion, which + 13 is go back to State Court and deal with it over + 14 there. + 15 THE COURT: What is the status of the State + 16 Court proceeding? + 17 MR. NEIWIRTH: May I defer to my partner, + 18 who is more familiar with that? + 19 MR. KNIGHT: Your Honor, Christopher + 20 Knight, if I may? While we were waiting for the + 21 documents from the Stettin office, we obviously + 22 wanted to go down two tracks because we had an + 23 October trial date. The status of it is we could not + 24 come to an agreement with the other side. + 25 Mr. Ackerman was at the last hearing, in which the + +Page 8 + +1 judge said, one, I need a representative of the + 2 trustee here and two, shouldn't this be back before + 3 you, Judge Ray. + 4 THE COURT: You can't proceed against + 5 Rothstein in the State Court, they're here. + 6 MR. KNIGHT: And that is the same thing I + 7 think Judge Crow recognized, and that's why we're + 8 back here, and that's why we had to file the motion. + 9 MR. ACKERMAN: The claim against + 10 Rothstein is against him individually, and it's + 11 against Brad Edwards individually, and it was + 12 against one of the claimants, LM individually. + 13 THE COURT: So it's not against the debtor + 14 estate. + 15 MR. ACKERMAN: That's correct. + 16 MR. KNIGHT: Just to go a little further on + 17 what Mr. Neiwirth was saying. Out of these documents + 18 we've been asking for for a long time, very few of + 19 them would even have privilege on their face because + 20 they have nothing to do with the clients that were + 21 represented, what's been called as LM. + 22 If there's going to be a log, if + 23 there's any need, which I don't think there is + 24 because I think privilege has been waived, it + 25 needs to be a log put together by the trustee, + +Page 9 + +1 not anybody else that has some sort of interest + 2 in it. + 3 If there's a problem with payment for + 4 those, et cetera, our client has already offered + 5 to the trustee, to Mr. Lichtman, we will pay for + 6 it, whether it's a special master or whether it's + 7 a contract attorney, if they need to do that, but + 8 I don't think we even need to reach that. + 9 I think these documents are long + 10 overdue. They have been produced to others, they + 11 have been used in depositions for others, they + 12 are out there, and I think the privilege issue is + 13 just being used as a smoke screen to keep our + 14 client from being able to get the documents he + 15 needs to be able to prove his case. + 16 Thank you. + 17 MR. ACKERMAN: Your Honor, one other + 18 matter. Judge Crow expressed a concern about + 19 entering any order against the trustee or his + 20 counsel without them being present. + 21 Initially we had filed a motion to + 22 compel in the State Court, but we didn't realize + 23 at the time or it was unclear, because we had + 24 just taken over the case from another law firm, + 25 that the Court had entered its order. + +Page 10 + +1 There was some discussion prior to the + 2 hearing and when we went to the hearing, it was + 3 clear that there was no agreement that had + 4 existed and Judge Crow said, I'm not entering an + 5 order, I'm not doing anything on this motion + 6 until the bankruptcy trustee is represented. + 7 He was concerned because this Court's + 8 order had set up the standardized procedure for + 9 dealing with these arguments and had reserved + 10 jurisdiction relating to any subpoena or request + 11 for documents from the trustee, so that's why + 12 we're here now. + 13 THE COURT: All right. + 14 MR. KNIGHT: Your Honor, just one other + 15 point. We tried to work, and we've been working with + 16 Mr. Lichtman, tried to work out a protective order + 17 between the trustee and Epstein regarding the + 18 subpoena. Mr. Lichtman and Ms. Sanchez agreed to + 19 language on it. I have a copy of it. + 20 Mr. Farmer, with his motion for + 21 protective order, would not agree to that, but if + 22 the Court would like to have a copy of what the + 23 draft was, I will approach your clerk, but if you + 24 do not want that, I also -- + 25 THE COURT: Well, let me hear from + +Page 11 + +1 everybody first. + 2 MR. KNIGHT: Okay. + 3 MR. FARMER: Thank you, your Honor, may it + 4 please the Court. Again, Gary Farmer on behalf of + 5 the interested party, LM, also on behalf of + 6 Brad Edwards and I'm sorry, your Honor, Mr. Edwards + 7 is here with me. I neglected to introduce him to the + 8 Court earlier. + 9 MR. EDWARDS: Good morning, your Honor. + 10 MR. FARMER: There has been a lot of + 11 discussion here about your Honor's standardized + 12 production order and I think that you need to + 13 understand that this particular matter, which is + 14 before you today, is anything but standard or common + 15 to the matters before this Court. + 16 You need to understand the nature of + 17 the case. Jeffrey Epstein is an admitted + 18 convicted pedophile. He sexually assaulted + 19 dozens and dozens of young girls under the age of + 20 15. He pled guilty to this and he has settled + 21 every civil lawsuit filed against him on this + 22 issue. + 23 Despite all of this, Mr. Epstein has + 24 seen fit to file a lawsuit against LM, who is one + 25 of the plaintiffs against him; against + +Page 12 + +1 Brad Edwards, LM's attorney; and against + 2 Mr. Rothstein. + 3 Now, Edwards, myself, and all the + 4 members of our firm were RRA attorneys when + 5 Mr. Rothstein took his ill-fated trip to Morocco + 6 and did the things which are now so well known, + 7 but the fact of the matter is that this discovery + 8 request is a blatant attempt to obtain clearly + 9 privileged documents related to the + 10 representation of LM and many other victims, by + 11 the way. + 12 And if I can show your Honor a copy of + 13 the subpoena itself, I don't think that the + 14 breadth of the subpoena has been adequately + 15 represented to the Court. If you peruse this, + 16 you will see they are asking for communications + 17 with private investigators, they're asking for + 18 contingency fee contracts, they're asking for + 19 every communication between any member of the + 20 firm, and they throw Rothstein in just to make it + 21 sexy, about these cases. + 22 Now, your Honor, clearly communication + 23 about the representation of a client falls under + 24 not only the work product, but if the client is + 25 involved in the communication, also the + +Page 13 + +1 attorney/client privilege. + 2 Now, most of this stuff we've already + 3 responded and said none, none, none, but for many + 4 of these items, we have asserted the privilege + 5 and we continue to assert the privilege. + 6 Now, the only reason the trustee is + 7 here -- + 8 THE COURT: Wait, there's been a privilege + 9 asserted in the State Court proceeding? + 10 MR. FARMER: Yes, sir. + 11 THE COURT: And there is a privilege log + 12 and the judge has made a ruling? + 13 MR. FARMER: No. The dispute now really is + 14 over who's going to file the privilege log and + 15 respectfully, Judge, what we suggest is that the + 16 trustee has been thrust into this matter simply + 17 because the trustee stands in the shoes of all the + 18 former attorneys at RRA, and the trustee is likewise + 19 bound by the privileges that attach to the cases and + 20 to the lawyers that were at the firm. + 21 The trustee has repeatedly acknowledged + 22 the fact that it is bound by those privileges + 23 and, of course, as your Honor knows, the + 24 privilege belongs to the client, not to any + 25 lawyer or any law firm. + +Page 14 + +1 So the trustee is really kind of stuck + 2 in the middle here. You've got the pedophile who + 3 wants documents related to the cases he's already + 4 settled and pled guilty for. Those documents, + 5 the electronic documents, at least, the e-mails, + 6 electronically stored information is how it's + 7 referred to in the discovery request, your Honor, + 8 are not in our possession, they are in the + 9 possession of the trustee because the trustee + 10 took the computer system. + 11 So the trustee doesn't want to incur + 12 the cost and expense of filing a privilege log + 13 and, frankly, I don't know that the trustee has a + 14 full appreciation of the nature and specific + 15 facts of the cases that would enable it to + 16 conduct a complete privilege log. + 17 So my suggestion, your Honor, and it's + 18 been rejected -- I believe it's acceptable to the + 19 trustee, but it's been rejected by Mr. Epstein's + 20 counsel, is the trustee be removed from this + 21 equation. There's no need that we come back + 22 before you. + 23 This case, this Epstein case, is not a + 24 matter which would involve bankruptcy estate + 25 assets going to Mr. Epstein. Unlike + +Page 15 + +1 Mr. Scherer's clients, who have claims before + 2 this Court, and hopefully they will get some form + 3 of relief from the Bankruptcy Court, Epstein is + 4 not seeking any bankruptcy assets. He's suing + 5 Brad Edwards and LM personally, and Scott + 6 Rothstein, and it's not an estate claim, it's + 7 against Scott Rothstein personally. + 8 So my suggestion, your Honor, is that + 9 you instruct the trustee to turn this electronic + 10 documentation information over to us. We will + 11 file the appropriate privilege log with the + 12 Circuit Court judge who is presiding over the + 13 case, who is most familiar with the case, who + 14 will be considering the upcoming motion for + 15 summary judgment, and possibly trying the case, + 16 and that way your Honor is not burdened with this + 17 matter, the trustee does not incur fees and + 18 expenses of having to go through all of these + 19 documents, prepare a privilege log and our + 20 clients and Mr. Edwards -- Mr. Edwards is also a + 21 party of that lawsuit. He enjoys his own + 22 privilege, your Honor, over and above, or in + 23 addition to, I should say, the privilege + 24 possessed by our former clients and, of course, I + 25 know counsel knows that the privilege extends + +Page 16 + +1 beyond the litigation. + 2 So although Mr. Epstein paid a ton of + 3 money for this claim that is supposedly + 4 frivolous, it has been settled, but the privilege + 5 still extends and it remains in place. So we + 6 simply want to make sure that our investigative + 7 materials, our reports, other documentation + 8 relating to the claims we have and have had + 9 against Jeffrey Epstein are not put into the + 10 hands of Jeffrey Epstein's attorneys. + 11 Now, we just want the chance to review + 12 these documents and prepare the privilege log and + 13 the trustee is kind of stuck in the middle here, + 14 Judge. Remove the trustee from the equation, let + 15 us get the documents, we'll file the privilege + 16 log, and then Mr. Epstein and us can go before + 17 Judge Crow. He can review the privilege log, + 18 review the documents in camera. + 19 All that is going to be pretty time + 20 consuming, but he's much more suited, a better + 21 suited judge because he's more familiar with the + 22 facts to engage in that inquiry. + 23 THE COURT: Thank you. + 24 MR. FARMER: Thank you, your Honor. + 25 THE COURT: Mr. Lichtman, Mr. Scherer, your + +Putt 17 + +I input, please. MR. L1CHTMAN: I'm going to let Mr. Scherer go first. MR. SCHERER: I think he wants me to go first. THE COURT: All right. MR. SCHERER: Your Honor, in November we filed a lawsuit in State Court and we alleged that as apart of Mr. Rothstein and the firm, and the firm's employees, and maybe some of the firm's attorneys, conspired to use the Epstein/LM litigation in order to lure \$13.5 million worth of my victims, my clients, into making investments in these phoney settlements. And as we alleged in that State Court proceeding, and we've sharpened the allegations as we've amended afew times, we edits\* that sometime in late October, that my clients were invited into the Rothstein finn with Mr. Rothstein, and he explained that he had a litigation going in State Court with Mr. Edwards representing LM, avictim of Mr. Epstein, and these are kind of sensational allegations and it's been printed widely. And my clients, anumber of them and + +Pas 19 + +Iallegations in the LM case that they knew were not true, in order to entice my clients into believing that Bill Clinton was on the airplane with Mr. Epstein and these young woman and other personages, I can't remember who they are, and all sorts of other allegations that really were not even related to the LM case. And to the extent that any lawyers from the RRA firm, limner lawyers, made a ton of money or however Mr. Farmer talked about it, we're II interested in that ton of money ben,,se if they were involved In this scheme, this fraud, there's a crime fraud exception, and in addition, l want to see the ten boxes that they brought down. The trustee does not have those tea boxes. Those ten boxes were taken by Mr. Edwards when he left the law firm, I presume. So we want the ten boxes, we want all the communications and we want to look through everything on behalf of my State Court case, but also on behalf of the creditors' committee because the creditors' committee is looking to see if anybody else in the firm, other than Rothstein, was involved in this massive fraud that used the Epstein case. The model of using an existing case and + +Par IS + +Itheir lawyer, went into the Rothstein conference room and Mr. Rothstein brought down — summoned the investigators, two of them, two or three of them, to bring down the Epstein file. And the lawyer that my clients brought from a national finn, went through the LM boxes, ten of them that the investigators brought down, and concluded that the Epstein ease was a real case. And what Mr. Rothstein did with that real case, of course, is he told everybody that I I not only did he have the LM client of Mr. Edwards, that there were a number of other young ladies, that was widely published in the newspaper, that the firm was representing and that wanted to settle with Mr. Epstein on a confidential basis. So he used the real case in order to defraud my clients into investing into these phoney settlements and paid 13 and a half million dollars. I believe that Mr. Rothstein and others in the firm also told that story to a lot of other people, and let a lot of other people examine those ten boxes of the real case. In addition, as we have alleged, that Mr. Edwards and the firm put sensational + + 1t then spinning off a fraud from it is the same that was perpetrated on the Morse — in the Morse situation, as has been alleged and widely produced. Ican't conceive that Mr. Edwards and the predecessor law firm would have any standir.g to prepare privilege logs or anything else, given what I just told the Court. That would be like having the fox guard the hen house. That Epstein case is settled, and to the extent it's the ten boxes of stuff that we looked through, and I'll have to get the boxes to see if the attorney who looked through them, and how much time he spent looking through them — THE COURT: Where are the ten boxes? MR. SOBERER: That's a good question. The trustee does not have the ten boxes. I presume the ten boxes are residing with the lawyers who took the case, Mr. Edwards and the successor law finn. The trustee does not have them. And then in addition, dimes about 6,000 e-mails that the trustee has, and I bet you when we look at Qtask, there's going to be a boatload more. My clients were also advised during + +Pao 20 + +|

1 their due diligence, short due diligence to
2 settle these cases with these young ladies --
3 these putative young ladies who had to get the
4 money and leave town because of whatever the
5 stories were, that there were other members of
6 the firm that told my clients that they, indeed,
7 had even identified more of these victims that
8 Mr. Rothstein didn't even know about at that
9 time. So we know it wasn't just Mr. Rothstein
10 spinning the tale, there were a lot of people in
11 the firm.
12 We've alleged almost all of this in our
13 State Court action that we filed in November, up
14 to where we are right now, but, your Honor, I
15 think your Honor is going to have to deal with
16 these issues in this court and I would urge you
17 to have the trustee get involved and let the
18 trustee do its job with respect to whether there
19 are privileges that need to be protected, work
20 product or attorney/client privileges, given
21 what's going on, and I believe the trustee will
22 be investigating whether the trustee wants to
23 bring any claims on behalf of the estate by
24 virtue of what I've just laid out for you.
25 Thank you.

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1 to take those ten boxes to start with.
2 THE COURT: All right. Mr. Lichtman.
3 MR. LICHTMAN: Good morning, Judge. I'm
4 going to try to walk you through sort of
5 chronologically the trustee's perspective of what has
6 happened here. I think that what I've heard from all
7 the parties are comments that are correct, and not
8 necessarily correct, and I'm not suggesting
9 falsehoods. We just have kind of a different
10 perspective of some things and there are some points
11 that ought to be corrected.
12 Mr. Stettin received a subpoena in a
13 Palm Beach State Court action for production of
14 documents, and as we had done in virtually every
15 subpoena, we went to our forensic accountants,
16 the Berkowitz Dick Pollack & Brant firm, and
17 said, okay, we need to produce e-mails and we
18 need to also then, with the staff that we have at
19 Berger Singerman and elsewhere, and look to see
20 if there are any hard documents that we can find,
21 notwithstanding what we'll call the issues as to
22 the RRA hard drive that contain client files.
23 We quickly realized that this is a
24 claim different than all of the other subpoenas.
25 The subpoenas that we had been receiving from

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1 THE COURT: So your lawsuit in State Court
2 names these people as defendants?
3 MR. SCHERER: It names Rothstein. It
4 does not name Mr. Edwards. It just names
5 Rothstein, not the firm, and lays out the facts
6 and says other people in the firm. We did not
7 name them because we want to see the documents
8 and see whether they had involvement.
9 But the facts that I have alleged for
10 you, your Honor, is pretty much what I've alleged
11 in my first through third amended complaint in
12 State Court.
13 THE COURT: So, in essence, your position
14 in this matter would be to support the motion to
15 compel and deny the motion for protective order?
16 MR. SCHERER: Yes, sir, notwithstanding
17 that Mr. Epstein is a convicted pedophile. I
18 want to put that on the record. You know, he's
19 served his time and whatever, but I support the
20 same position that he -- that he has asked the
21 Court, and that is to have the trustee deal with
22 this, get these documents and deal with it with
23 you, rather than allow the successor law firm to
24 have them.
25 I don't know where they had the right

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1 virtually every other party in the case were
2 requests for production of documents related to
3 claims that those moving parties or requesting
4 parties would have as it pertains to them trying
5 to recover some aspect of money as pertained to
6 the Ponzi scheme.
7 Okay. Like Mr. Scherer, who said I
8 need a bunch of documents, can you help us? So
9 we would enter into, on a one by one basis, a
10 protective order that was very, very tightly
11 negotiated. There is no standard form protective
12 order in this case, contrary to what everybody
13 has told you. We have a form that we use, and
14 everybody that has come to us, we said, we need
15 to have a protective order in place --
16 THE COURT: We have Docket Entry 672, which
17 apparently is the document production protocol.
18 MR. LICHTMAN: We have that, yes, but then
19 we also, as an example, Document 685, have a
20 protective order that was entered with Mr. Scherer's
21 clients. We have, as an example, Document 715 that
22 pertains to MS Capital, and on and on.
23 So, in any event, what we realized is
24 the case with respect to the Epstein vs. Scott
25 Rothstein, Bradley Edwards case, is this is

| + +Page 25 + +1 different. This is not an asset either to the + 2 RRA estate, nor is it really an asset to any + 3 potential creditor of the RRA estate that is + 4 investigating claims that can bring a recovery + 5 that can help in terms of the overall dollars + 6 into either RRA or to a particular creditor on + 7 their individual lawsuits. + 8 The Epstein case, rather, is a lawsuit + 9 between a third party that was being sued by the + 10 Rothstein firm against Rothstein lawyers, and we + 11 had a different privilege issue than we had + 12 focused on with all these other document + 13 productions. + 14 So we get the 6,000 e-mails, and on the + 15 eve of one of my colleagues getting ready to + 16 enter into -- either enter into one of these + 17 protective orders or say, here, take them, like + 18 we've done with everybody else, we looked up and + 19 Mr. Stettin and I said, time out. We have a + 20 legitimate privilege issue here. + 21 And I want to be clear, we don't want + 22 to come anywhere close to stepping in the mess of + 23 waiving attorney/client privilege, unless and + 24 until the Court tells us to, and I want to also + 25 be clear, we wish we weren't here. We would + +Page 26 + +1 prefer not to have a fight on any of this stuff + 2 and on one hand, we don't care who does the + 3 privilege log and who gets the documents, and on + 4 the other hand, because of some things that + 5 Mr. Scherer just commented on, that I learned + 6 literally today, and because of the common + 7 interest agreement that everybody knows we have + 8 with Mr. Scherer and the committee, in some + 9 respects, I don't think it prudent for me to + 10 discuss why I would want to look at some of those + 11 documents. + 12 But be that as it may, we found that + 13 there were 6,000 e-mails and this was the one + 14 time that rather than go through the usual + 15 protocol of preparing the stipulated protective + 16 order that is effectively a mirror image of that + 17 which is provided by Federal Rule of Evidence + 18 502, we said there is a need for a real privilege + 19 log here. + 20 There are 6,000 e-mails, give or take, + 21 and we quickly assessed that the time to review + 22 6,000 e-mails, this could not be done by a + 23 paralegal, it would have to be done by a lawyer. + 24 THE COURT: Does this include Qtask or is + 25 this in addition to? + +Page 27 + +1 MR. LICHTMAN: Qtask is not part of this + 2 equation as of right now. Now, it may be, and we're + 3 still trying to get that. I'm just talking about + 4 internal e-mails where we would put in a name search, + 5 give it to the Berkowitz firm and say, run an e-mail + 6 search on the following names. + 7 And when we realized the volume of + 8 work, and you can imagine, you know, like from a + 9 ream of paper, 500 sheets of paper, and you + 10 multiply that out and you get to 12 reams of that + 11 paper, it takes up a lot of paper, it takes up a + 12 tremendous amount of time. This is not an asset + 13 of the estate that we can, if we have to, warrant + 14 doing the work, the hard work, as we've done on + 15 many of the other claims, some of which already + 16 are before you for settlement purposes. This is + 17 a liability to the estate and an expensive one. + 18 So we really didn't want to go through + 19 the undertaking of having to protect the + 20 privilege, though we would, and candidly, + 21 Epstein's counsel has said we'll pay you to do + 22 it, but then there's also the manpower issue + 23 because we are pressed very hard to get certain + 24 adversaries moving as quickly as we can and we're + 25 fighting a lot of battles on a lot of different + +Page 28 + +1 grounds, we still really don't want to do that, + 2 and also because we don't know the Epstein case + 3 well enough to be able to assess what is + 4 privileged, what is not, and preparing a + 5 privilege log the proper way is really a time + 6 consuming mess. + 7 So I teed it up for both sides and + 8 said, here's what I'm willing to do. Putting + 9 aside the issue as to really whether or not the + 10 Court does have jurisdiction on a State Court + 11 subpoena, which ultimately I leave to you, we + 12 said, we're still willing to enter into a + 13 modified version of the protective order that we + 14 gave to you, which effectively provides the + 15 additional language of no claims can be brought + 16 against Mr. Stettin or the estate if we produce + 17 these documents. + 18 We don't really have a bone to pick in + 19 this mess, we just want to make sure that we + 20 follow all of the ethical boundaries required by + 21 Florida law, by rules of professional conduct. + 22 We don't wish to necessarily waive somebody + 23 else's privilege. We don't think that's + 24 necessarily prudent, but we really don't want to + 25 have a fight in this battle, and we wanted the + +Fn. 29 + +Court to approve — whatever it is you want us to do, to tell you the truth, were happy to do. We just want to make sure that Mr. Stettin is personally insulated and that the estate is insulated in whatever it Is — THE COURT: All I see is — MR. LICHTMAN: you direct a THE COURT: — the potential of a claim against Stettin and the estate for breach of the attorney/oilcan privilege. MR. LICHTMAN: correct. THE COURT: So the basis — MR. LiCHTMAN: And hence the dilemma. THE COURT: — for the claim Is there. MR. LICITIMAN: Yeah, right, hence the dilemma. Now we come to the issue of hard documents because the o-malls are one thing, and I had anumber of conversations candidly with Ms. Sanchez, where I think that we had told her originally we had heard there were, as an example, some loan files or transaction files related to Pont deals related to Mr. Epstein, because I remember myself even hearing that going back many, many, many months ago. + +Pate SI + +they had been counsel for LM and others in litigation respecting Epstein, and that we assumed that they would have been files they would mom and B, because at the time that this matter on the subpoena came before the State Court judge, we stood outside the courtroom and here's what happened. I was effectively going to tell the State Court judge basically the same story I've told you in complete detail and say, we don't really care. We just want to make sure Mr. Stettin Is protected and the estate is protected. And we bad reached an agreement that day, which was we were going to turn over the boxes to Mr. Farmer's firm and we were going to give e-mails to them, and they were going to do the privilege log because that would save us a ton of time, Important time, and as important, a lot of money to the estate, and we did not wish to burden the creditors of the estate with legal fees for putting together the privilege log, so it was agreed that we would do that. I, personally, reiterated the terms to all the lawyers that were standing outside the courtroom, as to what was to be reflected in a + +Pay 10 + +Suffice it to say, that I have conducted a very thorough discussion, without waiving our internal privileges or work product, and we can't find those, and it appears as if they really did not exist, that what had occurred is that somehow Epstein was listed on asheet for a potential deal that never closed. In terms of the ten boxes of documents, one of the functions the trustee served early on in the case was to facilitate transfers of II files - THE COURT: 1 remember that. I3 MR. LICHTMAN: — from two attorneys that were handling cases. All right. I had a general understanding that most of the files were picked up by the Farmer firm because they were continuing on with that litigation, and that would have made some sense, but Then wo had also heard that there were some boxes that were left behind. I believe there are two boxes, I'm not positive of that, two boxes I think that we may still have, and I'm pretty sure we've sent a-mails a couple of times to the Farmer firm saying, come get your documents. Now, why would we do that? A, because + +Pate 32 + +I written order because I didn't want to leave it to dame as to what was agreed on. Suffice it to say, when the lawyers for Mr. Epstein and the lawyers for Mr. Edwards went back to try to reduce to writing that which was in part agreed upon outside the courtroom, they '1 were unable to do so, and that teed up the filing of the motion before you to compel us to produce the e-mails and the document. I wish to reiterate, 1 think that II Mr. Scherer has shared something with me that we need to investigate and will, and 1 was unaware of that literally until 1 rode up the elevator with him this morning. And I don't wish to spend more time on It than that right now, but I take him at his word because an awful lot of whet I've seen him work on so far has borne fruk. I don't care what you want us to do. All 1 want to Irnow is that at the end I can walk out of court with an order that protects the estate and protects Mr. Stettin. So I have told you the story and leave it to you to fashion what remedy you think appropriate. If 1 can answer any questions, I'm happy to. + +Paso 33 THE COURT: Well, the trustee knows what the trustee has, obviously. MR. LICIITMAN: Yes. THE COURT: So the trustee is capable of preparing a log of what he has. MR. LICHTMAN: Meaning we have the following data. THE COURT: Yes. MR. LICHTMAN: Yes, we can do that. THE COURT: Then the parties can then argue whether or not that is subject to privilege. The plaintiff can still get from Mr. Farmer and his clients in the State Court discovery. The discovery being sought here is born the trustee MR. LICHTMAN: Correct. THE COURT: and would be subject to the trustee's responsibility for the privilege log because of his potential liability. MR. LICHTMAN: Yes, and I think you understand, though, why if we can somehow deflect that responsibility, because of the extreme amount of cost and time to do that, we would be happy to do that because, you know, otherwise, we submit fee petitions that show a tremendous amount of time on something that doesn't produce an asset to the + +Page 35 MR. FARMER: Yes, your Honor. Just very briefly. I thank you for the opportunity to address the Court again. !just wanted to clear something up, your Honor. Understand that when this all happened, there were six of us now who are partners, who had dozens and dozens of on-going cases. THE COURT: ! remember we held hearings and I authorized the Mateo — MR. FARMER.: And you authorized, yes. THE COURT: — to deliver the information so the lawyers could continue to represent the clients. MR. FARMER: kiwi seemed to be maybe suggested hero today that something untoward occurred as far as the removal of these boxes. These were litigation files, pleadings, investigative reports, all of these things. So we needed to get on with those cases, but I think you've heard now from the =tee that this is not an asset and it is an expense. I still think that we arc the party who should prepare this privilege log. We arc most familiar — THE COURT: Well, no, if I appoint a special neuter, you will have an input into that + + Pee 34 estate, just a liability. THE COURT: Rigs. This is not an asset of the estate. MR. LICHTMAN: No, its just aliability. THE COURT: But could be a substantial liability. MR. LICHTMAN: Hence the dilemma. THE COURT: Well, I can appoint a special master to do it at the expense of the movant end not release the information until the special master reports back to me and I authorize the release. What I propose to do by my authorizing the release — I'm sorry, Stettin, as trustee, to release the information, I would, therefore, be protecting the estate from any claims for the release of that information. MR. LICHTMAN: We would be happy to do that, your Honor, and I note, I don't wish to speak for the Epstein lawyers, they actually offered to pay time for us doing that, end 1 said, well, you know, that's pert of the equation, the other part is — THE COURT: No, no, no, I can appoint a special master. MR. LICHTMAN: Yes. THE COURT: All right. Mr. Fanner. + + Is 27. ►qe **36 special master and you'll have an opportunity to be heard before me before I authorize the release of the inforrnation, because ultimately the order that's going to authorize the release of the In fon nation is going to provide protection to the trustee and the estate. MR. FARMER: And, thank you, Judge, I iota wanted to make sure, and I was going to request, that we have an opportunity to review whatever the master does and if we think they've missed a privilege or are wrong in an assertion, that we have an opportunity to address that. THE COURT: There is going to be a hearing before the information gets released. MR. FARMER: Understood. Thank you, your Honor. THE COURT: All right. Mr. Lichtrnan — MR. LICHTMAN: Yes. THE COURT: — I want you to prepare the order. I'm going to continue the hearing on the two motions, Docket Entry 807 and 819, and I'm going to have you draft an order appointing a special master, the expense of which will be borne by the Epstein movants. The special master will meet with both sides, Epstein and Edwards, and then with the** + +Pan 37 Rte 39 + +trustee, and will prepare aprivilege log, the 1 release of which will be noticed for hearing in front 2 of me. 3 CERTIFICATION MR. LICHTMAN: Do I pick the special master 4 or do you? 5 STATE OF FLORIDA: THE COURT: You con - if you all can —1 6 hate to use the word agree, but If you all can agree, i 1, Margaret and Reporter that's fine. If you can% agree, give me three names 9 and Notary Public in and for tae State of Florida to choose from. 10 at Large, do hereby certify that the (ongoing MR. LICHTMAN: Okay. II proceedings were date and taken before me at THE COURT: You're going to have to check 12 place as stated in the caption hurt° on Pagel; with this, quote, 'special master" to make sure they 13 that the (ongoing computer-aided transcription is have the time to review the privilege log. 14 a true record of my stenographic notes taken at said MR. LICHTMAN: The documents. IS proceedings. THE COURT: And it has to be somebody that I6 WITNESS my hand this 5th day of doesn't have aconflict of interest. 17 August, 2010. MR. LICHTMAN: Right Okay. 18 THE COURT: All right. Run the order by 20 Mr. NeiwIrth and Mr. Fanner. Margaret Franzen MR. LICHTMAN: Thank you. 21 Court Reporter and Notary Public MR. FARMER: Thank you, your Honor. In and for the State of Florida at lap MR. NEIWIRTH: Your Honor, may it please 22 My Commission Expires: April 14, 2014 the Court? 23 THE COURT: Yes. 24 MR. NEIW1R114: Can we say something about 25 + +COUNTY OF DARE: + +toed + +Roe 38 + +the time frame because as we sit here right now we still have a trial coming in October. THE COURT: Well, I understand that, but I probably have between five and 6,000 active cases right now and within the Rothstein case, I don't even know bow many adversaries and contested matters are pending. III get to it as soon as I can. But you can proceed to obtain the information from Edwards and LM in the State Court proceeding. All I'm governing Is what the II trustee Is going to release from the debtor estate. All right. Mr. Lichtman, see to the order. MR. EDWARDS: Thank you, your Honor. MR. FARMER: Thank you for your time, your Honor. MR. =WIRTH: Thank you, Judge. 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b/marker2/ds9/EFTA00206624/_page_0_Picture_4.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..231d3f49e5fe9401e77f53caf7486812cac0c9ef --- /dev/null +++ b/marker2/ds9/EFTA00206624/_page_0_Picture_4.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:0e62c43b6ad65b70390873010b69e1094f5ada57c2e6959478dca64d0fc01ce4 +size 13324 diff --git a/marker2/ds9/EFTA00206634/EFTA00206634.md b/marker2/ds9/EFTA00206634/EFTA00206634.md new file mode 100644 index 0000000000000000000000000000000000000000..cdf495fb741b04c7e17357a2fe261970fdd92e00 --- /dev/null +++ b/marker2/ds9/EFTA00206634/EFTA00206634.md @@ -0,0 +1,17 @@ +From: To: + +Subject: Out of Office AutoReply: Jeffrey Epstein + +Date: Thu, 02 Sep 2010 21:44:55 +0000 + +lmportance: Normal + +I will be out of the office from September 2 -10, 2010. 1 will be back in the office on Monday, September 13, 2010. If this is a press matter and you need immediate attention, please contad the following AUSAs: + +September 2 and 3, 2010: + +Sepgtember 7-10, 2010: + +Othenvise, 1 will reply to your cm:ni whcn I retum to the office on Monday, September 13, 2010. Thank you and have a nice day. + +Estare fuera de la oficina desde el 2 al 10 de septiembre. Si se trata de un asunto de prensa, favor de comunicarse con los fiscales anotados anteriormente. 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I have replied the same to both. + +**From:** [REDACTED] + +**Sent:** Thursday, July 29, 2010 1:33 PM + +**To:** 'Reeve, Elle' + +**Cc:** [REDACTED] + +**Subject:** RE: Request for Official Comment on an Investigation + +Hi Elle. + +Thank you for your email. The USAO cannot comment. It is against DOJ and USAO Guidelines to either confirm or deny the existence of any investigation. Thank you for checking with me. + +![](_page_0_Picture_156.jpeg) + +**From:** Reeve, Elle [mailto:[REDACTED]] + +**Sent:** Thursday, July 29, 2010 12:19 PM + +**To:** [REDACTED] + +**Subject:** Request for Official Comment on an Investigation + +Hello [REDACTED] + +My name is Elle Reeve and I'm a fact-checker with the news website [The Daily Beast](#). We're running an article stating that the FBI has re-opened an investigation into Jeffrey Epstein, that the investigation has been widened to include Epstein's associate Jean Luc Brunel plus Brunel's modelling agency, and that investigators are looking for evidence of child trafficking. 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Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +## U.S. District Court + +## Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered by Edwards, Bradley on 9/13/2010 at 10:09 AM EDT and filed on 9/13/2010 + +Case Name: Doe I Epstein Case Number: 9:08-cv-80893-KAM + +Filer: Bradley J. Edwards + +WARNING: CASE CLOSED on 07/20/2010 + +Document Number: 217 + +## Docket Text: + +RESPONSE to Motion re [214] Defendant's MOTION for Protective Order and Objection to Disclosure of Certain Documents with Integrated Memorandum of Law MOTION for Leave to File filed by Bradley J. Edwards. Replies due by 9/23/2010. (Edwards, Bradley) + +9:08-cv-80893-ICAM Notice has been electronically mailed to: + +Bradley James Edwards + +Jack Alan Goldberger • + +Katherine Warthen Ezell + +Lilly Ann Sanchez + +Michael James Pike + +9:08-cv-80893-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +The following document(s) are associated with this transaction: + +Document description:Main Document + +Original filenamem/a + +Electronic document Stamp: + +[STAMP dcecfStamp\_IL 1105629215 [Date=9/13/2010] [FileNumber=7989596-0 ] [5ee04dc71296e680d86f9b8f61671 eel4ab8995228bIbfed8b561016df00766d1b1 26b00b4c9b631O70a29138713bfl8c9ed63367b8ee448c4e1280c8a8ccca]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00206637/EFTA00206637.metadata.json b/marker2/ds9/EFTA00206637/EFTA00206637.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1ff1112f1c94f3ba5df05c66a88b5084af470d35 --- /dev/null +++ b/marker2/ds9/EFTA00206637/EFTA00206637.metadata.json @@ -0,0 +1,181 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206637.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2156, + "elapsed_seconds": 1.42, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "U.S. District Court", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 253.98, + 257.58 + ], + [ + 357.4490966796875, + 257.58 + ], + [ + 357.4490966796875, + 273.3170166015625 + ], + [ + 253.98, + 273.3170166015625 + ] + ] + }, + { + "title": "Southern District of Florida", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 231.33599999999998, + 284.31 + ], + [ + 380.6522216796875, + 284.31 + ], + [ + 380.6522216796875, + 298.81707763671875 + ], + [ + 231.33599999999998, + 298.81707763671875 + ] + ] + }, + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 31.212, + 309.42 + ], + [ + 185.391357421875, + 309.42 + ], + [ + 185.391357421875, + 323.9470520019531 + ], + [ + 31.212, + 323.9470520019531 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 31.212, + 452.79 + ], + [ + 101.52233123779297, + 452.79 + ], + [ + 101.52233123779297, + 466.8170471191406 + ], + [ + 31.212, + 466.8170471191406 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 69 + ], + [ + "Line", + 35 + ], + [ + "Text", + 20 + ], + [ + "SectionHeader", + 4 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 20 + ], + [ + "Line", + 10 + ], + [ + "Text", + 6 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206637" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206639/EFTA00206639.md b/marker2/ds9/EFTA00206639/EFTA00206639.md new file mode 100644 index 0000000000000000000000000000000000000000..7882b0e3c05626b621462908ad94bee32b7cb50b --- /dev/null +++ b/marker2/ds9/EFTA00206639/EFTA00206639.md @@ -0,0 +1,47 @@ +From: ' To:" + +Subject: Activity in Case 9:08-cv-80893-KAM Doe I Epstein Clerks Notice of Docket Correction and Instruction to Filer - Attorney + +Date: Tue, 07 Sep 2010 13:36:30 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered on 9/7/2010 at 9:36 AM EDT and filed on 9/7/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80893-1CAM + +Filer: + +WARNING: CASE CLOSED on 07/20/2010 + +Document Number: 216(No document attached) + +## Docket Text: + +Clerks Notice to Filer re [214] Defendants MOTION for Protective Order and Objection to Disclosure of Certain Documents with Integrated Memorandum of Law MOTION for Leave to File. Motion with Multiple Reliefs Filed as One Relief; ERROR - The Filer selected only one relief event and failed to select the additional corresponding events for each relief requested in the motion. The docket entry was corrected by the Clerk. It is not necessary to refile this document but future filings must comply with the instructions in the CM/ECF Attorney User's Manual. (tp) + +9:08-cv-80893-KAM Notice has been electronically mailed to: + +Bradley James Edwards + +Jack Alan Goldberger f + +Katherine Warthen Ezell + +Paul G. Cassell + +Robert Deweese Critton , Jr + +9:08-cv-80893-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. 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Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered by Sanchez, Lilly Ann on 9/2/2010 at 4:14 PM EDT and filed on 9/2/2010 + +Case Name: Doe I Epstein + +Case Number: 9:08-cv-80893-KAM + +Jeffrey Epstein + +WARNING: CASE CLOSED on 07/20/2010 + +Document Number: 213 + +## Docket Text: + +Defendant's MOTION for Hearing Jeffrey Epstein's Request for Oral Argument in Connection with his Motion for Protective Order and Objection to Disclosure of Certain Documents by Jeffrey Epstein. (Sanchez, Lilly Ann) + +9:08-cv-80893-ICAM Notice has been electronically mailed to: + +Ann Marie C. Villafana ann marie.c.villafana@usdoj.gov, shawn.ball®usdoj.gov + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Jack Alan Goldberger jagesq®bellsouth.net, nalanis®agwpa.com + +Katherine Warthen Ezell KEzell@podhurst.com, mestrada@podhurst.com + +Lilly Ann Sanchez Isanchez@fowler-white.com + +Michael James Pike MPike@bciclaw.com, bobbie@bciclaw.com, jcadwell@bciclaw.com + +9:08-cv-80893-1CAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +The following document(s) are associated with this transaction: + +Document description:Main Document + +Original filenamem/a + +Electronic document Stamp: + +[STAMP dcecfStamp\_1E 1105629215 [Date=9/2/2010] [FileNumber=7962310-0) + +[2a54ecbd12801fc9122023184861f454ffb0e5c6cd08060c4a540355d9c9lbdf39a5 + +d2d4c22198a98acdd7fd821112467a519483e6f997e7288824748ae81d09]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00206641/EFTA00206641.metadata.json b/marker2/ds9/EFTA00206641/EFTA00206641.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f92f1d6ed5a6e8acfb3f68fd9f5c7d9e8110d2ac --- /dev/null +++ b/marker2/ds9/EFTA00206641/EFTA00206641.metadata.json @@ -0,0 +1,135 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206641.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2467, + "elapsed_seconds": 1.23, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 308.61 + ], + [ + 184.74722290039062, + 308.61 + ], + [ + 184.74722290039062, + 324.23358154296875 + ], + [ + 30.6, + 324.23358154296875 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 438.21000000000004 + ], + [ + 101.52233123779297, + 438.21000000000004 + ], + [ + 101.52233123779297, + 453.3170471191406 + ], + [ + 30.6, + 453.3170471191406 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 76 + ], + [ + "Line", + 35 + ], + [ + "Text", + 25 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 20 + ], + [ + "Line", + 10 + ], + [ + "Text", + 8 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206641" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206643/EFTA00206643.md b/marker2/ds9/EFTA00206643/EFTA00206643.md new file mode 100644 index 0000000000000000000000000000000000000000..a86df05bcb2b4f8783268c474b4aec911146c437 --- /dev/null +++ b/marker2/ds9/EFTA00206643/EFTA00206643.md @@ -0,0 +1,41 @@ +**To:** [REDACTED] + +**Cc:** [REDACTED] + +**Subject:** FW: Jeffrey Epstein + +**Date:** Fri, 30 Jul 2010 18:23:14 +0000 + +**Importance:** Normal + +--- + +HI [REDACTED] – I am forwarding your email to the AUSA and FBI for response. I told the reporter to call you, as he was talking about a DOJ investigation. + +Re DSFL, I told him we neither confirm nor deny..... + +[REDACTED] – please fill in [REDACTED] + +Thanks + +[REDACTED] + +--- + +**From:** [REDACTED] + +**Sent:** Friday, July 30, 2010 1:57 PM + +**To:** [REDACTED] + +**Subject:** Jeffrey Epstein + +Any idea if its true that there is an ongoing investigation? CNN just called and if this is completely untrue, I want to wave them off reporting that he is under investigation (without of course actually confirming or denying the existence thereof.) + + + +[REDACTED] +*Office of Public Affairs* +*Department of Justice* + +[REDACTED] \ No newline at end of file diff --git a/marker2/ds9/EFTA00206643/EFTA00206643.metadata.json b/marker2/ds9/EFTA00206643/EFTA00206643.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..fabd661cd20246de179bc4315e7ca5076884d40d --- /dev/null +++ b/marker2/ds9/EFTA00206643/EFTA00206643.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206643.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 985, + "elapsed_seconds": 5.04, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 43 + ], + [ + "Text", + 37 + ], + [ + "Line", + 21 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206643" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206644/EFTA00206644.md b/marker2/ds9/EFTA00206644/EFTA00206644.md new file mode 100644 index 0000000000000000000000000000000000000000..21f32b60a23f0838f4200695f3142a8a196077f9 --- /dev/null +++ b/marker2/ds9/EFTA00206644/EFTA00206644.md @@ -0,0 +1,103 @@ +From: "cmecfautosender@flsd.uscourts.gov" + +To: "flsd\_cmecf notice®flsd.uscourts.gov" + +Subject: Activity in Case 9:08-cv-80893-KAM Doe 1 Epstein Motion for Protective Order + +Date: Thu, 02 Sep 2010 20:20:39 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered by Sanchez, Lilly Ann on 9/2/2010 at 4:20 PM EDT and filed on 9/2/2010 + +Case Name: Doe I Epstein + +Case Number: 9:08-cv-80893-KAM + +Filer: Jeffrey Epstein + +WARNING: CASE CLOSED on 07/20/2010 + +Document Number: 214 + +## Docket Text: + +Defendant's MOTION for Protective Order and Objection to Disclosure of Certain Documents with Integrated Memorandum of Law by Jeffrey Epstein. (Attachments: # (1) Exhibit Joint Stipulation, # (2) Exhibit Notice of Intent to Use, # (3) Exhibit Transcript, # (4) Exhibit Order) (Sanchez, Lilly Ann) + +9:08-cv-80893-KAM Notice has been electronically mailed to: + +![](_page_0_Picture_19.jpeg) + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Jack Alan Goldberger jagesq@bellsouth.net, nalanis®agwpa.com + +Katherine Warthen Ezell KEzell@podhurst.com, mestrada@podhurst.com + +Lilly Ann Sanchez Isanchez@fowler-white.com + +Michael James Pike MPike@bciclaw.com, bobbie@bciclaw.com, jcadwell@bciclaw.com + +**9:08-cv-80893-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.:** + +The following document(s) are associated with this transaction: + +**Document description:**Main Document + +**Original filename:**n/a + +**Electronic document Stamp:** + +[STAMP dcecfStamp\_ID=1105629215 [Date=9/2/2010] [FileNumber=7962354-0] +[14676a51ceedd27e31ae77d88d074577deb251aea23deb381936eefa34e8b0c7ac95 +df85baca182ae13f38007003e0299962b98e5c5b2c9c61659036d0a26e93]] + +**Document description:**Exhibit Joint Stipulation + +**Original filename:**n/a + +**Electronic document Stamp:** + +[STAMP dcecfStamp\_ID=1105629215 [Date=9/2/2010] [FileNumber=7962354-1] +[762b0221cff9c114bc71e6240c6ed256913579ebec9d43d552964704b687ac9d9e28 +598fc5dbd3e86673c3b2cc2a97ba3ca6dc5d4b9cb4f482e1f2262a386ac0]] + +**Document description:**Exhibit Notice of Intent to Use + +**Original filename:**n/a + +**Electronic document Stamp:** + +[STAMP dcecfStamp\_ID=1105629215 [Date=9/2/2010] [FileNumber=7962354-2] +[88032a009b58fa73f46b74677ebffa6dbf1599e3df4fdafc614bc621029f8f1ef58e +c754418557e5aad2c56b12a482b91c6512254ce6a33a56a9936dd0af0a55]] + +**Document description:**Exhibit Transcript + +**Original filename:**n/a + +**Electronic document Stamp:** + +[STAMP dcecfStamp\_ID=1105629215 [Date=9/2/2010] [FileNumber=7962354-3] +[066ef955bab0fcdc7bbdd3ab737728d21deedcb451d004197c08013e111269ff4ae43 +193241173cc058199e5e9e54792a32726b44a6c692855098f3d3cc60477b]] + +**Document description:**Exhibit Order + +**Original filename:**n/a + +**Electronic document Stamp:** + +[STAMP dcecfStamp\_ID=1105629215 [Date=9/2/2010] [FileNumber=7962354-4] +[620c5c4cf5b0e2cfd2c7d1a79a9b07bfddea057bd4f2dfccda73364985aef5c3b0f3 +b25b6510e345f93a81eb636dbbd8bfeaeba47530679830e193dd56b50af]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00206644/EFTA00206644.metadata.json b/marker2/ds9/EFTA00206644/EFTA00206644.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e5d2260aea57c425c8b641058a6df5e654ae96d1 --- /dev/null +++ b/marker2/ds9/EFTA00206644/EFTA00206644.metadata.json @@ -0,0 +1,133 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206644.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 3883, + "elapsed_seconds": 7.33, + "image_assets": [ + "_page_0_Picture_19.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 308.61 + ], + [ + 184.7442169189453, + 308.61 + ], + [ + 184.7442169189453, + 324.363037109375 + ], + [ + 30.6, + 324.363037109375 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 438.21000000000004 + ], + [ + 101.648193359375, + 438.21000000000004 + ], + [ + 101.648193359375, + 453.7330322265625 + ], + [ + 30.6, + 453.7330322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 73 + ], + [ + "Line", + 35 + ], + [ + "Text", + 24 + ], + [ + "SectionHeader", + 2 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 44 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206644" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206644/_page_0_Picture_19.jpeg b/marker2/ds9/EFTA00206644/_page_0_Picture_19.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..d1870d409cd3c046565243db8a0da7d3a3cadf61 --- /dev/null +++ b/marker2/ds9/EFTA00206644/_page_0_Picture_19.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:38ae798d57cf7b8eb349733de5664839670563b9b79c0bb443c35046bda112bc +size 7022 diff --git a/marker2/ds9/EFTA00206646/EFTA00206646.md b/marker2/ds9/EFTA00206646/EFTA00206646.md new file mode 100644 index 0000000000000000000000000000000000000000..ad6b14d9dda57ac7867b782cdf8d416ee8aff01d --- /dev/null +++ b/marker2/ds9/EFTA00206646/EFTA00206646.md @@ -0,0 +1,53 @@ +To: + +Cc: + +Subject: RE: Jeffrey Epstein + +Date: Fri• 30 Jul 2010 19:32:14 +0000 + +Importance: Normal + +Thanks guys - all very helpful. I'll tell Ewe don't confirm or deny investigations but off the record caution him about mirroring this daily beast story. + +From: + +Sent: Friday, July 30, 2010 3:29 PM + +To: Sweeney, Laura; + +Cc: + +Subject: RE: Jeffrey Epstein + +I just talked to SAI I who has the Epstein case out of our West Palm Beach office. He advised that recently he met with the civil attorney Brad Edwards who is handling the lawsuits filed by several girls against Epstein. He said he might have information regarding lean Luc Brunel and his modeling agency, but we are waiting for him to provide the name of a victim, if there are any that want to come forward or any information that might lead to a spin off case. As of today, we do not have an open case on Brunel. Thanks. + +From: + +Sent: ppm imumi + +To • + +Cc + +Subject: FW: Jeffrey Epstel + +HI Laura — I am forwarding your email to the AUSA and FBI for response. I told the reporter to call you, as he was talking about a DOJ investigation. + +Re DSFL, I told him we neither confirm nor deny + +— please fill in Laura. + +From: Sweeney, Laura (SMO) + +Sent: Friday, July 30, 2010 1:57 PM + +To: + +Subject: Jeffrey Epstein + +Any idea if its true that there is an ongoing investigation? CNN just called and if this is completely untrue, I want to wave them off reporting that he is under investigation (without of course actually confirming or denying the existence thereof.) + +Laura E. Sweeney Office of Public Affairs Department of Justice + +![](_page_1_Picture_1.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00206646/EFTA00206646.metadata.json b/marker2/ds9/EFTA00206646/EFTA00206646.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..767f509e66e72e2f8ac92e9ffa0fabf23c99e191 --- /dev/null +++ b/marker2/ds9/EFTA00206646/EFTA00206646.metadata.json @@ -0,0 +1,90 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206646.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1606, + "elapsed_seconds": 1.39, + "image_assets": [ + "_page_1_Picture_1.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 78 + ], + [ + "Line", + 35 + ], + [ + "Text", + 29 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 7 + ], + [ + "Line", + 4 + ], + [ + "Text", + 1 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206646" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206646/_page_1_Picture_1.jpeg b/marker2/ds9/EFTA00206646/_page_1_Picture_1.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..09e5dcedd0ae02fe15de8b67a93007681d23dd62 --- /dev/null +++ b/marker2/ds9/EFTA00206646/_page_1_Picture_1.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:9251366e5b0f5fbe26485fb4a59189ecc51c495a9e375aeba164a72aaa8e9714 +size 2079 diff --git a/marker2/ds9/EFTA00206648/EFTA00206648.md b/marker2/ds9/EFTA00206648/EFTA00206648.md new file mode 100644 index 0000000000000000000000000000000000000000..e2702f31be5f1ec5c2d83e2c4ecab135a5116b7a --- /dev/null +++ b/marker2/ds9/EFTA00206648/EFTA00206648.md @@ -0,0 +1,59 @@ +To: "flsd\_cmecf notice®flsd.uscourts.gov" + +Subject: Activity in Case 9:08-cv-80893-ICAM Doe 1 Epstein Order + +Date: Wed, 20 Oct 2010 17:10:29 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CIVUECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered on 10/20/2010 at 1:10 PM EDT and filed on 10/20/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80893-KAM + +Filer: + +WARNING: CASE CLOSED on 07/20/2010 + +Document Number: 222 + +## Docket Text: + +ORDER re [220] Appeal of Magistrate Judge Order [218] to District Court, filed by Jeffrey Epstein. The Magistrate's Order is set aside and this case is REMANDED to the Magistrate Judge for further proceedings consistent with the directives of this Order. Signed by Judge Kenneth A. Marra on 10/20/2010. (ir) + +9:08-cv-80893-KAM Notice has been electronically mailed to: + +Ann Marie C. Villafana ann.marie.c.villafana@usdoj.gov, shawn.ball®usdoj.gov + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Jack Alan Goldberger jagesq@bellsouth.net, nalanis®agwpa.com + +Katherine Warthen Ezell KEzell@podhurst.com, mestrada@podhurst.com + +Lilly Ann Sanchez Isanchez@fowler-white.com + +Michael James Pike MPike@bciclaw.com, bobbie@bciclaw.com, jcadwell@bciclaw.com + +9:08-cv-80893-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +The following document(s) are associated with this transaction: + +Document description:Main Document + +Original filenamem/a + +Electronic document Stamp: + +[STAMP dcecfStamp\_11: 1105629215 [Date=10/20/2010] [FileNumber=8117157- 0] [75488d8aa92aafce2dbeb7dece4cbf8a4e92a8006eeb53bca5531528c2a59b4022 69a744bcf005f542c125530525dde3b7a45c0c766c4f5844718853a1c7bf4d]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00206648/EFTA00206648.metadata.json b/marker2/ds9/EFTA00206648/EFTA00206648.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..8c5660558400c576d7d5379b441ce7a24fd4bf73 --- /dev/null +++ b/marker2/ds9/EFTA00206648/EFTA00206648.metadata.json @@ -0,0 +1,135 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206648.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2522, + "elapsed_seconds": 1.25, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 308.61 + ], + [ + 184.74722290039062, + 308.61 + ], + [ + 184.74722290039062, + 324.23358154296875 + ], + [ + 30.6, + 324.23358154296875 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 438.21000000000004 + ], + [ + 101.65031433105469, + 438.21000000000004 + ], + [ + 101.65031433105469, + 453.6035461425781 + ], + [ + 30.6, + 453.6035461425781 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 73 + ], + [ + "Line", + 36 + ], + [ + "Text", + 25 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 20 + ], + [ + "Line", + 10 + ], + [ + "Text", + 6 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206648" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206650/EFTA00206650.md b/marker2/ds9/EFTA00206650/EFTA00206650.md new file mode 100644 index 0000000000000000000000000000000000000000..63ec71159f0ba65493e37e30b722e54778b68f4a --- /dev/null +++ b/marker2/ds9/EFTA00206650/EFTA00206650.md @@ -0,0 +1,20 @@ +![]()**Date:** Thu, 21 Oct 2010 18:05:42 +0000 + +**Importance:** Normal + +--- + +Interviews have been conducted of potential new victims. Let me check in with the case agent and get back to you. + +![]()**Sent:** Thursday, October 21, 2010 2:00 PM + +![]()**Subject:** Fw: current status of new criminal investigation + +![]()![]()![]()![]()As you know, Mike Fisten and others met with representatives from the FBI in about late July of this year to provide information to the FBI about Epstein's sexual abuse of other young girls – girls not covered by the non-prosecution agreement. At the conclusion of the meeting, the agents said that they would investigate further and get back to us. I am writing to ask: + +1. (1) What is the current status of that investigation; +2. (2) What can be said about the current status in our pleading – as you know, one of the reasons we did not file something more quickly was waiting to hear back from you on the status of this new criminal investigation and whether it would be produce new criminal charges against Epstein. We may want to make reference to that fact in our pleading, but of course do not want to say anything that might jeopardize the Government's new investigation. + +Please advise on these points – thanks for your help. Paul Cassell, Counsel for Jane Doe #1 and Jane Doe #2 + +![](_page_1_Picture_0.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00206650/EFTA00206650.metadata.json b/marker2/ds9/EFTA00206650/EFTA00206650.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..cb62475195729e0b0e9e49aac23a29c9b95a2a70 --- /dev/null +++ b/marker2/ds9/EFTA00206650/EFTA00206650.metadata.json @@ -0,0 +1,90 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206650.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1348, + "elapsed_seconds": 5.66, + "image_assets": [ + "_page_1_Picture_0.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 58 + ], + [ + "Text", + 34 + ], + [ + "Line", + 27 + ], + [ + "ListGroup", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ], + [ + "Line", + 1 + ], + [ + "Span", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206650" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206650/_page_1_Picture_0.jpeg b/marker2/ds9/EFTA00206650/_page_1_Picture_0.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..6c0dfa7941f44b5f752807a6cd977c08169fb2d3 --- /dev/null +++ b/marker2/ds9/EFTA00206650/_page_1_Picture_0.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:3f642e2a8102de46c8eb670b8e8950895c8dedd621b15b5d51a4981c1a319341 +size 18854 diff --git a/marker2/ds9/EFTA00206652/EFTA00206652.md b/marker2/ds9/EFTA00206652/EFTA00206652.md new file mode 100644 index 0000000000000000000000000000000000000000..411a2f504da5d84d870eb2eaaeefd8711cd0a78a --- /dev/null +++ b/marker2/ds9/EFTA00206652/EFTA00206652.md @@ -0,0 +1,19 @@ +To: ' (USAFLS)" + +Subject: RE: Epstein + +Date: Mon, 13 Sep 2010 19:04:50 +0000 + +Importance: Normal + +This is really interesting. They can't get any money out of the U.S. Government since they have not filed a claim under the Federal Tort Claims Act, assuming they could even make a claim that the U.S. Government engaged in tortuous conduct. Their lawsuit for money damages against Epstein has been resolved, so their CVRA action cannot be used as a vehicle to get information to support their other lawsuit. + +Other than trying to heap scorn and abuse on our office, does Brad think he can get the district court to set aside the non-prosecution agreement? Even if that were to occur, the district court could not order our office to prosecute Epstein, since separation of powers precludes that action. What do you think Brad wants? + +From: (USAFLS) Sent: Monde September 13, 2010 2:36 PM To: (USAFLS) Subject: Epstein + +— Don't know if you have been watching CM/ECF, but this just came in today on Jane Does I United States. + +« File: DE39\_20100913\_Notice in response to admin order closing case.pdf » + +Nothing really for us to respond to, yet . . . \ No newline at end of file diff --git a/marker2/ds9/EFTA00206652/EFTA00206652.metadata.json b/marker2/ds9/EFTA00206652/EFTA00206652.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..189c3a5e66a18469acc29d3403cd07948db19d57 --- /dev/null +++ b/marker2/ds9/EFTA00206652/EFTA00206652.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206652.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1146, + "elapsed_seconds": 0.62, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 45 + ], + [ + "Line", + 21 + ], + [ + "Text", + 11 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206652" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206653/EFTA00206653.md b/marker2/ds9/EFTA00206653/EFTA00206653.md new file mode 100644 index 0000000000000000000000000000000000000000..384513879cc8ae2da19018ee947f9522ae6b7809 --- /dev/null +++ b/marker2/ds9/EFTA00206653/EFTA00206653.md @@ -0,0 +1,71 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA + +CASE NO. 08-80736-CIV-MARRA/JOHNSON + +JANE DOES #1 and #2, + +Petitioners, + +1. + +UNITED STATES, + +Respondent. + +/ + +## PETITIONERS JANE DOE #1 AND JANE DOE #2'S NOTICE IN RESPONSE TO ADMINISTRATIVE ORDER CLOSING CASE + +As the Court is aware, this is an action under the Crime Victims' Rights Act (CVRA), 18 U.S.C. § 3771, in which two crime victims, petitioners Jane Doe #1 and Jane Doe #2, allege that the U.S. Attorney's Office violated their rights under the Act by failing to advise them of a plea agreement it had reached with sex offender Jeffrey Epstein. On September 9, 2010, this Court sua sponte entered an administrative order "closing" the case. The basis for this order was "the underlying [civil settlements] between the victims and Mr. Epstein." Order at 1. Jane Doe #1 and Jane Doe #2 hereby give notice that they intend to make subsequent filings in this case shortly. They accordingly request administrative reopening of the case and, if the Court deems it advisable, a scheduling conference with the U.S. Attorney's Office regarding the case. + +Precisely what the effect is of an order administratively closing a case is not immediately clear to Jane Doe #1 and Jane Doe #2. They believe that such an order would automatically lose effect in the event of a subsequent filing. They note that the Court did not dismiss their case. Nonetheless, out of an abundance of caution — and to provide the Court with additional information about the status of the case -- Jane Doe #1 and Jane Doe #2 are filing this brief notice that they will be making subsequent filings shortly. + +The fact that Jane Doe #1 and Jane Doe #2 have settled their civil cases against sex offender Jeffrey Epstein in no way affects their determination to move forward with the above-captioned CVRA action against a different entity — the U.S. Attorney's Office for the Southern District of Florida. For reasons explained in their earlier pleadings, that Office grossly violated their rights under the Act. The fact that Epstein has settled with Jane Doe #1 and #2 to resolve his civil liability in no way exonerates the U.S. Attorney's Office for its failure to discharge its responsibilities under the Act. + +If the Court wishes to proceed to an expeditious conclusion to this case, Jane Doe #1 and Jane Doe #2 have no objection to the Court setting up an expedited schedule for proceeding on the case. The Court should be aware, however, of the reasons why Jane Doe #1 and Jane Doe #2 have not yet filed for summary judgment in this case. + +Jane Doe #1 and Jane Doe #2 have long believed that correspondence between the U.S. Attorney's Office and Jeffrey Epstein would corroborate their argument that the Office had grossly violated their rights under the CVRA. Just two months ago, in connection with their civil case against Epstein, Jane Doe #1 and Jane Doe #2's suspicions were confirmed when their legal counsel received correspondence between Epstein's criminal defense lawyers and the Office proving that the Office had tried to conceal the existence of the plea agreement from them. In addition to the correspondence, Counsel has received other information from witnesses that further strengthens our clients' case under the CVRA. Counsel are now in the process of attempting to move forward on this new information and prove their clients' cases against the Defendant United States and will be filing the appropriate pleadings to do SO. + +In light of all this, Jane Doe #1 and #2 ask that the case be administratively reopened and, if the Court deems it advisable, that a scheduling conference be set for this case. + +DATED: September 13, 2010 + +Respectfully Submitted, + +/s/ Bradley J. Edwards + +Bradley J. Edwards + +![](_page_2_Picture_8.jpeg) + +Paul G. Cassell + +Pro Hac Vice + +332 S. 1400 E. + +Salt Lake City, UT 84112 + +Telephone: 801-585-5202 + +Facsimile: 801-585-6833 + +E-Mail: cassellp@law.utah.edu + +-and- + +Jay Howell, Esq. jay@jayhowell.com Jay Howell & Assoc. 644 Cesery Boulevard Suite 250 Jacksonville, FL 32211 + +## CERTIFICATE OF SERVICE + +I HEREBY CERTIFY that on September 13, 2010 I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day on all parties on the attached Service List in the manner specified, either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those parties who are not authorized to receive electronically filed Notices of Electronic Filing. + +> /s/ Bradley J. Edwards Bradley J. Edwards + +## SERVICE LIST + +Jane Does 1 and 2 I. United States United States District Court, Southern District of Florida Case No. 08-80736-CIV-MARRA/JOHNSON + +Attorney for United States + +![](_page_3_Picture_8.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00206653/EFTA00206653.metadata.json b/marker2/ds9/EFTA00206653/EFTA00206653.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..669b9a45153a02d0029de44dfbf20075df4eaa78 --- /dev/null +++ b/marker2/ds9/EFTA00206653/EFTA00206653.metadata.json @@ -0,0 +1,272 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206653.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 4, + "chars": 4819, + "elapsed_seconds": 1.36, + "image_assets": [ + "_page_2_Picture_8.jpeg", + "_page_3_Picture_8.jpeg" + ], + 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a/marker2/ds9/EFTA00206657/EFTA00206657.md b/marker2/ds9/EFTA00206657/EFTA00206657.md new file mode 100644 index 0000000000000000000000000000000000000000..b9ffaa3f0a44ae130140227219aa7af5e20c4beb --- /dev/null +++ b/marker2/ds9/EFTA00206657/EFTA00206657.md @@ -0,0 +1,37 @@ +From: ' (USAFLS)" + +To: "- (USAFLS)" + +Subject: RE: Epstein + +Date: Mon, 13 Sep 2010 19:07:10 +0000 + +Importance: Normal + +Publicity and scorn, I think. Possibly an internal investigation, although all of the parties, other than myself, are gone. I tracked down my emails to reminding him of our obligations to the victims. There also was a mention in papers about a plan to lobby Congress to revise the victims' rights legislation. + +From: (USAFLS) + +Sent: Monday, September 13, 2010 3:05 PM + +To: -.(USAFLS) + +Subject: RE: Epstein + +This is really interesting. They can't get any money out of the U.S. Government since they have not filed a claim under the Federal Tort Claims Act, assuming they could even make a claim that the U.S. Government engaged in tortuous conduct. Their lawsuit for money damages against Epstein has been resolved, so their CVRA action cannot be used as a vehicle to get information to support their other lawsuit. + +Other than trying to heap scorn and abuse on our office, does Brad think he can get the district court to set aside the non-prosecution agreement? Even if that were to occur, the district court could not order our office to prosecute Epstein, since separation of powers precludes that action. What do you think Brad wants? + +From: (USAFLS) + +Sent: Monde September 13, 2010 2:36 PM + +To: (USAFLS) + +Subject: Epstein + +— Don't know if you have been watching CM/ECF, but this just came in today on Jane Does I United States. + +« File: DE39\_20100913\_Notice in response to admin order closing case.pdf » + +Nothing really for us to respond to, yet . . . \ No newline at end of file diff --git a/marker2/ds9/EFTA00206657/EFTA00206657.metadata.json b/marker2/ds9/EFTA00206657/EFTA00206657.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..173866153b7b3deba302666bce7483b510949bf5 --- /dev/null +++ b/marker2/ds9/EFTA00206657/EFTA00206657.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206657.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1576, + "elapsed_seconds": 0.89, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 65 + ], + [ + "Line", + 30 + ], + [ + "Text", + 19 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206657" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206658/EFTA00206658.md b/marker2/ds9/EFTA00206658/EFTA00206658.md new file mode 100644 index 0000000000000000000000000000000000000000..4dabb57d1e1bd949f63635c671fa315ed21f8e3c --- /dev/null +++ b/marker2/ds9/EFTA00206658/EFTA00206658.md @@ -0,0 +1,41 @@ +To: (USAFLS)" + +Subject: Fw: + +Date: Wed, 25 Aug 2010 15:42:29 —0000 + +Importance: Normal + +So much for lunch. + +From: (USAFLS) + +Sent: Wednesday, August 25, 2010 11:40 AM + +To: .(USAFLS) + +Subject: Re: + +Can you come up at 12:15? Thanks. + +From: (USAFLS) + +Sent: Wednesday, August 25, 2010 10:54 AM + +To: (USAFLS) + +Subject: RE: + +I am here in Miami today. Are you in your office? + +From (USAFLS) + +Sent: Wednesday, August 25, 2010 9:31 AM + +To: (USAFLS) + +Subject: + +Hi Marie, + +I got your voicemail that said you were in meetings so I figured I'd send you an e-mail. Can you call me when you get a chance? I got a strange inquiry from a reporter on Epstein. Thanks. \ No newline at end of file diff --git a/marker2/ds9/EFTA00206658/EFTA00206658.metadata.json b/marker2/ds9/EFTA00206658/EFTA00206658.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..bb26be056efb5e9637780f14070e38015093c98c --- /dev/null +++ b/marker2/ds9/EFTA00206658/EFTA00206658.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206658.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 648, + "elapsed_seconds": 0.99, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 51 + ], + [ + "Line", + 24 + ], + [ + "Text", + 22 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206658" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206659/EFTA00206659.md b/marker2/ds9/EFTA00206659/EFTA00206659.md new file mode 100644 index 0000000000000000000000000000000000000000..2957f613f67166d89cb84dede5fa0432fad1f28b --- /dev/null +++ b/marker2/ds9/EFTA00206659/EFTA00206659.md @@ -0,0 +1,87 @@ +From: ' (USAFLS)" + +To: (USAFLS)" + +Subject: RE: CVRA case + +Date: Tue, 12 Oct 2010 20:49:04 +0000 + +Importance: Normal + +I agree with your statement. I thought that you had framed our initial response to their complaint in terms of "mootness," but your response has reminded me that you didn't say it was moot, just that the Court had no authority to set aside the non-prosecution agreement. + +I will watch CM/ECF while you are at the NAC. + +Assistant U.S. Attorne + +Fax + +From: (USAFLS) + +Sent: Tuesday, October 12, 2010 4:46 PM + +To: . (USAFLS) + +Subject: RE: CVRA case + +A moot case is one where there is no longer any dispute for which the court can grant relief. If their previous conduct is any indication, plaintiffs will probably assert that the CVRA obligated the government to consult with them prior to entering into the non-prosecution agreement. They seem to be resigned to the fact that the court cannot or will not set aside the non-prosecution agreement, since the relief plaintiffs seek is a declaratory judgment. I don't believe we can argue there is no longer any dispute between the parties. + +I agree that plaintiffs' leisurely pace in conducting the litigation has undermined the vitality of their case, but the issue is whether there is still a live controversy between plaintiffs and the government. Plaintiffs will no doubt dispute the government's contention that the court has no authority to grant relief. Moreover, a declaratory judgment is a form of relief. I will take a closer look at the caselaw to determine if we can advance a good faith mootness argument. + +I will be at the NAC next week. I intend to tell Judge Cassell that the government has no objection to stipulating to facts which we agree are correct, but we don't agree plaintiffs are entitled to any relief since we did not violate the CVRA. Please let me know what you think + +Front: (USAFLS) + +Sent Thesda October 12, 2010 4:23 PM + +To: (USAFLS) + +Subject: RE: CVRA case + +.Assistant U.S. Attorney + +Fax + +From: (USAFLS) + +Sent: Tuesday, October 12, 2010 3:58 PM + +To: . (USAFLS) + +Subject: FW: CVRA case + +This is plaintiffs' response to the order to show cause. + +From: Paul Cassell [mailto + +Sent: Tuesda October 12, 2010 3:47 PM + +To: (USAFLS) + +Cc: Brad Edwards + +Subject: CVRA case + +Hi (if I may), + +I believe we have communicated electronically before. As you probably know, I am co-counsel with Brad Edwards on the CVRA case concerning the Epstein (non) prosecution. + +You will have seen Judge Marra's order today asking for us to explain the current situation on the CVRA case by October 23. By October 23, we plan to file a motion asking the court to declare that there were violations of the CVRA. We will be doing that on the basis of a set of fact in the case, of course. + +I am writing to see if you would be interested in working with us on a stipulated set of facts? We will be in a position to give you a set of facts early to middle of next week. Would you be able to look at them quickly and let us know which facts are not dispute? + +Thanks in advance for your cooperation on narrowing the factual issues in this case and any idea for helping the case to progress smoothly. + +Sincerely, + +Paul Cassell + +Counsel for Jane Does + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law + +S.J. Quinney College of Law at the University of Utah + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the sender by reply electronic mail and delete the original message. Thank you. \ No newline at end of file diff --git a/marker2/ds9/EFTA00206659/EFTA00206659.metadata.json b/marker2/ds9/EFTA00206659/EFTA00206659.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..a2749b73c51e818b77964d194d7259ce679e484a --- /dev/null +++ b/marker2/ds9/EFTA00206659/EFTA00206659.metadata.json @@ -0,0 +1,114 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206659.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 3807, + "elapsed_seconds": 1.6, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 77 + ], + [ + "Line", + 34 + ], + [ + "Text", + 28 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 71 + ], + [ + "Text", + 35 + ], + [ + "Line", + 34 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 9 + ], + [ + "Line", + 5 + ], + [ + "Text", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206659" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206662/EFTA00206662.md b/marker2/ds9/EFTA00206662/EFTA00206662.md new file mode 100644 index 0000000000000000000000000000000000000000..56023f38d4e58d4d70d7baea9ccd55dfb3c0818d --- /dev/null +++ b/marker2/ds9/EFTA00206662/EFTA00206662.md @@ -0,0 +1,53 @@ +Subject: Fwd: Google Alert - "jeffrey epstein" + +Date: Wed, 25 Aug 2010 15:21:47 +0000 + +Importance: Normal + +Begin forwarded message: + +From: Google Alerts + +M GMT-04:00 + +Subject: Google Alert - "jeffrey epstein" + +News 4 new results for "jeffrey epstein" + +## Epstein and Saintil: same charges different treatment? + +Palm Beach Post + +... that prosecutors treated him differently from billionaire sex offender Jeffrey Epstein. + +The US Attorney's office should have prosecuted Johnny Saintil.... + +![](_page_0_Picture_13.jpeg) + +Palm Beach Post + +## 3 plead guilty in underage Internet sex ring + +MiamiHerald.com + +... Beach billionaire, Jeffrey Epstein. US District Judge William Zloch disagreed, denying the dismissal motion, which was joined by Wilson and Defrand.... + +## System can't shake this case + +Palm Beach Post + +... prosecutors treated him differently from Palm Beach resident Jeffrey Epstein. The US Attorney's Office prosecuted Johnny Saintil, as it should have.... + +## Three men plead guilty to sex trafficking including one who ... + +Palm Beach Post + +The investor, Jeffrey Epstein, was later convicted of two state charges of solicitation and served 13 months in jail, the Herald found. ... + +lip: Use a plus sign (+) to match a term in your query exactly as is.Leam more. + +Remove this alert. + +Create another alert. + +Manage your alerts. \ No newline at end of file diff --git a/marker2/ds9/EFTA00206662/EFTA00206662.metadata.json b/marker2/ds9/EFTA00206662/EFTA00206662.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..54560b72200e0f1ae8c1b0bd95aa0971a03e3eaa --- /dev/null +++ b/marker2/ds9/EFTA00206662/EFTA00206662.metadata.json @@ -0,0 +1,157 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206662.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1371, + "elapsed_seconds": 1.3, + "image_assets": [ + "_page_0_Picture_13.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Epstein and Saintil: same charges different treatment?", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 39.78, + 353.96999999999997 + ], + [ + 342.1777648925781, + 353.96999999999997 + ], + [ + 342.1777648925781, + 370.4830322265625 + ], + [ + 39.78, + 370.4830322265625 + ] + ] + }, + { + "title": "3 plead guilty in underage Internet sex ring", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 39.78, + 436.59000000000003 + ], + [ + 273.9360656738281, + 436.59000000000003 + ], + [ + 273.9360656738281, + 452.2330322265625 + ], + [ + 39.78, + 452.2330322265625 + ] + ] + }, + { + "title": "System can't shake this case", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 39.78, + 495.72 + ], + [ + 201.1444549560547, + 495.72 + ], + [ + 201.1444549560547, + 511.18353271484375 + ], + [ + 39.78, + 511.18353271484375 + ] + ] + }, + { + "title": "Three men plead guilty to sex trafficking including one who ...", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 39.78, + 555.6600000000001 + ], + [ + 375.272705078125, + 555.6600000000001 + ], + [ + 375.272705078125, + 570.4335174560547 + ], + [ + 39.78, + 570.4335174560547 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 74 + ], + [ + "Line", + 30 + ], + [ + "Text", + 23 + ], + [ + "SectionHeader", + 4 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206662" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206662/_page_0_Picture_13.jpeg b/marker2/ds9/EFTA00206662/_page_0_Picture_13.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..e21b492574c56547fee6fc66e8344977003a028d --- /dev/null +++ b/marker2/ds9/EFTA00206662/_page_0_Picture_13.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:9c8215432e145eb98ddd10fa26056aa8f02b736fd688fb5056366919ea92b096 +size 2062 diff --git a/marker2/ds9/EFTA00206663/EFTA00206663.md b/marker2/ds9/EFTA00206663/EFTA00206663.md new file mode 100644 index 0000000000000000000000000000000000000000..121ae8e19ae2e411141ac3096697da12ee389f1a --- /dev/null +++ b/marker2/ds9/EFTA00206663/EFTA00206663.md @@ -0,0 +1,5 @@ +Date: Wed, 25 Aug 2010 13:31:13 +0000 + +Importance: Normal + +I got your voicemail that said you were in meetings so I figured I'd send you an e-mail. Can you call me when you get a chance? I got a strange inquiry from a reporter on Epstein. Thanks. \ No newline at end of file diff --git a/marker2/ds9/EFTA00206663/EFTA00206663.metadata.json b/marker2/ds9/EFTA00206663/EFTA00206663.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..35ce92e49737a60d7b2d3eca4fa606a6a5b0bab8 --- /dev/null +++ b/marker2/ds9/EFTA00206663/EFTA00206663.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206663.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 246, + "elapsed_seconds": 0.27, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 9 + ], + [ + "Line", + 5 + ], + [ + "Text", + 3 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206663" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206664/EFTA00206664.md b/marker2/ds9/EFTA00206664/EFTA00206664.md new file mode 100644 index 0000000000000000000000000000000000000000..1916801e9e67f01195e96e48b36eff2415e4b612 --- /dev/null +++ b/marker2/ds9/EFTA00206664/EFTA00206664.md @@ -0,0 +1,60 @@ +From: "[REDACTED]" <[REDACTED]> +To: "[REDACTED]" <[REDACTED]> + +Subject: Activity in Case 9:08-cv-80893-KAM Doe v. Epstein Order on Motion for Hearing +Date: Tue, 21 Sep 2010 12:47:13 +0000 + +Importance: Normal + +**This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended.** + +**\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\*** Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +**Notice of Electronic Filing** + +The following transaction was entered on 9/21/2010 at 8:47 AM EDT and filed on 9/21/2010 + +Case Name: Doe v. Epstein + +Case Number: [9:08-cv-80893-KAM](#) + +Filer: + +WARNING: CASE CLOSED on 07/20/2010 + +Document Number: [219](#) + +Docket Text: + +**ORDER Denying as Moot [213] Motion for Hearing. Signed by Magistrate Judge Linnea R. Johnson on 9/21/2010. (sa)** + +**9:08-cv-80893-KAM Notice has been electronically mailed to:** + +[REDACTED] [REDACTED], [REDACTED] +Bradley James Edwards [REDACTED], [REDACTED] +Jack Alan Goldberger [REDACTED], [REDACTED] +Katherine Warthen Ezell [REDACTED], [REDACTED] +Lilly Ann Sanchez [REDACTED] +Michael James Pike [REDACTED], [REDACTED], [REDACTED] +Paul G. Cassell [REDACTED] +Robert Deweese Critton , Jr [REDACTED], [REDACTED] + +9:08-cv-80893-ICAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at + +The following document(s) are associated with this transaction: + +Document description:Main Document + +Original filenamem/a + +Electronic document Stamp: + +[STAMP dcecfStamp\_11: 1105629215 [Date=9/21/2010] [FileNumber=8018675-0 + +] [0c197dOdel4e86d39abbfe87e0798ed03c371454c 185aaeb8446fdaaaf75a8ed459 + +4ec0eaf6149dbf137136153a338 fd951b8fd44823437d9955fd5a63d8c8c00)] \ No newline at end of file diff --git a/marker2/ds9/EFTA00206664/EFTA00206664.metadata.json b/marker2/ds9/EFTA00206664/EFTA00206664.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1b642998df483c1b674ac7dbf85a9cec164970ad --- /dev/null +++ b/marker2/ds9/EFTA00206664/EFTA00206664.metadata.json @@ -0,0 +1,112 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206664.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2283, + "elapsed_seconds": 7.19, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 309.42 + ], + [ + 182.37599999999998, + 309.42 + ], + [ + 182.37599999999998, + 323.19 + ], + [ + 30.6, + 323.19 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 65 + ], + [ + "Text", + 43 + ], + [ + "Line", + 33 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 20 + ], + [ + "Line", + 10 + ], + [ + "Text", + 8 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206664" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206666/EFTA00206666.md b/marker2/ds9/EFTA00206666/EFTA00206666.md new file mode 100644 index 0000000000000000000000000000000000000000..0bbc4f82a939e9ec35bb7f9074bea70e4bd6aea0 --- /dev/null +++ b/marker2/ds9/EFTA00206666/EFTA00206666.md @@ -0,0 +1,57 @@ +To: "[REDACTED]" + +Subject: Activity in Case 9:08-cv-80893-KAM Doe [REDACTED] Epstein Appeal of Magistrate Judge Order to District Court + +Date: Tue, 28 Sep 2010 22:40:44 +0000 + +Importance: Normal + +**This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended.** + +**\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\*** Judicial Conference of the United States policy permits attorneys of record and parties in a case (including prose litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +**Notice of Electronic Filing** + +The following transaction was entered by Ackerman, Joseph on 9/28/2010 at 6:40 PM EDT and filed on 9/28/2010 + +Case Name: Doe [REDACTED] Epstein + +Case Number: [9:08-cv-80893-KAM](#) + +Filer: Jeffrey Epstein + +**WARNING: CASE CLOSED on 07/20/2010** + +Document Number: [220](#) + +**Docket Text:** + +**APPEAL OF MAGISTRATE JUDGE ORDER to District Court by Jeffrey Epstein re [216] Clerks Notice of Docket Correction and Instruction to Filer - Attorney,, [218] Order on Motion for Protective Order, Order on Motion for Leave to File, [217] Response to Motion, (Ackerman, Joseph)** + +9:08-cv-80893-KAM Notice has been electronically mailed to: + +[REDACTED] + +Bradley James Edwards [REDACTED] + +Jack Alan Goldberger [REDACTED] + +Katherine Warthen Ezell [REDACTED] + +Lilly Ann Sanchez [REDACTED] + +9:08-cv-80893-KAM Notice has not been delivered electronically to those listed below and will be pros ided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +The following document(s) are associated with this transaction: + +Document description:Main Document + +Original filename:n/a + +Electronic document Stamp: + +[STAMP dcecfStamp\_1 1105629215 [Date=9/28/2010] [FileNumber=8046506-0 ] [19d68cc5321ccdb119db81c2cf6771588cb26cd0757d2273e61f2af1338d2d3d3bb e59449ab81d9c9fc9e3aa6b0flIf69455e025 f509a7f7587919c2e8 ffb0ce]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00206666/EFTA00206666.metadata.json b/marker2/ds9/EFTA00206666/EFTA00206666.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..897688deaae1891d875a1decfbfd33ba05415569 --- /dev/null +++ b/marker2/ds9/EFTA00206666/EFTA00206666.metadata.json @@ -0,0 +1,135 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206666.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2289, + "elapsed_seconds": 7.65, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 322.38 + ], + [ + 181.76399999999998, + 322.38 + ], + [ + 181.76399999999998, + 336.96 + ], + [ + 30.6, + 336.96 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 465.75 + ], + [ + 99.144, + 465.75 + ], + [ + 99.144, + 478.71 + ], + [ + 30.6, + 478.71 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 71 + ], + [ + "Text", + 48 + ], + [ + "Line", + 36 + ], + [ + "SectionHeader", + 4 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 26 + ], + [ + "Line", + 11 + ], + [ + "Text", + 7 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206666" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206668/EFTA00206668.md b/marker2/ds9/EFTA00206668/EFTA00206668.md new file mode 100644 index 0000000000000000000000000000000000000000..3f9f8c38b8a14e74e16312885e6bfaf14b577adc --- /dev/null +++ b/marker2/ds9/EFTA00206668/EFTA00206668.md @@ -0,0 +1,61 @@ +From: To: + +Subject: Activity in Case 9:08-cv-80893-KAM Doe 1 Epstein Order on Motion for Protective Order + +Date: Tue, 14 Sep 2010 12:48:14 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered on 9/14/2010 at 8:48 AM EDT and filed on 9/14/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80893-KAM + +Filer: + +WARNING: CASE CLOSED on 07/20/2010 + +Document Number: 218 + +Docket Text: + +ORDER Denying Without Prejudice [214] Motion for Protective Order; Denying Without Prejudice [214] Motion for Leave to File. Signed by Magistrate Judge Linnea R. Johnson on 9/14/2010. (sa) + +9:08-cv-80893-KAM Notice has been electronically mailed to: + +Bradley James Edwards + +Jack Alan Goldberger j + +Katherine Warthen Ezell + +Lilly Ann Sanchez Isa + +Michael James Pike M + +9:08-cv-80893-ICAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +The following document(s) are associated with this transaction: + +Document description:Main Document + +Original filenamem/a + +Electronic document Stamp: + +[STAMP dcecfStamp\_11: 1105629215 [Date=9/14/2010] [FileNumber=7993999-0 + +] [9c078264607f4bb2a43b82ee3e255f9a36 1 cl9c9f39d3ee9ea66196af475c62c0c5 + +3f3lbbcca37e3ea3fl0afa79568cdb7c14b1cdffecee99fd6bfbd377c9a84]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00206668/EFTA00206668.metadata.json b/marker2/ds9/EFTA00206668/EFTA00206668.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..15fd845ffcce5c0756647ee310cb08b02eb9817c --- /dev/null +++ b/marker2/ds9/EFTA00206668/EFTA00206668.metadata.json @@ -0,0 +1,112 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206668.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2073, + "elapsed_seconds": 1.14, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 31.212, + 309.42 + ], + [ + 185.8275909423828, + 309.42 + ], + [ + 185.8275909423828, + 323.9470520019531 + ], + [ + 31.212, + 323.9470520019531 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 68 + ], + [ + "Line", + 34 + ], + [ + "Text", + 24 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 20 + ], + [ + "Line", + 10 + ], + [ + "Text", + 8 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206668" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206670/EFTA00206670.md b/marker2/ds9/EFTA00206670/EFTA00206670.md new file mode 100644 index 0000000000000000000000000000000000000000..1d12f1a11c856eadefea57c844ded071c86f7daa --- /dev/null +++ b/marker2/ds9/EFTA00206670/EFTA00206670.md @@ -0,0 +1,41 @@ +To:" + +Subject: Re: pstem + +Date: Fri, 27 Aug 2010 21:50:23 +0000 + +Importance: Normal + +Sure. Whenever is fine. + +From: + +To: + +Subject: Re: Epstein + +Sure. We're going to be out on surveillance first thing Monday morning. Would late morning / early afternoon be ok? + +From: + +To: + +Sent: Fri Aug 27 17:14:04 2010 + +Subject: FW: Epstein + +Ms. Sarnoff has called former U.S. Attorney Acosta with some information. Can we all talk on Monday? + +Thanks. + +Assistant U.S. Attorney + +From: Greenberg, Benjamin (USAFLS) + +Sent: Friday, August 27, 2010 4:07 PM + +To: Villafana, Ann Marie C. (USAFLS) + +Subject: + +Conchita Sarnoff: Thanks. \ No newline at end of file diff --git a/marker2/ds9/EFTA00206670/EFTA00206670.metadata.json b/marker2/ds9/EFTA00206670/EFTA00206670.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..c7019d8125ab5fc06c593ba5c4c7ca8ca481d6ce --- /dev/null +++ b/marker2/ds9/EFTA00206670/EFTA00206670.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206670.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 611, + "elapsed_seconds": 1.0, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 47 + ], + [ + "Text", + 23 + ], + [ + "Line", + 23 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206670" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206671/EFTA00206671.md b/marker2/ds9/EFTA00206671/EFTA00206671.md new file mode 100644 index 0000000000000000000000000000000000000000..18181a2837c5da87f873ca9bab794da058f9cd0a --- /dev/null +++ b/marker2/ds9/EFTA00206671/EFTA00206671.md @@ -0,0 +1,67 @@ +From: + +[REDACTED] + +To: + +[REDACTED] + +Subject: Activity in Case 9:08-cv-80893-KAM Doe v. Epstein Response/Reply (Other) + +Date: Thu, 07 Oct 2010 15:08:24 +0000 + +Importance: Normal + +--- + +**This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended.** + +**\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\*** Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +### Notice of Electronic Filing + +The following transaction was entered by Edwards, Bradley on 10/7/2010 at 11:08 AM EDT and filed on 10/7/2010 + +Case Name: Doe v. Epstein + +Case Number: [9:08-cv-80893-KAM](#) + +Filer: Bradley J. Edwards + +WARNING: CASE CLOSED on 07/20/2010 + +Document Number: [221](#) + +### Docket Text: + +**RESPONSE/REPLY to [220] Appeal of Magistrate Judge Order to District Court, *Response to Defendant, Epstein Appeal of Denial of Motion for Protective Order and Objection to Disclosure of Certain Documents* by Bradley J. Edwards. (Edwards, Bradley)** + +9:08-cv-80893-KAM Notice has been electronically mailed to: + +[REDACTED] + +Bradley James Edwards [REDACTED] + +Jack Alan Goldberger [REDACTED] + +Katherine Warthen Ezell [REDACTED] + +Lilly Ann Sanchez [REDACTED] + +Michael James Pike [REDACTED] + +9:08-cv-80893-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +The following document(s) are associated with this transaction: + +Document description:Main Document + +Original filenamem/a + +Electronic document Stamp: + +[STAMP dcecfStamp\_11 1105629215 [Date=10/7/2010] [FileNumber=8074880-0 ] [4f7054da73305fal317071f2faa059671de287376a3d4196836eblfe537435a798 e87901938ffc07dc315f4b05215939a963374227cb53b0825a545e775b303]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00206671/EFTA00206671.metadata.json b/marker2/ds9/EFTA00206671/EFTA00206671.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..674e7df206119ac716c969f19dc601f929cc76ee --- /dev/null +++ b/marker2/ds9/EFTA00206671/EFTA00206671.metadata.json @@ -0,0 +1,135 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206671.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2268, + "elapsed_seconds": 7.64, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 308.61 + ], + [ + 182.37599999999998, + 308.61 + ], + [ + 182.37599999999998, + 322.38 + ], + [ + 30.6, + 322.38 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 451.9800000000001 + ], + [ + 99.144, + 451.9800000000001 + ], + [ + 99.144, + 464.93999999999994 + ], + [ + 30.6, + 464.93999999999994 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 75 + ], + [ + "Text", + 49 + ], + [ + "Line", + 35 + ], + [ + "SectionHeader", + 6 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 20 + ], + [ + "Line", + 10 + ], + [ + "Text", + 6 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206671" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206673/EFTA00206673.md b/marker2/ds9/EFTA00206673/EFTA00206673.md new file mode 100644 index 0000000000000000000000000000000000000000..a82f3c1f915f58dd9bd2256bc7361ec09aa40ede --- /dev/null +++ b/marker2/ds9/EFTA00206673/EFTA00206673.md @@ -0,0 +1,19 @@ +Subject: Re: Epstein + +Date: Fri, 27 Aug 2010 21:48:21 +0000 + +Importance: Normal + +Sure. We're going to be out on surveillance first thing Monday morning. Would late morning / early afternoon be ok? + +Sent: Fri Aug 27 17:14:04 2010 + +Subject: FW: Epstein + +Ms. Sarnoff has called former U.S. Attorney Acosta with some information. Can we all talk on Monday? + +Thanks. + +I + +Sent: Friday, August 27, 2010 4:07 PM \ No newline at end of file diff --git a/marker2/ds9/EFTA00206673/EFTA00206673.metadata.json b/marker2/ds9/EFTA00206673/EFTA00206673.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..20bae3da2899916d9a38645b6d489384c4c79c01 --- /dev/null +++ b/marker2/ds9/EFTA00206673/EFTA00206673.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206673.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 403, + "elapsed_seconds": 0.49, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 27 + ], + [ + "Line", + 11 + ], + [ + "Text", + 10 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206673" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206674/EFTA00206674.md b/marker2/ds9/EFTA00206674/EFTA00206674.md new file mode 100644 index 0000000000000000000000000000000000000000..0609881eb801774ba54d6fe6b93cb463a173a8d7 --- /dev/null +++ b/marker2/ds9/EFTA00206674/EFTA00206674.md @@ -0,0 +1,23 @@ +![](_page_0_Picture_34.jpeg) + +**Subject:** FW: Epstein + +**Date:** Fri, 27 Aug 2010 21:14:04 +0000 + +**Importance:** Normal + +--- + +Ms. Sarnoff has called former U.S. Attorney Acosta with some information. Can we all talk on Monday? + +Thanks. + +![](_page_0_Picture_40.jpeg) + +From: Erenberg, Benjamin (eer@es) + +Sent: Friday, August 27, 2010 4:07 PM + +**Subject:** + +Conchita Sarnoff: 2 [REDACTED] Thanks. \ No newline at end of file diff --git a/marker2/ds9/EFTA00206674/EFTA00206674.metadata.json b/marker2/ds9/EFTA00206674/EFTA00206674.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..31480dc2ee77d3a07eb6c80171bc8fd3e02eaf9f --- /dev/null +++ b/marker2/ds9/EFTA00206674/EFTA00206674.metadata.json @@ -0,0 +1,61 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206674.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 395, + "elapsed_seconds": 2.3, + "image_assets": [ + "_page_0_Picture_34.jpeg", + "_page_0_Picture_40.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 18 + ], + [ + "Span", + 16 + ], + [ + "Line", + 8 + ], + [ + "PageFooter", + 2 + ], + [ + "Picture", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206674" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206674/_page_0_Picture_34.jpeg b/marker2/ds9/EFTA00206674/_page_0_Picture_34.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..06d3f3ee1ed64ba5f6f153b0feb3f5e48139bb7b --- /dev/null +++ b/marker2/ds9/EFTA00206674/_page_0_Picture_34.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:b9f24104b4d0b0abcc020f894451a11f54782a8e8617a9423b223b4885d88c7a +size 8548 diff --git a/marker2/ds9/EFTA00206674/_page_0_Picture_40.jpeg b/marker2/ds9/EFTA00206674/_page_0_Picture_40.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..184589936b8559ffad84f4e0304d5d8325eacb8a --- /dev/null +++ b/marker2/ds9/EFTA00206674/_page_0_Picture_40.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:43e9f0eed153aba2151378244eb97d43b252f64dbdec6481117df00a338574b4 +size 6517 diff --git a/marker2/ds9/EFTA00206675/EFTA00206675.md b/marker2/ds9/EFTA00206675/EFTA00206675.md new file mode 100644 index 0000000000000000000000000000000000000000..76a8d82fda8f402718fd37bc81530c005b89dd42 --- /dev/null +++ b/marker2/ds9/EFTA00206675/EFTA00206675.md @@ -0,0 +1,49 @@ +From: " i> + +To: Paul Cassell +**To:** Paul Cassell <[REDACTED]>, "[REDACTED] (USAFLS)" <[REDACTED]> +**Cc:** Brad Edwards <[REDACTED]>, "[REDACTED] (USAFLS)" +<[REDACTED]> + +**Subject:** RE: Proposed Pleading to File - fixed a couple of sentences + +**Date:** Wed, 27 Oct 2010 20:10:21 +0000 + +**Importance:** Normal + +**Attachments:** response-order-show-cause-usattyrevision2.docx + +I noticed that I missed a couple of sentences in the pleading I sent to you that made reference to the simultaneously filed declaration of Brad Edwards. This revision fixes those couple of sentences, making reference only to a soon-to-be filed declaration. Paul + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law +S.J. Quinney College of Law at the University of Utah + +[REDACTED] +Salt Lake City, UT 84112-0730 + +[REDACTED] + + + +**CONFIDENTIAL:** This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the sender by reply electronic mail and delete the original message. Thank you. + +-----Original Message----- + +**From:** Paul Cassell + +**Sent:** Wednesday, October 27, 2010 1:50 PM + +[REDACTED] + +**Subject:** RE: Proposed Pleading to File + +THE FOLLOWING COMMUNICATION IS A SETTLEMENT OFFER WITHIN THE MEANING OF FEDERAL RULE OF EVIDENCE 408 + +[REDACTED] + +Attached is proposed pleading that we would file, reflecting your request that we delay and reflecting your stipulation that the passage of time to this point has not prejudiced the U.S. Attorney's Office. + +I want to continue to remind your office of its obligation to use its "best efforts" to protect the rights of crime victims. 19 USC 3771(c) (1). I trust that as you review our proposed pleading you will bear that requirement in mind. + +I can be reached on my cell at [REDACTED] As you know, we have to file today and are prepared to do so if we can't work something out. At the same time, we would like to work cooperatively with your office to bring Epstein to justice -- our revised pleadings are a step in that direction, while hopefully responding to the concerns that your Office has raised. + +Salt Lake City, UT 84112-0730 + +httplAvww.law.utah.edu/profiles/default.asp?PersonID=57&name=Cassell Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the sender by reply electronic mail and delete the original message. Thank you. + +-----Original Message--- + +Sent: Monday, October 25, 2010 10:16 AM + +To: Paul Cassell + +Subject: Out of Office AutoReply: Conferring on Statement of Facts Before Wednesday's Filing + +I will be on government travel from October 25.26, 2010. If you need to reach me, please call me at Thanks. \ No newline at end of file diff --git a/marker2/ds9/EFTA00206679/EFTA00206679.metadata.json b/marker2/ds9/EFTA00206679/EFTA00206679.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..7374a5c246cb147a512242a3f43d42c6531b2b65 --- /dev/null +++ b/marker2/ds9/EFTA00206679/EFTA00206679.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206679.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 3330, + "elapsed_seconds": 9.51, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 77 + ], + [ + "Text", + 50 + ], + [ + "Line", + 35 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 29 + ], + [ + "Line", + 14 + ], + [ + "Text", + 10 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206679" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206681/EFTA00206681.md b/marker2/ds9/EFTA00206681/EFTA00206681.md new file mode 100644 index 0000000000000000000000000000000000000000..3fc19d12aa5168aabeaa7ee750db83cd617542bf --- /dev/null +++ b/marker2/ds9/EFTA00206681/EFTA00206681.md @@ -0,0 +1,99 @@ +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA + +Case No. 08-80736-Civ-Marra/Johnson + +JANE DOES #1 and #2 + +v. + +UNITED STATES + +#### JANE DOE #1 AND JANE DOE #2'S STATUS REPORT AND RESPONSE TO COURT'S ORDER TO SHOW LACK OF PROSEUCTION + +Jane Doe #1 and Jane Doe #2 ("the victims"), through counsel, file the response to Court's order to file a status report and show cause regarding prosecution of the case (doc. #40). + +## BACKGROUND + +As the Court is aware, it entered an order administratively closing this case on September 9, 2010 (doc. #38). That order recited that fact that Jane Doe #1 and Jane Doe #2 had recently settled their civil cases with Jeffrey Epstein as the basis for closure. On September 13, 2010, the victims promptly filed a notice that, while they had settled their case with Jeffrey Epstein, they had reached no settlement with the U.S. Attorney's Office and intended to make filings in this case shortly (doc. #39). The victims requested administrative reopening of the case and, if the Court deemed it advisable, a prompt scheduling conference with the U.S. Attorney's Office regarding the case. The victims also advised that they had only recently received important correspondence between the U.S. Attorney's Office and the Epstein proving that there had been an orchestrated decision to deny them their rights. + +On October 8, 2010, the Court entered an order directing the victims to file a status report and show cause why the case should not be dismissed for want of prosecution. + +#### STATUS REPORT + +As the Court is aware from the victims' filing on September 13, 2010 (doc. #39), the victims have now received important evidence that allows them to file a comprehensive motion explaining the factual background underlying the denials of their rights under the Crime Victims Rights Act and the legal reasons for concluding that their rights under the Act have been violated. The victims prepared a full motion to that effect — accompanied by a detailed factual and legal memorandum. They planned to file the motion and memorandum simultaneously with this pleading. The motion looks something like a summary judgment motion, although the exact procedures for CVRA cases are unclear. + +In an effort to narrow and resolve disputes in this case, the victims then provided an advance copy of their factual and legal pleadings to the U.S. Attorney's Office, along with a request that the U.S. Attorney's Office stipulate to as many facts as possible. The U.S. Attorney's Office then asked the victims to delay filing their pleading for a period up to and including two weeks from today to permit further discussions about the facts and about possible settlement of the disputes. The U.S. Attorney's Office represented that, from their perspective, if the victims were to file their pleadings today it would make it more difficult to reach a resolution of the case. + +In view of this request from the U.S. Attorney's Office, the victims have accordingly agreed to delay filing their comprehensive motion for a period of two weeks. In exchange, the U.S. Attorney's Office has agreed to stipulate that it has not been prejudiced by the passage of time involved in resolving this case and that it will not be prejudiced by an additional two weeks before the victims file their motion. + +The victims wish to make clear that they stand ready to file their comprehensive motion for a finding of violations of their rights in two weeks, on November 10, 2010. They are also prepared to make that filing in whatever form the Court might direct as the most appropriate to resolve this case quickly. + +It should be noted that the victims' motion will ask for an evidentiary hearing if the facts are disputed by the U.S. Attorney's Office. Before filing the motion, the victims had also sent a copy of the facts to the U.S. Attorney's Office in an effort to obtain their agreement to them and to expedite the case. (As the Court is aware from the victims' earlier filing, the victims attempted to negotiate a stipulated set of facts with the U.S. Attorney's Office, only to be rebuffed by the U.S. Attorney's Office. See doc. #17 (U.S. Attorney giving "notice" that only two facts are relevant to this case and declining to provide information on other facts in the case); doc. #19 (victims response); doc. #22 (U.S. Attorney's reply).) The parties jointly advise the Court that they believe that two weeks of discussions may narrow the issues on which the victims would request an evidentiary hearing. The U.S. Attorney's Office, at this time, opposes any evidentiary hearing. + +If no resolution of the case is achieved in the next two weeks, the victims would propose the following schedule for bringing this case to a conclusion: + +November 10, 2010 — Victims file comprehensive motion. + +November 24, 2010 — U.S. Attorney's Office files response to the victims' motion. + +December 3, 2010 — Victims' file Reply to Response. + +Evidentiary Hearing (if facts contested) — early December, at a time convenient to the Court. + +January 1, 2011 — Court issues ruling on whether victims' rights were violated. + +If the Court enters a finding that the victims' rights were violated, then .... + +January 14, 2011— Victims brief on the appropriate remedy for a violation; + +January 28, 2011 -- U.S. Attorney's Office (and any other interested person) files response to victims' remedy brief. + +February 4, 2011 — Victims reply on remedy issues. + +Hearing if necessary — mid-February, at a time convenient to the Court. + +This proposed schedule would allow Jane Doe #1 and Jane Doe #2 to have their case fully resolved on the merits within the next few months. The victims would have no objection to the Court accelerating the schedule. The U.S. Attorney's Office agrees that this schedule is appropriate to resolve the victims' motion, although it may have additional motions and arguments it wishes to file as well. + +### THE CASE SHOULD NOT BE DISMISSED FOR LACK OF PROSECUTION + +Jane Doe #1 and Jane Doe #2 should not have their case dismissed for lack of prosecution for the simple reason that they have not failed to prosecute it. To the contrary, as will be recounted more fully in the statement of facts contained in their motion for a finding of violation of their rights, they have been attempting to secure information that would help prove their case. (If the Court wishes, the Court are prepared to file immediately more information on this point.) + +Although the victims will rely on all of the information contained in the statement of facts that they are preparing to file, in the interest of a brief summary the victims would note that they have been diligently attempting to secure correspondence between Epstein and the U.S. Attorney's Office regarding the non-prosecution agreement reached in this case. After the U.S. Attorney's Office declined to provide the information, the victims sought to secure that information as part of their civil lawsuits against Epstein. This was because of a reasonable legal judgment that the victims' counsel that it was in their best interest to pursue the civil lawsuit against Epstein had a faster pace. Because of protracted litigation from Epstein's battery of lawyers, the victims did not secure any of the correspondence they sought until June 30, 2010. Even then, they secured only part of that correspondence — litigation to secure the rest of that correspondence continues to this day. + +The victims have also never been asked by the U.S. Attorney's Office to accelerate the resolution of this case. During the last year, the victims' counsel have been in contact with the U.S. Attorney's Office on numerous matters related to Jeffrey Epstein. At no time did the U.S. Attorney's Office ask the victims to begin moving more quickly to resolve this case. As noted above, the U.S. Attorney's Office agrees it has not been prejudiced by the passage of time that has taken place in the case so far. + +The victims would also note that the Court has never advised them of a deadline for moving forward with their CVRA case. The victims also knew that the Court was aware of the intense and protracted litigation what was proceeding with Epstein in the various civil cases against him. It seemed reasonable to the victim to resolve those cases first and then turn to the CVRA case — and the victims assumed that the Court was also proceeding on this approach, as the victims never received any inquiry from the Court about their CVRA case until the September 2010 order "administratively" closing the case. Within 5 days of receiving that communication from the Court, the victims promptly advised the Court of their intent to continue moving forward with the case and suggesting a scheduling conference if the Court deemed it advisable. + +The victims have now proposed a specific schedule that will bring this matter to a final conclusion in the next few months. There is no reason to dismiss the case precipitously now on the eve of a final resolution. + +The Eleventh Circuit has repeatedly noted that dismissal with prejudice is an "extreme sanction" and "is plainly improper unless and until the district court finds a clear record of delay or willful conduct and that lesser sanctions are inadequate to correct such conduct." Betty K Agencies, Ltd. v. M/VMONADA, 432 F.3d 1333, 1338-39 (11th Cir.2005). In this case, there is + +no clear record of delay or willful conduct. To the contrary, there is a pattern of the victims diligently attempting to secure evidence (i.e., the correspondence) vital to their case in the face of determined opposition from both the United States and a billionaire sex offender represented by a battery of attorneys. The Eleventh Circuit has held that simple negligence in meeting a courtimposed deadline is not sufficient to warrant dismissal. See McKelvey'. AT & T Techs., Inc., 789 F.2d 1518, 1520 (11th Cir.1986) (per curiam). Here, there is not even negligence, as the victims have not failed to meet any deadline that the Court has set and today stand ready to bring the case to an expeditious conclusion on the schedule they propose. On September 13, 2010, the victims also suggested to the Court that a scheduling conference would be one way to proceed in this case — a suggestion that they continue to offer to the Court. + +## CONCLUSION + +The Court should establish the schedule proposed by the victims and bring this case to a conclusion on the merits as the victims propose. + +DATED: October 27, 2010 + +Respectfully Submitted, + +s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARD FIT t LEHRMAN P.L. + +and + +Paul G. Cassell Pro Hac Vice + +[Redacted] + +Salt Lake City, UT 84112 + +[Redacted] + +Attorneys for Jane Doe #1 and Jane Doe #2 + +# CERTIFICATE OF SERVICE + +Dexter Lee + +Epstein through current counsel. \ No newline at end of file diff --git a/marker2/ds9/EFTA00206681/EFTA00206681.metadata.json b/marker2/ds9/EFTA00206681/EFTA00206681.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1b05d9695f65469f60a95b809cb55121b133130f --- /dev/null +++ b/marker2/ds9/EFTA00206681/EFTA00206681.metadata.json @@ -0,0 +1,446 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206681.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 8, + "chars": 10810, + "elapsed_seconds": 2.21, + "image_assets": [], + "marker_metadata": { + 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As far as an update, I would probably just say that the investigation is continuing but we cannot share further. + +A. Halatia + +Assistant U.S. Attorney + +500 S. Australian Ave, Suite 400 + +West Palm Beach, FL 33401 + +Fax + +From: MI, (USAFLS) + +SenSilda October 221\_2010 1:02 PM + +To: El (USAFLS) + +Subject: FW: CVRA case - meeting in July + +Here is the latest from the plaintiffs. I don't believe we can provide any update on what is going on in the "new" Epstein case, unless the CVRA provides a right to be given status reports to a crime victim. Insofar as the rest of the e-mail, I'm going to respond to Judge Cassell by advising him that: (1) the government will agree to facts presented by plaintiffs if we agree that they are correct; (2) if plaintiffs can base a summary judgment motion based on that set of agreed facts, then the government will respond to plaintiffs' motion. However, we will not agree to an evidentiary hearing for disputed facts. + +I will tell him the government intends to file a motion to dismiss for lack of prosecution and failure to state a claim, insofar as the right to consultation claim. + +From: Paul racspii [manta + +Sent: FricEactober 22, 2010 12:50 PM + +To: M, (USAFLS) + +Cc: Brad Edwards + +Subject: RE: CVRA case - meeting in July + +Hi I= + +Still waiting to hear from you on what the current status is regarding the next criminal prosecution of Epstein. Whatsup? + +Also, regarding our pleading we are preparing to file, Brad reminds me of the great importance both you and we place on not "tipping off" Epstein to anything. Accordingly, we are thinking of taking out the paragraph in our pleading regarding the meeting we had with the FBI agents in July 2010. The main reason for that paragraph was to show that we have been proceeding diligently in moving this case along, including having a meeting with the FBI and waiting to hear back from them. Perhaps you would agree that that we have been proceeding diligently, in which case it would be not be necessary for us to include such a paragraph. + +Another option would be for us to file that paragraph under seal with the court, although that creates the possibility of some sort of unsealing (and or motion to unseal) that could be complicated. + +I'm around all day if you want to chat. . I hope to be able to send you a proposed statement of facts for you and to review later today. Paul + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law + +S.J. Quinney College of Law at the University of Utah + +332 South 1400 East, Room 101 + +Salt Lake City, UT 84112-0730 + +Voice: + +Fax: + +Email: + +http://www.law.utah.eduiprofilesidefault.asp?PersonID=S7&name.Cassell Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the sender by reply electronic mail and delete the original message. Thank you. + +From: MI, (USAFLS) [mailto: + +Sent: Tuesday, October 12, 2010 3:02 PM + +To: Paul Cassell + +Cc: Brad Edwards + +Subject: RE: CVRA case + +Judge Cassell, + +Please feel free to call me We don't have any problem with agreeing that a factual assertion is correct if we agree that is what occurred. However, the government does not agree that it violated the CVRA, or that plaintiffs are entitled to any relief. + +I will be at the National Advocacy Center in Columbia, South Carolina, from October 17-21. I will have access to my emails but it may be difficult for me to respond quickly to what you send to me. Also, in determining whether your statement of facts is correct, I will need to consult with my colleague who handled the Epstein matter. + +From: Paul Cassell [mailto + +Sent: TuaOctober 12, 2010 3:47 PM + +To: M, (USAFLS) + +Cc: Brad Edwards + +Subject: CVRA case + +Hi (if I may), + +I believe we have communicated electronically before. As you probably know, I am co-counsel with Brad Edwards on the CVRA case concerning the Epstein (non) prosecution. + +You will have seen Judge Marra's order today asking for us to explain the current situation on the CVRA case by October 23. By October 23, we plan to file a motion asking the court to declare that there were violations of the CVRA. We will be doing that on the basis of a set of fact in the case, of course. + +I am writing to see if you would be interested in working with us on a stipulated set of facts? We will be in a position to give you a set of facts early to middle of next week. Would you be able to look at them quickly and let us know which facts are not dispute? + +Thanks in advance for your cooperation on narrowing the factual issues in this case and any idea for helping the case to progress smoothly. + +Sincerely, + +Paul Cassell + +Counsel for Jane Does + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law + +S.J. Quinney College of Law at the University of Utah + +332 South 1400 East, Room 101 + +Salt Lake City, UT 84112-0730 + +Voice: + +Fax: + +Email: + +http://www.law.utah.edu/profilesidefault.asp?PersonID=S7&name=Cassell Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the sender by reply electronic mail and delete the original message. Thank you. \ No newline at end of file diff --git a/marker2/ds9/EFTA00206689/EFTA00206689.metadata.json b/marker2/ds9/EFTA00206689/EFTA00206689.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..cd24f72c595b0754fec1bf6bf80f548fb86ec2bc --- /dev/null +++ b/marker2/ds9/EFTA00206689/EFTA00206689.metadata.json @@ -0,0 +1,114 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206689.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 5873, + "elapsed_seconds": 1.61, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 81 + ], + [ + "Line", + 38 + ], + [ + "Text", + 26 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 82 + ], + [ + "Line", + 41 + ], + [ + "Text", + 28 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 45 + ], + [ + "Line", + 22 + ], + [ + "Text", + 15 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206689" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206692/EFTA00206692.md b/marker2/ds9/EFTA00206692/EFTA00206692.md new file mode 100644 index 0000000000000000000000000000000000000000..c279d1b4be1bed38c24c7db64b2c1b64e2b24151 --- /dev/null +++ b/marker2/ds9/EFTA00206692/EFTA00206692.md @@ -0,0 +1,103 @@ +To: SAFLS)" + +Cc: Lla The notification promises that the Justice Department would makes its "best efforts" to protect Jane Doe #1's rights, including "[t]he reasonable right to confer with the attorney for the United States in the case" and "to be reasonably heard at any public proceeding in the district court + +involving . . . plea . . . ." The notification further explained that "[a]t this time, your case is under investigation." That notification meant that the FBI had identified Jane Doe #1 as a victim of a federal offense and therefore as someone protected by the CVRA + +5. On about August 11, 2007, Jane Doe #2 received a standard CVRA victim notification letter. See Doc. #14 (attachment 2 to declaration of A. Marie IME). The notification promises that the Justice Department would makes its "best efforts" to protect Jane Doe #1's rights, including "[t]he reasonable right to confer with the attorney for the United States in the case" and "to be reasonably heard at any public proceeding in the district court involving . . . plea . . . ." The notification further explained that "Nit this time, your case is under investigation." That notification meant that the FBI had identified Jane Doe #2 as a victim of a federal offense and therefore as someone protected by the CVRA. + +6. Early in the investigation, the FBI agents and the Assistant U.S. Attorney had several meetings with Jane Doe #1. Jane Doe #2 was represented by counsel and, accordingly, all contact was made through that attorney. Edwards Declaration at 1. + +7. In May 2007, the U.S. Attorney's Office had a 82-page prosecution memorandum outlining numerous federal sexual offenses committed by Epstein, and had prepared a 53-page indictment for numerous federal offenses. U.S. Attorney's Correspondence at 4. + +8. In and around September 2007, plea discussions took place between Jeffrey Epstein, represented by numerous attorneys (including lead criminal defense counsel Jay Lefkowitz) and the U.S. Attorney's office for the Southern District of Florida, represented primarily by Assistant U.S. Attorney A. Marie The plea discussions generally began from the premise that Epstein would plead guilty at least one federal felony offense surrounding his sexual assaults of more than 40 minor girls. From there, the numerous defense attorneys progressively and + +relentlessly negotiated more favorable plea terms so that Epstein would ultimately plead to only two misdemeanor offenses and would serve only jail time. Many of the negotiations are reflected in e-mails between Lefkowitz and Copies of the correspondence are attached as Exhibit 2 to the Edwards Declaration accompanying this filing (hereinafter cited as "U.S. Attorney's Correspondence" and referenced by Bates number stamp).1 Because Epstein has moved to keep these documents under seal, they are at this time filed under seal with the Court. + +9. In September 2007, in connection with plea discussions about a possible federal assault charges against Epstein, Assistant U.S. Attorney (AUSA) A. Marie proposed that Epstein plead to an assault charge involving a telephone call made by Epstein while he was on his private jet. During the telephone call, Epstein warned his personal assistant, Lesley Groff, against turning over documents and electronic evidence responsive to a subpoena issued by a federal grand jury in the Southern District of Florida investigating Epstein's sex offenses. U.S. Attorney's Correspondence at 49, 58. + +10. The correspondence also shows that AUSA was interested in finding a place to conclude a plea bargain that would effectively keep the victims from learning what was happening through the press. She wrote in an e-mail to defense counsel: "On an 'avoid the press' note, I believe that Mr. Epstein's airplane was in Miami on the day of the Ms. Groff telephone call. If he was in Mimi-Dade County at the time, then I can file the charge in the District Court in Miami, which will hopefully cut the press coverage significantly." U.S. Attorney's Correspondence at 29. Ms. was aware that most of the victims of Epstein, + +Through diligent efforts, counsel for Jane Doe #1 and Jane Doe #2 received copies of half of the e-mail correspondence (the half reflecting communications to defense counsel) on about June 30, 2010. + +including Jane Doe #1 and Jane Doe #2, resided in the West Palm Beach area rather than the Miami area. + +11. On about September 24, 2007, Assistant U.S. Attorney A. Marie sent an e-mail to Jay Lefkowitz, criminal defense counsel for Epstein, regarding the agreement. The e-mail stated that the Government and Epstein's counsel would negotiate between themselves about what information would be disclosed to the victims about the agreement: + +Thank you, Jay. I have forwarded your message only to Alex [Acosta], Andy, and Roland. I don't anticipate it going any further than that. When I receive the originals, I will sign and return one copy to you. The other will be placed in the case file, which will be kept confidential since it also contains identifying information about the girls. + +When we reach an agreement about the attorney representative for the girls, we can discuss what I can tell him and the girls about the agreement. I know that Andy promised Chief Reiter an update when a resolution was achieved. . . . Rolando is calling, but Rolando knows not to tell Chief Reiter about the money issue, just about what crimes Mr. Epstein is pleading guilty to and the amount of time that has been agreed to. Rolando also is telling Chief Reiter not to disclose the outcome to anyone. + +U.S. Attorney's Correspondence at 153 (emphases added). + +12. On about September 25, 2007, AUSA send an e-mail to Lefkowitz stating: "And can we have a conference call to discuss what I may disclose to . . . the girls regarding the agreement." U.S. Attorney's Correspondence at 156. + +13. On about September 26, 2007, AUSA. sent an e-mail to Lefkowitz in which she stated: "Hi Jay — Can you give me a call at 561 209-[xxxx] this morning? I am meeting with the agents and want to give them their marching orders regarding what they can tell the girls." U.S. Attorney's Correspondence at xxxxx. The reasonable inference is that the "marching orders" agreed to between the Government and Epstein's defense counsel was that no mention would be + +made of the non-prosecution agreement between the U.S. Attorney's Office and Epstein, as no subsequent mention was made to the victims of the non-prosecution agreement. + +14. On about September 27, 2007, Assistant U.S. Attorney A. Marie revealed to an attorney (Bert Ocariz), who was under discussion to be a representative of victims of Epstein's sexual abuse, that a non-prosecution agreement was in the process of being reached with Epstein. The e-mail stated: "Bert's firm has raised a number of good questions about how they are going to get paid." U.S. Attorney's Correspondence at 161. The e-mail went on to state: "I told Bert that as part of our agreement we (the federal government) are not going to indict Mr. Epstein, but him an idea of the charged that we had planned to bring as related to 18 USC 2255." Id. The email also asked permission from Epstein's counsel to send to Ocariz a copy of parts of the plea agreement: "With respect to question 2 [a question from Ocariz regarding "[w]hen will it be possible to see the plea agreement so that we understand exactly what Epstein concedes to in the civil case?], do I have your permission to send Bert just that section of the plea agreement that applies to the damages claims (I would recommend sending paragraphs 7 through 10, or at least 7 and 8)?" Id. + +15. In a letter later sent by Jay Lefkowitz to the U.S. Attorney for the Southern District of Florida, Lefkowitz stated that ASUA had "assiduously" hidden from him the fact that Bert Ocariz was a friend of boyfriend. U.S. Attorney's Correspondence at 267. Lefkowitz also stated that had misleadingly used the term "friend" rather than the more accurate term "boyfriend" to describe the connection. Id. at 268 Lefkowitz further stated the boyfriend had a business relationship with Ocariz and that the boyfriend would have financially benefitted from the presumably lucrative referral of sexual assault cases against Epstein to Ocariz. On December 13, 2007, wrote a letter to Lefkowitz to deny these + +accusations. In the letter, stated: ". . . I am surprised by your allegations regarding my role because I thought that we had worked very well together in resolving this dispute. I also am surprised because I feel that I bent over backwards to keep in mind the effect that the agreement would have on Mr. Epstein and to make sure that you (and he) understood the repercussions of the agreement." Id. + +16. On about September 24, 2007, Epstein and the U.S. Attorney's Office reached an agreement whereby the United States would defer federal prosecution in favor of prosecution by the State of Florida. Epstein and the U.S. Attorney's Office accordingly entered into a "Non-Prosecution Agreement" (NPA) reflecting their agreement. Most significantly, the NPA gave Epstein a promise that he would not be prosecuted for a series of federal felony offenses involving his sexual abuse of more than 30 minor girls. The NPA instead allowed Epstein to plead guilty to two state felony offenses for solicitation of prostitution and procurement of minors for prostitution. The NPA also set up a procedure whereby a victim of Epstein's sexual abuse could obtain an attorney to proceed with a civil claim against Epstein, provided that the victim agreed to proceed exclusively under 18 U.S.C. § 2255 (i.e., provided that the victim agreed to seek no more than \$150,000 in damages against Epstein). See Affidavit of Bradley J. Edwards, Attachment xxxxxx (copy of the non-prosecution agreement). The agreement was signed by Epstein and his legal counsel, as well as the U.S. Attorney's Office, on about September 24, 2007. + +17. A provision in the non-prosecution agreement made the agreement secret. In particular, the agreement stated: "The parties anticipate that this agreement will not be made part of any public record. If the United States receives a Freedom of Information Act request or any compulsory process commanding the disclosure of the agreement, it will provide notice to Epstein before + +making the disclosure." See Edwards Declaration, Exhibit xxx (copy of the non-prosecution agreement), at &13. By entering into such a confidentiality agreement, the U.S. Attorney's Office put itself in a position notifying the crime victims (including Jane Doe #1 and Jane Doe #2) of the non-prosecution agreement would violate terms of the agreement — specifically the confidentiality provision. Accordingly, from September 24, 2007 through at least June 2008 — a period of more than nine months -- the U.S Attorney's Office did not notify any of the victims of the existence of the non-prosecution agreement. + +18. A reasonable inference from the evidence is that the U.S. Attorney's Office wanted the nonprosecution agreement kept from public view because of the intense public criticism that would have resulted from allowing a billionaire who had sexually abused more than 40 minor girls to escape from federal prosecution with only a county court jail sentence and because of the possibility that the victims could have objected to the agreement in court and prevented its consummation. + +19. The Non-Prosecution Agreement that had been entered into between the U.S. Attorney's Office and Epstein was subsequently modified by an October 2007 Addendum and a December 19, 2007, letter from the U.S. Attorney to Attorney Lilly Ann Sanchez. See Supplemental Declaration of A. Marie doe. #35, at 1; U.S. Attorney's Correspondence at 234-37. The U.S. Attorney's Office did not notify any of the victims of the existence of these modifications of the agreement through at least June 2008 — a period of more than six months. On about August 14, 2008, Epstein's defense counsel told the U.S. Attorney's Office that they did not consider the December 19, 2007, letter to be operative. Id. + +20. In October 2007, shortly after the initial plea agreement was signed, Jane Doe #1 was contacted to be advised regarding the resolution of the investigation. On October 26, 2007, + +met in person with Jane Doe #1. The Special Agents explained that Epstein would plead guilty to state charges, he would be required to register as a sex offender for life, and he had made certain concessions related to the payment of damages to the victims, including Jane Doe #1. During this meeting, the Special Agents did not explain that an agreement had already been signed that precluded any prosecution of Epstein for federal charges. The agents could not have revealed this part of the non-prosecution agreement without violating the terms of the non-prosecution agreement. Whether the agents themselves had been informed of the existence of the non-prosecution agreement by the U.S. Attorney's Office is not certain. Because the plea agreement had already been reached with Epstein, the agents made no attempt to secure Jane Doe #1's view on the proposed resolution of the case. Edwards Declaration at xxxxxx. + +21. Jane Doe #1's perception of the explanation provided by the Special Agents was that only the State part of the Epstein investigation had been resolved, and that the federal investigation would continue, possibly leading to a federal prosecution. Edwards Declaration at xxxxxx. + +22. On about November 27, 2007, Assistant U.S. Attorney isle sent an e-mail to Jay Lefkowitz, defense counsel for Epstein. The e-mail stated: + +The United States has a statutory obligation (Justice for All Act of 2004) to notify the victims of the anticipated upcoming events and their rights associated with the agreement entered into by the United States and Mr. Epstein in a timely fashion. Tomorrow will make one full week since you were formally notified of the selection. I must insist that the vetting process come to an end. Therefore, unless you provide me with a good faith objection to Judge Davis's selection [as special master for selecting legal counsel for victim pursuing claims against Epstein] by COB tomorrow, November 28, 2007, I will authorize the notification of the victims. Should you give me the go-head on Podhurst and Josephsberg selection by COB tomorrow, I will simultaneously send you a draft of the letter. I intend to notify the victims by letter after COB Thursday, November 29t°. + +U.S. Attorney's Correspondence at 255. + +23. On about November 29, 2007, Assistant U.S. Attorney A. Marie sent a draft of a crime victim notification letter to Jay Lefkowitz, defense counsel for Jeffrey Epstein. The notification letter explained: "I am writing to inform you that the federal investigation of Jeffrey Epstein has been completed, and Mr. Epstein and the U.S. Attorney's Office have reached an agreement containing the following terms . ." The letter then went on to explain that Epstein would plead guilty to two state offenses and receive an 18 month sentence. The letter did not explain that, as part of the agreement with Epstein, the Justice Department was agreeing not to prosecute Epstein for any of the numerous federal offenses that had been committed. U.S. Attorney's Correspondence at 256-59. + +24. Apparently because of concerns from Epstein's attorneys, the U.S. Attorney's Office never sent the proposed victim notification letter discussed in the previous paragraph to the victims. Instead, a misleading letter stating that the case was "currently under investigation" (described below) was sent in January 2008. At no time before reaching non-prosecution agreement did the Justice Department contact any victims, including Jane Doe #1, about their views on the nonprosecution. + +25. On about December 6, 2007, Jeffrey H. , First Assistant U.S. Attorney sent a letter to Jay Lefkowitz, noting the U.S. Attorney's Office's legal obligations to keep victims informed of the status of plea negotiations with Epstein. The letter stated: + +Finally, let me address your objections to the draft Victim Notification Letter. You write that you don't understand the basis for the Office's belief that it is appropriate to notify the victims. Pursuant to the "Justice for All Act of 2004," [another name from the CVRA] crime victims are entitled to: `The right to reasonable, accurate, and timely notice of any public court proceeding . . . involving the crime' and the 'right not to be excluded from any such public court proceeding . . 18 U.S.C. § 3771(a)(2) & (3). Section 3771 also commands that 'employees of the Department of Justice . . engaged in the detection, investigation, or prosecution of crime shall make their best efforts to see that + +crime victims are notified of, and accorded, the rights described in subection (a).' 18 U.S.C. § 377 1(c)(1).... + +Our Non-Prosecution Agreement resolves the federal investigation by allowing Mr. Epstein to plead to a state offense. The victims identified through the federal investigation should be appropriately informed, and our Non-Prosecution Agreement does not require the U.S. Attorney's Office to forego its legal obligation. + +U.S. Attorney's Correspondence at 191-92. + +26. Despite this recognition of its obligation to keep victims "appropriately informed" about the non-prosecution agreement, the U.S. Attorney's Office did not follow through and inform the victims of the non-prosecution agreement. To the contrary, as discussed below, it continued to tell the victims that the case was "under investigation." Edwards Declaration at xxxxxxx. + +27. On December 13, 2007, A. Marie sent a letter to Jay Lefkowitz, defense counsel for Epstein, rebutting charges that had apparently been made against her by the Epstein defense. The letter stated that a federal indictment against Epstein "was postponed for more than five months to allow you and Mr. Epstein's other attorneys to make presentations to the Office to convince the Office not to prosecute." The letter also recounted that "You and I spent hours negotiating the terms [of the non-prosecution agreement], including 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. Lourie, Menchel, , and Acosta in the negotiations at various times." U.S. Attorney's Correspondence at 269. + +28. The December 13, 2007, letter also reveals that the Justice Department stopped making victim notifications because of objections from Epstein's criminal defense counsel: "Three victims were notified shortly after the signing of the Non-Prosecution Agreement of the general terms of the Agreement. You raised objections to any victim notification, and no further notifications were done." U.S. Attorney's Correspondence at 270 (emphasis added). + +29. Following the signing of the Agreement and the modifications thereto, Epstein's performance was delayed while he sought higher level review within the Department of Justice. See U.S. Attorney's Correspondence passim. + +30. On January 10, 2008, Jane Doe #1 and Jane Doe #2 received letters from the FBI advising them that "Rlhis case is currently under investigation. This can be a lengthy process and we request you continued patience while we conduct a thorough investigation." See Doc. #14 (attachments 3 and 4 to declaration of A. Marie (emphasis added). The statement in the notification letter was false. The case was not currently "under investigation." To the contrary, the case had been resolved by the non-prosecution agreement entered into by Epstein and the U.S. Attorney's Office discussed previously. Moreover, the FBI did not notify Jane Doe #1 or Jane Doe #2 that a plea agreement had been reached previously, and that part of the agreement was a non-prosecution agreement with the U.S. Attorney's Office for the Southern District of Florida. Edwards Declaration at xxxx. + +31. In early 2008, Jane Doe #1 and Jane Doe #2 came to believe that criminal prosecution of Epstein was extremely important. The also desired to be consulted by the FBI and/or other representatives of the federal government about the prosecution of Epstein. In light of the letters that they had received around January 10, they believed that a criminal investigation of Epstein was on-going and that they would be contacted before the federal government reached any final resolution of that investigation. Edwards Declaration at xxxx. + +32. On about February 25, 2008, Assistant U.S. Attorney Jay sent an e-mail to Jay Lefkowitz, Epstein's criminal defense counsel, explaining that the Justice Department's Child Exploitation Obscenity Section (CEOS) had agreed to review Epstein's objections to the proposed plea agreement that had been reached with the U.S. Attorney's Office for the Southern District of Florida. The letter indicated that, should CEOS reject Epstein's objections to the agreement, then "Mr. Epstein shall have one week to abide by the terms and conditions of the September 24, 2007 Agreement as amended by letter from United States Attorney Acosta to Jay Lefkowitz." U.S. Attorneys Correspondence at 290-91. + +33. In about April 2008, Jane Doe #1 contacted the FBI because Epstein's counsel was attempting to take her deposition and private investigators were harassing her. Assistant U.S. Attorney A. Marie secured pro bono counsel to represent Jane Doe #1 and several other identified victims in connection with the criminal investigation. Pro bono counsel was able to assist Jane Doe #1 in avoiding the improper deposition. AUSA secured pro bono counsel by contacting Meg Garvin, Esq. of the the National Crime Victims' Law Center in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. Garvin was not advised that a non-prosecution agreement had been reached in this matter. + +34. In mid-June 2008, Mr. Edwards contacted AUSA to inform her that he represented Jane Doe #1 and, later, Jane Doe #2. Mr. Edwards asked to meet to provide information about the federal crimes committed by Epstein, hoping to secure a significant federal indictment against Epstein. AUSA and Mr. Edwards discussed the possibility of federal charges being filed. At the end of the call, AUSA asked Mr. Edwards was asked to send any information that he wanted considered by the U.S. Attorney's Office in determining whether to file federal charges. Because of the confidentiality provision that existed in the plea agreement, Mr. Edwards was not informed that previously, in September 2007, the U.S. Attorney's Office had reached an agreement not to file federal charges. Mr. Edwards was also not informed that any resolution of the criminal matter was imminent. Edwards Declaration at xxxxxx. + +35. On Friday, June 27, 2008, at approximately 4:15 p.m., AUSA received a copy of Epstein's proposed state plea agreement and learned that the plea was scheduled for 8:30 a.m., Monday, June 30, 2008. AUSA and the Palm Beach Police Department attempted to provide notification to victims in the short time that Epstein's counsel had provided. Attorney Edwards was called to provide notice to his clients regarding the hearing. AUSA did not tell Attorney Edwards that the guilty pleas in state court would bring an end to the possibility of federal prosecution pursuant to the plea agreement. Edwards Declaration at xxxxxx. + +36. On June 30, 2008, AUSA sent an e-mail to Jack Goldberger, criminal defense counsel for Epstein, that stated: "Jack: The FBI has received several calls regarding the Non-Prosecution Agreement. I do not know whether the title of the document was disclosed when the Agreement was filed under seal, but the FBI and our office are declining comment if asked." U.S. Attorney's Correspondence at 321. + +37. On July 3, 2008, Mr. Edwards sent to AUSA a letter. See Affidavit of Bradley J. Edwards, Esq., at xxxxxx (attachment 2). In the letter, Mr. Edwards indicated his client's desire that federal charges be filed against defendant Epstein. In particular, he wrote on behalf of his clients: "We urge the Attorney General and our United States Attorney to consider the fundamental import of the vigorous enforcement of our Federal laws. We urge you to move forward with the traditional indictments and criminal prosecution commensurate with the crimes Mr. Epstein has committed, and we further urge you to take the steps necessary to protect our children from this very dangerous sexual predator." When Mr. Edwards wrote this letter, he was still unaware that a non-prosecution agreement had been reached with Epstein — a fact that continued to be concealed from him (and the victims) by the U.S. Attorney's Office. Mr. Edwards first saw a reference to the NPA on or after July 9, 2008, when the Government filed its + +responsive pleading to Jane Doe's emergency petition. That pleading was the first public mention of the non-prosecution agreement and the first disclosure to Mr. Edwards (and thus to Jane Doe #1 and Jane Doe #2) of the possible existence of a non-prosecution agreement. Edwards Declaration at xxxx. + +38. On July 9, 2008, AUSA sent a victim notification to Jane Doe #1 via her attorney, Bradley Edwards, which is attached as Exhibit 6 to the Declaration. That notification contains a written explanation of some of the terms of the agreement between Epstein and the U.S. Attorney's Office. A full copy of the terms was not provided. A notification was not provided to Jane Doe #2 because the agreement limited Epstein's liability to victims whom the United States was prepared to name in an indictment. As a result, Jane Doe #2 never received a notification a letter about the agreement. The notification did not mention the non-prosecution agreement with the U.S. Attorney's Office. Edwards Declaration at xxxx. + +39. On July 9, 2008, AUSA filed a sworn declaration with the Court in connection with the case (doc. #14). The declaration purported to recount limit parts of the non-prosecution agreement and stated that "these provisions were discussed" with several victims, including Jane Doe #1. Id. at 4. + +40. On July 11, 2008, the Court held a hearing on Jane Doe #1 and Jane Doe #2's Emergency Petition for Enforcement of Rights. During the hearing, the Government conceded that Jane Doe #1 and Jane Doe #2 were "victims" within the meaning of the Crime Victim's Rights Act. Tr. at 14-15. + +41. During the July 11 hearing, the Court and the parties discussed the fact that the petition should not be treated as an "emergency" petition because there was not any particular rush to ruling on it. Tr. at 24-25. The Court further discussed a need to "hav[e] a complete record, and + +this is going to be an issue that's ... going to go to the Eleventh Circuit, [s] it] may be better to have acomplete record as to what your position is and the government's is as to what actions were taken. And I don't know if I have enough information, based on Ms. Villafana's affidavit or I need additional information. And because it is not an emergency, I don't have to do something quickly, we can play it b[y] ear and make this into a more complete record for the court of appeals." Tr. at 25-26. Counsel for Jane Doe #1 and Jane Doe #2 explained: " . . . Your Honor is correct in stating that it is not an emergency and it doesn't need to happen today. And, I will confer with the government on this and if evidence needs to be taken, it [can] be taken at a later date. It doesn't seem like there will be any prejudice to any party [from delay]." Tr. at 26. The hearing concluded: "So I'll let both of you confer about whether there is a need for any additional evidence to be presented. Let me know one way or the other. If there is, we'll schedule a hearing. If there isn't and you want to submit some additional stipulated information, do that, and then I'll take care of this in due course." Tr. at 32. The Court then adjourned, taking the victims' petition under advisement. + +42. The U.S. Attorney's Office and the victims then attempted to reach a stipulated set of facts underlying the case. The U.S. Attorney's Office set a proposed set of facts, and the victims sent a counter-proposal. Rather than respond to the victims' proposal, however, the U.S. Attorney's Office suddenly reversed course. (Doc. #19 at 2). On July 29, 2008, it filed a Notice to Court Regarding Absence of Need for Evidentiary Hearing (doc. #17). The Government took the position that, because no federal criminal charges had been filed in the Southern District of Florida, no additional evidence was required to decide the petition before the Court. + +43. On August 1, 2008, Jane Doe # I and Jane Doe #2 filed (doc. #19) a response to the Government's "Notice." In the response, Jane Doe #1 and Jane Doe #2 gave a proposed statement of facts surrounding the case. The proposed statement of fact was based on the information available to the victims at that time. The proposed statement of facts highlighted the fact that the Government had signed a non-prosecution agreement containing an express confidentiality provision, which prevented the Government from disclosing the agreement to them and other victims. Id. at 5. The response also noted that the Court had taken the victims' petition under advisement. The response further noted that the Government had not attempted to work with the victims to draft a full set of undisputed facts and had refused the victims' efforts to obtain documents relevant to the case. Id. at 9. The victims response also requested that the Court direct the Government to confer with the victims regarding the undisputed facts of the case, produce the non-prosecution agreement at issue in the case, and produce an FBI Report of Interview with Jane Doe #1. The response also requested that the Court enter judgment for the victims' on their petition finding a violation of rights and schedule a hearing on the appropriate remedy. Id. at 14. + +44.On August 14, 2008, the Court held a hearing on the case. No schedule for further proceedings was established at that hearing. + +45. On October 9, 2008, Bradley J. Edwards, counsel for Jane Doe #1 and Jane Doe #2, sent a letter to counsel for the U.S. Attorney's Office in this case advising that two possibly false statements had been made to the Court in the July 9th sworn declaration of AUSA See Oct. 9, 2008, Letter from Bradley J. Edwards to Marie at 1, Attachment xxxx to Edwards Declaration. First, while Ms. had described a term as being part of the plea agreement with Epstein, that term later became defunct, at least in the view of Epstein's attorneys (and apparently acceded to by the U.S. Attorney's Office). Second, Ms. had + +said that "four victims [including C.W. — i.e., Jane Doe #1] were contacted and these provisions were discussed," it was not clear what provisions had in fact been discussed. + +46. On December 22, 2008, AUSA Marie filed a supplemental affidavit, "correcting" the statement made in her July 8, 2008, declaration about the terms of the plea agreement (doe. #35). The supplemental affidavit stated that "part 3" of the agreement with defendant Epstein was, in the view Epstein' legal counsel no longer operative. The supplemental affidavit, however, did not clarify what terms of the agreement had been discussed. + +47. On April 9, 2009, counsel for Jane Doe #1 and Jane Doe #2 sent to the Court in this case (via the PACER system) a notice of a change of law firm affiliation. Doc. #37. + +48. In approximately May 2009, counsel for Jane Doe #1 and Jane Doe #2 propounded discovery requests in both state and federal civil cases against Epstein, seeking to obtain correspondence between Epstein and prosecutors regarding his plea agreement — information that the U.S. Attorney's Office was unwilling to provide to Jane Doe #1 and Jane Doe #2. Epstein refused to produce that information, and extended litigation to obtain the materials followed. Edwards Declaration at xxxxx. + +49. Because of this extended litigation, Jane Doe #1 and Jane Doe #2 did not have access to important correspondence demonstrating a violation of their rights until June 30, 2010. On that day, counsel for Epstein sent to Bradley J. Edwards, Esq., legal counsel for Jane Doe #1 and Jane Doe #2, approximately 358 pages of e-mail correspondence between his legal counsel and the U.S. Attorney's Office for the Southern District of Florida regarding the plea agreement that had been negotiated between them. See Attachment 1 to Edwards Aff. These e-mail disclosed for the first time the steps that had been taken by the U.S. Attorney's Office to avoid having the victims in the case learn about the non-prosecution agreement that had been reached between + +Epstein and the Government. Litigation continues to this day to obtain the correspondence regarding the state prosecution and regarding what Epstein's attorneys said in the correspondence with the prosecutors. Edwards Declaration at xxxxxx. + +50. In mid-July 2010, Jane Doe #1 and Jane Doe #2 settled their civil lawsuits against Mr. Epstein. Notice of this fact was promptly provided to the Court. Edwards Declaration at xxx. + +51. On September 8, 2010, the Court entered an order stating that "[a]n examination fo the docket reveals that no activity has taken place in this case since April of 2009. In light of the underlying settlements between the victims and Mr. Epstein, it is hereby ordered and adjudged that this case is closed." Doc. #38. + +52. Promptly on the heels of this administrative order, on September 13, 2010, Jane Doe #1 and Jane Doe #2 filed a notice that they "intend to make subsequent filing in the case shortly. They accordingly request administrative reopening of the case and, if the Court deems it advisable, a scheduling conference with the U.S. Attorney's Office regarding the case." Doc. #39 at 1. They further advised the Court that their settlements with Jeffrey Epstein in no way affected "their determination to move forward with the above-captioned CVRA action against a different entity — the U.S. Attorney's Office for the Southern District of Florida." Id. at 2. The pleading further advised that "[i]f the Court wishes to proceed to an expeditious conclusion to this Case, Jane Doe #1 and Jane Doe #2 have no objection to the Court setting up an expedited schedule for proceeding on the case." Id. The pleading further advised that the reason the victims had not filed for summary judgment in the case was that they had been attempting to secure correspondence between the U.S. Attorney's Office and Epstein to corroborate their argument that the Office had violated their rights. They noted that they had just secured half of that + +correspondence two months earlier. Id. at 2. The victim asked that, "if the Court deems it advisable, that a scheduling conference be set for this case." + +53. At all times material to this statement of facts, it would have been practical and feasible for federal government to inform Jane Doe #1 and Jane Doe #2 of the details of the proposed nonprosecution agreement with Epstein, including in particular the fact that the agreement barred any federal criminal prosecution. 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} + } + ], + "debug_data_path": "debug_data/EFTA00206695" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206714/EFTA00206714.md b/marker2/ds9/EFTA00206714/EFTA00206714.md new file mode 100644 index 0000000000000000000000000000000000000000..226e357be236273c3bb46cea03becb19c68cd244 --- /dev/null +++ b/marker2/ds9/EFTA00206714/EFTA00206714.md @@ -0,0 +1,63 @@ +To: Paul Cassell <1 + +Subject: RE: proposed schedule to resolve the case + +Date: Fri, 22 Oct 2010 19:47:08 +0000 + +Importance: Normal + +Judge Cassell, + +The government will review your statement of facts and we will agree to a factual assertion if we believe it is correct. Insofar as your proposal to resolve the case, if there are disputed facts, the government does not agree to an evidentiary hearing on the facts disputed by the government. This case was filed on July 7, 2008, as an emergency. The government filed its response two days' later, on July 9, and an emergency hearing was held on July 11, 2008. Since that time, plaintiffs have not proceeded apace to pursue their claims. No complaint has been filed, which is the normal mechanism for commencing a civil action. Consequently, the government has not filed an answer. + +I believe the major point of contention between the parties is whether the U.S. Attorney's Office was obligated under 18 3371(a)(5) to consult with plaintiffs before entering into the non-prosecution agreement. Since there was no pending "case" in the district court, we believe the U.S. Attorney's had no obligation to consult with plaintiffs. The government will be filing a motion to dismiss under Rule 12(b)(6) on the claim under 18 =. 3771(a)(5). We will also be seeking dismissal on the grounds of failure to prosecute. + +If plaintiffs believe the agreed upon facts constitute a basis for seeking summary judgment, and files a motion seeking summary judgment, the government will respond to the plaintiffs' motion. However, we will not agree to an evidentiary hearing on the disputed facts. + +As to the status of any pending investigation of Epstein, the DOJ's policy is not to comment on whether an investigation exists, or the progress of an investigation. + +I can be reached at if you wish to discuss this further. Thanks. + +Dexter + +From: Paul Cassell [mailto + +Sent: Thursday, October 21, 2010 5:39 PM + +To: Lee, Dexter (USAFLS) + +Cc: Brad Edwards + +Subject: proposed schedule to resolve the case + +Hi Dexter, + +The Court wants a status report from us regarding resolving the case. + +We are planning to file a motion for summary judgment/finding of violations of victims rights on Wednesday, October 27. This will include a statement of proposed facts and legal arguments. The motion also requests an evidentiary hearing in the event the U.S. Attorney's Office contests are proposed facts. We would then ask for a hearing on the appropriate remedy, if the court find a violation of rights. + +Evidentiary Hearing (if facts contested) — early December + +January 1, 2011— Court issues ruling on whether victims' rights were violated. If it enters a finding that the victims' rights were violated, we would propose that we file a brief on the appropriate remedy on January 14, you file a response on January 28, and we file a reply on February 4 — with the Court to hold a hearing and/or enter a ruling on remedy issue by the end of February. + +Let me know if this schedule seems agreeable to you. Paul Cassell Counsel for Jane Doe #1 and Jane Doe #2 + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law + +S.J. Quinney College of Law at the University of Utah + +332 South 1400 East, Room 101 + +Salt Lake City, UT 84112-0730 + +Voice: + +Fax: + +Email: + +http://www.law.utah.edu/profiles/default.asp?PersonID=S7&name=Cassell Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the sender by reply electronic mail and delete the original message. Thank you. \ No newline at end of file diff --git a/marker2/ds9/EFTA00206714/EFTA00206714.metadata.json b/marker2/ds9/EFTA00206714/EFTA00206714.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..9459218f85907d06485909263278ba2eaf59ad12 --- /dev/null +++ b/marker2/ds9/EFTA00206714/EFTA00206714.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206714.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 3834, + "elapsed_seconds": 1.12, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 75 + ], + [ + "Line", + 38 + ], + [ + "Text", + 22 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 43 + ], + [ + "Line", + 21 + ], + [ + "Text", + 14 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206714" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206716/EFTA00206716.md b/marker2/ds9/EFTA00206716/EFTA00206716.md new file mode 100644 index 0000000000000000000000000000000000000000..89cfe1cd4a09fdf60a5b8a5205a55bde85c5b380 --- /dev/null +++ b/marker2/ds9/EFTA00206716/EFTA00206716.md @@ -0,0 +1,31 @@ +.... ...,...... I. N.1LO • .L/LII, + +Cc: Brad Edwards , + +Subject: RE: Proposed Pleading to File + +Date: Wed, 27 Oct 2010 19:49:47 +0000 + +Importance: Normal + +Attachments: response-order-show-cause-usattyrevision.docx + +THE FOLLOWING COMMUNICATION IS A SETTLEMENT OFFER WITHIN THE MEANING OF FEDERAL RULE OF EVIDENCE 408 + +Attached is proposed pleading that we would file, reflecting your request that we delay and reflecting your stipulation that the passage of time to this point has not prejudiced the U.S. Attorney's Office. + +I want to continue to remind your office of its obligation to use its "best efforts" to protect the rights of crime victims. 19 USC 3771(c) (I). I trust that as you review our proposed pleading you will bear that requirement in mind. + +I can be reached on my cell at As you know, we have to file today and are prepared to do so if we can't work something out. At the same time, we would like to work cooperatively with your office to bring Epstein to justice — our revised pleadings are a step in that direction, while hopefully responding to the concerns that your Office has raised. + +Paul Cassell Counsel for Jane Doe #1 and Jane Doe #2 + +Paul G. Cassell + +en : on ay, to r , : + +To: Paul Cassell + +Subject: Out of Office AutoReply: Conferring on Statement of Facts Before Wednesday's Filing + +I will be on government travel from October 25.26, 2010. If you need to reach me, please call me l'hanks. \ No newline at end of file diff --git a/marker2/ds9/EFTA00206716/EFTA00206716.metadata.json b/marker2/ds9/EFTA00206716/EFTA00206716.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..a475b7c5f82f8e62758877cae3970d79fc819510 --- /dev/null +++ b/marker2/ds9/EFTA00206716/EFTA00206716.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206716.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1477, + "elapsed_seconds": 0.86, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 53 + ], + [ + "Line", + 25 + ], + [ + "Text", + 18 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206716" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206717/EFTA00206717.md b/marker2/ds9/EFTA00206717/EFTA00206717.md new file mode 100644 index 0000000000000000000000000000000000000000..50d1c9b4451d86c78bd5272b2995120146935bb6 --- /dev/null +++ b/marker2/ds9/EFTA00206717/EFTA00206717.md @@ -0,0 +1,97 @@ +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA + +Case No. 08-80736-Civ-Marra/Johnson + +JANE DOES #1 and #2 + +UNITED STATES + +#### JANE DOE #1 AND JANE DOE #2'S STATUS REPORT AND RESPONSE TO COURT'S ORDER TO SHOW LACK OF PROSEUCTION + +Jane Doe #1 and Jane Doe #2 ("the victims"), through counsel, file the response to Court's order to file a status report and show cause regarding prosecution of the case (doc. #40). + +## BACKGROUND + +As the Court is aware, it entered an order administratively closing this case on September 9, 2010 (doc. #38). That order recited that fact that Jane Doe #1 and Jane Doe #2 had recently settled their civil cases with Jeffrey Epstein as the basis for closure. On September 13, 2010, the victims promptly filed a notice that, while they had settled their case with Jeffrey Epstein, they had reached no settlement with the U.S. Attorney's Office and intended to make filings in this case shortly (doc. #39). The victims requested administrative reopening of the case and, if the Court deemed it advisable, a prompt scheduling conference with the U.S. Attorney's Office regarding the case. The victims also advised that they had only recently received important correspondence between the U.S. Attorney's Office and the Epstein proving that there had been an orchestrated decision to deny them their rights. + +On October 8, 2010, the Court entered an order directing the victims to file a status report and show cause why the case should not be dismissed for want of prosecution. + +### STATUS REPORT + +As the Court is aware from the victims' filing on September 13, 2010 (doc. #39), the victims have now received important evidence that allows them to file a comprehensive motion explaining the factual background underlying the denials of their rights under the Crime Victims Rights Act and the legal reasons for concluding that their rights under the Act have been violated. The victims prepared a full motion to that effect — accompanied by a detailed factual and legal memorandum. They planned to file the motion and memorandum simultaneously with this pleading. The motion looks something like a summary judgment motion, although the exact procedures for CVRA cases are unclear. + +In an effort to narrow and resolve disputes in this case, the victims then provided an advance copy of their factual and legal pleadings to the U.S. Attorney's Office, along with a request that the U.S. Attorney's Office stipulate to as many facts as possible. The U.S. Attorney's Office then asked the victims to delay filing their pleading for a period up to and including two weeks from today to permit further discussions about the facts and about possible settlement of the disputes. The U.S. Attorney's Office represented that, from their perspective, if the victims were to file their pleadings today it would make it more difficult to reach a resolution of the case. + +In view of this request from the U.S. Attorney's Office, the victims have accordingly agreed to delay filing their comprehensive motion for a period of two weeks. In exchange, the U.S. Attorney's Office has agreed to stipulate that it has not been prejudiced by the passage of time involved in resolving this case and that it will not be prejudiced by an additional two weeks before the victims file their motion. + +The victims wish to make clear that they stand ready to file their comprehensive motion for a finding of violations of their rights in two weeks, on November 10, 2010. They are also prepared to make that filing in whatever form the Court might direct as the most appropriate to resolve this case quickly. + +It should be noted that the victims' motion will ask for an evidentiary hearing if the facts are disputed by the U.S. Attorney's Office. Before filing the motion, the victims had also sent a copy of the facts to the U.S. Attorney's Office in an effort to obtain their agreement to them and to expedite the case. (As the Court is aware from the victims' earlier filing, the victims attempted to negotiate a stipulated set of facts with the U.S. Attorney's Office, only to be rebuffed by the U.S. Attorney's Office. See doc. #17 (U.S. Attorney giving "notice" that only two facts are relevant to this case and declining to provide information on other facts in the case); doc. #19 (victims response); doc. #22 (U.S. Attorney's reply).) The parties jointly advise the Court that they believe that two weeks of discussions may narrow the issues on which the victims would request an evidentiary hearing. The U.S. Attorney's Office, at this time, opposes any evidentiary hearing. + +If no resolution of the case is achieved in the next two weeks, the victims would propose the following schedule for bringing this case to a conclusion: + +November 10, 2010 — Victims file comprehensive motion. + +November 24, 2010 — U.S. Attorney's Office files response to the victims' motion. + +December 3, 2010 — Victims' file Reply to Response. + +Evidentiary Hearing (if facts contested) — early December, at a time convenient to the Court. + +January 1, 2011 — Court issues ruling on whether victims' rights were violated. + +If the Court enters a finding that the victims' rights were violated, then .... + +January 14, 2011— Victims brief on the appropriate remedy for a violation; + +January 28, 2011 -- U.S. Attorney's Office (and any other interested person) files response to victims' remedy brief. + +February 4, 2011 — Victims reply on remedy issues. + +Hearing if necessary — mid-February, at a time convenient to the Court. + +This proposed schedule would allow Jane Doe #1 and Jane Doe #2 to have their case fully resolved on the merits within the next few months. The victims would have no objection to the Court accelerating the schedule. The U.S. Attorney's Office agrees that this schedule is appropriate to resolve the victims' motion, although it may have additional motions and arguments it wishes to file as well. + +### THE CASE SHOULD NOT BE DISMISSED FOR LACK OF PROSECUTION + +Jane Doe #1 and Jane Doe #2 should not have their case dismissed for lack of prosecution for the simple reason that they have not failed to prosecute it. To the contrary, as recounted more fully in the statement of facts contained in their contemporaneously filed motion for a finding of violation of their rights, they have been attempting to secure information that would help prove their case. The victims hereby expressly incorporate that statement of facts, and supporting evidence (particularly the Declaration from Bradley J. Edwards, Esq.,) as part of this pleading. + +Although the victims rely on all of the information contained in the statement of facts, in the interest of a brief summary the victims would note that they have been diligently attempting to secure correspondence between Epstein and the U.S. Attorney's Office regarding the nonprosecution agreement reached in this case. After the U.S. Attorney's Office declined to provide the information, the victims sought to secure that information as part of their civil lawsuits against Epstein. This was because of a reasonable legal judgment that the victims' counsel that it was in their best interest to pursue the civil lawsuit against Epstein had a faster pace. Because of protracted litigation from Epstein's battery of lawyers, the victims did not secure any of the correspondence they sought until June 30, 2010. Even then, they secured only part of that correspondence — litigation to secure the rest of that correspondence continues to this day. See + +Declaration of Bradley J. Edwards, Esq., Attachment to Jane Doe #1 and Jane Doe #2's Motion for Finding of Violations of the Crime Victims' Rights Act. + +The victims have also never been asked by the U.S. Attorney's Office to accelerate the resolution of this case. During the last year, the victims' counsel have been in contact with the U.S. Attorney's Office on numerous matters related to Jeffrey Epstein. At no time did the U.S. Attorney's Office ask the victims to begin moving more quickly to resolve this case. As noted above, the U.S. Attorney's Office agrees it has not been prejudiced by the passage of time that has taken place in the case so far. + +The victims would also note that the Court has never advised them of a deadline for moving forward with their CVRA case. The victims also knew that the Court was aware of the intense and protracted litigation what was proceeding with Epstein in the various civil cases against him. It seemed reasonable to the victim to resolve those cases first and then turn to the CVRA case — and the victims assumed that the Court was also proceeding on this approach, as the victims never received any inquiry from the Court about their CVRA case until the September 2010 order "administratively" closing the case. Within 5 days of receiving that communication from the Court, the victims promptly advised the Court of their intent to continue moving forward with the case and suggesting a scheduling conference if the Court deemed it advisable. + +The victims have now proposed a specific schedule that will bring this matter to a final conclusion in the next few months. There is no reason to dismiss the case precipitously now on the eve of a final resolution. + +The Eleventh Circuit has repeatedly noted that dismissal with prejudice is an "extreme sanction" and "is plainly improper unless and until the district court finds a clear record of delay or willful conduct and that lesser sanctions are inadequate to correct such conduct." Betty K Agencies, Ltd. I. MIMONADA, 432 F.3d 1333, 1338-39 (11th Cir.2005). In this case, there is no clear record of delay or willful conduct. To the contrary, there is a pattern of the victims diligently attempting to secure evidence (i.e., the correspondence) vital to their case in the face of determined opposition from both the United States and a billionaire sex offender represented by a battery of attorneys. The Eleventh Circuit has held that simple negligence in meeting a courtimposed deadline is not sufficient to warrant dismissal. See McKelvey" AT & T Techs., Inc., 789 F.2d 1518, 1520 (11th Cir.1986) (per curiam). Here, there is not even negligence, as the victims have not failed to meet any deadline that the Court has set and today stand ready to bring the case to an expeditious conclusion on the schedule they propose. On September 13, 2010, the victims also suggested to the Court that a scheduling conference would be one way to proceed in this case — a suggestion that they continue to offer to the Court. + +## CONCLUSION + +The Court should establish the schedule proposed by the victims and bring this case to a conclusion on the merits as the victims propose. + +DATED: October 27. 2010 + +Respectfully Submitted, + +s/ Bradley J. Edwards Bradley J. Edwards + +![](_page_5_Picture_6.jpeg) + +P.L. + +Paul G. Cassell + +Pro Hac Vice + +![](_page_6_Picture_2.jpeg) + +Attorneys for Jane Doe #1 and Jane Doe #2 + +# CERTIFICATE OF SERVICE + +![](_page_7_Picture_1.jpeg) + +Epstein through current counsel. \ No newline at end of file diff --git a/marker2/ds9/EFTA00206717/EFTA00206717.metadata.json b/marker2/ds9/EFTA00206717/EFTA00206717.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..da4a188a83697ce4d2085ee081bcb92d5dfc2192 --- /dev/null +++ b/marker2/ds9/EFTA00206717/EFTA00206717.metadata.json @@ -0,0 +1,462 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206717.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 8, + "chars": 10993, + "elapsed_seconds": 1.26, + "image_assets": [ + "_page_5_Picture_6.jpeg", + 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Petitioners, + +![](_page_0_Picture_2.jpeg) + +UNITED STATES Respondent. + +### RESPONDENT'S MOTION TO DISMISS + +Respondent, United States of America, by and through its undersigned counsel, files its Motion to Dismiss, pursuant to Rules 12(6)(6) and 41(b), Federal Rules of Civil Procedure, and states: + +### I. LITIGATION HISTORY + +On July 7, 2008, plaintiff Jane Doe filed her "Emergency Victim's Petition for Enforcement of Crime Victim's Rights Act, 18 U.S.C. Section 3771." (D.E. I). On the same day, this Court issued an Order directing the United States Attorney to file a response to the petition by 5:00 p.m., Wednesday, July 9, 2008. (D.E. 3). + +On July 9, 2008, the United States Attorney filed the "Government's Response to Victim's Emergency Petition for Enforcement of Crime Victim Rights Act, 18 U.S.C. § 3771." (D.E. 7). The Court held a hearing on July 11, 2008. + +On August 18, 2008, the Court held a status conference. On August 21, 2008, the Court ordered the Government to produce a copy of the Non-Prosecution Agreement between the United States Attorney and Jeffrey Epstein, and simultaneously entered a protective order prohibiting petitioners from disseminating the Non-Prosecution Agreement beyond designated individuals. (D.E. 26). + +On September 25, 2008, petitioners filed their motion to unseal document. (D.E. 28). On October 8, 2008, the Government filed its response in opposition to petitioners' motion. (D.E. 29). Petitioners filed their reply on October 16, 2008. (D.E. 30). On February 12, 2009, the Court denied petitioners' motion to unseal document. (D.E. 36). + +Since February 12, 2009, there has been no activity in this case, other than the filing of a notice by petitioners' counsel of his change in firm affiliation. (D.E. 37). + +# II. THIS CASE SHOULD BE DISMISSED FOR LACK OF PROSECUTION + +Under Fed.R.Civ.P. 41(b), "[i]f the plaintiff fails to prosecute or to comply with these rules or a court order, a defendant may move to dismiss the action or any claim against it." In Goforth i Owens, 766 F.2d 1533 (11 ih Cir. 1985), the Eleventh Circuit observed that "[a] district court is authorized, on defendant's motion, to dismiss an action for failure to prosecute or to obey a court order or federal rule." iii at 1535. A court's + +power to dismiss is an inherent aspect of its authority to enforce its orders and insure prompt disposition of lawsuits. Id. , citing Link Wabash Railroad Co. , 370 U.S. 626, 630-31 (1962), and Jones Graham , 709 F.2d 1457, 1458 (11 di Cir. 1983). Under Rule 41(b), the legal standard to be applied is "whether there is a clear record of delay or willful contempt and a finding that lesser sanctions would not suffice." 766 F.3d at 1535. + +Dismissal of a case with prejudice is considered a sanction of last resort, applicable only in extreme circumstances. Id. + +The Government believes the instant case should be dismissed because of the clear record of delay. + +After the initial filing on July 7, 2008, and the emergency hearing on July 11, 2008, the only notable activity in the case was petitioners' invocation of this Court's authority to obtain a copy of the Non-Prosecution Agreement. + +D.E. 19. The Government, pursuant to the Court's Order to Compel Production and Protective Order (D.E. 26), provided a copy of the Agreement to petitioners. On September 25, 2008, petitioners attempted to have the Court "unseal" the Non-Prosecution Agreement (D.E. 28). The Government opposed the motion because the Non-Prosecution Agreement had never been filed with the Court, under seal or otherwise. D.E. 29. On February 12, 2009, the Court denied petitioners' motion (D.E. 36). The Court specifically addressed petitioners' claim that the Non-Prosecution Agreement should be unsealed because the government had mischaracterized some of its provisions: + +> If and when such alleged mischaracterizations become relevant to an issue to be decided by the Court, the parties will be given an opportunity to advance their positions and the Court will resolve the issue. If disclosure of the Agreement will be required for the Court to resolve the issue, appropriate disclosure will be ordered (D.E. 36 at 1-2). + +Since nothing has occurred in the instant case since the February 12, 2009 Order, presumably petitioners did not believe the mischaracterizations they claimed were made by the Government became relevant to any issue to be decided by the Court. + +On September 8, 2010, this Court entered its Order Closing Case (D.E. 38). The Court noted that "[a]n examination of the docket reveals that no activity has taken place in this case since April of 2009. In light of the underlying settlements between the victims and Mr. Epstein, it is hereby ORDERED AND ADJUDGED that this case is CLOSED ." (D.E. 38)(emphasis in original). It is not unreasonable to believe that the instant action under the Crime Victims Rights Act was auxiliary litigation to support petitioners' claims against Jeffrey Epstein for money damages, particularly with regard to obtaining documents and information from the United States Attorney. Once petitioners' damage claims against Mr. Epstein had been resolved, there would be no + +need for this auxiliary litigation. The absence of any activity in the case since April 2009 supports the conclusion that vindicating the petitioners' rights under the CVRA was not the primary purpose of this case. + +"A district court has inherent authority to manage its own docket `so as to achieve the orderly and expeditious disposition of cases." yL Properties, Inc. Florida Mowing and Landscape Service, Inc. , 556 F.3d 1232, 1240 (11 d. Cir. 2009)(citation omitted). Under Rule 41(b), the court may dismiss a claim if the plaintiff fails to prosecute it or comply with a court order. Id. "The power to invoke this sanction is necessary in order to prevent undue delays in the disposition of pending cases and to avoid congestion in the calendars of the District Court." Id. , citing Durham I. Fla. East Coast Ry. Co. , 385 F.2d 366, 367 (5 th Cir. 1967). The instant case was filed as an emergency matter on July 7, 2008. Within two days, the government filed a written response to the emergency petition, and the Court held an emergency hearing four days after the emergency petition was filed. After this initial flurry of activity, predicated on petitioners' claim of an emergency, petitioners have done little to advance the litigation and seek resolution of their claims. a This clear record of delay provides ample basis for this Court to exercise its discretion and dismiss this case for lack of prosecution under Rule 41(b). + +## III. PETITIONERS HAVE FAILED TO STATE A CLAIM UPON WHICH RELIEF CAN BE GRANTED UNDER 18 U.S.C. § 3771(aX5) + +The heart of petitioners' claim under the Crime Victims Rights Act (CVRA) is that the United States Attorney was legally obligated, under 18 U.S.C. § 3771(a)(5), to consult with them prior to entering into the Non-prosecution Agreement with Jeffrey Epstein. D.E. 1, ¶ 5. This claim should be dismissed under Rule 12(b)(6) because it fails to state a claim upon which relief can be granted. + +In Bell Atlantic Corp. Twombly , 127 S.Ct. 1955 (2007), the Supreme Court observed that a plaintiff's obligation to provide the grounds of his entitlement to relief requires more than labels and conclusions, and a formulaic recitation of the elements of a cause of action will not do. Id. at 1964-65. Instead, factual allegations must be enough to raise a right to relief above the speculative level. "The standard is one of "plausible grounds to infer." Id. In Ashcroft I bal , 129 S.Ct. 1937 (2009), the Supreme Court noted that two working principles underlay its decision in Twombly : (1) the tenet that a court must accept as true all of the allegations contained in a complaint is inapplicable to legal conclusions; and (2) only a complaint that states a plausible claim for relief survives a motion to dismiss. Id. at 1949-50. + +The rights of crime victims are set forth in 18 U.S.C. § 3771(a), and include eight (8) specific rights. + +3771(a)(2), the right to reasonable, accurate, and timely notice of any public court proceeding; § 3771(a)(6), the right to full and timely restitution as provided in law; and notice of her rights under the CVRA. + +It is undisputed that no federal criminal charges have been filed against Jeffrey Epstein, in the U.S. District Court, Southern District of Florida, pertaining to the sexual abuse of minors. fi The United States submits that, since there is no "case" pending in the Southern District of Florida against Epstein, or any "court proceeding" involving an offense against Jane Does 1 and 2, they cannot invoke any protections under 18 U.S.C. § 3771(a)(2) and (5). + +Title 18, United States Code, § 3771(a)(5), provides that a crime victim has "(t]he reasonable right to confer with the attorney for the Government in the case." In its interpretation of a federal statute, the court assumes that "Congress used words in a statute as they are commonly and ordinarily understood," and reads the statute to give full effect to each of its provisions. United States U DBB, Inc. , 180 F.3d 1277, 1281 (11 LI' Cir. + +1999), citing United States McLymont , 45 F3d 400, 401 (11 di Cir. 1995). Section 3771(a)(5) grants a crime victim the reasonable right to confer with the attorney for the Government "in the case." The phrase "in the case" must be considered since there is a canon of statutory construction that "discourages courts from adopting a reading of a statute that renders any part of the statute mere surplusage." Baile' United States , 516 U.S. 137, 146 (1995)(noting that each word in a statute is intended to have "particular, nonsuperfluous meaning"). + +Respondents submit that Congress intended the phrase "in the case" to mean a case filed in the district court. Federal criminal cases are filed in the United States district courts through the filing of a criminal complaint, Fed.R.Crim.P. 3, or indictment, Fed.R.Crim.P. 7. In each instance, an attorney representing the United States Government is required to sign the complaint or indictment. Thus, each criminal case filed in the district court has an attorney for the Government representing the sovereign United States. + +In contrast, § 3771(a)(1) provides that a crime victim "has the right to be reasonably protected from the accused." No mention is made about a case or court proceeding. Thus, Congress intended that this right attaches even before a case is filed in the district court. The absence of any mention of the attorney for the Government is also telling, since the case may still be in the investigative stage, and not yet been assigned an attorney. In such a case, the federal law enforcement agency would be responsible for providing the reasonable protection from the accused. + +Because there is not any case against Epstein in the Southern District of Florida, Jane Does 1 and 2 have no rights under § 3771(a)(5) to consult with the attorney for the Government. The United States Attorney's + +Office was under no obligation to consult with Jane Does 1 and 2 prior to concluding its Non-Prosecution Agreement with Epstein. For the same reason, Jane Doe's claim under § 3771(a)(2) also fails. There has been no "public court proceeding" against Epstein in the U.S. District Court, Southern District of Florida, since no criminal case has been filed against him in the federal court. Consequently, there has been nothing for which the U.S. Attorney's Office was required to give notice to Jane Doe. + +A different provision in the CVRA, 18 U.S.C. § 3771(b), also supports the Government's interpretation of § 3771(a)(5). Section 3771(b)(1) provides as follows: + +> In any court proceeding involving an offense against a crime victim, the court shall ensure that the crime victim is afforded the rights described in subsection (a). + +> Before making a determination described in subsection (a)(3), the court shall make every effort to permit the fullest attendance possible by the victim and shall consider reasonable alternatives to the exclusion of the victim from the criminal proceeding. The reasons for any decision denying relief under this chapter shall be clearly stated on the record. + +There is no "court proceeding" in this case because no federal criminal charges have been lodged against Jeffrey Epstein. Section 3771(b)(1) envisions that a district court presiding over a criminal trial will be responsible for ensuring that a crime victim will be afforded rights granted in § 3771(a). Section 3771(a)(3), which is expressly referenced in § 3771(b)(1), provides that a crime victim has + +> The right not to be excluded from any such public court proceeding, unless the court, after receiving clear and convincing evidence, determines that testimony by the victim would be materially altered if the victim heard other testimony at that proceeding. + +This provision contemplates that, in the event a defendant invokes the rule of sequestration in Fed.R.Evid. 615, the court must consider the crime victim's rights under § 3771(a)(3), and can only exclude the victim from the proceeding if the court finds there is clear and convincing evidence that the victim's testimony would be materially altered if the victim was allowed to hear other testimony at the proceeding. By providing a difficult evidentiary standard which must be met before a victim's right to be present in the court proceeding can be denied, Congress was purposefully limiting a court's discretion in sequestering trial witnesses. + +In the instant case, there is no "court proceeding" since no federal criminal charges have been brought against Epstein. Therefore, § 3771(b)(1) is inapplicable. There is no role for this Court to fulfill under § 3771(b)(1). + +The petition fails to state facts upon which the Court can find a plausible claim for relief exists. + +Accordingly, the petition should be dismissed for failure to state a claim upon which relief can be granted. + +## IV. SEPARATION OF POWERS PRINCIPLES PRECLUDE THE COURT FROM GRANTING ANY RELIEF REGARDING THE NON-PROSECUTION AGREEMENT + +In the instant case, the Non-Prosecution Agreement between the Government and Jeffrey Epstein was concluded in September and October 2007, months before petitioners instituted their action. By entering into the Non-Prosecution Agreement, the United States was exercising its prosecutorial discretion as to the best means to resolve the allegations that Epstein had violated federal law by engaging in criminal sexual misconduct with minors. + +The Executive Branch enjoys exceedingly broad discretion in deciding how, or whether, to charge an individual. Bordenkircher l Hayes , 434 U.S. 357, 668 (1978)("In our system, so long as the prosecutor has probable cause to believe that the accused committed an offense defined by statute, the decision whether or not to prosecute, and what charge to file or bring before a grand jury, generally rests entirely in his discretion") (footnote omitted), and Nixon I United States, 418 U.S. 683, 693 (1974)(Executive Branch has exclusive authority and absolute discretion to decide whether to prosecute a case). Mindful of that principle, Congress expressly provided in the CVRA that, "Enjothing in this chapter shall be construed to impair the prosecutorial discretion of the Attorney General or any officer under his direction." 18 U.S.C. § 3771(d)(6). + +Petitioners had no right under the CVRA to confer with the attorney for the Government, prior to the entry into the Non-Prosecution Agreement, because there was no existing case in the U.S. District Court. + +Moreover, even if they had the right to confer, they had no legal means to prevent the United States from negotiating the Agreement it ultimately entered into with Epstein. Unlike the situation in In Re Dean , 527 F.3d 391 (5 1 Cir. 2008), the Non-Prosecution Agreement did not come before any federal court for review and approval, nor was such action required. In Dean , if the district court believed that the victims had been denied their right to consult under § 3771(a)(5), it could reject the plea agreement and direct that the required consultation occur prior to the negotiation of any new plea agreement. In contrast, the Non-Prosecution Agreement never came before this court. Therefore, this Court is without authority to provide a remedy under § 3771(b)(1). + +Respectfully submitted, + +WIFREDO A. FERRER UNITED STATES ATTORNEY + +By: + +![](_page_5_Picture_7.jpeg) + +I HEREBY CERTIFY that on October , 2010, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. + +![](_page_6_Picture_2.jpeg) + +#### SERVICE LIST + +Jane Does 1 and 2 1 United States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida + +Brad Edwards, Esq., The Law Offices of Brad Edwards & Associates, LLC + +![](_page_6_Picture_6.jpeg) + +Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law + +![](_page_6_Picture_8.jpeg) + +- + +Attorneys for Petitioners + +a The emergency was based upon petitioners' belief that Jeffrey Epstein was engaged in plea negotiations with the United States Attorney's Office and that such negotiations would likely result in a disposition of the charges within the "next several days." D.E. 1, ¶ 3. The petitioner noted that Epstein had already entered a plea of guilty on June 30, 2008, in the Circuit Court for Palm Beach County, Florida, to similar state offenses including solicitation of minors for prostitution. D.E. 1, ¶ 2. + +E "A district court may take judicial notice of public records within its files relating to the particular case before it or other related cases." Cash Inn of Dade, Inc. I Metropolitan Dade County , 932 F.2d 1239, 1243 (11 ih Cir. 1991)(citations omitted). 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Between about 2003 and 2006, defendant Jeffrey Epstein (a billionaire with significant political connections) sexually abused more than 40 minor girls at his mansion in West Palm Beach, Florida, and elsewhere. + +2. In 2006, at the request of the Palm Beach Police Department, the Federal Bureau of Investigation ("FBI") opened an investigation into allegations that Jeffrey Epstein ("Epstein") and his personal assistants had used facilities of interstate commerce to induce young girls between the ages of thirteen and seventeen to engage in prostitution, among other offenses. The case was presented to the United States Attorney's Office for the Southern District of Florida, which accepted the case for investigation. See Declaration of Bradley J. Edwards, Esq. at 1 (hereinafter "Edwards Declaration"). The Palm Beach County State Attorney's Office was investigating the case. Edwards Declaration at 1. + +3. The FBI determined that both Jane Doe #1 and Jane Doe #2 were victims of sexual assaults by Epstein while they were minors beginning when they were approximately thirteen years of age and approximately xxxxx years of age. Both Jane Does were initially identified through the Palm Beach Police Department's investigation of Epstein. Edwards Declaration at 1. + +4. On about June 7, 2007, FBI agents hand-delivered to Jane Doe #1 a standard CVRA victim notification letter. See Doc. #1 he notification promises that the Justice Department would makes its "best efforts" to protect Jane Doe #1's rights, including "[t]he reasonable right to confer with the attorney for the United States in the case" and "to be reasonably heard at any public proceeding in the district court + +involving . . . plea . . . ." The notification further explained that "[a]t this time, your case is under investigation." That notification meant that the FBI had identified Jane Doe #1 as a victim of a federal offense and therefore as someone protected by the CVRA + +5. On about August 11, 2007, Jane Doe #2 received a standard CVRA victim notification letter. See Doc. #14 (attachment 2 to declaration of A. Marie IME). The notification promises that the Justice Department would makes its "best efforts" to protect Jane Doe #1's rights, including "[t]he reasonable right to confer with the attorney for the United States in the case" and "to be reasonably heard at any public proceeding in the district court involving . . . plea . . . ." The notification further explained that "Nit this time, your case is under investigation." That notification meant that the FBI had identified Jane Doe #2 as a victim of a federal offense and therefore as someone protected by the CVRA. + +6. Early in the investigation, the FBI agents and the Assistant U.S. Attorney had several meetings with Jane Doe #1. Jane Doe #2 was represented by counsel and, accordingly, all contact was made through that attorney. Edwards Declaration at 1. + +7. In May 2007, the U.S. Attorney's Office had a 82-page prosecution memorandum outlining numerous federal sexual offenses committed by Epstein, and had prepared a 53-page indictment for numerous federal offenses. U.S. Attorney's Correspondence at 4. + +8. In and around September 2007, plea discussions took place between Jeffrey Epstein, represented by numerous attorneys (including lead criminal defense counsel Jay Lefkowitz) and the U.S. Attorney's office for the Southern District of Florida, represented primarily by Assistant U.S. Attorney A. Marie The plea discussions generally began from the premise that Epstein would plead guilty at least one federal felony offense surrounding his sexual assaults of more than 40 minor girls. From there, the numerous defense attorneys progressively and + +relentlessly negotiated more favorable plea terms so that Epstein would ultimately plead to only two misdemeanor offenses and would serve only jail time. Many of the negotiations are reflected in e-mails between Lefkowitz and Copies of the correspondence are attached as Exhibit 2 to the Edwards Declaration accompanying this filing (hereinafter cited as "U.S. Attorney's Correspondence" and referenced by Bates number stamp).1 Because Epstein has moved to keep these documents under seal, they are at this time filed under seal with the Court. + +9. In September 2007, in connection with plea discussions about a possible federal assault charges against Epstein, Assistant U.S. Attorney (AUSA) posed that Epstein plead to an assault charge involving a telephone call made by Epstein while he was on his private jet. During the telephone call, Epstein warned his personal assistant, Lesley Groff, against turning over documents and electronic evidence responsive to a subpoena issued by a federal grand jury in the Southern District of Florida investigating Epstein's sex offenses. U.S. Attorney's Correspondence at 49, 58. + +10. The correspondence also shows that was interested in finding a place to conclude a plea bargain that would effectively keep the victims from learning what was happening through the press. She wrote in an e-mail to defense counsel: "On an 'avoid the press' note, I believe that Mr. Epstein's airplane was in Miami on the day of the Ms. Groff telephone call. If he was in Mimi-Dade County at the time, then I can file the charge in the District Court in Miami, which will hopefully cut the press coverage significantly." U.S. Attorney's Correspondence at 29. Ille ,as aware that most of the victims of Epstein, + +Through diligent efforts, counsel for Jane Doe #1 and Jane Doe #2 received copies of half of the e-mail correspondence (the half reflecting communications to defense counsel) on about June 30, 2010. + +including Jane Doe #1 and Jane Doe #2, resided in the West Palm Beach area rather than the Miami area. + +11. On about September 24, 2007, .i sent an e-mail to Jay Lefkowitz, criminal defense counsel for Epstein, regarding the agreement. The e-mail stated that the Government and Epstein's counsel would negotiate between themselves about what information would be disclosed to the victims about the agreement: + +Thank you, Jay. I have forwarded your message only to Alex [Acosta], Andy, and Roland. I don't anticipate it going any further than that. When I receive the originals, I will sign and return one copy to you. The other will be placed in the case file, which will be kept confidential since it also contains identifying information about the girls. + +When we reach an agreement about the attorney representative for the girls, we can discuss what I can tell him and the girls about the agreement. I know that Andy promised Chief Reiter an update when a resolution was achieved. . . . Rolando is calling, but Rolando knows not to tell Chief Reiter about the money issue, just about what crimes Mr. Epstein is pleading guilty to and the amount of time that has been agreed to. Rolando also is telling Chief Reiter not to disclose the outcome to anyone. + +U.S. Attorney's Correspondence at 153 (emphases added). + +12. On about September 25, 2007, AUSA send an e-mail to Lefkowitz stating: "And can we have a conference call to discuss what I may disclose to . . . the girls regarding the agreement." U.S. Attorney's Correspondence at 156. + +13. On about September 26, 2007, AUSA. sent an e-mail to Lefkowitz in which she stated: "Hi Jay — Can you give me a call at 561 209-[xxxx] this morning? I am meeting with the agents and want to give them their marching orders regarding what they can tell the girls." U.S. Attorney's Correspondence at xxxxx. The reasonable inference is that the "marching orders" agreed to between the Government and Epstein's defense counsel was that no mention would be + +made of the non-prosecution agreement between the U.S. Attorney's Office and Epstein, as no subsequent mention was made to the victims of the non-prosecution agreement. + +14. On about September 27, 2007, Assistant U.S. Attorney A. Marie revealed to an attorney (Bert Ocariz), who was under discussion to be a representative of victims of Epstein's sexual abuse, that a non-prosecution agreement was in the process of being reached with Epstein. The e-mail stated: "Bert's firm has raised a number of good questions about how they are going to get paid." U.S. Attorney's Correspondence at 161. The e-mail went on to state: "I told Bert that as part of our agreement we (the federal government) are not going to indict Mr. Epstein, but him an idea of the charged that we had planned to bring as related to 18 USC 2255." Id. The email also asked permission from Epstein's counsel to send to Ocariz a copy of parts of the plea agreement: "With respect to question 2 [a question from Ocariz regarding "[w]hen will it be possible to see the plea agreement so that we understand exactly what Epstein concedes to in the civil case?], do I have your permission to send Bert just that section of the plea agreement that applies to the damages claims (I would recommend sending paragraphs 7 through 10, or at least 7 and 8)?" Id. + +15. In a letter later sent by Jay Lefkowitz to the U.S. Attorney for the Southern District of Florida, Lefkowitz stated that ASUA had "assiduously" hidden from him the fact that Bert Ocariz was a friend of boyfriend. U.S. Attorney's Correspondence at 267. Lefkowitz also stated that had misleadingly used the term "friend" rather than the more accurate term "boyfriend" to describe the connection. Id. at 268 Lefkowitz further stated the boyfriend had a business relationship with Ocariz and that the boyfriend would have financially benefitted from the presumably lucrative referral of sexual assault cases against Epstein to Ocariz. On December 13, 2007, wrote a letter to Lefkowitz to deny these + +accusations. In the letter, stated: ". . . I am surprised by your allegations regarding my role because I thought that we had worked very well together in resolving this dispute. I also am surprised because I feel that I bent over backwards to keep in mind the effect that the agreement would have on Mr. Epstein and to make sure that you (and he) understood the repercussions of the agreement." Id. + +16. On about September 24, 2007, Epstein and the U.S. Attorney's Office reached an agreement whereby the United States would defer federal prosecution in favor of prosecution by the State of Florida. Epstein and the U.S. Attorney's Office accordingly entered into a "Non-Prosecution Agreement" (NPA) reflecting their agreement. Most significantly, the NPA gave Epstein a promise that he would not be prosecuted for a series of federal felony offenses involving his sexual abuse of more than 30 minor girls. The NPA instead allowed Epstein to plead guilty to two state felony offenses for solicitation of prostitution and procurement of minors for prostitution. The NPA also set up a procedure whereby a victim of Epstein's sexual abuse could obtain an attorney to proceed with a civil claim against Epstein, provided that the victim agreed to proceed exclusively under 18 U.S.C. § 2255 (i.e., provided that the victim agreed to seek no more than \$150,000 in damages against Epstein). See Affidavit of Bradley J. Edwards, Attachment xxxxxx (copy of the non-prosecution agreement). The agreement was signed by Epstein and his legal counsel, as well as the U.S. Attorney's Office, on about September 24, 2007. + +17. A provision in the non-prosecution agreement made the agreement secret. In particular, the agreement stated: "The parties anticipate that this agreement will not be made part of any public record. If the United States receives a Freedom of Information Act request or any compulsory process commanding the disclosure of the agreement, it will provide notice to Epstein before + +making the disclosure." See Edwards Declaration, Exhibit xxx (copy of the non-prosecution agreement), at &13. By entering into such a confidentiality agreement, the U.S. Attorney's Office put itself in a position notifying the crime victims (including Jane Doe #1 and Jane Doe #2) of the non-prosecution agreement would violate terms of the agreement — specifically the confidentiality provision. Accordingly, from September 24, 2007 through at least June 2008 — a period of more than nine months -- the U.S Attorney's Office did not notify any of the victims of the existence of the non-prosecution agreement. + +18. A reasonable inference from the evidence is that the U.S. Attorney's Office wanted the nonprosecution agreement kept from public view because of the intense public criticism that would have resulted from allowing a billionaire who had sexually abused more than 40 minor girls to escape from federal prosecution with only a county court jail sentence and because of the possibility that the victims could have objected to the agreement in court and prevented its consummation. + +19. The Non-Prosecution Agreement that had been entered into between the U.S. Attorney's Office and Epstein was subsequently modified by an October 2007 Addendum and a December 19, 2007, letter from the U.S. Attorney to Attorney Lilly Ann Sanchez. See Supplemental Declaration of A. Marie doe. #35, at 1; U.S. Attorney's Correspondence at 234-37. The U.S. Attorney's Office did not notify any of the victims of the existence of these modifications of the agreement through at least June 2008 — a period of more than six months. On about August 14, 2008, Epstein's defense counsel told the U.S. Attorney's Office that they did not consider the December 19, 2007, letter to be operative. Id. + +20. In October 2007, shortly after the initial plea agreement was signed, Jane Doe #1 was contacted to be advised regarding the resolution of the investigation. On October 26, 2007, + +Special Agents E. Nesbitt Kuyrkendall and Jason Richards met in person with Jane Doe #1. The Special Agents explained that Epstein would plead guilty to state charges, he would be required to register as a sex offender for life, and he had made certain concessions related to the payment of damages to the victims, including Jane Doe #1. During this meeting, the Special Agents did not explain that an agreement had already been signed that precluded any prosecution of Epstein for federal charges. The agents could not have revealed this part of the non-prosecution agreement without violating the terms of the non-prosecution agreement. Whether the agents themselves had been informed of the existence of the non-prosecution agreement by the U.S. Attorney's Office is not certain. Because the plea agreement had already been reached with Epstein, the agents made no attempt to secure Jane Doe #1's view on the proposed resolution of the case. Edwards Declaration at xxxxxx. + +21. Jane Doe #1's perception of the explanation provided by the Special Agents was that only the State part of the Epstein investigation had been resolved, and that the federal investigation would continue, possibly leading to a federal prosecution. Edwards Declaration at xxxxxx. + +22. On about November 27, 2007, Assistant U.S. Attorney Jeff Sloman sent an e-mail to Jay Lefkowitz, defense counsel for Epstein. The e-mail stated: + +The United States has a statutory obligation (Justice for All Act of 2004) to notify the victims of the anticipated upcoming events and their rights associated with the agreement entered into by the United States and Mr. Epstein in a timely fashion. Tomorrow will make one full week since you were formally notified of the selection. I must insist that the vetting process come to an end. Therefore, unless you provide me with a good faith objection to Judge Davis's selection [as special master for selecting legal counsel for victim pursuing claims against Epstein] by COB tomorrow, November 28, 2007, I will authorize the notification of the victims. Should you give me the go-head on Podhurst and Josephsberg selection by COB tomorrow, I will simultaneously send you a draft of the letter. I intend to notify the victims by letter after COB Thursday, November 29t°. + +U.S. Attorney's Correspondence at 255. + +23. On about November 29, 2007, Assistant U.S. Attorney A. Marie sent a draft of a crime victim notification letter to Jay Lefkowitz, defense counsel for Jeffrey Epstein. The notification letter explained: "I am writing to inform you that the federal investigation of Jeffrey Epstein has been completed, and Mr. Epstein and the U.S. Attorney's Office have reached an agreement containing the following terms . ." The letter then went on to explain that Epstein would plead guilty to two state offenses and receive an 18 month sentence. The letter did not explain that, as part of the agreement with Epstein, the Justice Department was agreeing not to prosecute Epstein for any of the numerous federal offenses that had been committed. U.S. Attorney's Correspondence at 256-59. + +24. Apparently because of concerns from Epstein's attorneys, the U.S. Attorney's Office never sent the proposed victim notification letter discussed in the previous paragraph to the victims. Instead, a misleading letter stating that the case was "currently under investigation" (described below) was sent in January 2008. At no time before reaching non-prosecution agreement did the Justice Department contact any victims, including Jane Doe #1, about their views on the nonprosecution. + +25. On about December 6, 2007, Jeffrey H. Sloman, First Assistant U.S. Attorney sent a letter to Jay Lefkowitz, noting the U.S. Attorney's Office's legal obligations to keep victims informed of the status of plea negotiations with Epstein. The letter stated: + +Finally, let me address your objections to the draft Victim Notification Letter. You write that you don't understand the basis for the Office's belief that it is appropriate to notify the victims. Pursuant to the "Justice for All Act of 2004," [another name from the CVRA] crime victims are entitled to: `The right to reasonable, accurate, and timely notice of any public court proceeding . . . involving the crime' and the 'right not to be excluded from any such public court proceeding . . 18 U.S.C. § 3771(a)(2) & (3). Section 3771 also commands that 'employees of the Department of Justice . . engaged in the detection, investigation, or prosecution of crime shall make their best efforts to see that + +crime victims are notified of, and accorded, the rights described in subection (a).' 18 U.S.C. § 377 1(c)(1).... + +Our Non-Prosecution Agreement resolves the federal investigation by allowing Mr. Epstein to plead to a state offense. The victims identified through the federal investigation should be appropriately informed, and our Non-Prosecution Agreement does not require the U.S. Attorney's Office to forego its legal obligation. + +U.S. Attorney's Correspondence at 191-92. + +26. Despite this recognition of its obligation to keep victims "appropriately informed" about the non-prosecution agreement, the U.S. Attorney's Office did not follow through and inform the victims of the non-prosecution agreement. To the contrary, as discussed below, it continued to tell the victims that the case was "under investigation." Edwards Declaration at xxxxxxx. + +27. On December 13, 2007, A. Marie sent a letter to Jay Lefkowitz, defense counsel for Epstein, rebutting charges that had apparently been made against her by the Epstein defense. The letter stated that a federal indictment against Epstein "was postponed for more than five months to allow you and Mr. Epstein's other attorneys to make presentations to the Office to convince the Office not to prosecute." The letter also recounted that "You and I spent hours negotiating the terms [of the non-prosecution agreement], including 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. Lourie, Menchel, Sloman, and Acosta in the negotiations at various times." U.S. Attorney's Correspondence at 269. + +28. The December 13, 2007, letter also reveals that the Justice Department stopped making victim notifications because of objections from Epstein's criminal defense counsel: "Three victims were notified shortly after the signing of the Non-Prosecution Agreement of the general terms of the Agreement. You raised objections to any victim notification, and no further notifications were done." U.S. Attorney's Correspondence at 270 (emphasis added). + +29. Following the signing of the Agreement and the modifications thereto, Epstein's performance was delayed while he sought higher level review within the Department of Justice. See U.S. Attorney's Correspondence passim. + +30. On January 10, 2008, Jane Doe #1 and Jane Doe #2 received letters from the FBI advising them that "Rlhis case is currently under investigation. This can be a lengthy process and we request you continued patience while we conduct a thorough investigation." See Doc. #14 (attachments 3 and 4 to declaration of A. Marie (emphasis added). The statement in the notification letter was false. The case was not currently "under investigation." To the contrary, the case had been resolved by the non-prosecution agreement entered into by Epstein and the U.S. Attorney's Office discussed previously. Moreover, the FBI did not notify Jane Doe #1 or Jane Doe #2 that a plea agreement had been reached previously, and that part of the agreement was a non-prosecution agreement with the U.S. Attorney's Office for the Southern District of Florida. Edwards Declaration at xxxx. + +31. In early 2008, Jane Doe #1 and Jane Doe #2 came to believe that criminal prosecution of Epstein was extremely important. The also desired to be consulted by the FBI and/or other representatives of the federal government about the prosecution of Epstein. In light of the letters that they had received around January 10, they believed that a criminal investigation of Epstein was on-going and that they would be contacted before the federal government reached any final resolution of that investigation. Edwards Declaration at xxxx. + +32. On about February 25, 2008, Assistant U.S. Attorney Jay Sloman sent an e-mail to Jay Lefkowitz, Epstein's criminal defense counsel, explaining that the Justice Department's Child Exploitation Obscenity Section (CEOS) had agreed to review Epstein's objections to the proposed plea agreement that had been reached with the U.S. Attorney's Office for the Southern District of Florida. The letter indicated that, should CEOS reject Epstein's objections to the agreement, then "Mr. Epstein shall have one week to abide by the terms and conditions of the September 24, 2007 Agreement as amended by letter from United States Attorney Acosta to Jay Lefkowitz." U.S. Attorneys Correspondence at 290-91. + +33. In about April 2008, Jane Doe #1 contacted the FBI because Epstein's counsel was attempting to take her deposition and private investigators were harassing her. Assistant U.S. Attorney A. Marie secured pro bono counsel to represent Jane Doe #1 and several other identified victims in connection with the criminal investigation. Pro bono counsel was able to assist Jane Doe #1 in avoiding the improper deposition. AUSA secured pro bono counsel by contacting Meg Garvin, Esq. of the the National Crime Victims' Law Center in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. Garvin was not advised that a non-prosecution agreement had been reached in this matter. + +34. In mid-June 2008, Mr. Edwards contacted AUSA to inform her that he represented Jane Doe #1 and, later, Jane Doe #2. Mr. Edwards asked to meet to provide information about the federal crimes committed by Epstein, hoping to secure a significant federal indictment against Epstein. AUSA and Mr. Edwards discussed the possibility of federal charges being filed. At the end of the call, AUSA asked Mr. Edwards was asked to send any information that he wanted considered by the U.S. Attorney's Office in determining whether to file federal charges. Because of the confidentiality provision that existed in the plea agreement, Mr. Edwards was not informed that previously, in September 2007, the U.S. Attorney's Office had reached an agreement not to file federal charges. Mr. Edwards was also not informed that any resolution of the criminal matter was imminent. Edwards Declaration at xxxxxx. + +35. On Friday, June 27, 2008, at approximately 4:15 p.m., AUSA received a copy of Epstein's proposed state plea agreement and learned that the plea was scheduled for 8:30 a.m., Monday, June 30, 2008. AUSA and the Palm Beach Police Department attempted to provide notification to victims in the short time that Epstein's counsel had provided. Attorney Edwards was called to provide notice to his clients regarding the hearing. AUSA did not tell Attorney Edwards that the guilty pleas in state court would bring an end to the possibility of federal prosecution pursuant to the plea agreement. Edwards Declaration at xxxxxx. + +36. On June 30, 2008, AUSA sent an e-mail to Jack Goldberger, criminal defense counsel for Epstein, that stated: "Jack: The FBI has received several calls regarding the Non-Prosecution Agreement. I do not know whether the title of the document was disclosed when the Agreement was filed under seal, but the FBI and our office are declining comment if asked." U.S. Attorney's Correspondence at 321. + +37. On July 3, 2008, Mr. Edwards sent to AUSA a letter. See Affidavit of Bradley J. Edwards, Esq., at xxxxxx (attachment 2). In the letter, Mr. Edwards indicated his client's desire that federal charges be filed against defendant Epstein. In particular, he wrote on behalf of his clients: "We urge the Attorney General and our United States Attorney to consider the fundamental import of the vigorous enforcement of our Federal laws. We urge you to move forward with the traditional indictments and criminal prosecution commensurate with the crimes Mr. Epstein has committed, and we further urge you to take the steps necessary to protect our children from this very dangerous sexual predator." When Mr. Edwards wrote this letter, he was still unaware that a non-prosecution agreement had been reached with Epstein — a fact that continued to be concealed from him (and the victims) by the U.S. Attorney's Office. Mr. Edwards first saw a reference to the NPA on or after July 9, 2008, when the Government filed its + +responsive pleading to Jane Doe's emergency petition. That pleading was the first public mention of the non-prosecution agreement and the first disclosure to Mr. Edwards (and thus to Jane Doe #1 and Jane Doe #2) of the possible existence of a non-prosecution agreement. Edwards Declaration at xxxx. + +38. On July 9, 2008, AUSA sent a victim notification to Jane Doe #1 via her attorney, Bradley Edwards, which is attached as Exhibit 6 to the Declaration. That notification contains a written explanation of some of the terms of the agreement between Epstein and the U.S. Attorney's Office. A full copy of the terms was not provided. A notification was not provided to Jane Doe #2 because the agreement limited Epstein's liability to victims whom the United States was prepared to name in an indictment. As a result, Jane Doe #2 never received a notification a letter about the agreement. The notification did not mention the non-prosecution agreement with the U.S. Attorney's Office. Edwards Declaration at xxxx. + +39. On July 9, 2008, AUSA filed a sworn declaration with the Court in connection with the case (doc. #14). The declaration purported to recount limit parts of the non-prosecution agreement and stated that "these provisions were discussed" with several victims, including Jane Doe #1. Id. at 4. + +40. On July 11, 2008, the Court held a hearing on Jane Doe #1 and Jane Doe #2's Emergency Petition for Enforcement of Rights. During the hearing, the Government conceded that Jane Doe #1 and Jane Doe #2 were "victims" within the meaning of the Crime Victim's Rights Act. Tr. at 14-15. + +41. During the July 11 hearing, the Court and the parties discussed the fact that the petition should not be treated as an "emergency" petition because there was not any particular rush to ruling on it. Tr. at 24-25. The Court further discussed a need to "hav[e] a complete record, and + +this is going to be an issue that's ... going to go to the Eleventh Circuit, [s] it] may be better to have acomplete record as to what your position is and the government's is as to what actions were taken. And I don't know if I have enough information, based on Ms. Villafana's affidavit or I need additional information. And because it is not an emergency, I don't have to do something quickly, we can play it b[y] ear and make this into a more complete record for the court of appeals." Tr. at 25-26. Counsel for Jane Doe #1 and Jane Doe #2 explained: " . . . Your Honor is correct in stating that it is not an emergency and it doesn't need to happen today. And, I will confer with the government on this and if evidence needs to be taken, it [can] be taken at a later date. It doesn't seem like there will be any prejudice to any party [from delay]." Tr. at 26. The hearing concluded: "So I'll let both of you confer about whether there is a need for any additional evidence to be presented. Let me know one way or the other. If there is, we'll schedule a hearing. If there isn't and you want to submit some additional stipulated information, do that, and then I'll take care of this in due course." Tr. at 32. The Court then adjourned, taking the victims' petition under advisement. + +42. The U.S. Attorney's Office and the victims then attempted to reach a stipulated set of facts underlying the case. The U.S. Attorney's Office set a proposed set of facts, and the victims sent a counter-proposal. Rather than respond to the victims' proposal, however, the U.S. Attorney's Office suddenly reversed course. (Doc. #19 at 2). On July 29, 2008, it filed a Notice to Court Regarding Absence of Need for Evidentiary Hearing (doc. #17). The Government took the position that, because no federal criminal charges had been filed in the Southern District of Florida, no additional evidence was required to decide the petition before the Court. + +43. On August 1, 2008, Jane Doe # I and Jane Doe #2 filed (doc. #19) a response to the Government's "Notice." In the response, Jane Doe #1 and Jane Doe #2 gave a proposed statement of facts surrounding the case. The proposed statement of fact was based on the information available to the victims at that time. The proposed statement of facts highlighted the fact that the Government had signed a non-prosecution agreement containing an express confidentiality provision, which prevented the Government from disclosing the agreement to them and other victims. Id. at 5. The response also noted that the Court had taken the victims' petition under advisement. The response further noted that the Government had not attempted to work with the victims to draft a full set of undisputed facts and had refused the victims' efforts to obtain documents relevant to the case. Id. at 9. The victims response also requested that the Court direct the Government to confer with the victims regarding the undisputed facts of the case, produce the non-prosecution agreement at issue in the case, and produce an FBI Report of Interview with Jane Doe #1. The response also requested that the Court enter judgment for the victims' on their petition finding a violation of rights and schedule a hearing on the appropriate remedy. Id. at 14. + +44.On August 14, 2008, the Court held a hearing on the case. No schedule for further proceedings was established at that hearing. + +45. On October 9, 2008, Bradley J. Edwards, counsel for Jane Doe #1 and Jane Doe #2, sent a letter to counsel for the U.S. Attorney's Office in this case advising that two possibly false statements had been made to the Court in the July 9th sworn declaration of AUSA See Oct. 9, 2008, Letter from Bradley J. Edwards to Marie at 1, Attachment xxxx to Edwards Declaration. First, while Ms. had described a term as being part of the plea agreement with Epstein, that term later became defunct, at least in the view of Epstein's attorneys (and apparently acceded to by the U.S. Attorney's Office). Second, Ms. had + +said that "four victims [including C.W. — i.e., Jane Doe #1] were contacted and these provisions were discussed," it was not clear what provisions had in fact been discussed. + +46. On December 22, 2008, AUSA Marie filed a supplemental affidavit, "correcting" the statement made in her July 8, 2008, declaration about the terms of the plea agreement (doe. #35). The supplemental affidavit stated that "part 3" of the agreement with defendant Epstein was, in the view Epstein' legal counsel no longer operative. The supplemental affidavit, however, did not clarify what terms of the agreement had been discussed. + +47. On April 9, 2009, counsel for Jane Doe #1 and Jane Doe #2 sent to the Court in this case (via the PACER system) a notice of a change of law firm affiliation. Doc. #37. + +48. In approximately May 2009, counsel for Jane Doe #1 and Jane Doe #2 propounded discovery requests in both state and federal civil cases against Epstein, seeking to obtain correspondence between Epstein and prosecutors regarding his plea agreement — information that the U.S. Attorney's Office was unwilling to provide to Jane Doe #1 and Jane Doe #2. Epstein refused to produce that information, and extended litigation to obtain the materials followed. Edwards Declaration at xxxxx. + +49. Because of this extended litigation, Jane Doe #1 and Jane Doe #2 did not have access to important correspondence demonstrating a violation of their rights until June 30, 2010. On that day, counsel for Epstein sent to Bradley J. Edwards, Esq., legal counsel for Jane Doe #1 and Jane Doe #2, approximately 358 pages of e-mail correspondence between his legal counsel and the U.S. Attorney's Office for the Southern District of Florida regarding the plea agreement that had been negotiated between them. See Attachment 1 to Edwards Aff. These e-mail disclosed for the first time the steps that had been taken by the U.S. Attorney's Office to avoid having the victims in the case learn about the non-prosecution agreement that had been reached between + +Epstein and the Government. Litigation continues to this day to obtain the correspondence regarding the state prosecution and regarding what Epstein's attorneys said in the correspondence with the prosecutors. Edwards Declaration at xxxxxx. + +50. In mid-July 2010, Jane Doe #1 and Jane Doe #2 settled their civil lawsuits against Mr. Epstein. Notice of this fact was promptly provided to the Court. Edwards Declaration at xxx. + +51. On September 8, 2010, the Court entered an order stating that "[a]n examination fo the docket reveals that no activity has taken place in this case since April of 2009. In light of the underlying settlements between the victims and Mr. Epstein, it is hereby ordered and adjudged that this case is closed." Doc. #38. + +52. Promptly on the heels of this administrative order, on September 13, 2010, Jane Doe #1 and Jane Doe #2 filed a notice that they "intend to make subsequent filing in the case shortly. They accordingly request administrative reopening of the case and, if the Court deems it advisable, a scheduling conference with the U.S. Attorney's Office regarding the case." Doc. #39 at 1. They further advised the Court that their settlements with Jeffrey Epstein in no way affected "their determination to move forward with the above-captioned CVRA action against a different entity — the U.S. Attorney's Office for the Southern District of Florida." Id. at 2. The pleading further advised that "[i]f the Court wishes to proceed to an expeditious conclusion to this Case, Jane Doe #1 and Jane Doe #2 have no objection to the Court setting up an expedited schedule for proceeding on the case." Id. The pleading further advised that the reason the victims had not filed for summary judgment in the case was that they had been attempting to secure correspondence between the U.S. Attorney's Office and Epstein to corroborate their argument that the Office had violated their rights. They noted that they had just secured half of that + +correspondence two months earlier. Id. at 2. The victim asked that, "if the Court deems it advisable, that a scheduling conference be set for this case." + +53. At all times material to this statement of facts, it would have been practical and feasible for federal government to inform Jane Doe #1 and Jane Doe #2 of the details of the proposed nonprosecution agreement with Epstein, including in particular the fact that the agreement barred any federal criminal prosecution. 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Cassell, Esq. + +222 S. 1490 E. Dr. - 101 +[Redacted] + +October 23, 2010 + +A [Redacted] +U.S. Attorney's Office +for the Southern District of Florida +99 N.E. 4th Street +Miami, FL 33131 Via [Redacted] + +Re: Protecting the Rights of Jane Doe #1 and Jane Doe #2 + +Dear Dexter: + +First, as mentioned before, please feel free to call me "~~Paul~~" rather than "Judge Cassell." Brad Edwards and I hope to build a close and friendly working relationship with you as we proceed with our efforts to protect victims' rights. Also, if you could copy [Redacted] on our e-mails, that would be helpful at our end. (Do you want me to "cc" [Redacted]). + +On behalf of Jane Doe #1 and Jane Doe #2 ("the victims"), I am writing to respond to the e-mail you sent to me yesterday. I am happy to hear that the Government will now agree with factual assertions that we present if they are correct. Attached along with this letter is a draft statement of facts section that the victims are in the process of preparing to file with the Court on October 27, 2010. The victims of course request your agreement to all of the facts presented there, as they obviously believe that they are all correct. + +If you believe that any of the facts they propose are incorrect, Jane Doe #1 and Jane Doe #2 would reiterate their long-standing request that you work with us to arrive at a mutually-agreed statement of facts. As you know, in the summer of 2008 Jane Doe #1 and Jane Doe #2 were working with you on a stipulation of facts when you reversed course and took that position that no recitation of the facts was necessary (*see* doc. #19 at 2). In particular, on July 29, 2008, you filed a Notice to Court Regarding Absence of Need for Evidentiary Hearing (doc. #17). At that time, you took the position that, because no federal criminal charges had been filed in the Southern District of Florida, no additional evidence was required to decide the victims' petition that was before the Court. I hope that your e-mail means that you will at least look at our facts and propose any modifications that you deem appropriate. Having that evidence quickly available to the Court could well help move this case to a conclusion. + +As you also know, because of the Government's decision not to work with us on agreed facts, we have had to secure information regarding the basis for your Office's treatment of the + +victims from other sources. This has been an arduous process, since the only remaining source for much of the information was Jeffrey Epstein. As you know, he is a politically-connected billionaire that employs legions of attorneys to obstruct any efforts to obtain information from him. Fortunately, after extended litigation, on June 30, 2010, we obtained information from him that was highly relevant to the treatment of Jane Doe #1 and Jane Doe #2 in the criminal justice system — namely, correspondence between your Office and legal counsel for Jeffrey Epstein during the negotiations surrounding the non-prosecution agreement. Many of our "facts" come straight from these e-mails. I trust that you will agree that our recitations of the e-mails are correct and that they accurately reflect communications between your Office and Epstein's legal counsel during the plea negotiation process. + +As you will note, Epstein's legal counsel redacted half of the correspondence specifically, all statements made by them to your Office. While this was done in violation of the court-ordered production, we never obtained a ruling on our motion for contempt because Epstein settled his civil cases with the victims shortly after we filed the contempt motion. Of course, that undisclosed half of the correspondence remains highly relevant to the issues under discussion in this CVRA case. We are continuing to try to obtain that information in Florida state court. While we have previously been politely rebuffed by you in our efforts to gain more information about Jane Doe #1 and Jane Doe #2's treatment, I wanted to make one more request to you to provide (in particular) the other half of the correspondence connected with the nonprosecution agreement. This correspondence would be highly useful to the victims, as well as to the Court, in developing a complete factual recording surrounding the victims' treatment. + +On another note, I was surprised to see in your e-mail what seemed to be a request for the victims to file a formal civil complaint. In particular, you stated: "No complaint has been filed [by the victims], which is the normal mechanism for commencing a civil action. Consequently, the government has not filed an answer." In July 2008, we elected to file a petition on behalf of Jane Doe #1 and Jane Doe #2 asking the Court to declare a CVRA violation — rather than a civil complaint. I have been involved in CVRA enforcement actions across the country at all levels of the federal courts, and this approach is the normal one for these courts (including courts of this Circuit). See, e.g., In re Stewart (I Ph Cir. 2008) (CVRA enforcement action commenced by motion); In re Antrobus (10th Circuit 2008) (same); In re Dean (5th Cir. 2008) (same). Indeed, in an important case in the District of Montana involving enforcement of victims' rights in the W.R. Grace case, I proceeded in this fashion at the direction of the Justice Department (i.e., the U.S. Attorney for the District of Montana, with whom we were working closely). In re Parker (9th Cir. 2009). So far as I can recall, in none of our previous discussions in this case have you raised the suggestion that a civil complaint was necessary to the resolution of this matter. Nor have you raised any such suggestion in court on previous hearings in this case. Would you be willing to explain what procedural steps you think we need to bring this matter to a conclusion? That way we can work with you to avoid unnecessary procedural wrangling. The Justice Department is, of course, statutorily obligated to use its "best efforts" to "see that crime victims are ... accorded the rights described in [the CVRA]." 18 U.S.C. § 3771(c)(1). Raising previously-undisclosed procedural objections to crime victims' efforts to protect their rights does not seem consistent with your Office's statutory obligations. + +I was also surprised to read in your e-mail the statement that "[w]e will also be seeking dismissal on the ground of failure to prosecute." On behalf of Jane Doe #1 and Jane Doe #2, I respectfully ask you to reconsider that decision to attempt to throw another procedural roadblock in the path of the victims as they seek to secure their rights. Any such motion would not be legally well-founded. And I would be less than candid if I did not report to you our perception that, with all due respect, such a motion would smack of Government sandbagging of the victims. We presume that you and others in your office (i.e., Assistant U.S. Attorney Marie Villafafta) have been well aware of Jane Doe #1's and Jane Doe #2's efforts that past year-and-ahalf to obtain information from Epstein relevant to their CVRA case. And during that time, Bradley J. Edwards and I have had many formal (and informal) contacts with the U.S. Attorney's Office. Until yesterday, no one in the Office has ever suggested that we had been less than diligent in pursuing the CVRA case or that we needed take steps other than the ones we were pursuing. For example, as you know, on September 13, 2010, we filed with the Court a notice in this CVRA case regarding our intention to make additional filings shortly. In that notice, we specifically offered to the Court (if it thought it helpful) to set up a scheduling conference with your Office to bring the case to an expeditious conclusion. That notice was served on your Office via the PACER electronic filing system. Yet, in spite of that offer to set up a scheduling conference made more than a month ago, your Office said nothing to the victims about doing so — until informing them yesterday of your intent to argue that we have failed to diligently prosecute the action. + +Jane Doe #1 and Jane Doe #2 believe that any such motion to dismiss their case would violate your Office's statutory obligations to use its "best efforts" to protect their rights. 18 U.S.C. § 3771(c)(1). To make a motion to dismiss for failure to prosecute, your Office would be required to assume the truth of the allegations made by the victims (i.e., that your Office has violated their rights under the CVRA) but nonetheless move to dismiss their case. Your Office has never communicated to the victims any belief that any deadline was pending in the CVRA case or that our approach of attempting to obtain information through litigation with Epstein was somehow taking too long. A phone call or e-mail to us at any point during the process would have alerted us to your view on the issue and allowed us to work with you to address any concerns that you had about moving this case more rapidly. I respectfully submit that your silence on any need to move more quickly — at the same time as we were repeatedly in connect with Justice Department representatives - should lead you not to file any such failure-toprosecute motion. + +If after reviewing Jane Doe #1 and Jane Doe #2's points in this letter you still believe such a motion is appropriate, I respectfully request that you extend to them the same consideration that you extended to Jeffrey Epstein, the man who repeatedly sexually abused them. In particular, we would respectfully request an opportunity to confer and discuss such a motion before it is filed with: (1) The First Assistant U.S. Attorney in your Office; (2) if necessary, the U.S. Attorney; and (3) if necessary, the Child Exploitation and Obscenity Section of the Criminal Division of the Justice Department (CEOS). + +As we have now learned from reading the e-mails, your Office decided to enter into a non-prosecution agreement with Jeffrey Epstein( and make numerous other concessions to him) only after his legal representatives were allowed to plead his case to the First Assistant, the U.S. Attorney, and CEOS through repeated meetings, telephone calls, e-mails, and letters. These discussions appear to have been far more extensive than is normally allowed to criminal defendants (particularly sex offenders) prosecuted by your Office. + +Unlike Epstein, Jane Doe #1 and Jane Doe #2 do not come from a wealthy background and lack political power. They nonetheless respectfully ask your Office to extend to them the same opportunities to protect their interests as you extended to him. Unlike Epstein — a man who committed numerous federal sexual offenses — they are innocent victims. Unlike Epstein — who had no right to engage in plea bargaining with your Office — they have a congressionallypromised "right" to "confer with the attorney for the Government in the case." 18 U.S.C. § 3771 (a)(5). Before taking any action that will prevent them from protecting their rights including in particular filing a motion to dismiss — we respectfully request the same conferral rights that you gave Mr. Epstein with the First Assistant, the U.S. Attorney, and (if necessary) CEOS. + +Finally, Mr. Edwards and I stand ready to work with you to narrow the range of issues under consideration in this case. The newly-revealed e-mails appear to make it clear that your Office made a decision not to inform that Jane Doe #1 and Jane Doe #2 (and other victims) about the non-prosecution agreement. If you would be willing to stipulate to that fact — and then fully pursue your legal arguments and responses to the significance of that fact — this might help to move the case along to a more expeditious conclusion. We would appreciate the opportunity to discuss this idea with you in a telephone conference call at a mutually convenient time. + +Thank you again for your willingness to discuss all these issues. We look forward to continuing to work with you to protect the rights of Jane Doe #1 and Jane Doe #2. + +Sincerely, + +Paul G. 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LITIGATION HISTORY + +On July 7, 2008, plaintiff Jane Doe filed her "Emergency Victim's Petition for Enforcement of Crime Victim's Rights Act, 18 U.S.C. Section 3771." (D.E. I). On the same day, this Court issued an Order directing the United States Attorney to file a response to the petition by 5:00 p.m., Wednesday, July 9, 2008. (D.E. 3). + +On July 9, 2008, the United States Attorney filed the "Government's Response to Victim's Emergency Petition for Enforcement of Crime Victim Rights Act, 18 U.S.C. § 3771." (D.E. 7). The Court held a hearing on July 11, 2008. + +On August 18, 2008, the Court held a status conference. On August 21, 2008, the Court ordered the Government to produce a copy of the Non-Prosecution Agreement between the United States Attorney and Jeffrey Epstein, and simultaneously entered a protective order prohibiting petitioners from disseminating the Non-Prosecution Agreement beyond designated individuals. (D.E. 26). + +On September 25, 2008, petitioners filed their motion to unseal document. (D.E. 28). On October 8, 2008, the Government filed its response in opposition to petitioners' motion. (D.E. 29). Petitioners filed their reply on October 16, 2008. (D.E. 30). On February 12, 2009, the Court denied petitioners' motion to unseal document. (D.E. 36). + +Since February 12, 2009, there has been no activity in this case, other than the filing of a notice by petitioners' counsel of his change in firm affiliation. (D.E. 37). + +# II. THIS CASE SHOULD BE DISMISSED FOR LACK OF PROSECUTION + +Under Fed.R.Civ.P. 41(b), "[i]f the plaintiff fails to prosecute or to comply with these rules or a court order, a defendant may move to dismiss the action or any claim against it." In Goforth i Owens, 766 F.2d 1533 (11 ih Cir. 1985), the Eleventh Circuit observed that "[a] district court is authorized, on defendant's motion, to dismiss an action for failure to prosecute or to obey a court order or federal rule." iii at 1535. A court's + +power to dismiss is an inherent aspect of its authority to enforce its orders and insure prompt disposition of lawsuits. Id. , citing Link Wabash Railroad Co. , 370 U.S. 626, 630-31 (1962), and Jones Graham , 709 F.2d 1457, 1458 (11 di Cir. 1983). Under Rule 41(b), the legal standard to be applied is "whether there is a clear record of delay or willful contempt and a finding that lesser sanctions would not suffice." 766 F.3d at 1535. + +Dismissal of a case with prejudice is considered a sanction of last resort, applicable only in extreme circumstances. Id. + +The Government believes the instant case should be dismissed because of the clear record of delay. + +After the initial filing on July 7, 2008, and the emergency hearing on July 11, 2008, the only notable activity in the case was petitioners' invocation of this Court's authority to obtain a copy of the Non-Prosecution Agreement. + +D.E. 19. The Government, pursuant to the Court's Order to Compel Production and Protective Order (D.E. 26), provided a copy of the Agreement to petitioners. On September 25, 2008, petitioners attempted to have the Court "unseal" the Non-Prosecution Agreement (D.E. 28). The Government opposed the motion because the Non-Prosecution Agreement had never been filed with the Court, under seal or otherwise. D.E. 29. On February 12, 2009, the Court denied petitioners' motion (D.E. 36). The Court specifically addressed petitioners' claim that the Non-Prosecution Agreement should be unsealed because the government had mischaracterized some of its provisions: + +> If and when such alleged mischaracterizations become relevant to an issue to be decided by the Court, the parties will be given an opportunity to advance their positions and the Court will resolve the issue. If disclosure of the Agreement will be required for the Court to resolve the issue, appropriate disclosure will be ordered (D.E. 36 at 1-2). + +Since nothing has occurred in the instant case since the February 12, 2009 Order, presumably petitioners did not believe the mischaracterizations they claimed were made by the Government became relevant to any issue to be decided by the Court. + +On September 8, 2010, this Court entered its Order Closing Case (D.E. 38). The Court noted that "[a]n examination of the docket reveals that no activity has taken place in this case since April of 2009. In light of the underlying settlements between the victims and Mr. Epstein, it is hereby ORDERED AND ADJUDGED that this case is CLOSED ." (D.E. 38)(emphasis in original). It is not unreasonable to believe that the instant action under the Crime Victims Rights Act was auxiliary litigation to support petitioners' claims against Jeffrey Epstein for money damages, particularly with regard to obtaining documents and information from the United States Attorney. Once petitioners' damage claims against Mr. Epstein had been resolved, there would be no + +need for this auxiliary litigation. The absence of any activity in the case since April 2009 supports the conclusion that vindicating the petitioners' rights under the CVRA was not the primary purpose of this case. + +"A district court has inherent authority to manage its own docket `so as to achieve the orderly and expeditious disposition of cases." yL Properties, Inc. Florida Mowing and Landscape Service, Inc. , 556 F.3d 1232, 1240 (11 d. Cir. 2009)(citation omitted). Under Rule 41(b), the court may dismiss a claim if the plaintiff fails to prosecute it or comply with a court order. Id. "The power to invoke this sanction is necessary in order to prevent undue delays in the disposition of pending cases and to avoid congestion in the calendars of the District Court." Id. , citing Durham I. Fla. East Coast Ry. Co. , 385 F.2d 366, 367 (5 th Cir. 1967). The instant case was filed as an emergency matter on July 7, 2008. Within two days, the government filed a written response to the emergency petition, and the Court held an emergency hearing four days after the emergency petition was filed. After this initial flurry of activity, predicated on petitioners' claim of an emergency, petitioners have done little to advance the litigation and seek resolution of their claims. a This clear record of delay provides ample basis for this Court to exercise its discretion and dismiss this case for lack of prosecution under Rule 41(b). + +### III. PETITIONERS HAVE FAILED TO STATE A CLAIM UPON WHICH RELIEF CAN BE GRANTED UNDER 18 U.S.C. § 3771(aX5) + +The heart of petitioners' claim under the Crime Victims Rights Act (CVRA) is that the United States Attorney was legally obligated, under 18 U.S.C. § 3771(a)(5), to consult with them prior to entering into the Non-prosecution Agreement with Jeffrey Epstein. D.E. 1, ¶ 5. This claim should be dismissed under Rule 12(b)(6) because it fails to state a claim upon which relief can be granted. + +In Bell Atlantic Corp. Twombly , 127 S.Ct. 1955 (2007), the Supreme Court observed that a plaintiff's obligation to provide the grounds of his entitlement to relief requires more than labels and conclusions, and a formulaic recitation of the elements of a cause of action will not do. Id. at 1964-65. Instead, factual allegations must be enough to raise a right to relief above the speculative level. "The standard is one of "plausible grounds to infer." Id. In Ashcroft I bal , 129 S.Ct. 1937 (2009), the Supreme Court noted that two working principles underlay its decision in Twombly : (1) the tenet that a court must accept as true all of the allegations contained in a complaint is inapplicable to legal conclusions; and (2) only a complaint that states a plausible claim for relief survives a motion to dismiss. Id. at 1949-50. + +The rights of crime victims are set forth in 18 U.S.C. § 3771(a), and include eight (8) specific rights. + +3771(a)(2), the right to reasonable, accurate, and timely notice of any public court proceeding; § 3771(a)(6), the right to full and timely restitution as provided in law; and notice of her rights under the CVRA. + +It is undisputed that no federal criminal charges have been filed against Jeffrey Epstein, in the U.S. District Court, Southern District of Florida, pertaining to the sexual abuse of minors. fi The United States submits that, since there is no "case" pending in the Southern District of Florida against Epstein, or any "court proceeding" involving an offense against Jane Does 1 and 2, they cannot invoke any protections under 18 U.S.C. § 3771(a)(2) and (5). + +Title 18, United States Code, § 3771(a)(5), provides that a crime victim has "(t]he reasonable right to confer with the attorney for the Government in the case." In its interpretation of a federal statute, the court assumes that "Congress used words in a statute as they are commonly and ordinarily understood," and reads the statute to give full effect to each of its provisions. United States U DBB, Inc. , 180 F.3d 1277, 1281 (11 LI' Cir. + +1999), citing United States McLymont , 45 F3d 400, 401 (11 di Cir. 1995). Section 3771(a)(5) grants a crime victim the reasonable right to confer with the attorney for the Government "in the case." The phrase "in the case" must be considered since there is a canon of statutory construction that "discourages courts from adopting a reading of a statute that renders any part of the statute mere surplusage." Baile' United States , 516 U.S. 137, 146 (1995)(noting that each word in a statute is intended to have "particular, nonsuperfluous meaning"). + +Respondents submit that Congress intended the phrase "in the case" to mean a case filed in the district court. Federal criminal cases are filed in the United States district courts through the filing of a criminal complaint, Fed.R.Crim.P. 3, or indictment, Fed.R.Crim.P. 7. In each instance, an attorney representing the United States Government is required to sign the complaint or indictment. Thus, each criminal case filed in the district court has an attorney for the Government representing the sovereign United States. + +In contrast, § 3771(a)(1) provides that a crime victim "has the right to be reasonably protected from the accused." No mention is made about a case or court proceeding. Thus, Congress intended that this right attaches even before a case is filed in the district court. The absence of any mention of the attorney for the Government is also telling, since the case may still be in the investigative stage, and not yet been assigned an attorney. In such a case, the federal law enforcement agency would be responsible for providing the reasonable protection from the accused. + +Because there is not any case against Epstein in the Southern District of Florida, Jane Does 1 and 2 have no rights under § 3771(a)(5) to consult with the attorney for the Government. The United States Attorney's + +Office was under no obligation to consult with Jane Does 1 and 2 prior to concluding its Non-Prosecution Agreement with Epstein. For the same reason, Jane Doe's claim under § 3771(a)(2) also fails. There has been no "public court proceeding" against Epstein in the U.S. District Court, Southern District of Florida, since no criminal case has been filed against him in the federal court. Consequently, there has been nothing for which the U.S. Attorney's Office was required to give notice to Jane Doe. + +A different provision in the CVRA, 18 U.S.C. § 3771(b), also supports the Government's interpretation of § 3771(a)(5). Section 3771(b)(1) provides as follows: + +> In any court proceeding involving an offense against a crime victim, the court shall ensure that the crime victim is afforded the rights described in subsection (a). + +> Before making a determination described in subsection (a)(3), the court shall make every effort to permit the fullest attendance possible by the victim and shall consider reasonable alternatives to the exclusion of the victim from the criminal proceeding. The reasons for any decision denying relief under this chapter shall be clearly stated on the record. + +There is no "court proceeding" in this case because no federal criminal charges have been lodged against Jeffrey Epstein. Section 3771(b)(1) envisions that a district court presiding over a criminal trial will be responsible for ensuring that a crime victim will be afforded rights granted in § 3771(a). Section 3771(a)(3), which is expressly referenced in § 3771(b)(1), provides that a crime victim has + +> The right not to be excluded from any such public court proceeding, unless the court, after receiving clear and convincing evidence, determines that testimony by the victim would be materially altered if the victim heard other testimony at that proceeding. + +This provision contemplates that, in the event a defendant invokes the rule of sequestration in Fed.R.Evid. 615, the court must consider the crime victim's rights under § 3771(a)(3), and can only exclude the victim from the proceeding if the court finds there is clear and convincing evidence that the victim's testimony would be materially altered if the victim was allowed to hear other testimony at the proceeding. By providing a difficult evidentiary standard which must be met before a victim's right to be present in the court proceeding can be denied, Congress was purposefully limiting a court's discretion in sequestering trial witnesses. + +In the instant case, there is no "court proceeding" since no federal criminal charges have been brought against Epstein. Therefore, § 3771(b)(1) is inapplicable. There is no role for this Court to fulfill under § 3771(b)(1). + +The petition fails to state facts upon which the Court can find a plausible claim for relief exists. + +Accordingly, the petition should be dismissed for failure to state a claim upon which relief can be granted. + +### IV. SEPARATION OF POWERS PRINCIPLES PRECLUDE THE COURT FROM GRANTING ANY RELIEF REGARDING THE NON-PROSECUTION AGREEMENT + +In the instant case, the Non-Prosecution Agreement between the Government and Jeffrey Epstein was concluded in September and October 2007, months before petitioners instituted their action. By entering into the Non-Prosecution Agreement, the United States was exercising its prosecutorial discretion as to the best means to resolve the allegations that Epstein had violated federal law by engaging in criminal sexual misconduct with minors. + +The Executive Branch enjoys exceedingly broad discretion in deciding how, or whether, to charge an individual. Bordenkircher l Hayes , 434 U.S. 357, 668 (1978)("In our system, so long as the prosecutor has probable cause to believe that the accused committed an offense defined by statute, the decision whether or not to prosecute, and what charge to file or bring before a grand jury, generally rests entirely in his discretion") (footnote omitted), and Nixon I United States, 418 U.S. 683, 693 (1974)(Executive Branch has exclusive authority and absolute discretion to decide whether to prosecute a case). Mindful of that principle, Congress expressly provided in the CVRA that, "Enjothing in this chapter shall be construed to impair the prosecutorial discretion of the Attorney General or any officer under his direction." 18 U.S.C. § 3771(d)(6). + +Petitioners had no right under the CVRA to confer with the attorney for the Government, prior to the entry into the Non-Prosecution Agreement, because there was no existing case in the U.S. District Court. + +Moreover, even if they had the right to confer, they had no legal means to prevent the United States from negotiating the Agreement it ultimately entered into with Epstein. Unlike the situation in In Re Dean , 527 F.3d 391 (5 1 Cir. 2008), the Non-Prosecution Agreement did not come before any federal court for review and approval, nor was such action required. In Dean , if the district court believed that the victims had been denied their right to consult under § 3771(a)(5), it could reject the plea agreement and direct that the required consultation occur prior to the negotiation of any new plea agreement. In contrast, the Non-Prosecution Agreement never came before this court. Therefore, this Court is without authority to provide a remedy under § 3771(b)(1). + +Respectfully submitted, + +WIFREDO A. FERRER UNITED STATES ATTORNEY + +By: + +![](_page_5_Picture_7.jpeg) + +I HEREBY CERTIFY that on October , 2010, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. + +![](_page_6_Picture_2.jpeg) + +#### SERVICE LIST + +Jane Does 1 and 2 1 United States, + +Case No. 08-80736-CIV-MARRA/JOHNSON + +United States District Court, Southern District of Florida + +Brad Edwards, Esq., + +The Law Offices of Brad Edwards & Associates LLC + +![](_page_6_Picture_9.jpeg) + +ttorneys for Petitioners + +a The emergency was based upon petitioners' belief that Jeffrey Epstein was engaged in plea negotiations with the United States Attorney's Office and that such negotiations would likely result in a disposition of the charges within the "next several days." D.E. 1, ¶ 3. The petitioner noted that Epstein had already entered a plea of guilty on June 30, 2008, in the Circuit Court for Palm Beach County, Florida, to similar state offenses including solicitation of minors for prostitution. D.E. 1, ¶ 2. + +E "A district court may take judicial notice of public records within its files relating to the particular case before it or other related cases." Cash Inn of Dade, Inc. I Metropolitan Dade County , 932 F.2d 1239, 1243 (11 ih Cir. 1991)(citations omitted). Additionally, in a Rule 12(b)(6) motion, a court may properly consider materials of which it has taken judicial notice. \ No newline at end of file diff --git a/marker2/ds9/EFTA00206755/EFTA00206755.metadata.json b/marker2/ds9/EFTA00206755/EFTA00206755.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..57b7b7fc369f967371d8b9a815df5baea51d5876 --- /dev/null +++ b/marker2/ds9/EFTA00206755/EFTA00206755.metadata.json @@ -0,0 +1,452 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206755.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 7, + "chars": 17921, + "elapsed_seconds": 1.58, + "image_assets": [ + "_page_0_Picture_2.jpeg", + "_page_5_Picture_7.jpeg", + "_page_6_Picture_2.jpeg", + "_page_6_Picture_9.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF FLORIDA \nCase No. 08-80736-Civ-Marra/Johnson", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 206.24400000000003, + 31.589999999999996 + ], + [ + 405.5555419921875, + 31.589999999999996 + ], + [ + 405.5555419921875, + 74.103515625 + ], + [ + 206.24400000000003, + 74.103515625 + ] + ] + }, + { + "title": "RESPONDENT'S MOTION TO DISMISS", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 198.89999999999998, + 153.09 + ], + [ + 413.7095947265625, + 153.09 + ], + [ + 413.7095947265625, + 168.603515625 + ], + [ + 198.89999999999998, + 168.603515625 + ] + ] + }, + { + "title": "I. 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+Attachments: motion-finding-violation3.doc; edwards-affidavit-cvra3.doc; response-order-showcause.docx + +Dear + +I wanted to send you drafts of the pleadings we are in the process of preparing to file tomorrow, pursuant to Judge Marra's order. As mentioned in several previous e-mails, we stand ready to work with you to try and narrow the range of disputed facts — and trust that you will be willing to stipulate to all the facts that are correct in our pleadings. (Most of them are now based on documented e-mails, so we trust the bulk of the facts will gain your stipulated approval.) + +I am also writing because co-counsel Brad Edwards has been working with on a possible approach to the filings tomorrow. At ilt s suggestion, Brad has offered to take out a paragraph that Marea was concerned about in our fact section and to file our pleadings under seal tomorrow for, say, a period of (at least) two weeks. This would give us an opportunity to work with you to resolve disputed facts and, more generally, to try and resolve the entire dispute. In exchange, we request that you agree not to file a motion to dismiss for lack of prosecution and not to argue that we need to file some sort of civil complaint to litigate these issues (both suggestions you raised in your earlier e-mail). Brad and I don't believe such arguments would be legally well founded in any event. But if you are asking for concessions on our part, we would like to narrow the subjects of the litigation that we have to respond to in exchange. + +As we have mentioned at every stage of this case, we stand ready to work with you to try and resolve the matter. We continue to be willing to attempt a fair resolution that protects our client's interests. Along those lines, if you have concerns about us filing our pleadings under seal tomorrow, we are ready to discuss the idea of delaying any filing for a period of, say, two weeks. Such a delay, however, would be contingent on your obtaining an extension from Judge Marra of our filing deadline. As you can see, we are ready to file and would delay only as an accommodation to you — and would except you to do the motion that would be required for such an extension). + +Brad and I stand ready to discuss these issues at any time with you and/or Marie. + +Sincerely, + +Paul Cassell + +Counsel for Jane Doe #1 and Jane Doe #2 + +801-201-8271 (cell phone) + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the sender by reply electronic mail and delete the original message. 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Based on this correspondence and other evidence, it is now clear that the U.S. Attorney's Office has repeatedly violated the protected rights of the victims under the CVRA, including their right to confer with prosecutors generally about the case and specifically about a non-prosecution agreement it signed with the defendant. It is now beyond dispute that in September 2007, the U.S. Attorney's Office reached a non-prosecution agreement with Jeffrey Epstein that barred his prosecution for numerous + +federal sex offense he committed against the victims (as well as against many other minor girls). Rather than confer with the victims about this non-prosecution agreement, however, the U.S. Attorney's Office agreed to a "confidentiality" provision in the agreement barring the agreement's disclosure to anyone — including the victims. For the next nine months, the U.S. Attorney's Office assiduously concealed from the victims the existence of this signed nonprosecution agreement. For example, the U.S. Attorney's Office stopped sending victim notifications about the case when defendant Epstein objected. Indeed, the Office went so far as to send (in January 2008) a false victim notification letter to the victims informing them that the "case is currently under investigation," when in fact the U.S. Attorney's Office had already resolved the case three months earlier by signing the non-prosecution agreement. Again on May 30, 2008, the U.S. Attorney's Office sent yet another victim notification letter to a recognized victim informing her that the "case is currently under investigation" and that it "can be a lengthy process and we request your continued patience while we conduct a thorough investigation." Then in June 2008, on the eve of consummating Epstein's state guilty plea that was part nonprosecution agreement, the U.S. Attorney's Office asked legal counsel for Jane Doe #1 and Jane Doe #2 to send a letter in writing expressing the victims' views on a possible plea bargain — not disclosing to the victims' legal counsel that this was a pointless exercise because the nonprosecution agreement had already been signed some nine months earlier. + +All of these actions and many more like them constitute clear violations of Jane Doe #1 and Jane Doe #2's rights under the Crime Victims Rights Act. The Court should accordingly find that the U.S. Attorney's Office has violated the Act and set a briefing schedule and hearing on the proper remedy for those violations. + +### STATEMENT OF FACTS + +Jane Doe #1 and Jane Doe #2 offer the following statement of facts, which they are prepared to establish at any evidentiary hearing that the Court might schedule. + +1. Between about 2001 and 2006, defendant Jeffrey Epstein (a billionaire with significant political connections) sexually abused more than 40 minor girls at his mansion in West Palm Beach, Florida, and elsewhere. Among the girls he sexually abused were Jane Doe #1 and Jane Doe #2. Because Epstein used a means of interstate commerce and knowingly traveled in interstate commerce to engage to abuse Jane Doe #1 and Jane Doe #2 (and the other victims), he committed violations of federal law, specifically repeated violations of 18 U.S.C. § 2422. + +2. In 2006, at the request of the Palm Beach Police Department, the Federal Bureau of Investigation ("FBI") opened an investigation into allegations that Jeffrey Epstein ("Epstein") and his personal assistants had used facilities of interstate commerce to induce young girls between the ages of thirteen and seventeen to engage in prostitution, among other offenses. The case was presented to the United States Attorney's Office for the Southern District of Florida, which accepted the case for investigation. The Palm Beach County State Attorney's Office was also investigating the case. See Declaration of Bradley J. Edwards, Esq. at & & 1-2 (hereinafter "Edwards Declaration"). + +3. The FBI determined that both Jane Doe #1 and Jane Doe #2 were victims of sexual assaults by Epstein while they were minors beginning when they were approximately fourteen years of age and approximately thirteen years of age respectively. Edwards Declaration at & 2. + +4. On about June 7, 2007, FBI agents hand-delivered to Jane Doe #1 a standard CVRA victim notification letter. See Edwards Declaration, Exhibit "A." The notification promises that the Justice Department would makes its "best efforts" to protect Jane Doe #1's rights, including "[t]he reasonable right to confer with the attorney for the United States in the case" and "to be reasonably heard at any public proceeding in the district court involving . . . plea . . . ." The notification further explained that "Tait this time, your case is under investigation." That notification meant that the FBI had identified Jane Doe #1 as a victim of a federal offense and as someone protected by the CVRA. + +5. On about August 11, 2007, Jane Doe #2 received a standard CVRA victim notification letter. See Edwards Declaration, Exhibit "B." The notification promised that the Justice Department would makes its "best efforts" to protect Jane Doe #2's rights, including "[t]he reasonable right to confer with the attorney for the United States in the case" and "to be reasonably heard at any public proceeding in the district court involving . . . plea ...." The notification further explained that "[a]t this time, your case is under investigation." That notification meant that the FBI had identified Jane Doe #2 as a victim of a federal offense and as someone protected by the CVRA. + +6. Early in the investigation, the FBI agents and the Assistant U.S. Attorney had several meetings with Jane Doe #1. Jane Doe #2 was represented by counsel that was paid for by the criminal target Epstein and, accordingly, all contact was made through that attorney. Edwards Declaration at & 5. + +7. In and around September 2007, plea discussions took place between Jeffrey Epstein, represented by numerous attorneys (including lead criminal defense counsel Jay Lefkowitz), and the U.S. Attorney's office for the Southern District of Florida, represented primarily by Assistant U.S. Attorney A. Marie The plea discussions generally began from the premise that Epstein would plead guilty at least one federal felony offense surrounding his sexual assaults of more than 40 minor girls. From there, the numerous defense attorneys progressively negotiated more favorable plea terms so that Epstein would ultimately plead to only two state court felony offenses and would serve only county jail time. Many of the negotiations are reflected in e-mails between Lefkowitz and Copies of the correspondence are attached as Exhibit J to the Edwards Declaration accompanying this filing (hereinafter cited as "U.S. Attorney's Correspondence" and referenced by Bates number stamp).1 Because Epstein has moved to keep these documents from the public, they are at this time filed under seal with the Court. + +8. At the time of plea discussions, the U.S. Attorney's Office had an 82-page prosecution memorandum outlining numerous federal sexual offenses committed by Epstein, and had prepared a 53-page indictment for numerous federal offenses. U.S. Attorney's Correspondence at 4. + +9. In September 2007, Assistant U.S. Attorney (AUSA) A. Marie in an effort to avoid prosecuting Epstein for his numerous sexual offenses against children, proposed to Epstein's attorneys that rather than plea to any charges relating to him molesting children, Epstein should instead plead to a single assault charge involving a telephone call made by Epstein while he was on his private jet. During the telephone call, Epstein warned his personal assistant, Lesley Groff, against turning over documents and electronic evidence responsive to a subpoena issued by a federal grand jury in the Southern District of Florida investigating Epstein's sex offenses. U.S. Attorney's Correspondence at 49, 58. + +Through diligent efforts, counsel for Jane Doe #1 and Jane Doe #2 received copies of half of the e-mail correspondence (the half reflecting communications to defense counsel) on about June 30, 2010. See Edwards Declaration at & &20-22. + +10. The correspondence also shows that itkaapevas interested in finding a place to conclude a plea bargain that would effectively keep the victims from learning what was happening through the press. She wrote in an e-mail to defense counsel: "On an 'avoid the press' note, I believe that Mr. Epstein's airplane was in Miami on the day of the Ms. Groff telephone call. If he was in Mimi-Dade County at the time, then I can file the charge in the District Court in Miami, which will hopefully cut the press coverage significantly." U.S. Attorney's Correspondence at 29. Ms. was aware that most of the victims of Epstein, including Jane Doe #1 and Jane Doe #2, resided outside the Miami area. + +II. On about September 24, 2007, Assistant U.S. Attorney A. Marie sent an e-mail to Jay Lefkowitz, criminal defense counsel for Epstein, regarding the agreement. The e-mail stated that the Government and Epstein's counsel would negotiate between themselves about what information would be disclosed to the victims about the agreement: + +Thank you, Jay. I have forwarded your message only to Alex [Acosta], PRIlly. ai iriI don't anticipate it going any further than that. When I receive the originals, I will sign and return one copy to you. The other will be placed in the case file, which will be kept confidential since it also contains identifying information about the girls. + +When we reach an agreement about the attorney representative for the girls, we can discuss what I can tell him and the girls about the agreement. I know that Andy promised IFIIIIIMPLIM an update when a resolution was achieved. . . . calling, but Slows not to tell Chief Relic' about the money issue, just about what crimes Mr. Epstein is pleading guilty to and the amount of time that has been agreed to. " ' ' ' 8 ' ' f 418•644466411840•60,100M12/ + +U.S. Attorney's Correspondence at 153 (emphases added). + +12. On about September 25, 2007, AUSA sent an e-mail to Lefkowitz stating: "And can we have a conference call to discuss what I may disclose to . . . the girls regarding the agreement." U.S. Attorney's Correspondence at 156. + +13. On about September 26, 2007, AUSA. sent an e-mail to Lefkowitz in which she stated: "Hi Jay — Can you give me a call at 561 209-[xxxx] this morning? I am meeting with the agents and want to give them their marching orders regarding what they can tell the girls." U.S. Attorney's Correspondence at 359. The reasonable inference is that the "marching orders" agreed to between the Government and Epstein's defense counsel was that no mention would be made of the non-prosecution agreement between the U.S. Attorney's Office and Epstein, as no subsequent mention was made to the victims of the non-prosecution agreement. + +14. On about September 27, 2007, Assistant U.S. Attorney revealed to an attorney (Bert Ocariz), who was under discussion to be a representative of victims of Epstein's sexual abuse in civil litigation, that the government was in the process of reaching a nonprosecution agreement with Epstein. An e-mail confirming these disclosures stated: "Bert's firm has raised a number of good questions about how they are going to get paid." U.S. Attorney's Correspondence at 161. The e-mail went on to state: "I told Bert that as part of our agreement we (the federal government) are not going to indict Mr. Epstein, but give him an idea of the charges that we had planned to bring as related to 18 USC 2255." Id. The e-mail also asked permission from Epstein's counsel to send to Ocariz a copy of parts of the plea agreement: "With respect to question 2 [a question from Ocariz regarding "[w]hen will it be possible to see the plea agreement so that we understand exactly what Epstein concedes to in the civil case?], do I have your permission to send Bert just that section of the plea agreement that applies to the damages claims (I would recommend sending paragraphs 7 through 10, or at least 7 and 8)?" Id. 15. On about September 25, 2007, ASUA sent a letter to Jay Jefkowitz in which she suggested that the victims should be represented by someone who was not an experienced personal injury attorney: "They [the other lawyers under consideration] are all very good personal injury lawyers, but I have concerns about whether there would be an inherent tension becaue they may feel that they might make more money . . . if they proceed outside the terms of the pela agreement. (Sony — I just have a bias against plaintiffs' attorneys.)" U.S. Attorney's Correspondence at 157. continued to push Ocariz as the best choice, in part because it would reduce publicity: "One nice thing about Bert [Ocariz] is that he is in Miami where teher has been almost no coverage of the case." Id. + +16. In a letter later sent by Jay Lefkowitz to the U.S. Attorney for the Southern District of Florida, Lefkowitz stated that ASUA had "assiduously" hidden from him the fact that Bert Ocariz was a friend of boyfriend. U.S. Attorney's Correspondence at 267. Lefkowitz also stated that had misleadingly used the term "friend" rather than the more accurate term "boyfriend" to describe who had recommended Ocariz. Id. at 268. Lefkowitz further stated the boyfriend had a business relationship with Ocariz and that the boyfriend would have financially benefitted from the presumably lucrative referral of sexual assault cases against Epstein to Ocariz. On December 13, 2007, wrote a letter to Lefkowitz to deny these accusations. In the letter, stated: ". I am surprised by your allegations regarding my role because I thought that we had worked very well together in resolving this dispute. I also am surprised because I feel that I bent over backwards to keep in + +mind the effect that the agreement would have on Mr. Epstein and to make sure that you (and he) understood the repercussions of the agreement." Id. + +17. On about September 24, 2007, Epstein and the U.S. Attorney's Office reached an agreement whereby the United States would defer federal prosecution in favor of prosecution by the State of Florida. Epstein and the U.S. Attorney's Office accordingly entered into a "Non-Prosecution Agreement" (NPA) reflecting their agreement. Most significantly, the NPA gave Epstein a promise that he would not be prosecuted for a series of federal felony offenses involving his sexual abuse of more than 30 minor girls. The NPA instead allowed Epstein to plead guilty to two state felony offenses for solicitation of prostitution and procurement of minors for prostitution. The NPA also set up a procedure whereby a victim of Epstein's sexual abuse could obtain an attorney representative to proceed with a civil claim against Epstein, provided that the victim agreed to proceed exclusively under 18 U.S.C. § 2255 (i.e., provided that the victim agreed to seek no more than \$150,000 in damages against Epstein — an amount that Epstein argued later was limited to \$50,000). See Edwards Declaration, Exhibit "C" (copy of the non-prosecution agreement). The agreement was signed by Epstein and his legal counsel, as well as the U.S. Attorney's Office, on about September 24, 2007. + +18. A provision in the non-prosecution agreement made the agreement secret. In particular, the agreement stated: "The parties anticipate that this agreement will not be made part of any public record. If the United States receives a Freedom of Information Act request or any compulsory process commanding the disclosure of the agreement, it will provide notice to Epstein before making the disclosure." By entering into such a confidentiality agreement, the U.S. Attorney's Office put itself in a position that notifying the crime victims (including Jane Doe #1 and Jane Doe #2) of the non-prosecution agreement would violate terms of the agreement — specifically the confidentiality provision. Accordingly, from September 24, 2007 through at least June 2008 — a period of more than nine months -- the U.S Attorney's Office did not notify any of the victims of the existence of the non-prosecution agreement. + +19. A reasonable inference from the evidence is that the U.S. Attorney's Office wanted the non-prosecution agreement kept from public view because of the intense public criticism that would have resulted from allowing a politically-connected billionaire who had sexually abused more than 40 minor girls to escape from federal prosecution with only a county court jail sentence and because of the possibility that the victims could have objected to the agreement in court and prevented its consummation. + +20. The Non-Prosecution Agreement that had been entered into between the U.S. Attorney's Office and Epstein was subsequently modified by an October 2007 Addendum and a December 19, 2007, letter from the U.S. Attorney to Attorney Lilly Ann Sanchez. See Supplemental Declaration of A. Marie doe. #35, at 1; U.S. Attorney's Correspondence at 234-37. The U.S. Attorney's Office did not notify any of the victims of the existence of these modifications of the agreement through at least June 2008 — a period of more than six months. On about August 14, 2008, Epstein's defense counsel told the U.S. Attorney's Office that they did not consider the December 19, 2007, letter to be operative. Id. + +21. In October 2007, shortly after the initial plea agreement was signed, Jane Doe #1 was contacted to be advised regarding the resolution of the investigation. On October 26, 2007, Special Agents • met in person with Jane Doe #1. The Special Agents explained that Epstein would plead guilty to state charges, he would be required + +to register as a sex offender for life, and he had made certain concessions related to the payment of damages to the victims, including Jane Doe #1. During this meeting, the Special Agents did not explain that an agreement had already been signed that precluded any prosecution of Epstein for federal charges. The agents could not have revealed this part of the non-prosecution agreement without violating the terms of the non-prosecution agreement. Whether the agents themselves had been informed of the existence of the non-prosecution agreement by the U.S. Attorney's Office is not certain. Because the plea agreement had already been reached with Epstein, the agents made no attempt to secure Jane Doe #1's view on the proposed resolution of the case. Edwards Declaration at & 7. + +22. Jane Doe # l's perception of the explanation provided by the Special Agents was that only the State part of the Epstein investigation had been resolved, and that the federal investigation would continue, possibly leading to a federal prosecution. Edwards Declaration at & 8. + +23. On about November 27, 2007, Assistant U.S. Attorney Jeff Sloman sent an e-mail to Jay Lefkowitz, defense counsel for Epstein. The e-mail stated that the U.S. Attorney's Office had an obligation to notify the victims about the plea agreement: + +The United States has a statutory obligation (Justice for All Act of 2004) to notify the victims of the anticipated upcoming events and their rights associated with the agreement entered into by the United States and Mr. Epstein in a timely fashion. Tomorrow will make one full week since you were formally notified of the selection. I must insist that the vetting process come to an end. Therefore, unless you provide me with a good faith objection to Judge Davis's selection [as special master for selecting legal counsel for victim pursuing claims against Epstein] by COB tomorrow, November 28, 2007, I will authorize the notification of the victims. Should you give me the go-head on Podhurst and Josephsberg selection by COB tomorrow, I will simultaneously send you a draft of the letter. I intend to notify the victims by letter after COB Thursday, November 29t°. + +U.S. Attorney's Correspondence at 255 (emphasis rearranged). + +24. On about November 29, 2007, Assistant U.S. AttorneyamIskiais sent a draft of a crime victim notification letter to Jay Lefkowitz, defense counsel for Jeffrey Epstein. The notification letter explained: "I am writing to inform you that the federal investigation of Jeffrey Epstein has been completed, and Mr. Epstein and the U.S. Attorney's Office have reached an agreement containing the following terms . ." The letter then went on to explain that Epstein would plead guilty to two state offenses and receive an 18 month sentence. The letter did not explain that, as part of the agreement with Epstein, the Justice Department had previously agreed not to prosecute Epstein for any of the numerous federal offenses that had been committed. U.S. Attorney's Correspondence at 256-59. + +25. Apparently because of concerns from Epstein's attorneys, the U.S. Attorney's Office never sent the proposed victim notification letter discussed in the previous paragraph to the victims. Instead, a misleading letter stating that the case was "currently under investigation" (described below) was sent in January 2008 and May 2008. At no time before reaching non-prosecution agreement did the Justice Department contact any victims, including for example Jane Doe #1, about their views on the non-prosecution. + +26. On about December 6, 2007, MNISSIINSIIMPII, First Assistant U.S. Attorney sent a letter to Jay Lefkowitz, noting the U.S. Attorney's Office's legal obligations to keep victims informed of the status of plea negotiations with Epstein. The letter stated: + +Finally, let me address your objections to the draft Victim Notification Letter. You write that you don't understand the basis for the Office's belief that it is appropriate to notify the victims. Pursuant to the "Justice for All Act of 2004," [another name from the CVRA] crime victims are entitled to: `The right to reasonable, accurate, and timely notice of any public court proceeding . . . involving the crime' and the `right not to be excluded from any such public court + +proceeding . . 18 U.S.C. § 3771(a)(2) & (3). Section 3771 also commands that `employees of the Department of Justice . . engaged in the detection, investigation, or prosecution of crime shall make their best efforts to see that crime victims are notified of, and accorded, the rights described in subection (a).' 18 U.S.C. § 3771(c)(1).... + +Our Non-Prosecution Agreement resolves the federal investigation by allowing Mr. Epstein to plead to a state offense. The victims identified through the federal investigation should be appropriately informed, and our Non-Prosecution Agreement does not require the U.S. Attorney's Office to forego its legal obligation. + +U.S. Attorney's Correspondence at 191-92 (emphasis added). + +27. Despite this recognition of its obligation to keep victims "appropriately informed" about the non-prosecution agreement, the U.S. Attorney's Office did not follow through and inform the victims of the non-prosecution agreement. To the contrary, as discussed below, it continued to tell the victims that the case was "under investigation." Edwards Declaration at & 4 and & 12. + +28. On December 13, 2007, sent a letter to Jay Lefkowitz, defense counsel for Epstein, rebutting charges that had apparently been made against her by the Epstein defense. The letter stated that a federal indictment against Epstein "was postponed for more than five months to allow you and Mr. Epstein's other attorneys to make presentations to the Office to convince the Office not to prosecute." The letter also recounted that "You and I spent hours negotiating the terms [of the non-prosecution agreement], including 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. •frentier -Meneheerrylemett and Acosta in the negotiations at various times." U.S. Attorney's Correspondence at 269. + +29. The December 13, 2007, letter also reveals that the Justice Department stopped making victim notifications because of objections from Epstein's criminal defense counsel: "Three victims were notified shortly after the signing of the Non-Prosecution Agreement of the general terms of the Agreement. You raised objections to any victim notification, and no further notifications were done." U.S. Attorney's Correspondence at 270 (emphasis added). + +30. Following the signing of the Agreement and the modifications thereto, Epstein's performance was delayed while he sought higher level review within the Department of Justice. See U.S. Attorney's Correspondence passim. + +31. On January 10, 2008, Jane Doe #1 and Jane Doe #2 received letters from the FBI advising them that "(t)his case is currently under investigation. This can be a lengthy process and we request you continued patience while we conduct a thorough investigation." See Doc. #14 (attachments 3 and 4 to declaration oall (emphasis added). The statement in the notification letter was false. The case was not currently "under investigation." To the contrary, the case had been resolved by the non-prosecution agreement entered into by Epstein and the U.S. Attorney's Office discussed previously. Moreover, the FBI did not notify Jane Doe #1 or Jane Doe #2 that a plea agreement had been reached previously, and that part of the agreement was a non-prosecution agreement with the U.S. Attorney's Office for the Southern District of Florida. Edwards Declaration at & 9. + +32. In early 2008, Jane Doe #1 and Jane Doe #2 came to believe that criminal prosecution of Epstein was extremely important. They also desired to be consulted by the FBI and/or other representatives of the federal government about the prosecution of Epstein. In light of the letters that they had received around January 10, they believed that a criminal investigation of Epstein was on-going and that they would be contacted before the federal government reached any final resolution of that investigation. Edwards Declaration at &10. + +33. On about February 25, 2008, Assistant U.S. Attorney Sloman sent an e-mail to Jay Lefkowitz, Epstein's criminal defense counsel, explaining that the Justice Department's Child Exploitation Obscenity Section (CEOS) had agreed to review Epstein's objections to the proposed plea agreement that had been reached with the U.S. Attorney's Office for the Southern District of Florida. The letter indicated that, should CEOS reject Epstein's objections to the agreement, then "Mr. Epstein shall have one week to abide by the terms and conditions of the September 24, 2007 Agreement as amended by letter from United States Attorney Acosta to Jay Lefkowitz." U.S. Attorneys Correspondence at 290-91. + +34. In about April 2008, Jane Doe #1 contacted the FBI because Epstein's counsel was attempting to take her deposition and private investigators were harassing her. Assistant U.S. Attorney ilmbia secured pro bono counsel to represent Jane Doe #1. Pro bono counsel was able to assist Jane Doe #1 in avoiding the improper deposition. AUSA secured pro bono counsel by contacting Meg Garvin, Esq. of the the National Crime Victims' Law Center in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. Garvin was not advised that a non-prosecution agreement had been reached. + +35. On May 30, 2008, another of Mr. Edwards's clients who was recognized as an Epstein victim by the U.S. Attorney's Office, received a letter from the FBI advising her that Whis case is currently under investigation. This can be a lengthy process and we request your continued patience while we conduct a thorough investigation." The statement in the notification letter was false. The case was not currently "under investigation." To the contrary, the case had been resolved by the non-prosecution agreement entered into by Epstein and the U.S. Attorney's Office discussed previously. Edwards Declaration at & 12. + +36. In mid-June 2008, Mr. Edwards contacted AUSA to inform her that he represented Jane Doe #1 and, later, Jane Doe #2. Mr. Edwards asked to meet to provide information about the federal crimes committed by Epstein, hoping to secure a significant federal indictment against Epstein. AUSA and Mr. Edwards discussed the possibility of federal charges being filed. At the end of the call, AUSA asked Mr. Edwards to send any information that he wanted considered by the U.S. Attorney's Office in determining whether to file federal charges. Because of the confidentiality provision that existed in the plea agreement, Mr. Edwards was not informed that previously, in September 2007, the U.S. Attorney's Office had reached an agreement not to file federal charges. Mr. Edwards was also not informed that resolution of the criminal matter was imminent. Edwards Declaration at & 13. + +37. On Friday, June 27, 2008, at approximately 4:15 p.m., AUSA received a copy of Epstein's proposed state plea agreement and learned that the plea was scheduled for 8:30 a.m., Monday, June 30, 2008. AUSA and the Palm Beach Police Department attempted to provide notification to victims in the short time that Epstein's counsel had provided. Attorney Edwards was called to provide notice to his clients regarding the hearing. AUSA did not tell Attorney Edwards that the guilty pleas in state court would bring an end to the possibility of federal prosecution pursuant to the plea agreement. Edwards Declaration at & 14. + +38. On June 30, 2008, AUSA sent an e-mail to Jack Goldberger, criminal defense counsel for Epstein, that stated: "Jack: The FBI has received several calls regarding the Non-Prosecution Agreement. I do not know whether the title of the document was disclosed when the Agreement was filed under seal, but the FBI and our office are declining comment if asked." U.S. Attorney's Correspondence at 321. + +39. On July 3, 2008, Mr. Edwards sent to AUSA a letter. See Affidavit of Bradley J. Edwards, Esq., at 15 (attachment 2). In the letter, Mr. Edwards indicated his client's desire that federal charges be filed against defendant Epstein. In particular, he wrote on behalf of his clients: "We urge the Attorney General and our United States Attorney to consider the fundamental import of the vigorous enforcement of our Federal laws. We urge you to move forward with the traditional indictments and criminal prosecution commensurate with the crimes Mr. Epstein has committed, and we further urge you to take the steps necessary to protect our children from this very dangerous sexual predator." When Mr. Edwards wrote this letter, he was still unaware that a non-prosecution agreement had been reached with Epstein — a fact that continued to be concealed from him (and the victims) by the U.S. Attorney's Office. Mr. Edwards first saw a reference to the NPA on or after July 9, 2008, when the Government filed its responsive pleading to Jane Doe's emergency petition. That pleading was the first public mention of the non-prosecution agreement and the first disclosure to Mr. Edwards (and thus to Jane Doe #1 and Jane Doe #2) of the possible existence of a non-prosecution agreement. Edwards Declaration at & 15. + +40. On July 9, 2008, AUSA sent a victim notification to Jane Doe #1 via her attorney, Bradley Edwards. Edwards Declaration, Exhibit "H." That notification contains a written explanation of some of the terms of the agreement between Epstein and the U.S. Attorney's Office. A full copy of the terms was not provided. A notification was not provided to Jane Doe #2 because the agreement limited Epstein's liability to victims whom the United States was prepared to name in an indictment. As a result, Jane Doe #2 never received a notification a letter about the agreement. The notification did not mention the non-prosecution agreement with the U.S. Attorney's Office. Edwards Declaration at & 16. + +41. On July 9, 2008, AUSA filed a sworn declaration with the Court in connection with the case (doe. #14). The declaration purported to recount limit parts of the non-prosecution agreement and stated that "these provisions were discussed" with several victims, including Jane Doe #1. Id. at 4. + +42. On July 11, 2008, the Court held a hearing on Jane Doe #1 and Jane Doe #2's Emergency Petition for Enforcement of Rights. During the hearing, the Government conceded that Jane Doe #1 and Jane Doe #2 were "victims" within the meaning of the Crime Victim's Rights Act. Tr. at 14-15. + +43. During the July 11 hearing, the Court and the parties discussed the fact that the petition should not be treated as an "emergency" petition because there was not any particular rush to ruling on it. Tr. at 24-25. The Court further discussed a need to "hav[e] a complete record, and this is going to be an issue that's ... going to go to the Eleventh Circuit, [s] it] may be better to have a complete record as to what your position is and the government's is as to what actions were taken. And I don't know if I have enough information, based on Ms. Villafana's affidavit or I need additional information. And because it is not an emergency, I don't have to do something quickly, we can play it b[y] ear and make this into a more complete record for the court of appeals." Tr. at 25-26. Counsel for Jane Doe #1 and Jane Doe #2 explained: " . . Your Honor is correct in stating that it is not an emergency and it doesn't need to happen today. And, I will confer with the government on this and if evidence needs to be taken, it [can] be taken at a later date. It doesn't seem like there will be any prejudice to any party [from delay]." Tr. at 26. The hearing concluded: "So I'll let both of you confer about whether there is a need for any additional evidence to be presented. Let me know one way or the other. If there is, we'll schedule a hearing. If there isn't and you want to submit some additional stipulated information, do that, and then I'll take care of this in due course." Tr. at 32. The Court then adjourned, taking the victims' petition under advisement. + +44. The U.S. Attorney's Office and the victims then attempted to reach a stipulated set of facts underlying the case. The U.S. Attorney's Office set a proposed set of facts, and the victims sent a counter-proposal. Rather than respond to the victims' counter-proposal, however, the U.S. Attorney's Office suddenly reversed course. (Doc. #19 at 2). On July 29, 2008, it filed a Notice to Court Regarding Absence of Need for Evidentiary Hearing (doc. #17). The Government took the position that, because no federal criminal charges had been filed in the Southern District of Florida, no additional evidence was required to decide the petition before the Court. + +45. On August 1, 2008, Jane Doe # 1 and Jane Doe #2 filed (doc. #19) a response to the Government's "Notice." In the response, Jane Doe #1 and Jane Doe #2 gave a proposed statement of facts surrounding the case. The proposed statement of fact was based on the information available to the victims at that time. The proposed statement of facts highlighted the fact that the Government had signed a non-prosecution agreement containing an express confidentiality provision, which prevented the Government from disclosing the agreement to them and other victims. Id. at 5. The response also noted that the Court had taken the victims' petition under advisement. The response further noted that the Government had not attempted to work with the victims to draft a full set of undisputed facts and had refused the victims' efforts to obtain documents relevant to the case. Id. at 9. The victims response also requested that the + +Court direct the Government to confer with the victims regarding the undisputed facts of the case, produce the non-prosecution agreement at issue in the case, and produce an FBI Report of Interview with Jane Doe #1. The response also requested that the Court enter judgment for the victims' finding a violation of rights and schedule a hearing on the appropriate remedy. Id. at 14. 46. On August 14, 2008, the Court held a hearing on the case. During that hearing, the U.S. Attorney's Office conceded "we do feel bound by the confidentiality provision such that we could not voluntarily disclose this non-prosecution agreement without court order compelling us to do so." Tr. at 8. The Office went on to further concede that it could not justify depriving the victims of the opportunity to see the agreement. Id. at 14. The hearing concluded without any schedule or deadlines being put in place. + +47. On October 9, 2008, Bradley J. Edwards, counsel for Jane Doe #1 and Jane Doe #2, sent a letter to counsel for the U.S. Attorney's Office in this case advising that two possibly false statements had been made to the Court in the July 9th sworn declaration of AUSA See Oct. 9, 2008, Letter from Bradley J. Edwards to Marie at I, Edwards Declaration, Attachment "I." First, while Ms. had described a term as being part of the plea agreement with Epstein, that term later became defunct, at least in the view of Epstein's attorneys (and apparently acceded to by the U.S. Attorney's Office). Second, Ms. had said that "four victims [including Jane Doe #1] were contacted and these provisions were discussed," it was not clear what provisions had in fact been discussed. + +48. On December 22, 2008, AUSA Marie filed a supplemental affidavit, "correcting" the statement made in her July 8, 2008, declaration about the terms of the plea agreement (doe. #35). The supplemental affidavit stated that "part 3" of the agreement with defendant Epstein + +was, in the view Epstein' legal counsel, no longer operative. The supplemental affidavit, however, did not clarify what terms of the agreement had been discussed. + +49. On April 9, 2009, counsel for Jane Doe #1 and Jane Doe #2 sent to the Court in this case (via the PACER system) a notice of a change of law firm affiliation. Doc. #37. + +50. In approximately May 2009, counsel for Jane Doe #1 and Jane Doe #2 propounded discovery requests in both state and federal civil cases against Epstein, seeking to obtain correspondence between Epstein and prosecutors regarding his plea agreement — information that the U.S. Attorney's Office was unwilling to provide to Jane Doe #1 and Jane Doe #2. Epstein refused to produce that information, and extended litigation to obtain the materials followed. Edwards Declaration at & 20. + +51. Because of this extended litigation, Jane Doe #1 and Jane Doe #2 did not have access to important correspondence demonstrating a violation of their rights until June 30, 2010. On that day, counsel for Epstein sent to Bradley J. Edwards, Esq., legal counsel for Jane Doe #1 and Jane Doe #2, approximately 358 pages of e-mail correspondence between his legal counsel and the U.S. Attorney's Office for the Southern District of Florida regarding the plea agreement that had been negotiated between them. See Edwards Declaration, Attachment "J." These e-mails disclosed for the first time the extreme and unusual steps that had been taken by the U.S. Attorney's Office to avoid prosecuting Epstein and to avoid having the victims in the case learn about the non-prosecution agreement that had been reached between Epstein and the Government. Litigation continues to this day to obtain the correspondence regarding the state prosecution and regarding what Epstein's attorneys said in the correspondence with the prosecutors. Edwards Declaration at & 22 + +52. In mid-July 2010, Jane Doe #1 and Jane Doe #2 settled their civil lawsuits against Mr. Epstein. Notice of this fact was promptly provided to the Court. Edwards Declaration at xxx. + +53. On September 8, 2010, the Court entered an order stating that "[a]it examination of the docket reveals that no activity has taken place in this case since April of 2009. In light of the underlying settlements between the victims and Mr. Epstein, it is hereby ordered and adjudged that this case is closed." Doc. #38. + +54. Promptly on the heels of this administrative order, on September 13, 2010, Jane Doe #1 and Jane Doe #2 filed a notice that they "intend to make subsequent filing in the case shortly. They accordingly request administrative reopening of the case and, if the Court deems it advisable, a scheduling conference with the U.S. Attorney's Office regarding the case." Doc. #39 at 1. They further advised the Court that their settlements with Jeffrey Epstein in no way affected "their determination to move forward with the above-captioned CVRA action against a different entity — the U.S. Attorney's Office for the Southern District of Florida." Id. at 2. The pleading further advised that "[i]f the Court wishes to proceed to an expeditious conclusion to this Case, Jane Doe #1 and Jane Doe #2 have no objection to the Court setting up an expedited schedule for proceeding on the case." Id. The pleading further advised that the reason the victims had not filed for summary judgment in the case was that they had been attempting to secure correspondence between the U.S. Attorney's Office and Epstein to corroborate their argument that the Office had violated their rights. They noted that they had just secured half of that correspondence two months earlier. Id. at 2. The victim asked that, "if the Court deems it advisable, that a scheduling conference be set for this case." + +55. At all times material to this statement of facts, it would have been practical and feasible for federal government to inform Jane Doe #1 and Jane Doe #2 of the details of the proposed nonprosecution agreement with Epstein, including in particular the fact that the agreement barred any federal criminal prosecution. Edwards Declaration at & 26. + +### LEGAL MEMORANDUM + +The victims have previously briefed the issues of why they are entitled to entry of an order by this Court finding that the U.S. Attorney's Office violated their rights under the CVRA. See Doc. #1; Doc #9 at 3-11; Doc. #19 at 3-9, 14. The victims specifically incorporate those pleadings by reference here. In short, as explained in the victims' earlier pleadings, the Office violated the victims' right to confer before reaching the non-prosecution agreement and also failed to use its best efforts to comply with the CVRA. + +In light of the new evidence that the victims have uncovered, it now palpably obvious that not only has the U.S. Attorney's Office violated their rights, but that the violations were part of an orchestrated, deliberate attempt to keep the victims in the dark about the non-prosecution agreement so that they could not raise any timely objection to it. The facts recounted demonstrate the following chain of events. The U.S. Attorney's Office first reached a nonprosecution agreement with Epstein, in which it agreed not to prosecute him for numerous crimes (including, for example, sex offenses committed by Epstein against Jane Doe #1). As part of that agreement, the U.S. Attorney's Office agreed to a "confidentiality" provision that forbade publicly disclosing the existence of the agreement. As a result, the U.S. Attorney's Office and FBI agents acting under its direction kept the existence of the non-prosecution agreement secret from the victims and the public. The reasonable inference from the evidence is that the U.S. Attorney's Office wanted to keep the agreement a secret to avoid intense criticism that would have surely ensued had the victims and the public learned that a billionaire sex offender with political connections had arranged to avoid federal prosecution for numerous felony sex offenses against minor girls. + +As part of this pattern of deception, the U.S. Attorney's Office discussed victim notification with the defendant sex offender and, after he raised objections, stopped making notification. Then later in January 2008, the U.S. Attorney's Office arranged for letters to be sent to the victims — including Jane Doe #1 and Jane Doe #2 — that falsely stated that to each that your "case is currently under investigation." This was untrue, as the U.S. Attorney's Office had already resolved the federal case by signing a non-prosecution agreement with Epstein. Indeed, the pattern of deception continued even after Jane Doe #1 and Jane Doe #2 were represented by legal counsel. In May 2008, the Office sent a similar letter stating "your case is currently investigation" to another victim (represented by Bradley J. Edwards). As late as the middle of June 2008 — more than eight months after the non-prosecution agreement had been signed -- the Assistant U.S. Attorney handling the case told the attorney representing Jane Doe #1 and Jane Doe #2 (Edwards) to send information that he wanted the Office to consider in determining whether to file federal charges. The Office concealed from him the fact that the determination had already been made and a non-prosecution agreement had been signed long ago. The Office also concealed from him the fact that guilty pleas in state court were imminent. The Office provided notice about the fact of the non-prosecution agreement only after Epstein had entered his guilty pleas in state court — in other words, only after the time for the victims to be able to + +object to the non-prosecution agreement during the plea process had come and gone. Even at that time, the Office did not disclose the provisions in the agreement. + +This behavior does not satisfy the Office's obligations under the CVRA to use its "best efforts" to insure that victims receive protection of their rights. 18 U.S.C. § 3771(c)(1). In particular, it makes clear that the victims were not afforded their right "to confer with the attorney for the Government in the case." 18 U.S.C. § 3771(a)(5). Whatever else may be said about the deception, it also starkly violates the victims' right "to be treated with fairness and with respect for the victim's dignity . . . ." 18 U.S.C. § 3771(a)(8). The pattern also denied the victims of timely notice of court proceedings, 18 U.S.C. § 3771(a)(3), including in particular the state court guilty plea + +The Court should find that these violations of the victims' rights were not accidental but deliberate. The U.S. Attorney's Office was well aware its resolution of the federal cases triggered an obligation under the CVRA to notify the victims of what was happening to their cases. Indeed, the First Assistant in the Office wrote to Epstein's defense counsel that pursuant to the CVRA + +crime victims are entitled to: "The right to reasonable, accurate, and timely notice of any public court proceeding . . . involving the crime" and the "right not to be excluded from any such public court proceeding . . . ." 18 U.S.C. § 3771(a)(2) & (3). Section 3771 also commands that "employees of the Department of Justice . engaged in the detection, investigation, or prosecution of crime shall make their best efforts to see that crime victims are notified of, and accorded, the rights described in subsection (a)." 18 U.S.C. § 3771(c)(1).... Our Non-Prosecution Agreement resolves the federal investigation by allowing Mr. Epstein to plead to a state offense. The victims identified through the federal investigation should be appropriately informed, and our Non-Prosecution Agreement does not require the U.S. Attorney's Office to forego its legal obligation. + +U.S. Attorney's Correspondence at 191-92. Despite recognizing in private correspondence with defense counsel that victims of Epstein's sexual assault should be "appropriately informed" about the Non-Prosecution agreement in a "timely" fashion, the U.S. Attorney's Office ultimately did nothing to inform them of the agreement until after the agreement had been consummated in court. + +In short, Jane Doe #1 and Jane Doe #2 — and the many other victims of the defendant's federal sex offenses — were deliberately kept in the dark about the fact that the U.S. Attorney's Office was planning to reach a deal that would permit the defendant to escape all federal punishment. This bald decision to conceal from the victims what was happening violated the core premise of the Crime Victim's Rights Act: that victims deserve to know what is happening in their cases. Congress was concerned that in the federal system crime victims were "treated as non-participants in a critical event in their lives. They were kept in the dark by prosecutors too busy to care enough ... and by a court system that simply did not have a place for them." 150 CONG. REC. S4262 (Apr. 22, 2004) (statement of Sen. Feinstein). To remedy this problem, Congress gave victims "the simple right to know what is going on, to participate in the process where the information that victims and their families can provide may be material and relevant ... ." Id. If ever a case cried out for a court finding that prosecutors have violated the rights of crime victims, it is this one. The victims respectfully ask for a finding that the U.S. Attorney's Office has violated their rights under the Crime Victims' Rights Act. + +# CERTIFICATE OF CONFERENCE + +Counsel for Jane Doe #1 and Jane Doe #2 are engaged in on-going discussions with counsel for the U.S. Attorney's Office to resolve the matters raised in this pleading. The U.S. Attorney's Office has agreed to stipulate to all facts presented by Jane Doe #1 and Jane Doe #2 that are correct. At this time, however, the parties have not been able to reach any further agreements. + +## CONCLUSION + +For all these reasons, the Court should find the U.S. Attorney's Office violated Jane Doe #1 and Jane Doe #2's rights under the Crime Victims Rights Act and then schedule an appropriate hearing on the remedy for these violations. The scope of the remedy that is appropriate may depend in part of the scope of the violations that the Court finds. For this reason, it makes sense to bifurcate the process and determine, first, the extent of the violations and then, second, the remedy appropriate for those violations. If the Court would prefer to see more immediate briefing on remedy issues, the victims stand prepared to provide that briefing at the Court's direction. + +DATED: October 27.2010 + +Respectfully Submitted, + +s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. + +![](_page_26_Picture_6.jpeg) + +and + +Paul G. Cassell + +Pro Hac Vice + +IS + +Attorneys for Jane Doe #1 and Jane Doe #2 + +# CERTIFICATE OF SERVICE + +![](_page_28_Picture_1.jpeg) + +Also serve Epstein through current lawyer. \ No newline at end of file diff --git a/marker2/ds9/EFTA00206764/EFTA00206764.metadata.json b/marker2/ds9/EFTA00206764/EFTA00206764.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1a7d6a24c2748295c17fc72237b5f4a9d3946b68 --- /dev/null +++ b/marker2/ds9/EFTA00206764/EFTA00206764.metadata.json @@ -0,0 +1,1095 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206764.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 29, + "chars": 51250, + "elapsed_seconds": 3.6, + "image_assets": [ + "_page_26_Picture_6.jpeg", + 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EDWARDS, ESQ. + +I. I, Bradley J. Edwards, Esq., do hereby declare that I am a member in good standing of the Bar of the State of Florida. Along with co-counsel, I have represented Jane Doe #1 and Jane Doe #2 in civil suits against Jeffrey Epstein for sexually abusing them. I have also represented other girls who were sexually abused by Epstein. As a result of that representation, I have become familiar with many aspects of the criminal investigation against Epstein and have reviewed discovery and correspondence connected with the criminal investigation. I have also spoken to Jane Doe #1 and Jane Doe #2 at length about the criminal investigation and their involvement in it, as well enforcement (or lack their of) of their rights as crime victims in the investigation. I also represent Jane Doe #1 and Jane Doe #2 in the pending case seeking enforcement of their rights under the Crime Victims' Rights Act. I am also familiar with the criminal justice system, having served as state prosecutor in the Broward County State Attorney's Office. + +2. In 2006, at the request of the Palm Beach Police Department, the Federal Bureau of Investigation ("FBI") opened an investigation into allegations that Jeffrey Epstein ("Epstein") and his personal assistants had used facilities of interstate commerce to induce young girls between the ages of thirteen and seventeen to engage in prostitution, amongst other offenses. + +The case was presented to the United States Attorney's Office for the Southern District of Florida, which accepted the case for investigation. At the time that the investigation was opened, the Palm Beach County State Attorney's Office was also investigating Epstein. The FBI determined that both Jane Doe #1 and Jane Doe #2 were victims of sexual assaults by Epstein while they were minors beginning when they were approximately fourteen years of age and approximately thirteen years of age respectively. These sexual assaults involved use of means of interstate commerce (i.e., a telephone) and travel in interstate commerce. Both Jane Does were initially identified through the Palm Beach Police Department's investigation of Epstein. + +3. On about June 7, 2007, FBI agents hand-delivered to Jane Doe #1 a standard CVRA victim notification letter. See Exhibit "A".' The notification promises that the Justice Department would makes its "best efforts" to protect Jane Doe #1's rights, including "Mlle reasonable right to confer with the attorney for the United States in the case" and "to be reasonably heard at any public proceeding in the district court involving . . . plea . . ." The notification further explained that "[a]t this time, your case is under investigation." + +4. On about August 11, 2007, FBI agents hand-delivered to Jane Doe #2 a standard CVRA victim notification letter. See Exhibit "B."2 The notification promises that the Justice Department would makes its "best efforts" to protect Jane Doe #1's rights, including "Mlle reasonable right to confer with the attorney for the United States in the case" and "to be + +This document has previously been made part of the record in this case. See Case No. 9:08-CV-80736, Doc. #14 (attachment 1). For the convenience of the Court, it is also attached as an exhibit here. + +2 This document has previously been made part of the record in this case. See Case No. 9:08-CV-80736, Doc. #14 (attachment 2). For the convenience of the Court, it is also attached as an exhibit here. + +reasonably heard at any public proceeding in the district court involving . . . plea . . . ." The notification further explained that "[ajt this time, your case is under investigation." + +5. Early in the investigation, the FBI agents and the Assistant U.S. Attorney had several meetings with Jane Doe #1. Jane Doe #2 was represented by counsel that was paid for by Epstein and, accordingly, all contact was made through that attorney. + +6. I have reviewed a copy of the non-prosecution agreement signed on about September 24, 2007, by Epstein and his attorneys and a representative of the U.S. Attorney's Office. What appears to be a tnie and accurate copy of that agreement is attached to this declaration as Exhibit + +7. In October 2007, shortly after the initial non-prosecution agreement was signed between Epstein and the U.S. Attorney's Office for the Southern District of Florida, Jane Doe #1 was contacted to be advised regarding the resolution of the investigation. On October 26, 2007, Special Agents teSiMINE Nsilibmiiernet in person with Jane Doe #1. The Special Agents explained that Epstein would plead guilty to state charges, he would be required to register as a sex offender for life, and he had made certain concessions related to the payment of damages to the victims, including Jane Doe #1. During this meeting, Jane Doe #1 was not represented by legal counsel. During this meeting, the Special Agents did not explain that an agreement had already been signed that precluded any prosecution of Epstein for federal charges. The agents could not have revealed this part of the non-prosecution agreement without violating the terms of the non-prosecution agreement. Whether the agents themselves had been informed of the existence of the non-prosecution agreement by the U.S. Attorney's Office is not certain. Because the plea agreement had already been reached with Epstein, the agents made no attempt + +to secure Jane Doe #1's view on the proposed resolution of the case. It appears that an FBI "Report of Interview" of this meeting exists. The U.S. Attorney's Office has refused to provide a copy of that report to Jane Doe #1. + +8. Jane Doe #1's perception of the explanation provided by the Special Agents was that only the State part of the Epstein investigation had been resolved, and that the federal investigation would continue, possibly leading to a federal prosecution. + +9. On about January 10, 2008, my clients Jane Doe #1 and Jane Doe #2 received letters from the FBI advising them that "Nhis case is currently under investigation. This can be a lengthy process and we request you continued patience while we conduct a thorough investigation." See Exhibit "D" and "E" (emphasis added). 3 The statement in the notification letter was false. The case was not currently "under investigation." To the contrary, the case had been resolved by the non-prosecution agreement entered into by Epstein and the U.S. Attorney's Office discussed previously. Moreover, the FBI did not notify Jane Doe #1 or Jane Doe #2 that a plea agreement had been reached previously, and that part of the agreement was a nonprosecution agreement with the U.S. Attorney's Office for the Southern District of Florida. + +10. In early 2008, Jane Doe #1 and Jane Doe #2 came to believe that criminal prosecution of Epstein was extremely important. The also desired to be consulted by the FBI and/or other representatives of the federal government about the prosecution of Epstein. In light of the letters that they had received around January 10, they believed that a criminal investigation of Epstein + +3 These document has previously been made part of the record in this case. See Case No. 9:08-CV-80736, Doc. #14 (attachments 3 and 4). For the convenience of the Court, there are also attached as exhibits here. + +was on-going and that they would be contacted before the federal government reached any final resolution of that investigation. + +II. In about April 2008, Jane Doe #1 contacted the FBI because Epstein's counsel was attempting to take her deposition and private investigators were harassing her. Assistant U.S. Attorney A—Masia. secured pro bono counsel to represent Jane Doe #1 and several other identified victims in connection with the criminal investigation. Pro bono counsel was able to assist Jane Doe #1 in avoiding the improper deposition. AUSA secured pro bono counsel by contacting Meg Garvin, Esq. of the the National Crime Victims' Law Center in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. Garvin was not advised that a non-prosecution agreement had been reached in this matter. + +12. On May 30, 2008, another one of my clients who was recognized as an Epstein victim by the U.S. Attorney's Office, received letters from the FBI advising her that Whis case is currently under investigation. This can be a lengthy process and we request your continued patience while we conduct a thorough investigation." See Exhibit "F." The statement in the notification letter was false. The case was not currently "under investigation." To the contrary, the case had been resolved by the non-prosecution agreement entered into by Epstein and the U.S. Attorney's Office in September 2007. + +13. In mid-June 2008, I contacted AUSA to inform her that I represented Jane Doe #1 and, later, Jane Doe #2. I asked to meet to provide information about the federal crimes committed by Epstein, hoping to secure a significant federal indictment against Epstein. AUSA and I discussed the possibility of federal charges being filed. At the end of the call, AUSA asked me to send any information that he wanted considered by the U.S. Attorney's Office in determining whether to file federal charges. Because of the confidentiality provision that existed in the plea agreement, I was not informed that previously, in September 2007, the U.S. Attorney's Office had reached an agreement not to file federal charges. I was also not informed that any resolution of the criminal matter was imminent. + +14. On Friday, June 27, 2008, at approximately 4:15 p.m., AUSA received a copy of Epstein's proposed state plea agreement and learned that the plea was scheduled for 8:30 a.m., Monday, June 30, 2008. AUSA and the Palm Beach Police Department attempted to provide notification to victims in the short time that Epstein's counsel had provided. AUSA did not tell me that the guilty pleas in state court would bring an end to the possibility of federal prosecution pursuant to the plea agreement. + +15. On July 3, 2008, Mr. Edwards sent to AUSA a letter. A copy of that letter is attached to this declaration as Exhibit "G". In the letter, I indicated my client's desire that federal charges be filed against defendant Epstein. In particular, I wrote on behalf of my clients: "We urge the Attorney General and our United States Attorney to consider the fundamental import of the vigorous enforcement of our Federal laws. We urge you to move forward with the traditional indictments and criminal prosecution commensurate with the crimes Mr. Epstein has committed, and we further urge you to take the steps necessary to protect our children from this very dangerous sexual predator." When I wrote this letter, I was still unaware that a nonprosecution agreement had been reached with Epstein — a fact that continued to be concealed from me (and the victims) by the U.S. Attorney's Office. I first learned of this fact on or after July 9, 2008, when the Government filed its responsive pleading to Jane Doe's emergency petition. That pleading was the first public mention of the non-prosecution agreement and the + +first disclosure to me (and thus to Jane Doe #1 and Jane Doe #2) of the existence of a document called a non-prosecution agreement. + +16. On July 9, 2008, AUSA sent a victim notification to Jane Doe #1 through me as her attorney. See Exhibit "H." That notification contains a written explanation of some of the terms of the agreement between Epstein and the U.S. Attorney's Office. A full copy of the terms was not provided. This was the first time that Jane Doe #2 was told that the plea arrangement blocked any possibility of federal criminal charges being filed against Epstein. A notification was not provided to Jane Doe #2, apparently because the agreement limited Epstein's liability to victims whom the United States was prepared to name in an indictment. + +17. On October 9, 2008, Bradley J. Edwards, counsel for Jane Doe #1 and Jane Doe #2, sent a letter to counsel for the U.S. Attorney's Office in this case advising that two possibly false statements had been made to the Court in the July 9th sworn declaration of AUSA See Exhibit "I" to this Declaration. + +18. During the summer of 2008, I attempted along with co-counsel in this case to work with the U.S. Attorney's Office to come up with an agreed set of facts regarding the case. For example, on July 17, 2008, I sent a letter to AUSA attempting to come up with an agreed set of facts. During the course of the summer, however, it became apparent to me that the U.S. Attorney's Office was not going to agree to all the facts and events relevant to the CVRA case. It also became apparently that the U.S. Attorney's Office was not prepared to provide any discovery of materials necessary to building a full factual record of the events surrounding the treatment of Jane Doe #1 and Jane Doe #2 during the criminal investigation. + +19. In view of the U.S. Attorney's reluctance to agree to appropriate facts or provide information about the plea negotiation process, I made the determination that it was in the best of interests of Jane Doe #1 and Jane Doe #2 to pursue their civil cases at a faster pace than the CVRA case. I believed that the civil cases might produce useful information for their CVRA claims and that there was no specific deadline set by the Court for bringing the CVRA case to a conclusion. + +20. As one example of the efforts I made to defend my clients' interests, I believed that correspondence between the U.S. Attorney's Office and Epstein would contain highly useful information for both my clients' civil cases and their CVRA case. To obtain that information, in approximately May 2009, I propounded discovery requests in both state and federal civil cases against Epstein, seeking to obtain correspondence between Epstein and prosecutors regarding his plea agreement — information that the U.S. Attorney's Office was unwilling to provide to Jane Doe #1 and Jane Doe #2. Epstein refused to produce that information, and extended litigation to obtain the materials followed — litigation that is reflected in the docket sheets of those cases. At all times, I proceeded diligently to obtain this correspondence. + +21. As an example of the extended litigation over the correspondence, in the federal case (case no. 9:08-CV-80893), on July 20, 2009, Jane Doe filed a motion to compel production of the information (case no. 9:08-cv-80119, doc. #210). Epstein obtained an extension of time in which to respond and, two-and-a-half months later, on October 6, 2009, Epstein filed an objection to producing these items primarily on Fifth Amendment grounds (doe. #339). On October 16, 2009, Jane Doe filed a reply in support of her motion (doc. #354). On January 22, 2010, Jane Doe filed a notice that more than 90 days had elapsed since the filing of her motion (doe. #453). + +On February 4, 2010, the magistrate judge granted in part and denied in part Jane Doe's motion to compel, specifically ruling that Epstein had to produce the discovery provided to him by state and federal prosecutors and the requested correspondence, rejecting Fifth Amendment and other objections raised by Epstein. Case no. 9:08-cv-80119, doc. #462. Epstein then filed for an extension of time in which to appeal (doc. #464), which Jane Doe opposed on grounds of delay (doc. #465). On February 11, 2010, the Court granted in part and denied in part the extension of time, specifically warning Epstein that "[ijn the event that Magistrate Judge Johnson's February 4, 2010 Order is affirmed on appeal, Defendant will have three (3) business days from the date of this Court's order to produce the documents at issue." (doc. #468). Epstein then ultimately filed his appeal/motion for reconsideration of the magistrate decision on February 26, 2010. (doe. #477). On March 10, 2010, Jane Doe then filed her response in Opposition to Defendant's Motion for reconsideration. (doc. #. 485). On April I, 2010, the magistrate judge rejected Epstein's challenge, reaffirming his earlier order that "compelled production from state and federal prosecutors in the criminal case against him." (doc. #513). On May 12, 2010, Epstein filed a "Consolidated" Rule 4 Review and Appeal of portions of the Magistrate Judge's orders (doc. #545). On May 27, 2010, Jane Doe filed a "protective" response to the consolidated reply, noting that she had previously responded to all of the arguments raised by the appeal and that the "consolidated" appeal did not require any new response from her (doc. #551). On Friday, June 25, 2010, this Court entered an order affirming the magistrate judge's discovery orders in all respects (case no. 9:08-cv-80119-1CAM, doc. #572) and, as it previously warned Epstein, requiring Epstein to produce the discovery materials within three business days. At this point, despite having had a year to assemble the requested discovery items and prepare for their + +production — and more than four months since this Court's warning to be prepared to produce the documents on three days notice — Epstein began filing motions to restrict production. On Monday evening, June 28, 2010, at approximately 5:11 p.m., Epstein filed a motion for a protective order regarding dissemination of the materials (case no. 9:09-cv-80893, doc. #170). On Tuesday morning, June 29, 2010, at approximately 9:31 a.m., this Court summarily denied the motion (doc. #172). Following these actions by the Court, on about June 30, 2010, Epstein made his production electronically to Jane Doe's counsel. However, Epstein also produced only correspondence with federal prosecutors — not with state prosecutors. Of course, this significantly limited the production he made, as Epstein pled guilty to state sex charges rather than federal sex charges — leaving Jane Doe with no correspondence about his guilty plea. Second, with regard to his correspondence with federal prosecutors that he did produce, Epstein redacted anything coming from attorneys, leaving only the responses from the federal prosecutors. Jane Doe then filed a motion to have Epstein held in contempt for violating his discovery production obligations (doc. #190). The case settled shortly thereafter before the Court could rule on the contempt motion. + +22. Because of this extended litigation, Jane Doe #1 and Jane Doe #2 did not have access to important correspondence demonstrating a violation of their rights until June 30, 2010. On that day, counsel for Epstein sent to me approximately 358 pages of e-mail correspondence between his legal counsel and the U.S. Attorney's Office for the Southern District of Florida regarding the plea agreement that had been negotiated between them. A true and correct copy of that correspondence is attached to this declaration at Exhibit "J". These e-mails disclosed for the first time the steps that had been taken by the U.S. Attorney's Office to avoid having the victims in the case learn about the non-prosecution agreement that had been reached between Epstein and the Government. Litigation continues to this day to obtain the correspondence regarding the state prosecution correspondence and regarding what Epstein's attorneys said in the correspondence with the prosecutors. + +23. Between July 2008 and September 2010, my co-counsel working on this matter (Professor Paul G. Cassell at the University of Utah College of Law) and I had numerous formal and informal contacts with the U.S. Attorney's Office regarding Epstein-related matters. In none of those contacts did the U.S. Attorney's Office ever indicate that they believed that a deadline was approaching in this CVRA case or that Jane Doe #1 and Jane Doe #2 were proceeding less than diligently on this case. During those contacts, the U.S. Attorney's Office was also made aware of on-going discovery efforts to obtain information from Epstein. + +24. At no time while this case was proceeding did I understand that the Court desired for us to make expedited filings. To the contrary, it was my understanding that the Court believed that the matter was not an "emergency" and therefore could proceed on a slower timetable. The case remained open at all times and I had several brief discussions with representatives of the U.S. Attorney's Office about the fact that my clients were still working on obtaining evidence to support their claims in the case. When on September 8, 2010, the Court entered an administrative order closing the case, I promptly filed a notice that additional filings were going to made in the case shortly. It has never been the intention of Jane Doe #1 or Jane Doe #2 to not pursue this case. If at any point they had been notified by the Court of a schedule for filing pleadings in this case, they would have made every effort to timely file those pleadings. + +25. In mid-July 2010, Jane Doe #1 and Jane Doe #2 settled their civil lawsuits against Mr. Epstein. Notice of this fact was promptly provided to the Court. Concluding those civil lawsuits consumed a great deal of time for the legal team representing them during the month of July. + +26. At all times material to this statement of facts, it would have been practical and feasible for the federal government to inform Jane Doe #1 and Jane Doe #2 of the details of the proposed plea agreement with Epstein, including in particular the fact that the agreement barred any federal criminal prosecution. During the times that I represented them, I stood ready, willing, and able to receive that information. + +27. 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b/marker2/ds9/EFTA00206805/EFTA00206805.md @@ -0,0 +1,91 @@ +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA + +Case No. 08-80736-Civ-Marra/Johnson + +JANE DOES #1 and #2 + +UNITED STATES + +#### JANE DOE #1 AND JANE DOE #2'S STATUS REPORT AND RESPONSE TO COURT'S ORDER TO SHOW LACK OF PROSEUCTION + +Jane Doe #1 and Jane Doe #2 ("the victims"), through counsel, file the response to Court's order to file a status report and show cause regarding prosecution of the case (doc. #40). + +### BACKGROUND + +As the Court is aware, it entered an order administratively closing this case on September 9, 2010 (doc. #38). That order recited that fact that Jane Doe #1 and Jane Doe #2 had recently settled their civil cases with Jeffrey Epstein as the basis for closure. On September 13, 2010, the victims promptly filed a notice that, while they had settled their case with Jeffrey Epstein, they had reached no settlement with the U.S. Attorney's Office and intended to make filings in this case shortly (doc. #39). The victims requested administrative reopening of the case and, if the Court deemed it advisable, a prompt scheduling conference with the U.S. Attorney's Office regarding the case. The victims also advised that they had only recently received important correspondence between the U.S. Attorney's Office and the Epstein proving that there had been an orchestrated decision to deny them their rights. + +On October 8, 2010, the Court entered an order directing the victims to file a status report and show cause why the case should not be dismissed for want of prosecution. + +## STATUS REPORT + +As the Court is aware from the victims' filing on September 13, 2010 (doc. #39), the victims have now received important evidence that allows them to file a comprehensive motion explaining the factual background underlying the denials of their rights under the Crime Victims Rights Act and the legal reasons for concluding that their rights under the Act have been violated. A full motion to that effect is being filed simultaneously with this pleading. The motion looks something like a summary judgment motion, although the exact procedures for CVRA cases are unclear. The victims stand ready to promptly provide whatever pleading or motion the Court believes is appropriate to resolve this case quickly. The victims' motion also asks for an evidentiary hearing if the facts are disputed by the U.S. Attorney's Office. Before filing the motion, the victims had also sent a copy of the facts to the U.S. Attorney's Office in an effort to obtain their agreement to them and to expedite the case. (As the Court is aware from the victims' earlier filing, the victims attempted to negotiate a stipulated set of facts with the U.S. Attorney's Office, only to be rebuffed by the U.S. Attorney's Office. See doc. #17 (U.S. Attorney giving "notice" that only two facts are relevant to this case and declining to provide information on other facts in the case); doe. #19 (victims response); doc. #22 (U.S. Attorney's reply).) Discussions with the U.S. Attorney's Office to reach a stipulated set of facts are continuing. + +In light of today's filing of a comprehensive motion, the victims would propose the following schedule for bringing this case to a conclusion: + +November 10, 2010 — U.S. Attorney's Office files response to the victims' motion. + +November 17, 29010 — Victims' file Reply to Response. + +Evidentiary Hearing (if facts contested) — early December, at a time convenient to the Court. + +January 1, 2011 — Court issues ruling on whether victims' rights were violated. + +If the Court enters a finding that the victims' rights were violated, then .... + +January 14, 2011— Victims brief on the appropriate remedy for a violation; + +January 28, 2011 -- U.S. Attorney's Office (and any other interested person) files response to victims' remedy brief. + +February 4, 2011 — Victims reply on remedy issues. + +Hearing if necessary — mid-February, at a time convenient to the Court. + +This proposed schedule would allow Jane Doe #1 and Jane Doe #2 to have their case fully resolved on the merits within the next few months. The victims would have no objection to the Court accelerating the schedule. The victims have also submitted this proposed schedule to the U.S. Attorney's Office in an effort to reach a stipulated and accelerated schedule. + +# THE CASE SHOULD NOT BE DISMISSED FOR LACK OF PROSECUTION + +Jane Doe #1 and Jane Doe #2 should not have their case dismissed for lack of prosecution for the simple reason that they have not failed to prosecute it. To the contrary, as recounted more fully in the statement of facts contained in their contemporaneously filed motion for a finding of violation of their rights, they have been attempting to secure information that would help prove their case. The victims hereby expressly incorporate that statement of facts, and supporting evidence (particularly the Declaration from Bradley J. Edwards, Esq.,) as part of this pleading. + +Although the victims rely on all of the information contained in the statement of facts, in the interest of a brief summary the victims would note that they have been diligently attempting to secure correspondence between Epstein and the U.S. Attorney's Office regarding the nonprosecution agreement reached in this case. After the U.S. Attorney's Office declined to provide the information, the victims sought to secure that information as part of their civil lawsuits against Epstein. This was because of a reasonable legal judgment that the victims' counsel that it was in their best interest to pursue the civil lawsuit against Epstein had a faster pace. Because of protracted litigation from Epstein's battery of lawyers, the victims did not secure any of the correspondence they sought until June 30, 2010. Even then, they secured only part of that correspondence — litigation to secure the rest of that correspondence continues to this day. See + +Declaration of Bradley J. Edwards, Esq., Attachment to Jane Doe #1 and Jane Doe #2's Motion for Finding of Violations of the Crime Victims' Rights Act. + +The victims would also note that the Court has never advised them of a deadline for moving forward with their CVRA case. The victims also knew that the Court was aware of the intense and protracted litigation what was proceeding with Epstein in the various civil cases against him. It seemed reasonable to the victim to resolve those cases first and then turn to the CVRA case — and the victims assumed that the Court was also proceeding on this approach, as the victims never received any inquiry from the Court about their CVRA case until the September 2010 order "administratively" closing the case. Within 5 days of receiving that communication from the Court, the victims promptly advised the Court of their intent to continue moving forward with the case and suggesting a scheduling conference if the Court deemed it advisable. + +The victims have now proposed a specific schedule that will bring this matter to a final conclusion in the next few months. There is no reason to dismiss the case precipitously now on the eve of a final resolution. + +The Eleventh Circuit has repeatedly noted that dismissal with prejudice is an "extreme sanction" and "is plainly improper unless and until the district court finds a clear record of delay or willful conduct and that lesser sanctions are inadequate to correct such conduct." Betty K Agencies, Ltd... MIMONADA, 432 F.3d 1333, 1338-39 (11th Cir.2005). In this case, there is no clear record of delay or willful conduct. To the contrary, there is a pattern of the victims diligently attempting to secure evidence (i.e., the correspondence) vital to their case in the face of determined opposition from both the United States and a billionaire sex offender represented by a battery of attorneys. The Eleventh Circuit has held that simple negligence in meeting a court- + +imposed deadline is not sufficient to warrant dismissal. *See McKelvey ¶. AT & T Techs., Inc., 789 F.2d 1518, 1520* (11th Cir.1986) (per curiam). Here, there is not even negligence, as the victims have not failed to meet any deadline that the Court has set and today stand ready to bring the case to an expeditious conclusion on the schedule they propose. On September 13, 2010, the victims also suggested to the Court that a scheduling conference would be one way to proceed in this case – a suggestion that they continue to offer to the Court. + +## CONCLUSION + +The Court should establish the schedule proposed by the victims and bring this case to a conclusion on the merits as the victims propose. + +DATED: October 27, 2010 + +Respectfully Submitted, + +s/ Bradley J. Edwards +Bradley J. Edwards +FARMER, JAFFE, WEISSING, +EDWARDS, FISTOS & LEHRMAN, P.L. +425 North Andrews Avenue Suite 2 + +![](_page_4_Picture_81.jpeg) + +*and* + +Paul G. Cassell +*Pro Hac Vice* + +![](_page_4_Picture_84.jpeg) + +Facsimile: 801-585-6833 +E-Mail: [cassellp@law.utah.edu](mailto:cassellp@law.utah.edu) + +# CERTIFICATE OF SERVICE + +![](_page_6_Picture_1.jpeg) + +Epstein through current counsel. \ No newline at end of file diff --git a/marker2/ds9/EFTA00206805/EFTA00206805.metadata.json b/marker2/ds9/EFTA00206805/EFTA00206805.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d05a6514b289e99244b893cfb74ae1591803dd9a --- /dev/null +++ b/marker2/ds9/EFTA00206805/EFTA00206805.metadata.json @@ -0,0 +1,428 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206805.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 7, + "chars": 8999, + "elapsed_seconds": 5.09, + 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index 0000000000000000000000000000000000000000..b75b2029ef7111818eb02d6303061535dd4f9d96 --- /dev/null +++ b/marker2/ds9/EFTA00206805/_page_6_Picture_1.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:7dc7e2172c942ef53d0daf71ce85f00fddc4cc5bb1c3417c541d485d8a93eb9d +size 2292 diff --git a/marker2/ds9/EFTA00206812/EFTA00206812.md b/marker2/ds9/EFTA00206812/EFTA00206812.md new file mode 100644 index 0000000000000000000000000000000000000000..35ed950f1d86924dd6e9e75d510c7de57121b609 --- /dev/null +++ b/marker2/ds9/EFTA00206812/EFTA00206812.md @@ -0,0 +1,7 @@ +Subject: Jeffrey Epstein + +Date: Tue, 26 Oct 2010 14:11:19 +0000 + +Importance: Normal + +I talked to Brad Edwards this morning, and he is going to send over a proposed joint motion for extension of time. I will fill you in on more details when we talk this morning. \ No newline at end of file diff --git a/marker2/ds9/EFTA00206812/EFTA00206812.metadata.json b/marker2/ds9/EFTA00206812/EFTA00206812.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..2a0e157e32d93651eb88c3bf141176d9b8288785 --- /dev/null +++ b/marker2/ds9/EFTA00206812/EFTA00206812.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206812.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 261, + "elapsed_seconds": 0.3, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 11 + ], + [ + "Line", + 6 + ], + [ + "Text", + 4 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206812" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206813/EFTA00206813.md b/marker2/ds9/EFTA00206813/EFTA00206813.md new file mode 100644 index 0000000000000000000000000000000000000000..0f3925da4d2681f783c327c56c1d58257b0b3207 --- /dev/null +++ b/marker2/ds9/EFTA00206813/EFTA00206813.md @@ -0,0 +1,25 @@ +From: (USAFLS)" <=1MIIM> + +To: (USAFLS)" + +Cc: 'ar, 'at" . (USAFLS)" + +Subject: Conference Call with Paul Cassell and Brad Edwards + +Date: Wed, 27 Oct 2010 16:31:04 +0000 + +Importance: Normal + +Willy and Ben, + +Marie and I just finished a conference call with Brad Edwards and Paul Cassell, attorneys for the victims. The objective of the victims is to have the Non-Prosecution Agreement set aside, and to have the federal government prosecute Jeffrey Epstein for the sexual exploitation of minors. Cassell agreed that the district court would have no authority to compel the Department of Justice to prosecute Epstein. + +Insofar as the victims' response to the order to show cause, which is due today, the victims would not agree to moving for an enlargement of time, because they feared it would make them look bad, in seeking further delay. Cassell said it would be a gesture of good faith for the government to agree not to file a motion to dismiss for lack of prosecution. When I said we would agree to withhold filing such a motion, during the pendency of the extension period(if granted by the court), Cassell said that would not be good enough, he wanted us to promise not to file such a motion at all. I told him I would not agree to that. + +Cassell then went on to say that such a motion would be lacking in merit, and would not be granted. I asked him why the victims were so concerned about the government filing such a motion, if it was so ill-founded. Cassell said the filing of such a motion would add to the "atmospherics" of delay by the victims. He even accused the government of "sandbagging" them. + +I told Cassell and Edwards that I would have to consult with the Executive Division on whether we would permanently forego filing a motion to dismiss for lack of prosecution. As it stands, the victims will file a joint motion to extend the period for filing the victims' response to the order to show cause (with our concurrence), only if the government agrees never to file a motion to dismiss for lack of prosecution. During this extension period, Edwards and Cassell would want to meet with the U.S. Attorney and Executive Staff regarding resolution of the case, to include a prosecution of Epstein. + +The issue is how important it is to our office to keep the victims from filing their documents with the Court today. The price of a joint motion to extend time is our forebearance from filing a motion to dismiss for lack of prosecution. There is no guarantee that any meetings between our office and Cassell and Edwards will resolve this matter, given what they seek. We may be in the same position again thirty days from now. + +We told Cassell and Edwards we would get back to them early this afternoon. Marie and I are available to chat about this case. Thank you. \ No newline at end of file diff --git a/marker2/ds9/EFTA00206813/EFTA00206813.metadata.json b/marker2/ds9/EFTA00206813/EFTA00206813.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d5c1b863dbc11f5964c178a3a209e73816440c64 --- /dev/null +++ b/marker2/ds9/EFTA00206813/EFTA00206813.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206813.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 2779, + "elapsed_seconds": 0.75, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 69 + ], + [ + "Line", + 35 + ], + [ + "Text", + 14 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206813" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206814/EFTA00206814.md b/marker2/ds9/EFTA00206814/EFTA00206814.md new file mode 100644 index 0000000000000000000000000000000000000000..e4047269209d23c53c0dc953b8a37cf1899575ba --- /dev/null +++ b/marker2/ds9/EFTA00206814/EFTA00206814.md @@ -0,0 +1,97 @@ +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA + +CASE NO. 08-80736-CIV-MAFtRA/JOHNSON + +IN RE: JANE DOE, + +Petitioner. + +I + +#### GOVERNMENT'S RESPONSE TO VICTIM'S EMERGENCY PETITION FOR ENFORCEMENT OF CRIME VICTIM RIGHTS ACT. 18 U.S.C. § 3771 + +FILED Dy D.C. JUL 0 9 2008 STE /EN M. LARIMORE E RA U S LIST. CT. S.D. OF P.A. . wPB. + +The United States of America, by and through its undersigned counsel, files its Response to Victim's Emergency Petition for Enforcement of Victim Rights Act, 18 U.S.C. § 3771, and states: + +# I. THERE IS NO "COURT PROCEEDING" UNDER 18 U.S.C. § 3771(b) + +Petitioner complains that she has been denied her rights under the Crime Victims Rights Act, 18 U.S.C. § 3771. In the emergency petition filed by the victim, she alleges the Government has denied her rights since she has received no consultation with the attorney for the government regarding possible disposition of the charges (18 U.S.C. § 3771(aX5)); no notice of any public court proceedings (18 U.S.C. § 3771(aX2)); no information regarding her right to restitution (18 U.S.C. § 3771(0(6)); and no notice of rights under the Crime Victim Rights Act (CVRA). Emergency Petition, ¶ 5. + +The instant case is unique in several respects. First, in 2006, Jeffrey Epstein was charged with felony solicitation of prostitution in the Circuit Court of the Fifteenth Judicial Circuit, Palm Beach County, Florida. This charge was based upon the offenses alleged in paragraph 1 of the petition. Second, while Epstein has been under federal investigation, he has not been charged in + +the Southern District of Florida. + +1 itle 18, U.S.C., Section 3771(bX1) provides in pertinent part that, "Tin any court proceeding involving an offense against a crime victim, the court shall ensure that the crime victim is afforded the rights described in subsection (a)." There is no "court proceeding" in the instant case since Epstein has not been charged with violation of any federal statute. No federal grand jury indictment has been returned, nor has any criminal information been filed. There can thus be no failure of a right to notice of a public court proceeding or the right to restitution. + +In her memorandum, petitioner relies upon In Re Dean, 527 F.3d 391 (5th Cir. 2008), where the Fifth Circuit held that the CVRA required the government to "confer in some reasonable way with the victims before ultimately exercising its broad discretion." Id. at 395. In Dean, the government sought and obtained an ex parte order permitting it to negotiate a plea agreement with BP Products North America, without first consulting with the victims, individuals injured and survivors of those killed in a refinery explosion. A plea agreement was ultimately negotiated and the victims objected. The appellate court found that the CVRA granted a right to confer. However, the court declined to grant mandamus relief for prudential reasons, finding that the district court had the benefit of the views of the victims who chose to participate at the hearing held on whether the plea agreement should be accepted. N. at 396. + +Dean is legally distinguishable in several respects. For one thing, the court's discussion of the scope of the right to confer was unnecessary because the court ultimately declined to issue mandamus relief. Dean 527 F.3d at 395. Also, in offering its view that this right applies precharge, it is noteworthy that the court, in purporting to quote the statute, omitted the last three words of section 3771(aX5)("in the case"), words that arguably point in the opposite direction by + +suggesting that the right applies post-charge. Further, the court went to great lengths to emphasize that its holding was limited to the particular circumstances presented in that case (i.e., the simultaneous filing of a plea agreement and formal charges), which of course, is not the case here. No federal charges have been filed in the instant case, and this case, unlike Dean, involves an agreement to defer federal prosecution in favor of prosecution by the State of Florida and not a guilty plea. Its at 394. Finally, the Dean court expressly declined to "speculate on the [right to confer's) applicability to other situations." Id. Nothing in § 3771(a)(5) supports the petitioner's claim that she had a right to be consulted before the Government could enter into a nonprosecution agreement which defers federal prosecution in exchange for state court resolution of criminal liability, and a significant concession on an element of a claim for compensation under 18 U.S.C. § 2255. + +## II. THE GOVERNMENT HAS USED ITS BEST EFFORTS TO COMPLY WITH 18 U.S.C.& 3771(al + +The Epstein case was investigated initially by the Palm Beach Police Department in 2006. Exhibit A, Declaration of Assistant United States Attorney A. Marie Villafafta, ¶ 2. Subsequently, the Palm Beach Police Department sought the assistance of the Federal Bureau of Investigation (FBI). Id. Throughout the investigation, when a victim was identified, victim notification letters were provided to the victim by both the FBI Victim-Witness Specialist and AUSA Villafafa. ILI 3. Petitioner's counsel, Brad Edwards, Esq., currently represents C.W., T.M., and S.R. The U.S. Attorney's Office victim notification letter to C.W. was provided by the FBI. and the letter to T.M. was hand-delivered by AUSA Villafaiia to her when she was interviewed in April 2007. FBI victim notification letters were mailed to C.W. and T.M. on + +January 10, 2008, and to S.R. on May 30, 2008. Villafafia Decl., 1 3. + +Throughout the investigation, AUSA Villafafia and the FBI's Victim-Witness Specialist had contact with C.W. Villafafia Decl., 1 4. Earlier in the investigation, T.M. was represented by James Eisenberg, Esq. Consequently, all contact with T.M. was made through Mr. Eisenberg. + +In mid-2007, Epstein's attorneys approached the U.S. Attorney's Office in an effort to resolve the federal investigation. al 5. At that time, Mr. Epstein had been charged by the State of Florida with solicitation of prostitution, in violation of Florida Statutes § 796.07. Mr. Epstein's attorneys sought a global resolution of this matter. The United States subsequently agreed to defer federal prosecution in favor of prosecution by the State of Florida, so long as certain basic preconditions were met. One of the key objectives for the Government was to preserve a federal remedy for the young girls whom Epstein had sexually exploited. Thus, one condition of that agreement, notice of which was provided to the victims on July 9, 2008, is the following: + +> "Any person, who while a minor, was a victim of a violation of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under Section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining which evidentiary burdens if any a plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." + +The Attorney General Guidelines for Victim and Witness Assistance (May 2005), Article + +IV, Services to Victims and Witnesses, provides the following guidance for proposed plea agreements: + +- (3) Proposed Plea Agreements. Responsible officials should make reasonable efforts to notify identified victims of, and consider victims' views about, prospective plea negotiations. In determining what is reasonable, the responsible official should consider factors relevant to the wisdom and practicality of giving notice and considering views in the context of the particular case, including, but not limited to, the following factors: +- (a) The impact on public safety and risks to personal safety. +- (b) The number of victims. +- (c) Whether time is of the essence in negotiating or entering a proposed plea. +- (d) Whether the proposed plea involves confidential information or conditions. +- (e) Whether there is another need for confidentiality. +- (f) Whether the victim is a possible witness in the case and the effect that relaying any information may have on the defendant's right to a fair trial. + +Throughout negotiations, Epstein's attorneys claimed that one reason victims came forward and pressed their claims was their desire for money. They argued that victims might have an inducement to fabricate or enhance their testimony, in order to maximize their opportunities to obtain financial recompense. Villafarla Dcel., ¶ 8. The Government was extremely concerned that disclosure of the proposed terms would compromise the investigation by providing Epstein the means of impeaching the victim witnesses, should the parties fail to reach an agreement. In light of the fact (i) that the United States agreed to defer prosecution to a previously filed state criminal case; (ii) that as a result sentencing would take place in state court before a state judge; (iii) that if the state resolution failed to meet minimum standards such that a federal prosecution was warranted, the victims would be witnesses and thus potential + +impeachment issues were of concern; and (iv) the United States was already making efforts to secure for victims the right to proceed federally under 18 U.S.C. § 2255 even if prosecution took place in state court, the Government determined that its actions in proceeding with this agreement best balanced the dual position of the Jane Does as both victims and potential witnesses in a criminal proceeding. + +On Friday, June 27, 2008, at approximately 4:15 p.m., AUSA Villafafia received a copy of the proposed state plea agreement, and learned that Epstein's state plea hearing was scheduled for Monday, June 30, 2008, at 8:30 a.m. Villafafia Decl., ¶ 10. AUSA Villafafia and the Palm Beach Police Department attempted to provide notification to victims in the short time that they had. 10, Although all known victims were not notified, AUSA Villafafia did call attorney Edwards to provide notice to his clients regarding the hearing. AUSA Villafafia did this, even though she had no obligation to provide notice of a state court hearing. Mr. Edwards advised that he could not attend but that someone would be present at the hearing. ld. + +The Government has complied with 18 U.S.C. § 3771(cX1) by using its best efforts to "see that crime victims are notified of, and accorded, the rights described in subsection (a)." Specifically, petitioner was afforded the reasonable right to confer with the attorney for the Government under 18 U.S.C. § 3771(a)(5). Disclosure of the specific terms of the negotiation were not disclosed prior to a final agreement being reached because the Government believed doing so would jeopardize and prejudice the prosecution in the event an agreement could not be made. Further, although 18 U.S.C. § 3771(a)(2) does not apply to state court proceedings, the government nonetheless notified petitioner's counsel on June 27, 2008, of the plea hearing in state court on June 30, 2008. + +Section 3771(dX6) provides, in relevant part, that InJothing in this chapter shall be construed to impair the prosecutorial discretion of the Attorney General or any officer under his direction." The Government exercised its judgment and discretion in determining that there was a need for confidentiality in the negotiations with Epstein. The significant benefit of obtaining Epstein's concession that victims suing him under 18 U.S.C. § 2255(a) were "victims" of the enumerated offenses, despite the fact he has not been convicted in federal court, was of sufficient importance to justify confidentiality of the negotiations. + +# III. THE GOVERNMENT'S DISCUSSIONS WITI1 T.M.. C.W,, AND S.R. + +Attorney Brad Edwards has advised the Government that he represents T.M., C.W., and S.R. Victim letters were provided to all three individuals. The letters to C.W. and T.M. were forwarded on January 10, 2008. Villafana Decl., 1 3. On May 28, 2008, S.R.'s status as a victim was confirmed when she was interviewed by federal agents. a The FBI Victim Witness specialist sent her a letter on May 30, 2008. + +When the agreement was signed in September 2007, T.M. was openly hostile to a prosecution of Epstein, and S.R. had refused to speak with federal investigators. Id., ¶ 7. While individual victims were not consulted regarding the agreement, none of Mr. Edwards' clients had expressed a desire to be consulted prior to the resolution of the federal investigation. Id. + +In October 2007, C.W. was not represented by counsel. a. y 8. She was given telephonic notice of the agreement, as were three other victims. Id. These four individuals were also given notice of an expected change of plea, in state court, in October 2007. + +In mid-June 2008, Mr. Edwards contacted AUSA Villafarla to advise that he represented C.W. and S.R., and requested a meeting. 11, 1 9. AUSA Villaftula asked Mr. Edwards to send + +to her any information that he wished her to consider. Nothing was provided. Id. AUSA Vitiate% also told Mr. Edwards he could contact the State Attorney's Office, if he wished. To her knowledge, Mr. Edwards did not make the contact. + +The Government has acted reasonably in keeping T.M, C.W., and S.R. informed. Petitioner's rights tinder the CVRA have not been violated. Therefore, her emergency petition should be denied. + +Respectfully submitted, + +R. ALEXANDER ACOSTA UNUED STAMS KITORNEY + +By: + +Assistant U.S. Attorney + +99 N.E. 414 Street Miami. Florida 33132 + +Attorney for Respondent + +### CERTIFICATE OF SERVICE + +I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via facsimile transmission and U.S. Mail, thi day of July, 2008, to: Brad Edwards, Esq., The Law Offices of Brad Edwards & Associates, LLC, + +Assistant U.S. Attorney \ No newline at end of file diff --git a/marker2/ds9/EFTA00206814/EFTA00206814.metadata.json b/marker2/ds9/EFTA00206814/EFTA00206814.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..0ade6990e0949d8a11ee3842081b1db254c54dc8 --- /dev/null +++ b/marker2/ds9/EFTA00206814/EFTA00206814.metadata.json @@ -0,0 +1,459 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206814.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 8, + "chars": 14111, + "elapsed_seconds": 1.44, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF FLORIDA", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 207.87, + 100.42889404296875 + ], + [ + 406.6198425292969, + 100.42889404296875 + ], + [ + 406.6198425292969, + 129.06353759765625 + ], + [ + 207.87, + 129.06353759765625 + ] + ] + }, + { + "title": "GOVERNMENT'S RESPONSE TO VICTIM'S EMERGENCY PETITION \nFOR ENFORCEMENT OF CRIME VICTIM RIGHTS ACT. 18 U.S.C. \u00a7 3771", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 114.39000000000001, + 255.14999999999998 + ], + [ + 500.0142822265625, + 255.14999999999998 + ], + [ + 500.0142822265625, + 284.68353271484375 + ], + [ + 114.39000000000001, + 284.68353271484375 + ] + ] + }, + { + "title": "I. 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UNITED STATES Respondent. + +# RESPONDENT'S MOTION TO DISMISS + +Respondent, United States of America, by and through its undersigned counsel, files its Motion to Dismiss, pursuant to Rules 12(6)(6) and 41(b), Federal Rules of Civil Procedure, and states: + +# I. LITIGATION HISTORY + +On July 7, 2008, plaintiff Jane Doe filed her "Emergency Victim's Petition for Enforcement of Crime Victim's Rights Act, 18 U.S.C. Section 3771." (D.E. I). On the same day, this Court issued an Order directing the United States Attorney to file a response to the petition by 5:00 p.m., Wednesday, July 9, 2008. (D.E. 3). + +On July 9, 2008, the United States Attorney filed the "Government's Response to Victim's Emergency Petition for Enforcement of Crime Victim Rights Act, 18 U.S.C. § 3771." (D.E. 7). The Court held a hearing on July 11, 2008. + +On August 18, 2008, the Court held a status conference. On August 21, 2008, the Court ordered the Government to produce a copy of the Non-Prosecution Agreement between the United States Attorney and Jeffrey Epstein, and simultaneously entered a protective order prohibiting petitioners from disseminating the Non-Prosecution Agreement beyond designated individuals. (D.E. 26). + +On September 25, 2008, petitioners filed their motion to unseal document. (D.E. 28). On October 8, 2008, the Government filed its response in opposition to petitioners' motion. (D.E. 29). Petitioners filed their reply on October 16, 2008. (D.E. 30). On February 12, 2009, the Court denied petitioners' motion to unseal document. (D.E. 36). + +Since February 12, 2009, there has been no activity in this case, other than the filing of a notice by petitioners' counsel of his change in firm affiliation. (D.E. 37). + +# II. THIS CASE SHOULD BE DISMISSED FOR LACK OF PROSECUTION + +Under Fed.R.Civ.P. 41(b), "[i]f the plaintiff fails to prosecute or to comply with these rules or a court order, a defendant may move to dismiss the action or any claim against it." In Goforth v. Owens, 766 F.2d 1533 (11 ih Cir. 1985), the Eleventh Circuit observed that "[a] district court is authorized, on defendant's motion, to dismiss an action for failure to prosecute or to obey a court order or federal rule." iii at 1535. A court's + +power to dismiss is an inherent aspect of its authority to enforce its orders and insure prompt disposition of lawsuits. Id. , citing Link v. Wabash Railroad Co. , 370 U.S. 626, 630-31 (1962), and Jones v. Graham , 709 F.2d 1457, 1458 (11 di Cir. 1983). Under Rule 41(b), the legal standard to be applied is "whether there is a clear record of delay or willful contempt and a finding that lesser sanctions would not suffice." 766 F.3d at 1535. + +Dismissal of a case with prejudice is considered a sanction of last resort, applicable only in extreme circumstances. Id. + +The Government believes the instant case should be dismissed because of the clear record of delay. + +After the initial filing on July 7, 2008, and the emergency hearing on July 11, 2008, the only notable activity in the case was petitioners' invocation of this Court's authority to obtain a copy of the Non-Prosecution Agreement. + +D.E. 19. The Government, pursuant to the Court's Order to Compel Production and Protective Order (D.E. 26), provided a copy of the Agreement to petitioners. On September 25, 2008, petitioners attempted to have the Court "unseal" the Non-Prosecution Agreement (D.E. 28). The Government opposed the motion because the Non-Prosecution Agreement had never been filed with the Court, under seal or otherwise. D.E. 29. On February 12, 2009, the Court denied petitioners' motion (D.E. 36). The Court specifically addressed petitioners' claim that the Non-Prosecution Agreement should be unsealed because the government had mischaracterized some of its provisions: + +> If and when such alleged mischaracterizations become relevant to an issue to be decided by the Court, the parties will be given an opportunity to advance their positions and the Court will resolve the issue. If disclosure of the Agreement will be required for the Court to resolve the issue, appropriate disclosure will be ordered (D.E. 36 at 1-2). + +Since nothing has occurred in the instant case since the February 12, 2009 Order, presumably petitioners did not believe the mischaracterizations they claimed were made by the Government became relevant to any issue to be decided by the Court. + +On September 8, 2010, this Court entered its Order Closing Case (D.E. 38). The Court noted that "[a]n examination of the docket reveals that no activity has taken place in this case since April of 2009. In light of the underlying settlements between the victims and Mr. Epstein, it is hereby ORDERED AND ADJUDGED that this case is CLOSED ." (D.E. 38)(emphasis in original). It is not unreasonable to believe that the instant action under the Crime Victims Rights Act was auxiliary litigation to support petitioners' claims against Jeffrey Epstein for money damages, particularly with regard to obtaining documents and information from the United States Attorney. Once petitioners' damage claims against Mr. Epstein had been resolved, there would be no + +need for this auxiliary litigation. The absence of any activity in the case since April 2009 supports the conclusion that vindicating the petitioners' rights under the CVRA was not the primary purpose of this case. + +"A district court has inherent authority to manage its own docket `so as to achieve the orderly and expeditious disposition of cases." yL Properties, Inc. v. Florida Mowing and Landscape Service, Inc. , 556 F.3d 1232, 1240 (11 th Cir. 2009)(citation omitted). Under Rule 41(b), the court may dismiss a claim if the plaintiff fails to prosecute it or comply with a court order. Id. "The power to invoke this sanction is necessary in order to prevent undue delays in the disposition of pending cases and to avoid congestion in the calendars of the District Court." Id. , citing Durham v. Fla. East Coast Ry. Co. , 385 F.2d 366, 367 (5 di Cir. 1967). The instant case was filed as an emergency matter on July 7, 2008. Within two days, the government filed a written response to the emergency petition, and the Court held an emergency hearing four days after the emergency petition was filed. After this initial flurry of activity, predicated on petitioners' claim of an emergency, petitioners have done little to advance the litigation and seek resolution of their claims. a This clear record of delay provides ample basis for this Court to exercise its discretion and dismiss this case for lack of prosecution under Rule 41(b). + +## III. PETITIONERS HAVE FAILED TO STATE A CLAIM UPON WHICH RELIEF CAN BE GRANTED UNDER 18 U.S.C. § 3771(aX5) + +The heart of petitioners' claim under the Crime Victims Rights Act (CVRA) is that the United States Attorney was legally obligated, under 18 U.S.C. § 3771(a)(5), to consult with them prior to entering into the Non-prosecution Agreement with Jeffrey Epstein. D.E. 1, ¶ 5. This claim should be dismissed under Rule 12(b)(6) because it fails to state a claim upon which relief can be granted. + +In Bell Atlantic Corp. v. Twombly , 127 S.Ct. 1955 (2007), the Supreme Court observed that a plaintiff's obligation to provide the grounds of his entitlement to relief requires more than labels and conclusions, and a formulaic recitation of the elements of a cause of action will not do. Id. at 1964-65. Instead, factual allegations must be enough to raise a right to relief above the speculative level. "The standard is one of "plausible grounds to infer." Id. In Ashcroft v. Iqbal , 129 S.Ct. 1937 (2009), the Supreme Court noted that two working principles underlay its decision in Twombly : (1) the tenet that a court must accept as true all of the allegations contained in a complaint is inapplicable to legal conclusions; and (2) only a complaint that states a plausible claim for relief survives a motion to dismiss. Id. at 1949-50. + +The rights of crime victims are set forth in 18 U.S.C. § 3771(a), and include eight (8) specific rights. + +3771(a)(2), the right to reasonable, accurate, and timely notice of any public court proceeding; § 3771(a)(6), the right to full and timely restitution as provided in law; and notice of her rights under the CVRA. + +It is undisputed that no federal criminal charges have been filed against Jeffrey Epstein, in the U.S. District Court, Southern District of Florida, pertaining to the sexual abuse of minors. fi The United States submits that, since there is no "case" pending in the Southern District of Florida against Epstein, or any "court proceeding" involving an offense against Jane Does 1 and 2, they cannot invoke any protections under 18 U.S.C. § 377l (a)(2) and (5). + +Title 18, United States Code, § 3771(a)(5), provides that a crime victim has "(t]he reasonable right to confer with the attorney for the Government in the case." In its interpretation of a federal statute, the court assumes that "Congress used words in a statute as they are commonly and ordinarily understood," and reads the statute to give full effect to each of its provisions. United States v. DBB, Inc. , 180 F.3d 1277, 1281 (11 di Cir. + +1999), citing United States v. McLymont , 45 F3d 400, 401 (11 th Cir. 1995). Section 3771(a)(5) grants a crime victim the reasonable right to confer with the attorney for the Government "in the case." The phrase "in the case" must be considered since there is a canon of statutory construction that "discourages courts from adopting a reading of a statute that renders any part of the statute mere surplusage." Bailey v. United States , 516 U.S. 137, 146 (1995)(noting that each word in a statute is intended to have "particular, nonsuperfluous meaning"). + +Respondents submit that Congress intended the phrase "in the case" to mean a case filed in the district court. Federal criminal cases are filed in the United States district courts through the filing of a criminal complaint, Fed.R.Crim.P. 3, or indictment, Fed.R.Crim.P. 7. In each instance, an attorney representing the United States Government is required to sign the complaint or indictment. Thus, each criminal case filed in the district court has an attorney for the Government representing the sovereign United States. + +In contrast, § 3771(a)(1) provides that a crime victim "has the right to be reasonably protected from the accused." No mention is made about a case or court proceeding. Thus, Congress intended that this right attaches even before a case is filed in the district court. The absence of any mention of the attorney for the Government is also telling, since the case may still be in the investigative stage, and not yet been assigned an attorney. In such a case, the federal law enforcement agency would be responsible for providing the reasonable protection from the accused. + +Because there is not any case against Epstein in the Southern District of Florida, Jane Does 1 and 2 have no rights under § 3771(a)(5) to consult with the attorney for the Government. The United States Attorney's + +Office was under no obligation to consult with Jane Does 1 and 2 prior to concluding its Non-Prosecution Agreement with Epstein. For the same reason, Jane Doe's claim under § 3771(a)(2) also fails. There has been no "public court proceeding" against Epstein in the U.S. District Court, Southern District of Florida, since no criminal case has been filed against him in the federal court. Consequently, there has been nothing for which the U.S. Attorney's Office was required to give notice to Jane Doe. + +A different provision in the CVRA, 18 U.S.C. § 3771(b), also supports the Government's interpretation of § 3771(a)(5). Section 3771(b)(1) provides as follows: + +> In any court proceeding involving an offense against a crime victim, the court shall ensure that the crime victim is afforded the rights described in subsection (a). + +> Before making a determination described in subsection (a)(3), the court shall make every effort to permit the fullest attendance possible by the victim and shall consider reasonable alternatives to the exclusion of the victim from the criminal proceeding. The reasons for any decision denying relief under this chapter shall be clearly stated on the record. + +There is no "court proceeding" in this case because no federal criminal charges have been lodged against Jeffrey Epstein. Section 3771(b)(1) envisions that a district court presiding over a criminal trial will be responsible for ensuring that a crime victim will be afforded rights granted in § 3771(a). Section 3771(a)(3), which is expressly referenced in § 3771(b)(1), provides that a crime victim has + +> The right not to be excluded from any such public court proceeding, unless the court, after receiving clear and convincing evidence, determines that testimony by the victim would be materially altered if the victim heard other testimony at that proceeding. + +This provision contemplates that, in the event a defendant invokes the rule of sequestration in Fed.R.Evid. 615, the court must consider the crime victim's rights under § 3771(a)(3), and can only exclude the victim from the proceeding if the court finds there is clear and convincing evidence that the victim's testimony would be materially altered if the victim was allowed to hear other testimony at the proceeding. By providing a difficult evidentiary standard which must be met before a victim's right to be present in the court proceeding can be denied, Congress was purposefully limiting a court's discretion in sequestering trial witnesses. + +In the instant case, there is no "court proceeding" since no federal criminal charges have been brought against Epstein. Therefore, § 3771(b)(1) is inapplicable. There is no role for this Court to fulfill under § 3771(b)(1). + +The petition fails to state facts upon which the Court can find a plausible claim for relief exists. + +Accordingly, the petition should be dismissed for failure to state a claim upon which relief can be granted. + +## IV. SEPARATION OF POWERS PRINCIPLES PRECLUDE THE COURT FROM GRANTING ANY RELIEF REGARDING THE NON-PROSECUTION AGREEMENT + +In the instant case, the Non-Prosecution Agreement between the Government and Jeffrey Epstein was concluded in September and October 2007, months before petitioners instituted their action. By entering into the Non-Prosecution Agreement, the United States was exercising its prosecutorial discretion as to the best means to resolve the allegations that Epstein had violated federal law by engaging in criminal sexual misconduct with minors. + +The Executive Branch enjoys exceedingly broad discretion in deciding how, or whether, to charge an individual. Bordenkircher v. Hayes , 434 U.S. 357, 668 (1978)("In our system, so long as the prosecutor has probable cause to believe that the accused committed an offense defined by statute, the decision whether or not to prosecute, and what charge to file or bring before a grand jury, generally rests entirely in his discretion") (footnote omitted), and Nixon v. United States , 418 U.S. 683, 693 (1974)(Executive Branch has exclusive authority and absolute discretion to decide whether to prosecute a case). Mindful of that principle, Congress expressly provided in the CVRA that, "[n]othing in this chapter shall be construed to impair the prosecutorial discretion of the Attorney General or any officer under his direction." 18 U.S.C. § 3771(d)(6). + +Petitioners had no right under the CVRA to confer with the attorney for the Government, prior to the entry into the Non-Prosecution Agreement, because there was no existing case in the U.S. District Court. + +Moreover, even if they had the right to confer, they had no legal means to prevent the United States from negotiating the Agreement it ultimately entered into with Epstein. Unlike the situation in In Re Dean , 527 F.3d 391 (5 th Cir. 2008), the Non-Prosecution Agreement did not come before any federal court for review and approval, nor was such action required. In Dean , if the district court believed that the victims had been denied their right to consult under § 3771(a)(5), it could reject the plea agreement and direct that the required consultation occur prior to the negotiation of any new plea agreement. In contrast, the Non-Prosecution Agreement never came before this court. Therefore, this Court is without authority to provide a remedy under § 3771(b)(1). + +Respectfully submitted, +WIFREDO A. FERRER +UNITED STATES ATTORNEY + +By: + +[REDACTED] + +Assistant U.S. Attorney + +[REDACTED] + +99 N.E. 4 th Street +Miami, Florida 33132 + +[REDACTED] + +I HEREBY CERTIFY that on October \_\_\_\_, 2010, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. + +![](_page_6_Picture_112.jpeg) + +Assistant U.S. Attorney +SERVICE LIST + +Jane Does 1 and 2 v. United States, +Case No. 08-80736-CIV-MARRA/JOHNSON +United States District Court, Southern District of Florida + +Brad Edwards, Esq., +The Law Offices of Brad Edwards & Associates, LLC + +![](_page_6_Picture_116.jpeg) + +Paul G. Cassell +Ronald N. Boyce Presidential Professor of Criminal Law +S.J. Quinney College of Law at the University of Utah + +![](_page_6_Picture_118.jpeg) + +Attorneys for Petitioners + +--- + +F1 The emergency was based upon petitioners' belief that Jeffrey Epstein was engaged in plea negotiations with the United States Attorney's Office and that such negotiations would likely result in a disposition of the charges within the "next several days." D.E. 1, ¶ 3. The petitioner noted that Epstein had already entered a plea of guilty on June 30, 2008, in the Circuit Court for Palm Beach County, Florida, to similar state offenses including solicitation of minors for prostitution. D.E. 1, ¶ 2. + +F2 "A district court may take judicial notice of public records within its files relating to the particular case before it or other related cases." Cash Inn of Dade, Inc. v. Metropolitan Dade County , 932 F.2d 1239, 1243 (11 th Cir. 1991)(citations omitted). Additionally, in a Rule 12(b)(6) motion, a court may properly consider materials of which it has taken judicial notice. Philips v. Pitt County Mem'l Hosp. , 572 F.3d 176, 180 (4 th Cir. 2009). \ No newline at end of file diff --git a/marker2/ds9/EFTA00206822/EFTA00206822.metadata.json b/marker2/ds9/EFTA00206822/EFTA00206822.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d4ab6ddf31634e590ba42acb1536d2360e64e63b --- /dev/null +++ b/marker2/ds9/EFTA00206822/EFTA00206822.metadata.json @@ -0,0 +1,443 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206822.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 7, + "chars": 18264, + "elapsed_seconds": 9.63, + "image_assets": [ + "_page_6_Picture_112.jpeg", + "_page_6_Picture_116.jpeg", + "_page_6_Picture_118.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF FLORIDA \nCase No. 08-80736-Civ-Marra/Johnson", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 206.24400000000003, + 31.589999999999996 + ], + [ + 405.5555419921875, + 31.589999999999996 + ], + [ + 405.5555419921875, + 74.103515625 + ], + [ + 206.24400000000003, + 74.103515625 + ] + ] + }, + { + "title": "RESPONDENT'S MOTION TO DISMISS", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 198.89999999999998, + 153.09 + ], + [ + 413.7095947265625, + 153.09 + ], + [ + 413.7095947265625, + 168.603515625 + ], + [ + 198.89999999999998, + 168.603515625 + ] + ] + }, + { + "title": "I. 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Brad did say that Paul agreed to the extension, if we made the motion. Dexter is on a flight right now. Brad and I have agreed to talk again in the morning. I will discuss with Dexter tonight, then hopefully try to set up a conference call with and I for tomorrow morning so we can get everyone on the same page. + +I will keep you all posted. + +![](_page_0_Picture_6.jpeg) + +400 + +![](_page_0_Picture_9.jpeg) + +Subject: RE: (draft) Pleadings to Be Filed Tomorrow -- RE JEFFREY EPSTEIN + +In addition to the thoughts I raised earlier, I'd note that two weeks doesn't seem like much time. + +![](_page_0_Picture_12.jpeg) + +Subject: FW: (draft) Pleadings to Be Filed Tomorrow -- RE JEFFREY EPSTEIN + +Good afternoon, everyone. So much for my telephone call this morning. Judge Cassell has apparently taken a different point of view. Please see below and attached. + +![](_page_0_Picture_16.jpeg) + +From: Paul Cassell [mailb3:casselig@flaw.utah.edu] + +Sent: Tuesday, October 26, 2010 4:49 PM + +![](_page_0_Picture_19.jpeg) + +I wanted to send you drafts of the pleadings we are in the process of preparing to file tomorrow, pursuant to Judge Marra's order. As mentioned in several previous e-mails, we stand ready to work with you to try and narrow the range of disputed facts — and trust that you will be willing to stipulate to all the facts that are correct in our pleadings. (Most of them are now based on documented e-mails, so we trust the bulk of the facts will gain your stipulated approval.) + +I am also writing because co-counsel Brad Edwards has been working with on a possible approach to the filings tomorrow. At MIEJggestion, Brad has offered to take out a paragraph that Marea was concerned about in our fact section and to file our pleadings under seal tomorrow for, say, a period of (at least) two weeks. This would give us an opportunity to work with you to resolve disputed facts and, more generally, to try and resolve the entire dispute. In exchange, we request that you agree not to file a motion to dismiss for lack of prosecution and not to argue that we need to file some sort of civil complaint to litigate these issues (both suggestions you raised in your earlier e-mail). Brad and I don't believe such arguments would be legally well founded in any event. But if you are asking for concessions on our part, we would like to narrow the subjects of the litigation that we have to respond to in exchange. + +As we have mentioned at every stage of this case, we stand ready to work with you to try and resolve the matter. We continue to be willing to attempt a fair resolution that protects our client's interests. Along those lines, if you have concerns about us filing our pleadings under seal tomorrow, we are ready to discuss the idea of delaying any filing for a period of, say, two weeks. Such a delay, however, would be contingent on your obtaining an extension from Judge Marra of our filing deadline. As you can see, we are ready to file and would delay only as an accommodation to you — and would except you to do the motion that would be required for such an extension). + +Brad and I stand ready to discuss these issues at any time with you and/or Marie. + +Sincerely, + +Paul Cassell + +Counsel for Jane Doe #1 and Jane Doe #2 + +CONFIDENTIAL: l 11.6 electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the sender by reply electronic mail and delete the original message. 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sha256:54ecbc45c31891436b1794e14f5cdad3dddee1f6cd7e1f684d1ee8846c2030b9 +size 4950 diff --git a/marker2/ds9/EFTA00206829/_page_0_Picture_9.jpeg b/marker2/ds9/EFTA00206829/_page_0_Picture_9.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..a78999b7582f09a2c7e3bb23d04c4775a0d36ae4 --- /dev/null +++ b/marker2/ds9/EFTA00206829/_page_0_Picture_9.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:a8ab5e74c67eb84589df22c1257a615017fdbe017f8802eda63709f238370733 +size 5241 diff --git a/marker2/ds9/EFTA00206831/EFTA00206831.md b/marker2/ds9/EFTA00206831/EFTA00206831.md new file mode 100644 index 0000000000000000000000000000000000000000..fb905e4ee269500db390a585b4b242ee7ecc4d6f --- /dev/null +++ b/marker2/ds9/EFTA00206831/EFTA00206831.md @@ -0,0 +1,47 @@ +![](_page_0_Picture_0.jpeg) + +Subject: RE: (draft) Pleadings to Be Filed Tomorrow -- RE JEFFREY EPSTEIN + +Date: Tue, 26 Oct 2010 21:08:42 +0000 + +Importance: Normal + +In addition to the thoughts I raised earlier, I'd note that two weeks doesn't seem like much time. + +Sent: Tuesday, October 26, 2010 5:02 PM + +Subject: FW: (draft) Pleadings to Be Filed Tomorrow -- RE JEFFREY EPSTEIN + +Good afternoon, everyone. So much for my telephone call this morning. Judge Cassell has apparently taken a different point of view. Please see below and attached. + +![](_page_0_Picture_8.jpeg) + +From: Paul Cassell [mailto:cassellp@law.utah.edu] + +Sent: Tuesday, October 26, 2010 4:49 PM + +Subject: (draft) Pleadings to Be Filed Tomorrow + +![](_page_0_Picture_13.jpeg) + +I wanted to send you drafts of the pleadings we are in the process of preparing to file tomorrow, pursuant to Judge Marra's order. As mentioned in several previous e-mails, we stand ready to work with you to try and narrow the range of disputed facts — and trust that you will be willing to stipulate to all the facts that are correct in our pleadings. (Most of them are now based on documented e-mails, so we trust the bulk of the facts will gain your stipulated approval.) + +I am also writing because co-counsel Brad Edwards has been working with a possible approach to the filings tomorrow. At•PuturIet suggestion, Brad has offered to take out a paragraph that Marea was concerned about in our fact section and to file our pleadings under seal tomorrow for, say, a period of (at least) two weeks. This would give us an opportunity to work with you to resolve disputed facts and, more generally, to try and resolve the entire dispute. In exchange, we request that you agree not to file a motion to dismiss for lack of prosecution and not to argue that we need to file some sort of civil complaint to litigate these issues (both suggestions you raised in your earlier e-mail). Brad and I don't believe such arguments would be legally well founded in any event. But if you are asking for concessions on our part, we would like to narrow the subjects of the litigation that we have to respond to in exchange. + +As we have mentioned at every stage of this case, we stand ready to work with you to try and resolve the matter. We continue to be willing to attempt a fair resolution that protects our client's interests. Along those lines, if you have + +concerns about us filing our pleadings under seal tomorrow, we are ready to discuss the idea of delaying any filing for a period of, say, two weeks. Such a delay, however, would be contingent on your obtaining an extension from Judge Marra of our filing deadline. As you can see, we are ready to file and would delay only as an accommodation to you — and would except you to do the motion that would be required for such an extension). + +Brad and I stand ready to discuss these issues at any time with you and/or + +Sincerely, + +Paul Cassell + +Counsel for Jane Doe #1 and Jane Doe #2 + +801-201-8271 (cell phone) + +F F 5 5 fly + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the sender by reply electronic mail and delete the original message. 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So much for my telephone call this morning. Judge Cassell has apparently taken a different point of view. Please see below and attached. + +Assistant U.S. Attorney + +West Palm Beach, FL 33401 + +From: Paul Cassell [mailto + +Sent: Tuesday, October 26, 2010 4:49 PM + +To: SAFLS + +Cc: (USAFLS); Brad Edwards + +Subject: (draft) ea ings to Be Filed Tomorrow + +Dear M, + +I wanted to send you drafts of the pleadings we are in the process of preparing to file tomorrow, pursuant to Judge Marra's order. As mentioned in several previous e-mails, we stand ready to work with you to try and narrow the range of disputed facts — and trust that you will be willing to stipulate to all the facts that are correct in our pleadings. (Most of them are now based on documented e-mails, so we trust the bulk of the facts will gain your stipulated approval.) + +I am also writing because co-counsel Brad Edwards has been working with a possible approach to the filings tomorrow. AtMs suggestion, Brad has offered to take out a paragraph that Marea was concerned about in our fact section and to file our pleadings under seal tomorrow for, say, a period of (at least) two weeks. This would give us an opportunity to work with you to resolve disputed facts and, more generally, to try and resolve the entire dispute. In exchange, we request that you agree not to file a motion to dismiss for lack of prosecution and not to argue that we need to file some sort of civil complaint to litigate these issues (both suggestions you raised in your earlier e-mail). Brad and I don't believe such arguments would be legally well founded in any event. But if you are asking for concessions on our part, we would like to narrow the subjects of the litigation that we have to respond to in exchange. + +As we have mentioned at every stage of this case, we stand ready to work with you to try and resolve the matter. We continue to be willing to attempt a fair resolution that protects our client's interests. Along those lines, if you have concerns about us filing our pleadings under seal tomorrow, we are ready to discuss the idea of delaying any filing for a period of, say, two weeks. Such a delay, however, would be contingent on your obtaining an extension from Judge Marra of our filing deadline. As you can see, we are ready to file and would delay only as an accommodation to you — and would except you to do the motion that would be required for such an extension). + +Sincerely, + +Paul Cassell + +Counsel for Jane Doe #1 and Jane Doe #2 + +801-201-8271 (cell phone) + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law + +S.J. Quinney College of Law at the University of Utah + +[REDACTED] +Salt Lake City, UT 84112-0730 + +[REDACTED] + + + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the sender by reply electronic mail and delete the original message. 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Based on this correspondence and other evidence, it is now clear that the U.S. Attorney's Office has repeatedly violated the protected rights of the victims under the CVRA, including their right to confer with prosecutors generally about the case and specifically about a non-prosecution agreement it signed with the defendant. It is now beyond dispute that in September 2007, the U.S. Attorney's Office reached a non-prosecution agreement with Jeffrey Epstein that barred his prosecution for numerous + +federal sex offense he committed against the victims (as well as against many other minor girls). Rather than confer with the victims about this non-prosecution agreement, however, the U.S. Attorney's Office agreed to a "confidentiality" provision in the agreement barring the agreement's disclosure to anyone — including the victims. For the next nine months, the U.S. Attorney's Office assiduously concealed from the victims the existence of this signed nonprosecution agreement. For example, the U.S. Attorney's Office stopped sending victim notifications about the case when defendant Epstein objected. Indeed, the Office went so far as to send (in January 2008) a false victim notification letter to the victims informing them that the "case is currently under investigation," when in fact the U.S. Attorney's Office had already resolved the case three months earlier by signing the non-prosecution agreement. Again on May 30, 2008, the U.S. Attorney's Office sent yet another victim notification letter to a recognized victim informing her that the "case is currently under investigation" and that it "can be a lengthy process and we request your continued patience while we conduct a thorough investigation." Then in June 2008, on the eve of consummating Epstein's state guilty plea that was part nonprosecution agreement, the U.S. Attorney's Office asked legal counsel for Jane Doe #1 and Jane Doe #2 to send a letter in writing expressing the victims' views on a possible plea bargain — not disclosing to the victims' legal counsel that this was a pointless exercise because the nonprosecution agreement had already been signed some nine months earlier. + +All of these actions and many more like them constitute clear violations of Jane Doe #1 and Jane Doe #2's rights under the Crime Victims Rights Act. The Court should accordingly find that the U.S. Attorney's Office has violated the Act and set a briefing schedule and hearing on the proper remedy for those violations. + +#### STATEMENT OF FACTS + +Jane Doe #1 and Jane Doe #2 offer the following statement of facts, which they are prepared to establish at any evidentiary hearing that the Court might schedule. + +1. Between about 2001 and 2006, defendant Jeffrey Epstein (a billionaire with significant political connections) sexually abused more than 40 minor girls at his mansion in West Palm Beach, Florida, and elsewhere. Among the girls he sexually abused were Jane Doe #1 and Jane Doe #2. Because Epstein used a means of interstate commerce and knowingly traveled in interstate commerce to engage to abuse Jane Doe #1 and Jane Doe #2 (and the other victims), he committed violations of federal law, specifically repeated violations of 18 U.S.C. § 2422. + +2. In 2006, at the request of the Palm Beach Police Department, the Federal Bureau of Investigation ("FBI") opened an investigation into allegations that Jeffrey Epstein ("Epstein") and his personal assistants had used facilities of interstate commerce to induce young girls between the ages of thirteen and seventeen to engage in prostitution, among other offenses. The case was presented to the United States Attorney's Office for the Southern District of Florida, which accepted the case for investigation. The Palm Beach County State Attorney's Office was also investigating the case. See Declaration of Bradley J. Edwards, Esq. at & & 1-2 (hereinafter "Edwards Declaration"). + +3. The FBI determined that both Jane Doe #1 and Jane Doe #2 were victims of sexual assaults by Epstein while they were minors beginning when they were approximately fourteen years of age and approximately thirteen years of age respectively. Edwards Declaration at & 2. + +4. On about June 7, 2007, FBI agents hand-delivered to Jane Doe #1 a standard CVRA victim notification letter. See Edwards Declaration, Exhibit "A." The notification promises that the Justice Department would makes its "best efforts" to protect Jane Doe #1's rights, including "[t]he reasonable right to confer with the attorney for the United States in the case" and "to be reasonably heard at any public proceeding in the district court involving . . . plea . . . ." The notification further explained that "Tait this time, your case is under investigation." That notification meant that the FBI had identified Jane Doe #1 as a victim of a federal offense and as someone protected by the CVRA. + +5. On about August 11, 2007, Jane Doe #2 received a standard CVRA victim notification letter. See Edwards Declaration, Exhibit "B." The notification promised that the Justice Department would makes its "best efforts" to protect Jane Doe #2's rights, including "[t]he reasonable right to confer with the attorney for the United States in the case" and "to be reasonably heard at any public proceeding in the district court involving . . . plea ...." The notification further explained that "[a]t this time, your case is under investigation." That notification meant that the FBI had identified Jane Doe #2 as a victim of a federal offense and as someone protected by the CVRA. + +6. Early in the investigation, the FBI agents and the Assistant U.S. Attorney had several meetings with Jane Doe #1. Jane Doe #2 was represented by counsel that was paid for by the criminal target Epstein and, accordingly, all contact was made through that attorney. Edwards Declaration at & 5. + +7. In and around September 2007, plea discussions took place between Jeffrey Epstein, represented by numerous attorneys (including lead criminal defense counsel Jay Lefkowitz), and the U.S. Attorney's office for the Southern District of Florida, represented primarily by Assistant U.S. Attorney The plea discussions generally began from the premise that Epstein would plead guilty at least one federal felony offense surrounding his sexual assaults of more than 40 minor girls. From there, the numerous defense attorneys progressively negotiated more favorable plea terms so that Epstein would ultimately plead to only two state court felony offenses and would serve only county jail time. Many of the negotiations are reflected in e-mails between Lefkowitz and Copies of the correspondence are attached as Exhibit J to the Edwards Declaration accompanying this filing (hereinafter cited as "U.S. Attorney's Correspondence" and referenced by Bates number stamp).1 Because Epstein has moved to keep these documents from the public, they are at this time filed under seal with the Court. + +8. At the time of plea discussions, the U.S. Attorney's Office had an 82-page prosecution memorandum outlining numerous federal sexual offenses committed by Epstein, and had prepared a 53-page indictment for numerous federal offenses. U.S. Attorney's Correspondence at 4. + +9. In September 2007, Assistant U.S. Attorney (AUSA) in an effort to avoid prosecuting Epstein for his numerous sexual offenses against children, proposed to Epstein's attorneys that rather than plea to any charges relating to him molesting children, Epstein should instead plead to a single assault charge involving a telephone call made by Epstein while he was on his private jet. During the telephone call, Epstein warned his personal assistant, Lesley Groff, against turning over documents and electronic evidence responsive to a subpoena issued by a federal grand jury in the Southern District of Florida investigating Epstein's sex offenses. U.S. Attorney's Correspondence at 49, 58. + +Through diligent efforts, counsel for Jane Doe #1 and Jane Doe #2 received copies of half of the e-mail correspondence (the half reflecting Villafafia's communications to defense counsel) on about June 30, 2010. See Edwards Declaration at & &20-22. + +10. The correspondence also shows that AUSA was interested in finding a place to conclude a plea bargain that would effectively keep the victims from learning what was happening through the press. She wrote in an e-mail to defense counsel: "On an 'avoid the press' note, I believe that Mr. Epstein's airplane was in Miami on the day of the Ms. Groff telephone call. If he was in Mimi-Dade County at the time, then I can file the charge in the District Court in Miami, which will hopefully cut the press coverage significantly." U.S. Attorney's Correspondence at 29. Ms. Villafafia was aware that most of the victims of Epstein, including Jane Doe #1 and Jane Doe #2, resided outside the Miami area. + +II. On about September 24, 2007, Assistant U.S. Attorney sent an e-mail to Jay Lefkowitz, criminal defense counsel for Epstein, regarding the agreement. The e-mail stated that the Government and Epstein's counsel would negotiate between themselves about what information would be disclosed to the victims about the agreement: + +Thank you, Jay. I have forwarded your message only to Alex [Acosta],MO, and I don't anticipate it going any further than that. When I receive the originals, I will sign and return one copy to you. The other will be placed in the case file, which will be kept confidential since it also contains identifying information about the girls. + +When we reach an agreement about the attorney representative for the girls, we can discuss what I can tell him and the girls about the agreement. I know that promised Chief Reiter an update when a resolution was achieved. . . . Rolando is calling, but knows not to tell Chief Reiter about the money issue, just about what crimes Mr. Epstein is pleading guilty to and the amount of time that has been agreed to. also is telling Chief Reiter not to disclose the outcome to anyone. + +U.S. Attorney's Correspondence at 153 (emphases added). + +12. On about September 25, 2007, AUSA sent an e-mail to Lefkowitz stating: "And can we have a conference call to discuss what I may disclose to . . . the girls regarding the agreement." U.S. Attorney's Correspondence at 156. + +13. On about September 26, 2007, AUSA. sent an e-mail to Lefkowitz in which she stated: "Hi Jay — Can you give me a call a [xxxx] this morning? I am meeting with the agents and want to give them their marching orders regarding what they can tell the girls." U.S. Attorney's Correspondence at 359. The reasonable inference is that the "marching orders" agreed to between the Government and Epstein's defense counsel was that no mention would be made of the non-prosecution agreement between the U.S. Attorney's Office and Epstein, as no subsequent mention was made to the victims of the non-prosecution agreement. + +14. On about September 27, 2007, Assistant U.S. Attorney revealed to an attorney (Bert Ocariz), who was under discussion to be a representative of victims of Epstein's sexual abuse in civil litigation, that the government was in the process of reaching a nonprosecution agreement with Epstein. An e-mail confirming these disclosures stated: "Bert's firm has raised a number of good questions about how they are going to get paid." U.S. Attorney's Correspondence at 161. The e-mail went on to state: "I told Bert that as part of our agreement we (the federal government) are not going to indict Mr. Epstein, but give him an idea of the charges that we had planned to bring as related to 18 USC 2255." Id. The e-mail also asked permission from Epstein's counsel to send to Ocariz a copy of parts of the plea agreement: "With respect to question 2 [a question from Ocariz regarding "[w]hen will it be possible to see the plea agreement so that we understand exactly what Epstein concedes to in the civil case?], do I have your permission to send Bert just that section of the plea agreement that applies to the damages claims (I would recommend sending paragraphs 7 through 10, or at least 7 and 8)?" Id. 15. On about September 25, 2007, ASUA sent a letter to Jay Jefkowitz in which she suggested that the victims should be represented by someone who was not an experienced personal injury attorney: "They [the other lawyers under consideration] are all very good personal injury lawyers, but I have concerns about whether there would be an inherent tension becaue they may feel that they might make more money . . . if they proceed outside the terms of the pela agreement. (Sony — I just have a bias against plaintiffs' attorneys.)" U.S. Attorney's Correspondence at 157. Villafaila continued to push Ocariz as the best choice, in part because it would reduce publicity: "One nice thing about Bert [Ocariz] is that he is in Miami where teher has been almost no coverage of the case." Id. + +16. In a letter later sent by Jay Lefkowitz to the U.S. Attorney for the Southern District of Florida, Lefkowitz stated that ASUA had "assiduously" hidden from him the fact that Bert Ocariz was a friend of boyfriend. U.S. Attorney's Correspondence at 267. Lefkowitz also stated that had misleadingly used the term "friend" rather than the more accurate term "boyfriend" to describe who had recommended Ocariz. Id. at 268. Lefkowitz further stated the boyfriend had a business relationship with Ocariz and that the boyfriend would have financially benefitted from the presumably lucrative referral of sexual assault cases against Epstein to Ocariz. On December 13, 2007, wrote a letter to Lefkowitz to deny these accusations. In the letter, stated: ". . . I am surprised by your allegations regarding my role because I thought that we had worked very well together in resolving this dispute. I also am surprised because I feel that I bent over backwards to keep in + +mind the effect that the agreement would have on Mr. Epstein and to make sure that you (and he) understood the repercussions of the agreement." Id. + +17. On about September 24, 2007, Epstein and the U.S. Attorney's Office reached an agreement whereby the United States would defer federal prosecution in favor of prosecution by the State of Florida. Epstein and the U.S. Attorney's Office accordingly entered into a "Non-Prosecution Agreement" (NPA) reflecting their agreement. Most significantly, the NPA gave Epstein a promise that he would not be prosecuted for a series of federal felony offenses involving his sexual abuse of more than 30 minor girls. The NPA instead allowed Epstein to plead guilty to two state felony offenses for solicitation of prostitution and procurement of minors for prostitution. The NPA also set up a procedure whereby a victim of Epstein's sexual abuse could obtain an attorney representative to proceed with a civil claim against Epstein, provided that the victim agreed to proceed exclusively under 18 U.S.C. § 2255 (i.e., provided that the victim agreed to seek no more than \$150,000 in damages against Epstein — an amount that Epstein argued later was limited to \$50,000). See Edwards Declaration, Exhibit "C" (copy of the non-prosecution agreement). The agreement was signed by Epstein and his legal counsel, as well as the U.S. Attorney's Office, on about September 24, 2007. + +18. A provision in the non-prosecution agreement made the agreement secret. In particular, the agreement stated: "The parties anticipate that this agreement will not be made part of any public record. If the United States receives a Freedom of Information Act request or any compulsory process commanding the disclosure of the agreement, it will provide notice to Epstein before making the disclosure." By entering into such a confidentiality agreement, the U.S. Attorney's Office put itself in a position that notifying the crime victims (including Jane Doe #1 and Jane Doe #2) of the non-prosecution agreement would violate terms of the agreement — specifically the confidentiality provision. Accordingly, from September 24, 2007 through at least June 2008 — a period of more than nine months -- the U.S Attorney's Office did not notify any of the victims of the existence of the non-prosecution agreement. + +19. A reasonable inference from the evidence is that the U.S. Attorney's Office wanted the non-prosecution agreement kept from public view because of the intense public criticism that would have resulted from allowing a politically-connected billionaire who had sexually abused more than 40 minor girls to escape from federal prosecution with only a county court jail sentence and because of the possibility that the victims could have objected to the agreement in court and prevented its consummation. + +20. The Non-Prosecution Agreement that had been entered into between the U.S. Attorney's Office and Epstein was subsequently modified by an October 2007 Addendum and a December 19, 2007, letter from the U.S. Attorney to Attorney Lilly Ann Sanchez. See Supplemental Declaration of doe. #35, at 1; U.S. Attorney's Correspondence at 234-37. The U.S. Attorney's Office did not notify any of the victims of the existence of these modifications of the agreement through at least June 2008 — a period of more than six months. On about August 14, 2008, Epstein's defense counsel told the U.S. Attorney's Office that they did not consider the December 19, 2007, letter to be operative. Id. + +21. In October 2007, shortly after the initial plea agreement was signed, Jane Doe #1 was contacted to be advised regarding the resolution of the investigation. On October 26, 2007, Special Agents and met in person with Jane Doe #1. The Special Agents explained that Epstein would plead guilty to state charges, he would be required + +to register as a sex offender for life, and he had made certain concessions related to the payment of damages to the victims, including Jane Doe #1. During this meeting, the Special Agents did not explain that an agreement had already been signed that precluded any prosecution of Epstein for federal charges. The agents could not have revealed this part of the non-prosecution agreement without violating the terms of the non-prosecution agreement. Whether the agents themselves had been informed of the existence of the non-prosecution agreement by the U.S. Attorney's Office is not certain. Because the plea agreement had already been reached with Epstein, the agents made no attempt to secure Jane Doe #1's view on the proposed resolution of the case. Edwards Declaration at & 7. + +22. Jane Doe # l's perception of the explanation provided by the Special Agents was that only the State part of the Epstein investigation had been resolved, and that the federal investigation would continue, possibly leading to a federal prosecution. Edwards Declaration at & 8. + +23. On about November 27, 2007, Assistant U.S. Attorney sent an e-mail to Jay Lefkowitz, defense counsel for Epstein. The e-mail stated that the U.S. Attorney's Office had an obligation to notify the victims about the plea agreement: + +The United States has a statutory obligation (Justice for All Act of 2004) to notify the victims of the anticipated upcoming events and their rights associated with the agreement entered into by the United States and Mr. Epstein in a timely fashion. Tomorrow will make one full week since you were formally notified of the selection. I must insist that the vetting process come to an end. Therefore, unless you provide me with a good faith objection to Judge Davis's selection [as special master for selecting legal counsel for victim pursuing claims against Epstein] by COB tomorrow, November 28, 2007, I will authorize the notification of the victims. Should you give me the go-head on Podhurst and Josephsberg selection by COB tomorrow, I will simultaneously send you a draft of the letter. I intend to notify the victims by letter after COB Thursday, November 29t°. + +U.S. Attorney's Correspondence at 255 (emphasis rearranged). + +24. On about November 29, 2007, Assistant U.S. Attorney sent a draft of a crime victim notification letter to Jay Lefkowitz, defense counsel for Jeffrey Epstein. The notification letter explained: "I am writing to inform you that the federal investigation of Jeffrey Epstein has been completed, and Mr. Epstein and the U.S. Attorney's Office have reached an agreement containing the following terms . ." The letter then went on to explain that Epstein would plead guilty to two state offenses and receive an 18 month sentence. The letter did not explain that, as part of the agreement with Epstein, the Justice Department had previously agreed not to prosecute Epstein for any of the numerous federal offenses that had been committed. U.S. Attorney's Correspondence at 256-59. + +25. Apparently because of concerns from Epstein's attorneys, the U.S. Attorney's Office never sent the proposed victim notification letter discussed in the previous paragraph to the victims. Instead, a misleading letter stating that the case was "currently under investigation" (described below) was sent in January 2008 and May 2008. At no time before reaching non-prosecution agreement did the Justice Department contact any victims, including for example Jane Doe #1, about their views on the non-prosecution. + +26. On about December 6, 2007, First Assistant U.S. Attorney sent a letter to Jay Lefkowitz, noting the U.S. Attorney's Office's legal obligations to keep victims informed of the status of plea negotiations with Epstein. The letter stated: + +Finally, let me address your objections to the draft Victim Notification Letter. You write that you don't understand the basis for the Office's belief that it is appropriate to notify the victims. Pursuant to the "Justice for All Act of 2004," [another name from the CVRA] crime victims are entitled to: `The right to reasonable, accurate, and timely notice of any public court proceeding . . . involving the crime' and the `right not to be excluded from any such public court + +proceeding . . 18 U.S.C. § 3771(a)(2) & (3). Section 3771 also commands that `employees of the Department of Justice . . engaged in the detection, investigation, or prosecution of crime shall make their best efforts to see that crime victims are notified of, and accorded, the rights described in subection (a).' 18 U.S.C. § 3771(c)(1).... + +Our Non-Prosecution Agreement resolves the federal investigation by allowing Mr. Epstein to plead to a state offense. The victims identified through the federal investigation should be appropriately informed, and our Non-Prosecution Agreement does not require the U.S. Attorney's Office to forego its legal obligation. + +U.S. Attorney's Correspondence at 191-92 (emphasis added). + +27. Despite this recognition of its obligation to keep victims "appropriately informed" about the non-prosecution agreement, the U.S. Attorney's Office did not follow through and inform the victims of the non-prosecution agreement. To the contrary, as discussed below, it continued to tell the victims that the case was "under investigation." Edwards Declaration at & 4 and & 12. + +28. On December 13, 2007, sent a letter to Jay Lefkowitz, defense counsel for Epstein, rebutting charges that had apparently been made against her by the Epstein defense. The letter stated that a federal indictment against Epstein "was postponed for more than five months to allow you and Mr. Epstein's other attorneys to make presentations to the Office to convince the Office not to prosecute." The letter also recounted that "You and I spent hours negotiating the terms [of the non-prosecution agreement], including 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. , and Acosta in the negotiations at various times." U.S. Attorney's Correspondence at 269. + +29. The December 13, 2007, letter also reveals that the Justice Department stopped making victim notifications because of objections from Epstein's criminal defense counsel: "Three victims were notified shortly after the signing of the Non-Prosecution Agreement of the general terms of the Agreement. You raised objections to any victim notification, and no further notifications were done." U.S. Attorney's Correspondence at 270 (emphasis added). + +30. Following the signing of the Agreement and the modifications thereto, Epstein's performance was delayed while he sought higher level review within the Department of Justice. See U.S. Attorney's Correspondence passim. + +31. On January 10, 2008, Jane Doe #1 and Jane Doe #2 received letters from the FBI advising them that "(t)his case is currently under investigation. This can be a lengthy process and we request you continued patience while we conduct a thorough investigation." See Doc. #14 (attachments 3 and 4 to declaration of (emphasis added). The statement in the notification letter was false. The case was not currently "under investigation." To the contrary, the case had been resolved by the non-prosecution agreement entered into by Epstein and the U.S. Attorney's Office discussed previously. Moreover, the FBI did not notify Jane Doe #1 or Jane Doe #2 that a plea agreement had been reached previously, and that part of the agreement was a non-prosecution agreement with the U.S. Attorney's Office for the Southern District of Florida. Edwards Declaration at & 9. + +32. In early 2008, Jane Doe #1 and Jane Doe #2 came to believe that criminal prosecution of Epstein was extremely important. They also desired to be consulted by the FBI and/or other representatives of the federal government about the prosecution of Epstein. In light of the letters that they had received around January 10, they believed that a criminal investigation of Epstein was on-going and that they would be contacted before the federal government reached any final resolution of that investigation. Edwards Declaration at &10. + +33. On about February 25, 2008, Assistant U.S. Attorney sent an e-mail to Jay Lefkowitz, Epstein's criminal defense counsel, explaining that the Justice Department's Child Exploitation Obscenity Section (CEOS) had agreed to review Epstein's objections to the proposed plea agreement that had been reached with the U.S. Attorney's Office for the Southern District of Florida. The letter indicated that, should CEOS reject Epstein's objections to the agreement, then "Mr. Epstein shall have one week to abide by the terms and conditions of the September 24, 2007 Agreement as amended by letter from United States Attorney Acosta to Jay Lefkowitz." U.S. Attorneys Correspondence at 290-91. + +34. In about April 2008, Jane Doe #1 contacted the FBI because Epstein's counsel was attempting to take her deposition and private investigators were harassing her. Assistant U.S. Attorney secured pro bono counsel to represent Jane Doe #1. Pro bono counsel was able to assist Jane Doe #1 in avoiding the improper deposition. AUSA secured pro bono counsel by contacting Meg Garvin, Esq. of the the National Crime Victims' Law Center in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. Garvin was not advised that a non-prosecution agreement had been reached. + +35. On May 30, 2008, another of Mr. Edwards's clients who was recognized as an Epstein victim by the U.S. Attorney's Office, received a letter from the FBI advising her that Whis case is currently under investigation. This can be a lengthy process and we request your continued patience while we conduct a thorough investigation." The statement in the notification letter was false. The case was not currently "under investigation." To the contrary, the case had been resolved by the non-prosecution agreement entered into by Epstein and the U.S. Attorney's Office discussed previously. Edwards Declaration at & 12. + +36. In mid-June 2008, Mr. Edwards contacted AUSA to inform her that he represented Jane Doe #1 and, later, Jane Doe #2. Mr. Edwards asked to meet to provide information about the federal crimes committed by Epstein, hoping to secure a significant federal indictment against Epstein. AUSA and Mr. Edwards discussed the possibility of federal charges being filed. At the end of the call, AUSA asked Mr. Edwards to send any information that he wanted considered by the U.S. Attorney's Office in determining whether to file federal charges. Because of the confidentiality provision that existed in the plea agreement, Mr. Edwards was not informed that previously, in September 2007, the U.S. Attorney's Office had reached an agreement not to file federal charges. Mr. Edwards was also not informed that resolution of the criminal matter was imminent. Edwards Declaration at & 13. + +37. On Friday, June 27, 2008, at approximately 4:15 p.m., AUSA received a copy of Epstein's proposed state plea agreement and learned that the plea was scheduled for 8:30 a.m., Monday, June 30, 2008. AUSA and the Palm Beach Police Department attempted to provide notification to victims in the short time that Epstein's counsel had provided. Attorney Edwards was called to provide notice to his clients regarding the hearing. AUSA a did not tell Attorney Edwards that the guilty pleas in state court would bring an end to the possibility of federal prosecution pursuant to the plea agreement. Edwards Declaration at & 14. + +38. On June 30, 2008, AUSA sent an e-mail to Jack Goldberger, criminal defense counsel for Epstein, that stated: "Jack: The FBI has received several calls regarding the Non-Prosecution Agreement. I do not know whether the title of the document was disclosed when the Agreement was filed under seal, but the FBI and our office are declining comment if asked." U.S. Attorney's Correspondence at 321. + +39. On July 3, 2008, Mr. Edwards sent to AUSA -a letter. See Affidavit of Bradley J. Edwards, Esq., at 15 (attachment 2). In the letter, Mr. Edwards indicated his client's desire that federal charges be filed against defendant Epstein. In particular, he wrote on behalf of his clients: "We urge the Attorney General and our United States Attorney to consider the fundamental import of the vigorous enforcement of our Federal laws. We urge you to move forward with the traditional indictments and criminal prosecution commensurate with the crimes Mr. Epstein has committed, and we further urge you to take the steps necessary to protect our children from this very dangerous sexual predator." When Mr. Edwards wrote this letter, he was still unaware that a non-prosecution agreement had been reached with Epstein — a fact that continued to be concealed from him (and the victims) by the U.S. Attorney's Office. Mr. Edwards first saw a reference to the NPA on or after July 9, 2008, when the Government filed its responsive pleading to Jane Doe's emergency petition. That pleading was the first public mention of the non-prosecution agreement and the first disclosure to Mr. Edwards (and thus to Jane Doe #1 and Jane Doe #2) of the possible existence of a non-prosecution agreement. Edwards Declaration at & 15. + +40. On July 9, 2008, AUSA sent a victim notification to Jane Doe #1 via her attorney, Bradley Edwards. Edwards Declaration, Exhibit "H." That notification contains a written explanation of some of the terms of the agreement between Epstein and the U.S. Attorney's Office. A full copy of the terms was not provided. A notification was not provided to Jane Doe #2 because the agreement limited Epstein's liability to victims whom the United States was prepared to name in an indictment. As a result, Jane Doe #2 never received a notification a letter about the agreement. The notification did not mention the non-prosecution agreement with the U.S. Attorney's Office. Edwards Declaration at & 16. + +41. On July 9, 2008, AUSA filed a sworn declaration with the Court in connection with the case (doe. #14). The declaration purported to recount limit parts of the non-prosecution agreement and stated that "these provisions were discussed" with several victims, including Jane Doe #1. Id. at 4. + +42. On July 11, 2008, the Court held a hearing on Jane Doe #1 and Jane Doe #2's Emergency Petition for Enforcement of Rights. During the hearing, the Government conceded that Jane Doe #1 and Jane Doe #2 were "victims" within the meaning of the Crime Victim's Rights Act. Tr. at 14-15. + +43. During the July 11 hearing, the Court and the parties discussed the fact that the petition should not be treated as an "emergency" petition because there was not any particular rush to ruling on it. Tr. at 24-25. The Court further discussed a need to "hav[e] a complete record, and this is going to be an issue that's ... going to go to the Eleventh Circuit, [s] it] may be better to have a complete record as to what your position is and the government's is as to what actions were taken. And I don't know if I have enough information, based onIM=. affidavit or I need additional information. And because it is not an emergency, I don't have to do something quickly, we can play it b[y] ear and make this into a more complete record for the court of appeals." Tr. at 25-26. Counsel for Jane Doe #1 and Jane Doe #2 explained: " . . Your Honor is correct in stating that it is not an emergency and it doesn't need to happen today. And, I will confer with the government on this and if evidence needs to be taken, it [can] be taken at a later date. It doesn't seem like there will be any prejudice to any party [from delay]." Tr. at 26. The hearing concluded: "So I'll let both of you confer about whether there is a need for any additional evidence to be presented. Let me know one way or the other. If there is, we'll schedule a hearing. If there isn't and you want to submit some additional stipulated information, do that, and then I'll take care of this in due course." Tr. at 32. The Court then adjourned, taking the victims' petition under advisement. + +44. The U.S. Attorney's Office and the victims then attempted to reach a stipulated set of facts underlying the case. The U.S. Attorney's Office set a proposed set of facts, and the victims sent a counter-proposal. Rather than respond to the victims' counter-proposal, however, the U.S. Attorney's Office suddenly reversed course. (Doc. #19 at 2). On July 29, 2008, it filed a Notice to Court Regarding Absence of Need for Evidentiary Hearing (doc. #17). The Government took the position that, because no federal criminal charges had been filed in the Southern District of Florida, no additional evidence was required to decide the petition before the Court. + +45. On August 1, 2008, Jane Doe # 1 and Jane Doe #2 filed (doc. #19) a response to the Government's "Notice." In the response, Jane Doe #1 and Jane Doe #2 gave a proposed statement of facts surrounding the case. The proposed statement of fact was based on the information available to the victims at that time. The proposed statement of facts highlighted the fact that the Government had signed a non-prosecution agreement containing an express confidentiality provision, which prevented the Government from disclosing the agreement to them and other victims. Id. at 5. The response also noted that the Court had taken the victims' petition under advisement. The response further noted that the Government had not attempted to work with the victims to draft a full set of undisputed facts and had refused the victims' efforts to obtain documents relevant to the case. Id. at 9. The victims response also requested that the + +Court direct the Government to confer with the victims regarding the undisputed facts of the case, produce the non-prosecution agreement at issue in the case, and produce an FBI Report of Interview with Jane Doe #1. The response also requested that the Court enter judgment for the victims' finding a violation of rights and schedule a hearing on the appropriate remedy. Id. at 14. 46. On August 14, 2008, the Court held a hearing on the case. During that hearing, the U.S. Attorney's Office conceded "we do feel bound by the confidentiality provision such that we could not voluntarily disclose this non-prosecution agreement without court order compelling us to do so." Tr. at 8. The Office went on to further concede that it could not justify depriving the victims of the opportunity to see the agreement. Id. at 14. The hearing concluded without any schedule or deadlines being put in place. + +47. On October 9, 2008, Bradley J. Edwards, counsel for Jane Doe #1 and Jane Doe #2, sent a letter to counsel for the U.S. Attorney's Office in this case advising that two possibly false statements had been made to the Court in the July 9th sworn declaration of AUSA See Oct. 9, 2008, Letter from Bradley J. Edwards to Marie Villafaila at 1, Edwards Declaration, Attachment "I." First, while Ms. had described a term as being part of the plea agreement with Epstein, that term later became defunct, at least in the view of Epstein's attorneys (and apparently acceded to by the U.S. Attorney's Office). Second, Ms. had said that "four victims [including Jane Doe #1] were contacted and these provisions were discussed," it was not clear what provisions had in fact been discussed. + +48. On December 22, 2008, AUSA Marie filed a supplemental affidavit, "correcting" the statement made in her July 8, 2008, declaration about the terms of the plea agreement (doe. #35). The supplemental affidavit stated that "part 3" of the agreement with defendant Epstein + +was, in the view Epstein' legal counsel, no longer operative. The supplemental affidavit, however, did not clarify what terms of the agreement had been discussed. + +49. On April 9, 2009, counsel for Jane Doe #1 and Jane Doe #2 sent to the Court in this case (via the PACER system) a notice of a change of law firm affiliation. Doc. #37. + +50. In approximately May 2009, counsel for Jane Doe #1 and Jane Doe #2 propounded discovery requests in both state and federal civil cases against Epstein, seeking to obtain correspondence between Epstein and prosecutors regarding his plea agreement — information that the U.S. Attorney's Office was unwilling to provide to Jane Doe #1 and Jane Doe #2. Epstein refused to produce that information, and extended litigation to obtain the materials followed. Edwards Declaration at & 20. + +51. Because of this extended litigation, Jane Doe #1 and Jane Doe #2 did not have access to important correspondence demonstrating a violation of their rights until June 30, 2010. On that day, counsel for Epstein sent to Bradley J. Edwards, Esq., legal counsel for Jane Doe #1 and Jane Doe #2, approximately 358 pages of e-mail correspondence between his legal counsel and the U.S. Attorney's Office for the Southern District of Florida regarding the plea agreement that had been negotiated between them. See Edwards Declaration, Attachment "J." These e-mails disclosed for the first time the extreme and unusual steps that had been taken by the U.S. Attorney's Office to avoid prosecuting Epstein and to avoid having the victims in the case learn about the non-prosecution agreement that had been reached between Epstein and the Government. Litigation continues to this day to obtain the correspondence regarding the state prosecution and regarding what Epstein's attorneys said in the correspondence with the prosecutors. Edwards Declaration at & 22 + +52. In mid-July 2010, Jane Doe #1 and Jane Doe #2 settled their civil lawsuits against Mr. Epstein. Notice of this fact was promptly provided to the Court. Edwards Declaration at xxx. + +53. On September 8, 2010, the Court entered an order stating that "[a]it examination of the docket reveals that no activity has taken place in this case since April of 2009. In light of the underlying settlements between the victims and Mr. Epstein, it is hereby ordered and adjudged that this case is closed." Doc. #38. + +54. Promptly on the heels of this administrative order, on September 13, 2010, Jane Doe #1 and Jane Doe #2 filed a notice that they "intend to make subsequent filing in the case shortly. They accordingly request administrative reopening of the case and, if the Court deems it advisable, a scheduling conference with the U.S. Attorney's Office regarding the case." Doc. #39 at 1. They further advised the Court that their settlements with Jeffrey Epstein in no way affected "their determination to move forward with the above-captioned CVRA action against a different entity — the U.S. Attorney's Office for the Southern District of Florida." Id. at 2. The pleading further advised that "[i]f the Court wishes to proceed to an expeditious conclusion to this Case, Jane Doe #1 and Jane Doe #2 have no objection to the Court setting up an expedited schedule for proceeding on the case." Id. The pleading further advised that the reason the victims had not filed for summary judgment in the case was that they had been attempting to secure correspondence between the U.S. Attorney's Office and Epstein to corroborate their argument that the Office had violated their rights. They noted that they had just secured half of that correspondence two months earlier. Id. at 2. The victim asked that, "if the Court deems it advisable, that a scheduling conference be set for this case." + +55. At all times material to this statement of facts, it would have been practical and feasible for federal government to inform Jane Doe #1 and Jane Doe #2 of the details of the proposed nonprosecution agreement with Epstein, including in particular the fact that the agreement barred any federal criminal prosecution. Edwards Declaration at & 26. + +### LEGAL MEMORANDUM + +The victims have previously briefed the issues of why they are entitled to entry of an order by this Court finding that the U.S. Attorney's Office violated their rights under the CVRA. See Doc. #1; Doc #9 at 3-11; Doc. #19 at 3-9, 14. The victims specifically incorporate those pleadings by reference here. In short, as explained in the victims' earlier pleadings, the Office violated the victims' right to confer before reaching the non-prosecution agreement and also failed to use its best efforts to comply with the CVRA. + +In light of the new evidence that the victims have uncovered, it now palpably obvious that not only has the U.S. Attorney's Office violated their rights, but that the violations were part of an orchestrated, deliberate attempt to keep the victims in the dark about the non-prosecution agreement so that they could not raise any timely objection to it. The facts recounted demonstrate the following chain of events. The U.S. Attorney's Office first reached a nonprosecution agreement with Epstein, in which it agreed not to prosecute him for numerous crimes (including, for example, sex offenses committed by Epstein against Jane Doe #1). As part of that agreement, the U.S. Attorney's Office agreed to a "confidentiality" provision that forbade publicly disclosing the existence of the agreement. As a result, the U.S. Attorney's Office and FBI agents acting under its direction kept the existence of the non-prosecution agreement secret from the victims and the public. The reasonable inference from the evidence is that the U.S. Attorney's Office wanted to keep the agreement a secret to avoid intense criticism that would have surely ensued had the victims and the public learned that a billionaire sex offender with political connections had arranged to avoid federal prosecution for numerous felony sex offenses against minor girls. + +As part of this pattern of deception, the U.S. Attorney's Office discussed victim notification with the defendant sex offender and, after he raised objections, stopped making notification. Then later in January 2008, the U.S. Attorney's Office arranged for letters to be sent to the victims — including Jane Doe #1 and Jane Doe #2 — that falsely stated that to each that your "case is currently under investigation." This was untrue, as the U.S. Attorney's Office had already resolved the federal case by signing a non-prosecution agreement with Epstein. Indeed, the pattern of deception continued even after Jane Doe #1 and Jane Doe #2 were represented by legal counsel. In May 2008, the Office sent a similar letter stating "your case is currently investigation" to another victim (represented by Bradley J. Edwards). As late as the middle of June 2008 — more than eight months after the non-prosecution agreement had been signed -- the Assistant U.S. Attorney handling the case told the attorney representing Jane Doe #1 and Jane Doe #2 (Edwards) to send information that he wanted the Office to consider in determining whether to file federal charges. The Office concealed from him the fact that the determination had already been made and a non-prosecution agreement had been signed long ago. The Office also concealed from him the fact that guilty pleas in state court were imminent. The Office provided notice about the fact of the non-prosecution agreement only after Epstein had entered his guilty pleas in state court — in other words, only after the time for the victims to be able to + +object to the non-prosecution agreement during the plea process had come and gone. Even at that time, the Office did not disclose the provisions in the agreement. + +This behavior does not satisfy the Office's obligations under the CVRA to use its "best efforts" to insure that victims receive protection of their rights. 18 U.S.C. § 3771(c)(1). In particular, it makes clear that the victims were not afforded their right "to confer with the attorney for the Government in the case." 18 U.S.C. § 3771(a)(5). Whatever else may be said about the deception, it also starkly violates the victims' right "to be treated with fairness and with respect for the victim's dignity . . . ." 18 U.S.C. § 3771(a)(8). The pattern also denied the victims of timely notice of court proceedings, 18 U.S.C. § 3771(a)(3), including in particular the state court guilty plea + +The Court should find that these violations of the victims' rights were not accidental but deliberate. The U.S. Attorney's Office was well aware its resolution of the federal cases triggered an obligation under the CVRA to notify the victims of what was happening to their cases. Indeed, the First Assistant in the Office wrote to Epstein's defense counsel that pursuant to the CVRA + +crime victims are entitled to: "The right to reasonable, accurate, and timely notice of any public court proceeding . . . involving the crime" and the "right not to be excluded from any such public court proceeding . . . ." 18 U.S.C. § 3771(a)(2) & (3). Section 3771 also commands that "employees of the Department of Justice . engaged in the detection, investigation, or prosecution of crime shall make their best efforts to see that crime victims are notified of, and accorded, the rights described in subsection (a)." 18 U.S.C. § 3771(c)(1).... Our Non-Prosecution Agreement resolves the federal investigation by allowing Mr. Epstein to plead to a state offense. The victims identified through the federal investigation should be appropriately informed, and our Non-Prosecution Agreement does not require the U.S. Attorney's Office to forego its legal obligation. + +U.S. Attorney's Correspondence at 191-92. Despite recognizing in private correspondence with defense counsel that victims of Epstein's sexual assault should be "appropriately informed" about the Non-Prosecution agreement in a "timely" fashion, the U.S. Attorney's Office ultimately did nothing to inform them of the agreement until after the agreement had been consummated in court. + +In short, Jane Doe #1 and Jane Doe #2 — and the many other victims of the defendant's federal sex offenses — were deliberately kept in the dark about the fact that the U.S. Attorney's Office was planning to reach a deal that would permit the defendant to escape all federal punishment. This bald decision to conceal from the victims what was happening violated the core premise of the Crime Victim's Rights Act: that victims deserve to know what is happening in their cases. Congress was concerned that in the federal system crime victims were "treated as non-participants in a critical event in their lives. They were kept in the dark by prosecutors too busy to care enough ... and by a court system that simply did not have a place for them." 150 CONG. REC. S4262 (Apr. 22, 2004) (statement of Sen. Feinstein). To remedy this problem, Congress gave victims "the simple right to know what is going on, to participate in the process where the information that victims and their families can provide may be material and relevant ... ." Id. If ever a case cried out for a court finding that prosecutors have violated the rights of crime victims, it is this one. The victims respectfully ask for a finding that the U.S. Attorney's Office has violated their rights under the Crime Victims' Rights Act. + +## CERTIFICATE OF CONFERENCE + +Counsel for Jane Doe #1 and Jane Doe #2 are engaged in on-going discussions with counsel for the U.S. Attorney's Office to resolve the matters raised in this pleading. The U.S. Attorney's Office has agreed to stipulate to all facts presented by Jane Doe #1 and Jane Doe #2 that are correct. At this time, however, the parties have not been able to reach any further agreements. + +### CONCLUSION + +For all these reasons, the Court should find the U.S. Attorney's Office violated Jane Doe #1 and Jane Doe #2's rights under the Crime Victims Rights Act and then schedule an appropriate hearing on the remedy for these violations. The scope of the remedy that is appropriate may depend in part of the scope of the violations that the Court finds. For this reason, it makes sense to bifurcate the process and determine, first, the extent of the violations and then, second, the remedy appropriate for those violations. If the Court would prefer to see more immediate briefing on remedy issues, the victims stand prepared to provide that briefing at the Court's direction. + +DATED: October 27.2010 + +Respectfully Submitted, + +s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS FISTOS & LEHRMAN P.L. + +Fort Lauderdale, Florida 33301 + +and + +Paul G. Cassell +*Pro Hac Vice* + +![]()Attorneys for Jane Doe #1 and Jane Doe #2 + +# CERTIFICATE OF SERVICE + +![](_page_28_Picture_1.jpeg) + +Also serve Epstein through current lawyer. \ No newline at end of file diff --git a/marker2/ds9/EFTA00206835/EFTA00206835.metadata.json b/marker2/ds9/EFTA00206835/EFTA00206835.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1cb1c00b6a4bdb0fa0dd7ec6423dbb02bb7af37e --- /dev/null +++ b/marker2/ds9/EFTA00206835/EFTA00206835.metadata.json @@ -0,0 +1,1090 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206835.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 29, + "chars": 51197, + "elapsed_seconds": 4.22, + "image_assets": [ + "_page_28_Picture_1.jpeg" + ], + 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a/marker2/ds9/EFTA00206835/_page_28_Picture_1.jpeg b/marker2/ds9/EFTA00206835/_page_28_Picture_1.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..9fad561a324f483d6994c871099fea4daa6836aa --- /dev/null +++ b/marker2/ds9/EFTA00206835/_page_28_Picture_1.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:5caa06c832b082c0fe2883643ef917f5ce26a7bb8461c6da7c3cd988cfd61341 +size 4043 diff --git a/marker2/ds9/EFTA00206864/EFTA00206864.md b/marker2/ds9/EFTA00206864/EFTA00206864.md new file mode 100644 index 0000000000000000000000000000000000000000..8f005614c3b25900e66cd24b0796df9c6beba778 --- /dev/null +++ b/marker2/ds9/EFTA00206864/EFTA00206864.md @@ -0,0 +1,85 @@ +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA + +Case No. 08-80736-Civ-Marra/Johnson + +JANE DOES #1 and #2 + +v. + +UNITED STATES + +### JANE DOE #1 AND JANE DOE #2'S STATUS REPORT AND RESPONSE TO COURT'S ORDER TO SHOW LACK OF PROSEUCTION + +Jane Doe #1 and Jane Doe #2 ("the victims"), through counsel, file the response to Court's order to file a status report and show cause regarding prosecution of the case (doc. #40). + +## BACKGROUND + +As the Court is aware, it entered an order administratively closing this case on September 9, 2010 (doc. #38). That order recited that fact that Jane Doe #1 and Jane Doe #2 had recently settled their civil cases with Jeffrey Epstein as the basis for closure. On September 13, 2010, the victims promptly filed a notice that, while they had settled their case with Jeffrey Epstein, they had reached no settlement with the U.S. Attorney's Office and intended to make filings in this case shortly (doc. #39). The victims requested administrative reopening of the case and, if the Court deemed it advisable, a prompt scheduling conference with the U.S. Attorney's Office regarding the case. The victims also advised that they had only recently received important correspondence between the U.S. Attorney's Office and the Epstein proving that there had been an orchestrated decision to deny them their rights. + +On October 8, 2010, the Court entered an order directing the victims to file a status report and show cause why the case should not be dismissed for want of prosecution. + +#### STATUS REPORT + +As the Court is aware from the victims' filing on September 13, 2010 (doc. #39), the victims have now received important evidence that allows them to file a comprehensive motion explaining the factual background underlying the denials of their rights under the Crime Victims Rights Act and the legal reasons for concluding that their rights under the Act have been violated. A full motion to that effect is being filed simultaneously with this pleading. The motion looks something like a summary judgment motion, although the exact procedures for CVRA cases are unclear. The victims stand ready to promptly provide whatever pleading or motion the Court believes is appropriate to resolve this case quickly. The victims' motion also asks for an evidentiary hearing if the facts are disputed by the U.S. Attorney's Office. Before filing the motion, the victims had also sent a copy of the facts to the U.S. Attorney's Office in an effort to obtain their agreement to them and to expedite the case. (As the Court is aware from the victims' earlier filing, the victims attempted to negotiate a stipulated set of facts with the U.S. Attorney's Office, only to be rebuffed by the U.S. Attorney's Office. See doc. #17 (U.S. Attorney giving "notice" that only two facts are relevant to this case and declining to provide information on other facts in the case); doe. #19 (victims response); doc. #22 (U.S. Attorney's reply).) Discussions with the U.S. Attorney's Office to reach a stipulated set of facts are continuing. + +In light of today's filing of a comprehensive motion, the victims would propose the following schedule for bringing this case to a conclusion: + +November 10, 2010 — U.S. Attorney's Office files response to the victims' motion. + +November 17, 29010 — Victims' file Reply to Response. + +Evidentiary Hearing (if facts contested) — early December, at a time convenient to the Court. + +January 1, 2011 — Court issues ruling on whether victims' rights were violated. + +If the Court enters a finding that the victims' rights were violated, then .... + +January 14, 2011— Victims brief on the appropriate remedy for a violation; + +January 28, 2011 -- U.S. Attorney's Office (and any other interested person) files response to victims' remedy brief. + +February 4, 2011 — Victims reply on remedy issues. + +Hearing if necessary — mid-February, at a time convenient to the Court. + +This proposed schedule would allow Jane Doe #1 and Jane Doe #2 to have their case fully resolved on the merits within the next few months. The victims would have no objection to the Court accelerating the schedule. The victims have also submitted this proposed schedule to the U.S. Attorney's Office in an effort to reach a stipulated and accelerated schedule. + +# THE CASE SHOULD NOT BE DISMISSED FOR LACK OF PROSECUTION + +Jane Doe #1 and Jane Doe #2 should not have their case dismissed for lack of prosecution for the simple reason that they have not failed to prosecute it. To the contrary, as recounted more fully in the statement of facts contained in their contemporaneously filed motion for a finding of violation of their rights, they have been attempting to secure information that would help prove their case. The victims hereby expressly incorporate that statement of facts, and supporting evidence (particularly the Declaration from Bradley J. Edwards, Esq.,) as part of this pleading. + +Although the victims rely on all of the information contained in the statement of facts, in the interest of a brief summary the victims would note that they have been diligently attempting to secure correspondence between Epstein and the U.S. Attorney's Office regarding the nonprosecution agreement reached in this case. After the U.S. Attorney's Office declined to provide the information, the victims sought to secure that information as part of their civil lawsuits against Epstein. This was because of a reasonable legal judgment that the victims' counsel that it was in their best interest to pursue the civil lawsuit against Epstein had a faster pace. Because of protracted litigation from Epstein's battery of lawyers, the victims did not secure any of the correspondence they sought until June 30, 2010. Even then, they secured only part of that correspondence — litigation to secure the rest of that correspondence continues to this day. See + +Declaration of Bradley J. Edwards, Esq., Attachment to Jane Doe #1 and Jane Doe #2's Motion for Finding of Violations of the Crime Victims' Rights Act. + +The victims would also note that the Court has never advised them of a deadline for moving forward with their CVRA case. The victims also knew that the Court was aware of the intense and protracted litigation what was proceeding with Epstein in the various civil cases against him. It seemed reasonable to the victim to resolve those cases first and then turn to the CVRA case — and the victims assumed that the Court was also proceeding on this approach, as the victims never received any inquiry from the Court about their CVRA case until the September 2010 order "administratively" closing the case. Within 5 days of receiving that communication from the Court, the victims promptly advised the Court of their intent to continue moving forward with the case and suggesting a scheduling conference if the Court deemed it advisable. + +The victims have now proposed a specific schedule that will bring this matter to a final conclusion in the next few months. There is no reason to dismiss the case precipitously now on the eve of a final resolution. + +The Eleventh Circuit has repeatedly noted that dismissal with prejudice is an "extreme sanction" and "is plainly improper unless and until the district court finds a clear record of delay or willful conduct and that lesser sanctions are inadequate to correct such conduct." Betty K Agencies, Ltd. v. M/VMONADA, 432 F.3d 1333, 1338-39 (11th Cir.2005). In this case, there is no clear record of delay or willful conduct. To the contrary, there is a pattern of the victims diligently attempting to secure evidence (i.e., the correspondence) vital to their case in the face of determined opposition from both the United States and a billionaire sex offender represented by a battery of attorneys. The Eleventh Circuit has held that simple negligence in meeting a court- + +imposed deadline is not sufficient to warrant dismissal. See McKelvey" AT & T Techs., Inc., 789 F.2d 1518, 1520 (11th Cir.1986) (per curiam). Here, there is not even negligence, as the victims have not failed to meet any deadline that the Court has set and today stand ready to bring the case to an expeditious conclusion on the schedule they propose. On September 13, 2010, the victims also suggested to the Court that a scheduling conference would be one way to proceed in this case — a suggestion that they continue to offer to the Court. + +## CONCLUSION + +The Court should establish the schedule proposed by the victims and bring this case to a conclusion on the merits as the victims propose. + +DATED: October 27 2010 + +Respectfully Submitted, + +s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. + +r I Fl ri + +and + +Paul G. Cassell Pro Hac Vice + +Salt Lake City, UT 84112 + +# CERTIFICATE OF SERVICE + +![](_page_6_Picture_1.jpeg) + +Epstein through current counsel. \ No newline at end of file diff --git a/marker2/ds9/EFTA00206864/EFTA00206864.metadata.json b/marker2/ds9/EFTA00206864/EFTA00206864.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..a6d17ee9aff7440988925132203674fa992b0dc9 --- /dev/null +++ b/marker2/ds9/EFTA00206864/EFTA00206864.metadata.json @@ -0,0 +1,422 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206864.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 7, + "chars": 8841, + "elapsed_seconds": 1.04, + "image_assets": [ + "_page_6_Picture_1.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + 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0000000000000000000000000000000000000000..607b47433dca38c4ef540aa64f8c012a9af39187 --- /dev/null +++ b/marker2/ds9/EFTA00206864/_page_6_Picture_1.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:f0b73d1af48c1310b1cd9528aace41c480c0bf2dfb86f103f11b2cd1213cf76b +size 2018 diff --git a/marker2/ds9/EFTA00206871/EFTA00206871.md b/marker2/ds9/EFTA00206871/EFTA00206871.md new file mode 100644 index 0000000000000000000000000000000000000000..40da37157a5905932fa73a516154fed2a838fc3c --- /dev/null +++ b/marker2/ds9/EFTA00206871/EFTA00206871.md @@ -0,0 +1,98 @@ +**From:** [REDACTED] +**To:** Paul Cassell <[REDACTED]> +**Cc:** Brad Edwards [REDACTED] +<[REDACTED]> + +**Subject:** RE: Proposed Pleading to File - right to confer + +**Date:** Wed, 27 Oct 2010 22:10:59 +0000 + +**Importance:** Normal + +Paul, + +The Acting U.S. Attorney stands ready to discuss with you and Brad the merits of this case and ways in which it can be resolved, but will not be speaking with you today regarding how the victims will respond to the order to show cause, or what the government is willing to stipulate to in the response. + +As an aside, I believe the reasonable right to confer under 18 U.S.C. 3771(a)(5) applies to crime victims in their criminal cases, filed in U.S. District Court, not civil litigation the victims have initiated against the government. + +As to the proposed stipulation of facts, I received your e-mail containing those proposed stipulation facts on Saturday, October 23, 2010, at 3:25 p.m., Eastern Daylight Time. I opened your e-mail some time after that. At 4:40 p.m, October 23, 2010, I forwarded your e-mail to [REDACTED]. + +Since I was on travel from October 25-26, I did not have any opportunity to sit down and confer with [REDACTED] regarding whether we could agree to some, or any, of the nineteen pages of proposed facts you submitted. Today, I told Brad Edwards that some of the facts are really legal conclusions or arguments, rather than statements of fact. The statement that one could reasonably infer something from an e-mail is not a factual assertion, but an argument. There are a number of statements that suffer from this deficiency. + +I do not believe we can resolve these differences in the time remaining for you to file your document. Thank you. + +[REDACTED] + +-----Original Message----- + +**From:** Paul Cassell [mailto:[REDACTED]] +**Sent:** Wednesday, October 27, 2010 5:01 PM +**To:** [REDACTED], [REDACTED] (USAFLS) +**Cc:** Brad Edwards; [REDACTED]) +**Subject:** RE: Proposed Pleading to File - right to confer + +Dear [REDACTED], + +1. 1. As you know, crime victims have the right to "confer" with the prosecutor on the case -- we respectfully request a chance to confer with the decisionmaker on this matter -- apparently the Acting U.S. Attorney. We would like to know why our very reasonable proposal has been turned down and why you are unwilling to work with us further. +2. 2. We respectfully request that you explain how you have been prejudiced and therefore will not stipulate to lack of prejudice. +3. 3. We respectfully request that you carry through on your commitment to us to review our statement of facts and indicate which facts you are objecting to and which you are not. As you know, we have to file today -- so please get back to me quickly. Thanks. Paul Cassell [REDACTED] + +Paul G. Cassell +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +Voice: Fax: Email: + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the sender by reply electronic mail and delete the original message. Thank you. + +----Original Message-- From: la (USAFLS) Sent: Wednesday, October 27, 2010 2:51 PM To: Paul Cassell Cc: Brad Edwards; Subject: RE: Proposed Pleading to File - fixed a couple of sentences mailto: + +Paul, + +Thank you for sending the revised document. I have spoken with the Acting U.S. Attorney on this matter. We believe that if the victims simply filed a response to the order to show cause, and deferred filing any motion for summary judgment, it would promote the process for the parties to meet and address mutual concerns. However, we will not stipulate that the government has not been prejudiced by the passage of time in this case from its initial filing in July 2008. + +----Original Message-- From: Paul Cassell Sent: Wednesday, October 27, 2010 4:10 PM To: Paul Cassell; M, (USAFLS) Cc: Brad Edwards; Subject: RE: Proposed Pleading to File - fixed a couple of sentences mailto: + +I noticed that I missed a couple of sentences in the pleading I sent to you that made reference to the simultaneously filed declaration of Brad Edwards. This revision fixes those couple of sentences, making reference only to a soon-to-be filed declaration. Paul + +Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the University of Utah Voice: ROC: Email: + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the sender by reply electronic mail and delete the original message. Thank you. + +----Original Message--- From: Paul Cassell Sent: Wednesday, October 27, 2010 1:50 PM To:', (USAFLS)' + +## THE FOLLOWING COMMUNICATION IS A SETTLEMENT OFFER WITHIN THE MEANING OF FEDERAL RULE OF EVIDENCE 408 + +Dear (and =), + +Attached is proposed pleading that we would file, reflecting your request that we delay and reflecting your stipulation that the passage of time to this point has not prejudiced the U.S. Attorney's Office. + +I want to continue to remind your office of its obligation to use its "best efforts" to protect the rights of crime victims. 19 USC 377I(c) (I). I trust that as you review our proposed pleading you will bear that requirement in mind. + +I can be reached on my cell at As you know, we have to file today and are prepared to do so if we can't work something out At the same time, we would like to work cooperatively with your office to bring Epstein to justice — our revised pleadings are a step in that direction, while hopefully responding to the concerns that your Office has raised. + +Paul Cassell Counsel for Jane Doe #1 and Jane Doe #2 + +Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the University of Utah + +Voice: + +Fax: + +Email: + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the sender by reply electronic mail and delete the original message. Thank you. + +----Original Message-- + +From: (USAFLS) mailto: + +Sent: Monday, October 25, 2010 10:16 AM + +To: Paul Cassell + +Subject: Out of Office AutoReply: Conferring on Statement of Facts Before Wednesday's Filing + +I will be on government travel from October 25-26, 2010. If you need to reach me, please call me at Thanks. \ No newline at end of file diff --git a/marker2/ds9/EFTA00206871/EFTA00206871.metadata.json b/marker2/ds9/EFTA00206871/EFTA00206871.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..89e064d1451f9af4df5890fac3e4f8d70e2e135d --- /dev/null +++ b/marker2/ds9/EFTA00206871/EFTA00206871.metadata.json @@ -0,0 +1,146 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206871.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 7086, + "elapsed_seconds": 10.1, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "THE FOLLOWING COMMUNICATION IS A SETTLEMENT OFFER WITHIN THE MEANING OF FEDERAL RULE OF \nEVIDENCE 408", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 31.212, + 62.37 + ], + [ + 530.633056640625, + 62.37 + ], + [ + 530.633056640625, + 87.08563232421875 + ], + [ + 31.212, + 87.08563232421875 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 69 + ], + [ + "Text", + 38 + ], + [ + "Line", + 35 + ], + [ + "ListGroup", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 83 + ], + [ + "Line", + 42 + ], + [ + "Text", + 10 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 61 + ], + [ + "Line", + 31 + ], + [ + "Text", + 19 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206871" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206874/EFTA00206874.md b/marker2/ds9/EFTA00206874/EFTA00206874.md new file mode 100644 index 0000000000000000000000000000000000000000..648bc0b05b7300a73628e07cb78575ac26dfe758 --- /dev/null +++ b/marker2/ds9/EFTA00206874/EFTA00206874.md @@ -0,0 +1,127 @@ +To: (USAFLS)" + +Subject: FW: Proposed Pleading to File - right to confer + +Date: Wed, 27 Oct 2010 22:45:28 +0000 + +Importance: Normal + +Assistant U.S. Attorney Fax + +-----Original Message---- + +From: la (USAFLS) + +Sent: Wednesday, October 27, 2010 6:11 PM + +To: Paul Cassell + +Cc: Brad Edwards; (USAFLS) + +Subject: RE: Proposed Pleading to File - right to confer + +Paul, + +The Acting U.S. Attorney stands ready to discuss with you and Brad the merits of this case and ways in which it can be resolved, but will not be speaking with you today regarding how the victims will respond to the order to show cause, or what the government is willing to stipulate to in the response. + +As an aside, I believe the reasonable right to confer under 18 U.S.C. 3771(a)(5) applies to crime victims in their criminal cases, filed in U.S. District Court, not civil litigation the victims have initiated against the government. + +As to the proposed stipulation of facts, I received your e-mail containing those proposed stipulation facts on Saturday, October 23, 2010, at 3:25 p.m., Eastern Daylight Time. I opened your e-mail some time after that. At 4:40 p.m, October 23, 2010, I forwarded your e-mail to + +Since I was on travel from October 25-26, I did not have any opportunity to sit down and confer with regarding whether we could agree to some, or any, of the nineteen pages of proposed facts you submitted. Today, I told Brad Edwards that some of the facts are really legal conclusions or arguments, rather than statements of fact. The statement that one could reasonably infer something from an e-mail is not a factual assertion, but an argument. There are a number of statements that suffer from this deficiency. + +I do not believe we can resolve these differences in the time remaining for you to file your document. Thank you. + +----Original Message-- + +From: Paul Cassell mailto: + +Sent: Wednesday, October 27, 2010 5:01 PM + +To: M, (USAFLS) + +I. As you know, crime victims have the right to "confer" with the prosecutor on the case -- we respectfully request a chance to confer with the decisionmaker on this matter -- apparently the Acting U.S. Attorney. We would like to know why our very reasonable proposal has been turned down and why you are unwilling to work with us further. + +2. We respectfully request that you explain how you have been prejudiced and therefore will not stipulate to lack of prejudice. + +3. We respectfully request that you carry through on your commitment to us to review our statement of facts and indicate which Facts you are objecting to and which you are not. As you know, we have to file today -- so please get back to me quickly. Thanks. Paul Cassell a + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law + +5.3. Quinney College of Law at the University of Utah + +Voice: + +Fax: + +Email: + +httplAvvAvlaw.utah.edu/profiles/default.asp?PersonID=57&name=Cassell Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the sender by reply electronic mail and delete the original message. Thank you. + +---Original Message-- + +From: la (USAFLS) mailto: + +Sent: Wednesday, October 27, 2010 2:51 PM + +To: Paul Cassell + +Cc: Brad Edwards; (USAFLS) + +Subject: RE: Proposed Pleading to File - fixed a couple of sentences + +Paul, + +Thank you for sending the revised document. I have spoken with the Acting U.S. Attorney on this matter. We believe that if the victims simply filed a response to the order to show cause, and deferred filing any motion for summary judgment, it would promote the process for the parties to meet and address mutual concerns. However, we will not stipulate that the government has not been prejudiced by the passage of time in this case from its initial filing in July 2008. + +----Original Message--- + +From: Paul Csicu.11 mailto: + +Sent: Wednesday, October 27, 2010 4:10 PM + +To: Paul Cassell; M, (USAFLS) + +Cc: Brad Edwards; (USAFLS) + +Subject: RE: Proposed Pleading to File - fixed a couple of sentences + +I noticed that I missed a couple of sentences in the pleading I sent to you that made reference to the simultaneously filed declaration of Brad Edwards. This revision fixes those couple of sentences, making reference only to a soon-to-be filed declaration. Paul + +Voice: Fax: Email: httplAvvAvlaw.utah.edulprofilesidefault.asp?PersonID=57&name=Cassell Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the sender by reply electronic mail and delete the original message. Thank you. + +----Original Message--- + +From: Paul Cassell Sent: Wednesday, October 27, 2010 1:50 PM To: (USAFLS)' Cc: 'Brad Edwards': Subject: RE: Proposed Pleading to File + +## THE FOLLOWING COMMUNICATION IS A SETTLEMENT OFFER WITHIN THE MEANING OF FEDERAL RULE OF EVIDENCE 408 + +Dear (and =), + +Attached is proposed pleading that we would file, reflecting your request that we delay and reflecting your stipulation that the passage of time to this point has not prejudiced the U.S. Attorney's Office. + +I want to continue to remind your office of its obligation to use its "best efforts" to protect the rights of crime victims. 19 USC 3771(c) (I). I trust that as you review our proposed pleading you will bear that requirement in mind. + +I can be reached on my cell at As you know, we have to file today and are prepared to do so if we can't work something out At the same time, we would like to work cooperatively with your office to bring Epstein to justice — our revised pleadings are a step in that direction, while hopefully responding to the concerns that your Office has raised. + +Paul Cassell Counsel for Jane Doe #1 and Jane Doe #2 + +Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the University of Utah + +Voice: Fax: Email: al llwww.law.urah.edulprofilesfdefault.asp?PersonID=57&name=Cassell Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the sender by reply electronic mail and delete the original message. Thank you. + +----Original Message-- + +From: la (USAFLS) mailto: + +Sent: Monday, October 25, 2010 10:16 AM + +To: Paul Cassell Subject: Out of Office AutoReply: Conferring on Statement of Facts Before Wednesday's Filing \ No newline at end of file diff --git a/marker2/ds9/EFTA00206874/EFTA00206874.metadata.json b/marker2/ds9/EFTA00206874/EFTA00206874.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..3541d0385868f3198cee87ac9b2fc19110bbcac5 --- /dev/null +++ b/marker2/ds9/EFTA00206874/EFTA00206874.metadata.json @@ -0,0 +1,142 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206874.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 7122, + "elapsed_seconds": 1.54, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "THE FOLLOWING COMMUNICATION IS A SETTLEMENT OFFER WITHIN THE MEANING OF FEDERAL RULE OF \nEVIDENCE 408", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 30.6, + 254.34 + ], + [ + 530.9174194335938, + 254.34 + ], + [ + 530.9174194335938, + 280.35113525390625 + ], + [ + 30.6, + 280.35113525390625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 67 + ], + [ + "Line", + 34 + ], + [ + "Text", + 24 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 83 + ], + [ + "Line", + 42 + ], + [ + "Text", + 30 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 91 + ], + [ + "Line", + 44 + ], + [ + "Text", + 18 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206874" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206877/EFTA00206877.md b/marker2/ds9/EFTA00206877/EFTA00206877.md new file mode 100644 index 0000000000000000000000000000000000000000..e8ff1724e1162c5f85044ab9ebe73ad342bd25a1 --- /dev/null +++ b/marker2/ds9/EFTA00206877/EFTA00206877.md @@ -0,0 +1,52 @@ +From: SAFLS)" To: ' (USAFLS)" < "Ferrer, Wifredo A. (USAFLS)" S)" , "Atkinson, Karen (USAFLS)" Cc: ' (USAFLS)" • + +Subject: FW: follow up today's filing -- re Victims' Rights Suit + +Date: Thu, 28 Oct 2010 01:16:38 +0000 + +Importance: Normal + +Attachments: DE41\_20101027\_Resp\_to\_Order\_to\_Show\_Cause.pdf + +Good evening, everyone. I have attached what was filed in the District Court, and below is Judge Cassell's latest correspondence. I will let you digest and we can talk tomorrow. + +Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 + +From: Paul Castel! [mallto:i 7, 2010 8:39 PM + +Subject: follow up today's filing + +- 1. Via PACER, you will have seen the pleading that we have filed today. We are saddened that the U.S. Attorney's Office has not seen fit to make any concession to us, while at the same time asking us to delay filing our pleadings. Nonetheless, as a show of good faith, we are delaying filing our motion so that we can continue discussions with your Office. +- 2. As noted in our pleading and as this e-mail will serve to confirm —while we are willing to continue discussions with you, we respectfully request that you immediately begin preparing your response to our motion so that if it becomes necessary for us to file it, your response can be filed quickly as well without any delay. +- 3. You have previously promised to review our statement of facts and tell us which facts are being disputed and to work with us to narrow the range of disputes. As you know, we would like to work with you quickly on that effort. Could you get back to us by Friday, October 29, 2010, on that point and then have a telephone conference call with us on that date to work out the disputed facts? +- 4. This e-mail will also serve to confirm our request, previously raised in our October 22, 2010, letter to you, for access to correspondence relevant to Jane Doe #1 and Jane Doe #2's claims. We have not heard back from you on whether you intend to give us access to this information and, if not, what is the basis for withholding that information. +- 5. Our October 22, 2010, letter also indicated our surprise at the suggestion that we need to file some sort of civil complaint to resolve this matter. We explained why such an approach was, to our knowledge, not standard procedure in CVRA cases. Could you please advise as to what mechanism you think we need to deploy to bring this matter to a conclusion. +- 6. Your e-mail today takes the position that this CVRA case is a "civil" case and therefore that CVRA rights (like the right to confer) need not be provided to Jane Doe #1 and Jane Doe #2. We don't understand this position. In 2007-08, Jane Doe #1 and Jane Doe #2 were advised by your office that they had CVRA rights in the Epstein case. Our CVRA + +motion is clearly filed in connection with that case. Do you think we need to re-docket our case so that it links directly to the CVRA case that you were providing notices about. If so, could you let us know what you think is the proper procedure for making that linkage. + +- 7. While we would like to resolve these particular items with you quickly, in addition we would like to meet with the U.S. Attorney to discuss how to best move forward on this case on the morning of November 8, 2010 - if that is a convenient date for the U.S. Attorney. + +Thanks for your prompt attention to these issues. We look forward to working with you and others in the office to try and resolve this matter in a way that is fair to all concerned. + +Sincerely, + +Paul Cassell + +Co-Counsel for Jane Doe #1 and Jane Doe tt2 + +Paul G. Cassell + +Ronald N. Boyce Presidential Professor of Criminal Law + +Quinney College of Law at the University of Utah + +332 South 1400 East, Room 101 + +Salt Lake City, UT 84112-0730 + +![](_page_1_Picture_11.jpeg) + +http://www.law.utah.eduiprofiles/default.asp?RersoMD=57&name=Cassell Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the sender by reply electronic mail and delete the original message. 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That order recited the fact that Jane Doe #1 and Jane Doe #2 had recently settled their civil cases with Jeffrey Epstein as the basis for closure. On September 13, 2010, the victims promptly filed a notice that, while they had settled their case with Jeffrey Epstein, they had reached no settlement with the U.S. Attorney's Office and intended to make filings in this case shortly (DE #39). The victims requested administrative reopening of the case and, if the Court deemed it advisable, a prompt scheduling conference with the U.S. Attorney's Office regarding the case. The victims also advised that they had only recently received important correspondence between the U.S. Attorney's Office and Epstein proving that there had been an orchestrated decision to deny them their rights. + +On October 8, 2010, the Court entered an order directing the victims to file a status report and show cause why the case should not be dismissed for want of prosecution. + +### STATUS REPORT + +As the Court is aware from the victims' filing on September 13, 2010 (DE 39), the victims have now received important evidence that allows them to file a comprehensive motion explaining the factual background underlying the denials of their rights under the Crime Victims Rights Act and the legal reasons for concluding that their rights under the Act have been violated. Over the last several weeks, the victims have prepared a full motion to that effect accompanied by a detailed factual and legal memorandum. They planned to file the motion and memorandum today, simultaneously with this pleading. The motion they have fully prepared is in the nature of summary judgment motion (with a proposed set of undisputed facts), although the exact procedures for CVRA cases are unclear. + +In an effort to narrow and resolve disputes in this case, the victims had previously notified the U.S. Attorney's Office that it was going to be filing such a motion and accompanying statement of facts. They had requested the U.S. Attorney's Office review the facts and identify which ones were disputed. On October 22, 2010, the U.S. Attorney's Office responded with an e-mail: "The government will review your statement of facts and we will agree to a factual assertion if we believe it is correct." On October 23, 2010, the victims emailed to the U.S. Attorney's Office a detailed proposed statement of facts, with many of the facts documented by correspondence between the U.S. Attorney's Office and Epstein's counsel. The victims requested that the U.S. Attorney's Office identify which facts it would agree to and which it would not. In a letter to the U.S. Attorney's Office, the victims stated: + +If you believe that any of the facts they propose are incorrect, Jane Doe #1 and Jane Doe #2 would reiterate their long-standing request that you work with us to arrive at a mutually-agreed statement of facts. As you know, in the summer of 2008 Jane Doe #1 and Jane Doe #2 were working with you on a stipulation of facts when you reversed course and took that position that no recitation of the facts was necessary (see doc. #19 at 2). In particular, on July 29, 2008, you filed + +a Notice to Court Regarding Absence of Need for Evidentiary Hearing (DE. 17). At that time, you took the position that, because no federal criminal charges had been filed in the Southern District of Florida, no additional evidence was required to decide the victims' petition that was before the Court. I hope that your e-mail means that you will at least look at our facts and propose any modifications that you deem appropriate. Having that evidence quickly available to the Court could well help move this case to a conclusion. + +As you also know, because of the Government's decision not to work with us on agreed facts, we have had to secure information regarding the basis for your Office's treatment of the victims from other sources. This has been an arduous process, since the only remaining source for much of the information was Jeffrey Epstein. As you know, he is a politically-connected billionaire that employs legions of attorneys to obstruct any efforts to obtain information from him. Fortunately, after extended litigation, on June 30, 2010, we obtained information from him that was highly relevant to the treatment of Jane Doe #1 and Jane Doe #2 in the criminal justice system — namely, correspondence between your Office and legal counsel for Jeffrey Epstein during the negotiations surrounding the nonprosecution agreement. Many of our "facts" come straight from these e-mails. I trust that you will agree that our recitations of the e-mails are correct and that they accurately reflect communications between your Office and Epstein's legal counsel during the plea negotiation process. + +That same day, the U.S. Attorney's Office agreed to forward the proposed statement of facts to the appropriate Assistant U.S. Attorney for review. + +On October 26, 2010, rather than stipulate to undisputed facts, the U.S. Attorney's Office contacted the victims' attorneys and asked them to delay the filing of their motion for a twoweek period of time so that negotiations could be held between the Office and the victims in an attempt to narrow the range of disputes in the case and to hopefully reach a settlement resolution without the need for further litigation. Negotiations between the victims and the U.S. Attorney's Office then followed over the next two days. However, at 6:11 p.m. on October 27, 2010 — the date on which this pleading is due — the U.S. Attorney's Office informed the victims that it did not believe that it had time to review the victims' proposed statement of facts and advise which were accurate and which were inaccurate. The Office further advised the victims that it believed that the victims did not have a right to confer with their Office under the CVRA in this case + +because in its view the case is "civil" litigation rather than the criminal litigation. The Office, however, indicated it was willing to nonetheless meet with the victims. + +Purely as an accommodation to the U.S. Attorney's Office, the victims have therefore agreed to delay filing their motion for up to two-weeks to see if negotiations can resolve (or narrow) the disputes with the U.S. Attorney's Office. The U.S. Attorney's Office has represented that settlement discussions would be more difficult if the victims filed their motion today. The victims, however, have requested that the U.S. Attorney's Office immediately begin preparing their response to the motion so that it can file a response without any further delay. The victims also further state that they reserve the right to immediately file their motion and memorandum as soon as they believe that further negotiations are not productive. + +If no resolution of the case is achieved in the next two weeks — and if the Court does not direct a more expedited schedule in the meantime' -- the victims would propose the following schedule for bringing this case to a conclusion: + +November 10, 2010 (or earlier if directed by the Court or decided by the victims) — Victims file their comprehensive motion and supporting memorandum. + +November 24, 2010 -- U.S. Attorney's Office files response to the victims' motion. + +December 3, 2010 — Victims' file Reply to the U.S. Attorney's Response. + +Evidentiary Hearing (if facts contested) — early December, at a time convenient to the Court. + +January 1, 2011— Court issues ruling on whether victims' rights were violated. + +If the Court enters a finding that the victims' rights were violated, then .... + +January 14, 2011 — Victims brief on the appropriate remedy for a violation; + +&#x27; The victims understand the Court's show cause order to require them to file today a pleading explaining the status of the case and showing why the case should not be dismissed for failure to prosecute — not a comprehensive motion for resolution of all claims. If the victims are mistaken and the Court is directing that they file a comprehensive motion by today's date, the victims would respectfully ask leave to promptly make such a filing on any date the Court may direct. The victims would note that the U.S. Attorney's Office has also indicated its understanding that no such comprehensive motion need be filed by the victims today to comply with the Court's order. + +January 28, 2011 -- U.S. Attorney's Office (and any other interested person) files response to victims' remedy brief. + +February 4, 2011 — Victims reply on remedy issues. + +Hearing if necessary — mid-February, at a time convenient to the Court. + +This proposed schedule would allow Jane Doe #1 and Jane Doe #2 to have their case fully resolved on the merits within the next few months. The victims would have no objection to the Court accelerating the schedule. The victims understand that the U.S. Attorney's Office would like a slower schedule to resolve this matter — specifically 30 days for them to file a response. + +## THE CASE SHOULD NOT BE DISMISSED FOR LACK OF PROSECUTION + +Jane Doe #1 and Jane Doe #2 should not have their case dismissed for lack of prosecution for the simple reason that they have not failed to prosecute it. To the contrary, as will be recounted more fully in the statement of facts contained in their motion for a finding of violation of their rights, they have been attempting to secure information that would help prove their case. (If the Court wishes, the victims are prepared to file immediately more information on this point.) + +Although the victims will rely on all of the information contained in the statement of facts that they are preparing to file, in the interest of a brief summary the victims would note that they have been diligently attempting to secure correspondence between Epstein and the U.S. Attorney's Office regarding the non-prosecution agreement reached in this case. After the U.S. Attorney's Office declined to provide the information, the victims sought to secure that information as part of their civil lawsuits against Epstein. Because of protracted litigation from Epstein's battery of lawyers, the victims did not secure any of the correspondence they sought until June 30, 2010. Even then, they secured only part of that correspondence — litigation to secure the rest of that correspondence continues to this day. + +The victims have also never been asked by the U.S. Attorney's Office to accelerate the resolution of this case. During the last year, the victims' counsel have been in contact with the U.S. Attorney's Office on numerous matters related to Jeffrey Epstein, including contacts with the two attorneys who appear to be handling this CVRA matter for the U.S. Attorney's Office. At no time did anyone in the U.S. Attorney's Office ask the victims to begin moving more quickly to resolve this case. Counsel for the U.S. Attorney's Office have never contacted the victims about any problems that any delay was causing. During the last two days, the victims have asked the U.S. Attorney's Office whether they have been prejudiced by the passage of time in this case. The U.S. Attorney's Office has declined to explain how (if at all) it has been prejudiced. + +The victims would also note that the Court has never advised them of a deadline for moving forward with their CVRA case. The victims also knew that the Court was aware of the intense and protracted litigation what was proceeding with Epstein in the various civil cases against him. It seemed reasonable to the victim to resolve those cases first and then turn to the CVRA case — and the victims assumed that the Court was also proceeding on this approach, as the victims never received any inquiry from the Court about their CVRA case until the September 2010 order "administratively" closing the case. Within 5 days of receiving that communication from the Court, the victims promptly advised the Court of their intent to continue moving forward with the case and suggesting a scheduling conference if the Court deemed it advisable. + +The victims have now proposed a specific schedule that will bring this matter to a final conclusion in the next few months. In fact, the victims feel their case is strong and were prepared to file the equivalent of a Summary Judgment Motion today and only delayed that filing at the insistence of the U.S. Attorney's Office. There is no reason to dismiss the case precipitously now on the eve of a final resolution. + +The Eleventh Circuit has repeatedly noted that dismissal with prejudice is an "extreme sanction" and "is plainly improper unless and until the district court finds a clear record of delay or willful conduct and that lesser sanctions are inadequate to correct such conduct." Betty K Agencies, Ltd... MI MONADA, 432 F.3d 1333, 1338-39 (11th Cir.2005). In this case, there is no clear record of delay or willful conduct. To the contrary, there is a pattern of the victims diligently attempting to secure evidence (i.e., the correspondence) vital to their case in the face of determined opposition from both the U.S. Attorney's Office and a billionaire sex offender represented by a battery of attorneys. The Eleventh Circuit has held that simple negligence in meeting a court-imposed deadline is not sufficient to warrant dismissal. See McKelvey v. AT & T Techs., Inc., 789 F.2d 1518, 1520 (11th Cir.1986) (per curiam). Here, there is not even negligence, as the victims have not failed to meet any deadline that the Court has set. + +In addition, the victims today stand ready to bring the case to an expeditious conclusion on the schedule they propose. On September 13, 2010, the victims also suggested to the Court that a scheduling conference would be one way to proceed in this case — a suggestion that they continue to offer to the Court. The Government — the other party in the case — has asked the victims to move more slowly on this matter and has (as of yet) declined to indicate which facts it is disputing in this case and which facts it is stipulating to. The victims continue to actively participate in on-going settlement negotiations with the U.S. Attorney's office to resolve this case, and should those negotiations break down, then the victims are prepared to litigate the issues raised in this action on an expedited schedule. In view of these circumstances, there is no basis for dismissing the case. + +#### CONCLUSION + +The Court should establish the schedule proposed by the victims and bring this case to a conclusion on the merits as the victims propose. + +DATED: October 27, 2010 + +Respectfully Submitted, + +s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 + +and + +Paul G. Cassell Pro Hac Vice 332 S. 1400 E. Salt Lake City, UT 84112 + +Attorneys for Jane Doe #1 and Jane Doe #2 + +# CERTIFICATE OF SERVICE + +I HEREBY CERTIFY that on October 27, 2010 I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day on all parties on the attached Service List in the manner specified, either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those parties who are not authorized to receive electronically filed Notices of Electronic Filing. + +/s/ Bradley J. Edwards + +Bradley J. Edwards + +### SERVICE LIST + +Jane Does 1 and 2 v. United States United States District Court, Southern District of Florida Case No. 08-80736-CIV-MARRA/JOHNSON + +Attorney for United States Attorney for United States + +U.S. Attorney's Office mtte States Attorney's Office 500 S. Australian Ave., Suite 400 99 N.E. 4th Street West Palm Beach, FL 33401 Miami, FL 33132 \ No newline at end of file diff --git a/marker2/ds9/EFTA00206879/EFTA00206879.metadata.json b/marker2/ds9/EFTA00206879/EFTA00206879.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..05379ec60723de117a63246390ced36504fe4c3e --- /dev/null +++ b/marker2/ds9/EFTA00206879/EFTA00206879.metadata.json @@ -0,0 +1,539 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206879.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 9, + "chars": 16268, + "elapsed_seconds": 1.59, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF FLORIDA", + "heading_level": 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As of this particular moment, he has convinced Judge Cassell that the only thing they should file today is the response to the order to show cause. They will cool off tomorrow, get together dates when Judge Cassell can come to the District to meet, and will give us dates on Friday. I know Willy will be up here on Friday before I leave on vacation (since I had to write part of his speech!), anand I can show him the documents that we have in storage here on the Epstein matter and maybe we can do another conference call as a group? \ No newline at end of file diff --git a/marker2/ds9/EFTA00206888/EFTA00206888.metadata.json b/marker2/ds9/EFTA00206888/EFTA00206888.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..ee89596d71c624a37a916ac696b4edbb0b7522db --- /dev/null +++ b/marker2/ds9/EFTA00206888/EFTA00206888.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206888.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 707, + "elapsed_seconds": 0.3, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 19 + ], + [ + "Line", + 10 + ], + [ + "Text", + 4 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206888" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206889/EFTA00206889.md b/marker2/ds9/EFTA00206889/EFTA00206889.md new file mode 100644 index 0000000000000000000000000000000000000000..9d252599f871d11eb930571d7d65b81444fe1544 --- /dev/null +++ b/marker2/ds9/EFTA00206889/EFTA00206889.md @@ -0,0 +1,69 @@ +**To:** [REDACTED] + +**Cc:** [REDACTED] + +**Subject:** RE: Jane Does [REDACTED] U.S. (re Jeffrey Epstein) - Litigation Hold + +**Date:** Tue, 16 Nov 2010 20:38:05 +0000 + +**Importance:** Normal + +**Attachments:** 20101117044620.pdf; 20101117044557.pdf + +H [REDACTED] - I have attached the two signed documents for your files. I have a series of large stored e-mail backup files but when I tried to access some of them a few months ago when this first started heating back up, they were empty. I mentioned it to Ricky Vidarte but then I got busy with something else. Some of those items were also pdf'd and burned to CD or put on the main server, so all may not be lost, but IT may have to do some digging. + +When I sent you the bunch of names earlier I forgot to include the following: + +Myesha Braden (attorney at CEOS in DC) + +Gerald Lefcourt (counsel for Epstein) + +[REDACTED] (victim coordinator at FBI in West Palm Beach) + +Thank you. + +<<20101117044620.pdf>> + +<<20101117044557.pdf>> + +![](_page_0_Picture_134.jpeg) + +0 + +**From:** [REDACTED] + +**Sent:** Tuesday, November 16, 2010 2:09 PM + +**To:** [REDACTED] + +**Cc:** [REDACTED] + +**Subject:** Jane Does [REDACTED] U.S. (re Jeffrey Epstein) - Litigation Hold + +**Importance:** High + +This email is a follow-up to my communication of Nov. 2 regarding a Litigation Hold in the above-referenced case. Please read and acknowledge your receipt and agreement to the terms of the attached letter. Kindly complete and sign the form accompanying the letter + +![](_page_1_Picture_63.jpeg) + +**From:** [REDACTED] + +**Sent:** Tuesday, November 02, 2010 5:48 PM + +**To:** [REDACTED] (U.S. - 11.2.2010 JAW Lit Hold Ltr to Individual in USAO-SDFLA.pdf >> << File: Re.Jeffrey Epstein.Jane Does [REDACTED] U.S. - Typable 3-13.300.003 Attachment.1.pdf >>) + +**Cc:** [REDACTED] + +**Subject:** Jane Does [REDACTED] U.S. (re Jeffrey Epstein) - Litigation Hold + +**Importance:** High + +<< File: Re.Jeffrey Epstein.Jane Does [REDACTED] U.S. - 11.2.2010 JAW Lit Hold Ltr to Individual in USAO-SDFLA.pdf >> << File: Re.Jeffrey Epstein.Jane Does [REDACTED] U.S. - Typable 3-13.300.003 Attachment.1.pdf >> + +As a follow-up to your recent meeting concerning the above-referenced case, I write this letter in my capacity as the Electronic Discovery Coordinator within the Civil Division of the United States Attorney's Office for the Southern District of Florida (USAO-SDFLA) to advise you of the USAO-SDFLA's legal obligation to preserve documents and data relevant to the lawsuit and to enlist your assistance in this regard. + +I request that you please read and acknowledge your receipt and agreement to the terms of this letter. I also ask that you please complete and sign the form accompanying this letter. Please return the originals of both documents to me by November 9, 2010. + +Should you have any questions, please let me know. + +![](_page_1_Picture_74.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00206889/EFTA00206889.metadata.json b/marker2/ds9/EFTA00206889/EFTA00206889.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..2bcfd35da106aa615f214fea105c4a70af0a0d7f --- /dev/null +++ b/marker2/ds9/EFTA00206889/EFTA00206889.metadata.json @@ -0,0 +1,96 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206889.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2864, + "elapsed_seconds": 80.49, + "image_assets": [ + "_page_0_Picture_134.jpeg", + "_page_1_Picture_63.jpeg", + "_page_1_Picture_74.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 64 + ], + [ + "Text", + 48 + ], + [ + "Line", + 30 + ], + [ + "PageFooter", + 2 + ], + [ + "Picture", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 35 + ], + [ + "Text", + 19 + ], + [ + "Line", + 18 + ], + [ + "PageFooter", + 2 + ], + [ + "Picture", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206889" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206889/_page_0_Picture_134.jpeg b/marker2/ds9/EFTA00206889/_page_0_Picture_134.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..6d12ba93d7162341431485f354026dca79b8e2f3 --- /dev/null +++ b/marker2/ds9/EFTA00206889/_page_0_Picture_134.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:65194d6c781fdf408661ad26aa87de51e0dad938d3b5b50fdeed62b03f1502bd +size 5600 diff --git a/marker2/ds9/EFTA00206889/_page_1_Picture_63.jpeg b/marker2/ds9/EFTA00206889/_page_1_Picture_63.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..433f93d87db3c58c28d74604419680a420305795 --- /dev/null +++ b/marker2/ds9/EFTA00206889/_page_1_Picture_63.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:957f634ad59832eda720d976cdf4fde9d00c15244ddc5b14623d696195ab86bf +size 1284 diff --git a/marker2/ds9/EFTA00206889/_page_1_Picture_74.jpeg b/marker2/ds9/EFTA00206889/_page_1_Picture_74.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..8565451dbaaed1e25491cfa7e0444b014eb2b453 --- /dev/null +++ b/marker2/ds9/EFTA00206889/_page_1_Picture_74.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:898db37366e18c8dcbae541b3a3fb98aa269566ccf096bd3125e79da5e16a909 +size 8379 diff --git a/marker2/ds9/EFTA00206891/EFTA00206891.md b/marker2/ds9/EFTA00206891/EFTA00206891.md new file mode 100644 index 0000000000000000000000000000000000000000..0a4edab80f8546ae15d70a92a2729ba56ccf8ad4 --- /dev/null +++ b/marker2/ds9/EFTA00206891/EFTA00206891.md @@ -0,0 +1,63 @@ +USAO System - Microsoft Outlook: usao system - evoip: + +# USER LITIGATION HOLD NOTICE AND CERTIFICATION FORM + +## PRIVACY ACT PROTECTED + +#### I. NOTICE + +Please be advised that, by and through this Notice, we, the United States Attorney's Office for the Southern District of Florida ("USAO"), have instituted a "Litigation Hold" in connection with the claims set forth in lone Does nand #21 United States, Case No.: 08.80736-CIV-MARRA/Johnson regarding alleged violation of the petitioners' rights under the Crime Victim's Rights Act ("CVRA"). + +To institute this Litigation Hold, we are implementing preservation procedures regarding any and all records, data, or other information, whether they exist in paper form or as electronically stored information ("ESI"), within the USAO's possession, custody or control relating to the Complaint/Claims (collectively, "Information"). The USAO's obligation to preserve this Information pertains not only to paper copies, or "hard copies" (whether in draft or final, partial or complete, versions), but also to ESI in its originally-created, or "native" format, as it exists on any computer system (whether it be on the USAO's system or your personal computer), as well as removable or portable electronic storage media. Specific examples of Information subject to this Litigation Hold include, but are not limited to, e-mails and other electronic communications, word processing documents, records, spreadsheets, databases, calendars, telephone logs, internet usage files, network access information, and information on other kinds of media, including PDAs (such as Palm Pilots, BlackBerries, and cell phones), thumb drives, CDs, as well as digital voicemail and text messages. + +Because the USAO must take reasonable steps to preserve such Information in whatever form it has been created and maintained, the USAO's Lit Hold Coordinator and Systems Manager must coordinate with all those who may have such Information. We therefore require your assistance to both identify and preserve any and all Information relating to the Complaint/Claims, whether or not the Information is ultimately discoverable. Furthermore, we must confirm that you understand and accept your preservation obligations under this Litigation Hold. + +Accordingly, you are required to take the two following steps: (1) Identify to us all such Information and where it resides (in Section II below); and (2) Certify having received notice of this litigation Hold and understanding and accepting your preservation obligations under this Litigation Hold (in Section Ill below). [NOTE: While seeking to identify all such Information, please refrain to the maximum extent possible from opening emails/files you believe to be relevant.( + +## II. IDENTIFY ALL INFORMATION SUBJECT TO THE LITIGATION HOLD + +Please identify all locations where the Information described above may exist. CHECK ALL THAT APPLY + +Hord Copy Documents: X Printed Emails )4 Case Fiks/Logs O Calendars/Appointment Books 'Other + +X Email messages isi Calendar Items ,k, Tasks O Telephone Data + +O Notes s ti—Pcrbtle-Polders— \*Contacts '.PST Files ("Archive") O Office Communicator + +(continued on next page) + +(continued from previous page) + +USAO System — Network Data fie., documents/files and folders residing on network drives(: + +,Personal (N, H & M) Drive Document/Files/Folders AShared Files/Folders UONs/Alcatraz/USA-S + +❑ Inter- and Intra-net ❑ Other + +USAO System — Mobile PIN/SMS: USAO System — ClassilleaSpeciol Doto: + +)?1Blackberry/Other ❑ Document/Files/Folders/Other + +Non-Network Data fit. documents/files and folders residing on local hard drives and thumb drives,: + +XLocal (C & D) Drives E Portable Media/Thumb Drives ❑ Deleted Items (Recycle Bin) + +Personal Non-Network Data (located or residing somewhere other than the ()SAO Systemt + +❑ Document/Files/Folders ❑ Internet A Email Messages ❑ Portable Media/Thumb Drives + +❑ PDAs/Other + +#### III. CERTIFICATION + +By this Notice and Certification, I acknowledge that I have received, understand, and accept my obligations to preserve any and all Information (as defined above) I may have now, as well as all such Information I may subsequently receive, create or modify. I further understand and accept that my continuing Litigation Hold obligations require that I preserve all such Information in "native" format and, conversely, that I not delete or destroy any such Information until I receive formal written notice that this Litigation Hold is discontinued. To fulfill these continuing obligations, I will undertake the necessary steps to preserve this Information, be it "hard copy" and/or ESI, in coordination with the USAO's Lit Hold Coordinator and Systems Manager. + +• • + +Please be advised that failure to preserve and retain this Information may result in sanctions and/or implicate professional conduct rules. Consequently, if you are unsure whether certain information should be preserved, err on the side of caution and preserve the information until you have spoken to the USAO's Lit Hold Coordinator about it. If you have any questions about whether to preserve certain ESI, or its native formatting, please contact the USAO's Lit Hold Coordinator or Systems Manager. + +Please sign below to acknowledge you have read this Notice and Certification and understand and accept your preservation obligations, then return the executed copy to the USAO's Ut Hold Coordinator. Thank you. + +![](_page_1_Picture_19.jpeg) + +INFORMATION CONTAINED IN THIS FORM MAY CONSTITUTE PRIVATE, CONFIDENTIAL AND/OR SENSITIVE, AS WELL AS PERHAPS ALSO PRIVILEGED AND/OR OTHERWISE PROTECTED, INFORMATION \ No newline at end of file diff --git a/marker2/ds9/EFTA00206891/EFTA00206891.metadata.json b/marker2/ds9/EFTA00206891/EFTA00206891.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..03cc882235ea66a63d17700d1a28a51c8bcbb45e --- /dev/null +++ b/marker2/ds9/EFTA00206891/EFTA00206891.metadata.json @@ -0,0 +1,222 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206891.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 5615, + "elapsed_seconds": 1.28, + "image_assets": [ + "_page_1_Picture_19.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "USER LITIGATION HOLD NOTICE AND CERTIFICATION FORM", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 140.14800000000002, + 81.81 + ], + [ + 476.7920837402344, + 81.81 + ], + [ + 476.7920837402344, + 97.55859375 + ], + [ + 140.14800000000002, + 97.55859375 + ] + ] + }, + { + "title": "PRIVACY ACT PROTECTED", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 244.188, + 110.16000000000003 + ], + [ + 371.7740783691406, + 110.16000000000003 + ], + [ + 371.7740783691406, + 123.59613037109375 + ], + [ + 244.188, + 123.59613037109375 + ] + ] + }, + { + "title": "I. 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Ferrer, United States Attome + +Office of the United Slates Attorney Southern District of Florida 99 NE 4th Street Miami, Florida 33132 + +## Privileged Communication + +Re: Litigation Hold re: Jane Does #1 and #21. United States, Case No.: 08-80736-C1V-MARRA/Johnson AND Jeffrey Epstein + +As a follow-up to your recent meeting concerning the above-referenced case, I write this letter in my capacity as the Electronic Discovery Coordinator within the Civil Division of the United States Attorney's Office for the Southern District of Florida (1JSAO-SDFLA). 1 write to advise you of the USAO-SDFLA's legal obligation to preserve documents and data relevant to the lawsuit and to enlist your assistance in this regard. + +The USAO-SDFLA is required by law to take all reasonable steps to preserve all documents and data relating to the claims set forth in the Victim's Emergency Petition for Enforcement of Crime Victim's Rights Act, 18 USC Section 3771 (DE I) ("Victim's Petition") in Case No.: 9:08-cv-80736-Marra/Johnson in the Southern District of Florida, filed on July 7, 2008. Based upon the facts set forth in the Court filings that are unsealed, I recommend that the Federal Bureau of Investigation (F.B.I.) and the Palm Beach Police Department also be requested to preserve any documents that they may have that arc relevant to the Claims asserted in the above-referenced lawsuit. + +I request that you please read and acknowledge your receipt and agreement to the terms of this letter. I also ask that you please complete and sign the form accompanying this letter. Please return the originals of both documents to me by November 9, 2010. + +With respect to the claims asserted in the litigation, in the Victim's Petition (DE I), Jane Doe # I brought claims against the United States for alleged violation of her rights under the Crime Victim's Rights Act ("CVRA"). The Jane Doe #1 petitioner alleges that she was the victim of federal crimes committed by Jeffrey Epstein, including sex trafficking of children by fraud in violation of 18 USC § 1591, use of interstate commerce to entice a minor to commit + +prostitution in violation of 18 USC § 2422 and wire fraud in violation of 18 USC § 1343. DE 1 at ¶1. The Victim's Petition further alleges that in violation of the CVRA, Jane Doe #1 was not consulted with respect to the USAO-SDFLA's negotiations with Epstein (DE 1 at ¶¶3-6). The "Jane Doe #1 and Jane Doe # 2 Status Report and Response to Court's Order to Show Lack of Prosecution" (DE 41) argues that "there [was] an orchestrated decision [between the "U.S. Attorney's Office and Epstein] to deny the [Jane Doe Petitioners] their rights." DE 41 at 1. The Status Report alludes to communications between the USAO-SDFLA and counsel for Jeffrey Epstein "that [i]s highly relevant to the treatment of Jane Doe #1 and Jane Doe #2 in the criminal justice system – namely, correspondence between the [USAO-SDFLA] and legal counsel for Jeffrey Epstein during the negotiations surrounding the non-prosecution agreement" and the USAO-SDFLA and counsel for the Jane Does, on numerous matters related to Jeffrey Epstein, including contacts with AUSAs "Marie Villafaña and Dexter Lee." DE 41 at 3. + +The Government's filings frame the issue before the Court as to whether the "Government was obligated, under 18 U.S.C. § 3771(a)(5), to confer with petitioners prior to entering into an agreement with Jeffrey Epstein, which permitted the pending State of Florida prosecution to go forward, so long as Epstein agreed to certain conditions." Government's Notice To Court Regarding Absence of Need for Evidentiary Hearing. DE 17. The Government argues there are two relevant facts which will permit the Court to resolve the legal issue: (1) there are no criminal charges in the United States District Court, Southern District of Florida, filed against Jeffrey Epstein; and (2) Epstein entered pleas of guilty in Florida State Court on June 30, 2008, was sentenced, and is now imprisoned in Palm Beach County. DE 17. The Government's Response to the Victim's Petition ("Government's Response") notes that in 2006, Jeffrey Epstein was charged in the 15th Judicial Circuit Court in and for Palm Beach County, Florida with felony solicitation of prostitution. DE 13 at 1. The Response further notes that Epstein was not charged in the Southern District of Florida. DE 13 at 1-2. The Declaration of [REDACTED] indicates that "in the summer of 2007, Mr. Epstein and the [USAO-SDFLA] entered into negotiations to resolve the investigation. At that time, Mr. Epstein had been charged by the State of Florida with solicitation of prostitution, in violation of Florida Statutes § 796.07." DE 14. The Declaration also details the communications that occurred when a victim was identified, including notification letters that were sent. DE 14. Attached to that Declaration are copies of redacted letters provided to victims "C.W.", "T.M.", and "S.R." by AUSA Villafaña and the FBI's Victim-Witness Specialist Twiller Smith. DE 14. In addition, appended to the Declaration are AUSA Villafaña's letters to the victim's counsel, Bradley J. Edwards, Esq. DE 14. Special Agent [REDACTED] is copied on AUSA Villafaña's letters and Special Agent Richards and Kuyrkendall are referenced in certain letters to Mr. Edwards. DE 14. Moreover, Epstein's counsel, Jack Goldberger, Esq. is copied on letters to Mr. Edwards. I also note that the Supplemental Declaration of [REDACTED] (DE 35) notes the existence of a September 2007 Non-Prosecution Agreement, an October 2007 Addendum and a letter dated December 19, 2007 from the U.S. Attorney to Attorney Lilly Ann Sanchez, Counsel to Jeffrey Epstein (DE 35 at ¶3).1 + +1 I assume those involved in the above-referenced litigation, have copies of the relevant court filings, but if you desire any of the unsealed filings, let me know. + +Included in this preservation order are all Documents and data, including electronically stored information ("ESI"), relating to the claims. The Victim's Petition alleges that in July 2008, negotiations were taking place that led to a Non-Prosecution Agreement. However, it appears from AUSA [REDACTED] Declaration that during the summer of 2007, negotiations between Epstein and the USAO-SDFLA commenced that led to the September 2007 Non-Prosecution Agreement. It would therefore appear that the logical time frame to preserve evidence is at least May 1, 2007 and/or as early as the commencement of the negotiations leading to the September 2007 Non-Prosecution Agreement and through the present. + +"Documents and data" as used herein means not only paper copies of documents, but electronically stored information ("ESI"), to include email, audio recordings, videotape, instant messages, word processing files, spreadsheets, databases, calendars, telephone logs, contact manager information, Internet usage files, and all other electronically stored information maintained, created, and/or received by the USAO-SDFLA or any of its employees and/or agents. "Sources" include all paper documents, computer hard drives and other electronic storage media (e.g., CDs/DVDs, thumb drives, etc.), laptop computers, PDAs, Blackberry devices, and any other location where paper documents or electronic data is stored. Sources of potentially relevant information may also include personal computers or personal email accounts you use or have access to at home, or anywhere else. Also, relevant electronic data may be located on inaccessible storage media, such as backup tapes, which must be preserved as well, if an identical copy is not found elsewhere. + +In order to comply with its legal obligations, the USAO-SDFLA must immediately preserve all existing documents and data relevant to the claim/investigation described above and suspend deletion, overwriting, or any other possible destruction of unique, potentially relevant information. Effective immediately, all routine destruction efforts under USAO-SDFLA's existing document management and email policies are suspended for all information relevant to the above-referenced lawsuit. + +Guidance on how to preserve relevant documents and data should be directed to Jacquie Varela, IT-Manager at [Jacquie.Varela@usdoj.gov](mailto:Jacquie.Varela@usdoj.gov) on whom I am copying this letter. If you have any questions on how to comply with this directive, please contact Jacquie at extension 9218. + +Electronically stored information is an important and irreplaceable source of discovery and/or evidence in this matter. You must take every reasonable step to preserve this information until further notice. Failure to do so could result in severe penalties against the USAO-SDFLA and you. Intentional destruction or deletion of any document or data relevant to the lawsuit will not be tolerated by the USAO-SDFLA and could expose you to criminal sanctions. + +I will contact those of you with more detailed information on the claims to ensure that I have the names of all relevant individuals for the Litigation Hold. In addition, in accordance with DOJ guidelines, you will be contacted in the future for an update on your preservation efforts and to answer any questions you may have. In the interim, if this correspondence is unclear, please contact me at extension 9290, for any assistance you may require. + +In accordance with Department of Justice guidelines, please sign and date a copy of this letter in the space provided below as an acknowledgment that you have received, read. + +Re: Jane Does #1 and #2 I. United States Case No.: 9:08-cv-80736-KAM November 2, 2010 Page -4- + +## Privileged Communication + +and agree to comply with the preservation instructions contained in this letter. Please also complete, date and sign the attached form (Note — for your convenience. I have made sure that you can type in the date and click in any relevant boxes). I request that you return to me the originals containing your signatures by November 9, 2010. If you wish, you can also send to me scanned copies of your letters. + +Should you have any questions, please feel free contact me. + +Regards, + +JAW/attachments + +cc: + +WIFREDO A. FERRER UNITED STATES ATTORNEY + +![](_page_3_Picture_6.jpeg) + +Meredith Perreira, Paralegal Jacquie Varela, IT Manager, Administrative Division + +## Acknowledgment of Receipt of Litigation Hold Letter: + +I acknowledge that I have received and read the Litigation Hold letter dated November 2, 2010 regarding Jane Does #1 and Ii2I United States, Case No.: 08.80736-CIV-MARRA/Johnson and I have taken and agree to continue to take all reasonable steps necessary to preserve the documents and data as instructed in the letter and Form appended thereto. + +Dated: the gAday of November, 2010 + +![](_page_3_Picture_13.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00206893/EFTA00206893.metadata.json b/marker2/ds9/EFTA00206893/EFTA00206893.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..df7360854b38800b4bb127d4a191537f74cbb9bd --- /dev/null +++ b/marker2/ds9/EFTA00206893/EFTA00206893.metadata.json @@ -0,0 +1,253 @@ +{ + "source_pdf": 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(re Jennie Epstein) = Litigation Hold = Additional + +Date: Thu, 04 Nov 2010 14:20:52 +0000 + +Importance: Normal + +--- + +Thanks much [REDACTED]. Enjoy your cruise and thank you very much for the information. + +--- + +From: [REDACTED], [REDACTED] [REDACTED]. (USAFLS) + +Sent: Thursday, November 04, 2010 10:18 AM + +To: [REDACTED] + +Cc: [REDACTED] + +Subject: Re: [REDACTED] Does [REDACTED] (re Jennie Epstein) = Litigation Hold = Additional + +Dear [REDACTED] -- I have received and reviewed your letter. I cannot print and sign until I am back in the office on 11/15. + +Here are the FBI agents involved in the original investigation: + +[REDACTED] + +Original supervisor was [REDACTED] (I think he is now in DC). + +Later replaced by [REDACTED] + +The ASAC and SAC also attended meetings to discuss the plea negotiations. + +From our Office, most of the key players are gone, but their electronic files will have to be preserved: + +R. Alexander Acosta + +[REDACTED] + +At DOJ, there is/was [REDACTED] + +At Palm Beach PD, [REDACTED] was the Chief, he is no longer there. [REDACTED] was the Detective. I think he is still there. Those were the only two we ever dealt with. + +The lawyers for Epstein were: + +Kenneth Starr + +Jay Lefkowitz + +Alan Dershowitz + +Robert Critton + +There were some others, but I can't remember them now. + +Hope this helps + +From: Sent: tresday, November 02, 2010 06:01 PM + +To: + +Cc: + +Sub : : oes . . re e ey ein - ga ion o - i Iona + +Good Afternoon: + +In furtherance of the Lit Hold materials I sent to you, please know that I have to inform the National Preservation Officer at EOUSA in Washington as well as Jacquie Varela (here in the S.D. Fla) of the Lit Hold and inform them of key names. + +To that end, I gathered from the unsealed Court filings the names set forth below. Please let me know if there are any other names that should be identified. Please let me know S.A. Richards' first name. + +I will also need the names of the victims that would be MI Doe # 1 and Doe #2 for preservation purposes. This information will be kept confidential. If the USAO-SDFLA Lit Hold efforts are ever the subject of discovery, we can redact the victim names...as was done in the letters filed with AUSA Villafaiia's first declaration. + +Also, I will need your assistance in preparing letters to the FBI and Palm Beach P.D. to urge them to place a Hold on any documents that they may have....unless you advise that a hold is already in place. + +Finally, please let me know if the Lit Hold Time Frame I suggested is correct, or if it should commence with an earlier date. + +- (Jane Doe Petitioner in Civil action ???) +- (Jane Doe Petitioner in Civil action ???) +- (Jane Doe Petitioner in Civil action ???) +- Bradley J. Edwards, Esq, Counsel for +- Paul G. Cassell, Counsel for +- Jay'. Howell, Counsel for +- James Eisenberg, Esq., Original counsel for +- Jeffrey Epstein, Defendant in state criminal action and party to USAO-SDFLA Non-Prosecution Agreement +- Lilly Ann Sanchez, Counsel For Epstein +- Jack Goldberger, Counsel for Epstein + +• pedal Agent, F.B.I. + +• Special Agent Richards, F.B.I. + +• Assistant United States Attorney + +• Federal Bureau of Investigation ("FBI") + +• a FBI Victim Specialist + +• Palm Beach Florida Police Department + +From Se • :4 PM + +• Cc: + +Subject: oes . . re e rey pstein -Litigation o + +Importance: High + +« File: Re.Jeffrey File: Re.Jeffrey Does I U.S. - 11.2.2010 JAW Lit Hold Ltr to Individual in USAO.SD.Fla.pdf » « Does I U.S. - Typable 3-13.300.003 Attachment.l.pdf » + +As a follow-up to your recent meeting concerning the above-referenced case, I write this letter in my capacity as the Electronic Discovery Coordinator within the Civil Division of the United States Attorney's Office for the Southern District of Florida (USAO-SDFLA) to advise you of the USAO-SDFLA's legal obligation to preserve documents and data relevant to the lawsuit and to enlist your assistance in this regard. + +I request that you please read and acknowledge your receipt and agreement to the terms of this letter. I also ask that you please complete and sign the form accompanying this letter. Please return the originals of both documents to me by November 9, 2010. + +Should you have any questions, please let me know. + +4:y \ No newline at end of file diff --git a/marker2/ds9/EFTA00206897/EFTA00206897.metadata.json b/marker2/ds9/EFTA00206897/EFTA00206897.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..9d9e5960a1a50dd18e1a2f278be59d16283e9e0a --- /dev/null +++ b/marker2/ds9/EFTA00206897/EFTA00206897.metadata.json @@ -0,0 +1,122 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206897.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 4267, + "elapsed_seconds": 6.64, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 60 + ], + [ + "Text", + 59 + ], + [ + "Line", + 28 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 70 + ], + [ + "Line", + 35 + ], + [ + "Text", + 14 + ], + [ + "ListItem", + 10 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 71 + ], + [ + "Line", + 34 + ], + [ + "Text", + 16 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206897" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206900/EFTA00206900.md b/marker2/ds9/EFTA00206900/EFTA00206900.md new file mode 100644 index 0000000000000000000000000000000000000000..11bce4175c88988ea06922faa324f87f737d2350 --- /dev/null +++ b/marker2/ds9/EFTA00206900/EFTA00206900.md @@ -0,0 +1,50 @@ +Subject: RE: Jane Does 1 U.S. (re Jeffrey Epstein) - Litigation Hold - Additional + +Date: Thu, 04 Nov 2010 14:20:37 +0000 + +Importance: Normal + +Thank you very much Enjoy your cruise! + +u : : lane uoes Us. (re y in - Litigation - Aaai + +P.s. I think you have to take your start date back much further -- 2005 or 2006. + +Subject: RE: Jane Does U.S. (re Jeffrey Epstein) - Litigation Hold - Additional + +Good Afternoon: + +In furtherance of the Lit Hold materials I sent to you, please know that I have to inform the National Preservation Officer at EOUSA in Washington as well as Jacquie Varela (here in the S.D. Fla) of the Lit Hold and inform them of key names. + +To that end, I gathered from the unsealed Court filings the names set forth below. Please let me know if there are any other names that should be identified. Please let me know first name. + +I will also need the names of the victims that would be Jane Doe # 1 and Jane Doe #2 for preservation purposes. This information will be kept confidential. If the USAO-SDFLA Lit Hold efforts are ever the subject of discovery, we can redact the victim names...as was done in the letters filed with declaration. + +Also, I will need your assistance in preparing letters to the FBI and Palm Beach P.D. to urge them to place a Hold on any documents that they may have....unless you advise that a hold is already in place. + +Finally, please let me know if the Lit Hold Time Frame I suggested is correct, or if it should commence with an earlier date. + +• • + +- • +- Bradley J. Edwards, Esq, Counsel fo +- Paul G. Cassell, Counsel for +- Jay C. Howell, Counsel for +- James Eisenberg, Esq., Original counsel fon? +- Jeffrey Epstein, Defendant in state criminal action and party to USAO-SDFLA Non-Prosecution Agreement +- Lilly Ann Sanchez, Counsel For Epstein +- Jack Goldberger, Counsel for Epstein Palm Beach Florida Police Department + +Subject: Jane Does I U.S. (re Jeffrey Epstein) - Litigation Hold Importance: High + +« File: Re.Jeffrey Epstein.Jane Does U.S. - 11.2.2010 JAW Lit Hold Ltr to Individual in USAO.SD.Fla.pdf » « File: Re.Jeffrey Epstein.Jane Does I U.S. - Typable 3-13.300.003 Attachment.l.pdf » + +As a follow-up to your recent meeting concerning the above-referenced case, I write this letter in my capacity as the Electronic Discovery Coordinator within the Civil Division of the United States Attorney's Office for the Southern District of Florida (USAO-SDFLA) to advise you of the USAO-SDFLA's legal obligation to preserve documents and data relevant to the lawsuit and to enlist your assistance in this regard. + +I request that you please read and acknowledge your receipt and agreement to the terms of this letter. I also ask that you please complete and sign the form accompanying this letter. Please return the originals of both documents to me by November 9, 2010. + +![](_page_2_Picture_4.jpeg) + +y + +orney \ No newline at end of file diff --git a/marker2/ds9/EFTA00206900/EFTA00206900.metadata.json b/marker2/ds9/EFTA00206900/EFTA00206900.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..768da197903d03cd9bb64155ce2460c881aebfb0 --- /dev/null +++ b/marker2/ds9/EFTA00206900/EFTA00206900.metadata.json @@ -0,0 +1,120 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206900.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 2854, + "elapsed_seconds": 1.62, + "image_assets": [ + "_page_2_Picture_4.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 55 + ], + [ + "Line", + 24 + ], + [ + "Text", + 15 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 47 + ], + [ + "Line", + 23 + ], + [ + "ListItem", + 8 + ], + [ + "Text", + 5 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 4 + ], + [ + "Picture", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206900" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206900/_page_2_Picture_4.jpeg b/marker2/ds9/EFTA00206900/_page_2_Picture_4.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..b9ff43bf8f03cfc5f14a4633808b6da037908507 --- /dev/null +++ b/marker2/ds9/EFTA00206900/_page_2_Picture_4.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:a52af29448fef5933bbf43510f66ceffd7c23c384b808ee33453163a6e85ffc0 +size 7550 diff --git a/marker2/ds9/EFTA00206903/EFTA00206903.md b/marker2/ds9/EFTA00206903/EFTA00206903.md new file mode 100644 index 0000000000000000000000000000000000000000..417e326357edbcb5156a6bd74f46fc6fb4099be3 --- /dev/null +++ b/marker2/ds9/EFTA00206903/EFTA00206903.md @@ -0,0 +1,17 @@ +To: (USAFLS)" alMIN> + +Cc: " 11•11e> ' (USAFLS)" + +Subject: Revised Statement of Facts - Jane Does 1 and 2 v. United States + +Date: Mon, 15 Nov 2010 19:47:20 +0000 + +Importance: Normal + +Attachments: victims\_State\_facts\_rev\_1115.docx + +Welcome back from your vacation. Attached please find a copy of the statement of facts submitted by Cassell, with interlineations, additions, and other edits taken from your October 28, 2010 redlined version. If this is accurate, I will forward it to Cassell. + +While you were away, Cassell balked at having a meeting with the Executive Division until we had an agreed statement of facts. I told him I could not understand why that mattered, but we would try to accommodate them. Cassell and I spoke this morning. He and Brad will be free to meet in Miami on or after December 2. + +«victims\_Statejacts\_rev\_1115.docx» \ No newline at end of file diff --git a/marker2/ds9/EFTA00206903/EFTA00206903.metadata.json b/marker2/ds9/EFTA00206903/EFTA00206903.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..be6b73762679504c20ead2dbec0ce23142fab3be --- /dev/null +++ b/marker2/ds9/EFTA00206903/EFTA00206903.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206903.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 851, + "elapsed_seconds": 0.55, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 33 + ], + [ + "Line", + 16 + ], + [ + "Text", + 10 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206903" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206904/EFTA00206904.md b/marker2/ds9/EFTA00206904/EFTA00206904.md new file mode 100644 index 0000000000000000000000000000000000000000..68ecea2134c5c9c5610c527a190ad5b63153ab8b --- /dev/null +++ b/marker2/ds9/EFTA00206904/EFTA00206904.md @@ -0,0 +1,32 @@ +sunject: ML: Revised JointStatement ae s + +Date: Mon, 29 Nov 2010 14:13:56 +0000 + +Importance: Normal + +The afternoon of December 1 is a good time for + +Subject: RE: Revised Joint Statement of Facts + +Dear Dexter, + +Thanks for giving us a proposed statement of facts from the Government. It immediately raises many question for us, including: + +- 1. We notice that you have objected to a number of our facts that are based -- word-for-word -- on e-mails prepared by the Government. You mention that you would like tosee these e-mails. Marie has a full copy of what we were sent by Epstein's counsel. And, of course, these are all the Govemmen't e-mails to begin with. +- 2. Given that you have copies all of these emails, can you agree to all the facts reflected by the e-mails? We really don't understand the basis for your objection to our facts quoting THE GOVERNMENT'S e-mails? Is there really some dispute about these facts? +- 3. As you and Marie know, the emails in our possession were, improperly, redacted by Epstein's attronehys to indude only the government's half of the conversation. Will you provide us with the other half of these converations? +- 4. Our previous e-mail to you, we requested a copy of various documents in your possession, including (for example) the reports of interviews of our clients. Your responsive e-mail did not reply to that question at all. Will you provide a copy of these materials? +- 5. Our previous message to you -- indeed, our messages dating back to October -- requested that you provide an outline of what you believe is the proper procedure for resolving our client's claims. In your view, do we need to file a new civil complaint? Can we file in the nature of our summary judgment motion in our existing case -- the procedure I have followed in our courts around the country? You have not responded -- just we needed to take two years to get you to respond regarding your statement of facts. (We understood, as you recounted in your previous e-mail, that in about August 2008 you reversed your position on working with us to draft a statement of facts and have, for the last two years (until October 2010) taken the view that you would not work with us to get a statement of facts put together.) What is your position on the appropriate procedural device? +- 6. It appears that we are going to have a number of things to hammer out. We would like to set up a conference call to work through some of the po' greement. Good days for us are Nov. 30, Dec. 1, and Dec. 2 -- what times those dahys are good for you (and discuss. + +Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. , Room 101 Salt Lake City, UT 84112-0730 (801) 585-5202 (phone) (801) 581-6897 (fax) cassellp law.utah.edu + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidenital. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the sender by reply electronic mail and delete the original message. Thank you. + +From: Lee, Dexter (USAFLS) [Dexter.Lee@usdoj.gov] Sent: Monday, November 22, 2010 9:24 AM To: Paul Cassell; Brad Edwards Cc: Villafana, Ann Marie C. (USAFLS) Subject: Revised Joint Statement of Facts + +Attached please find a revised Joint Statement of Facts, which indicates what the government agrees is factually correct and relevant to the resolution of this case. I switched the first two paragraphs, to indicate that the FBI was investigating Epstein for various offenses. We deleted the reference to Epstein "committing" the offenses because he was neither convicted or charged, with any violation of federal law. Even when the Dal publicly announces an indictment being returned, we note that the accused enjoys the presumption of innocence. + +We are also checking the hearing transcript to determine whether what you claim was said by the government is accurate. There are a number of inaccuracies in your November 21, 2010 e-mail that I need to address. You claim that "more than two years since we proposed a set of facts to you ... all without any answers." Paragraph 1. This is not correct. After MIrovided the proposed statement of facts on July 17 and 21, 2008, I sent him a letter on July 25, 2008, explaining that the government believed 18 U.S.C. 3771(a)(5) was not triggered until an offense was charged in United States District Court. We also stated that, in the government's view, the relevant facts were: (1) there are no charges in district court filed against Jeffrey Epstein; and (2) Epstein entered pleas of guilty in Florida State Court on June 30, 2008, was sentenced, and is now imprisoned in Palm Beach County. On July 29, 2008, the government filed a Notice to Court Regarding Absence of Need for Evidentiary Hearing, explaining the government's position that only two relevant facts were necessary to decide whether the government had any obligation under 18 U.S.C. 3771(a) (5). I think this constitutes an answer to the proposed statement of facts offered by the petitioners in July 2008. You claim that most of your proposed facts are based upon e-mails written by the U.S. Attorney's Office e-mails. Rather than include dueling reasonable interpretations in a Statement of Facts, perhaps you can show us the e-mails and we can agree that they are authentic. Each party can argue what is a reasonable interpretation/inference in their respective legal memoranda. The government was prepared to meet with you as early as November 16, 2010, after eturned from her annual leave on November 13, and I returned from Columbia, South Carolina, on November 12. However, you wanted to have an agreed statement of facts before having a meeting with the Executive Division, so the meeting was postponed. Your e-mail states that you and Brad are available between December 9 and 17. I will schedule a meeting here in Miami during that k you. + +«victim\_Proposed Joint Statement of Facts.docx» \ No newline at end of file diff --git a/marker2/ds9/EFTA00206904/EFTA00206904.metadata.json b/marker2/ds9/EFTA00206904/EFTA00206904.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..60954c5beda0c8384e08b72687722fb0d0263664 --- /dev/null +++ b/marker2/ds9/EFTA00206904/EFTA00206904.metadata.json @@ -0,0 +1,92 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206904.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 6180, + "elapsed_seconds": 0.63, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 65 + ], + [ + "Line", + 32 + ], + [ + "Text", + 8 + ], + [ + "ListItem", + 6 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 81 + ], + [ + "Line", + 40 + ], + [ + "Text", + 6 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206904" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206906/EFTA00206906.md b/marker2/ds9/EFTA00206906/EFTA00206906.md new file mode 100644 index 0000000000000000000000000000000000000000..67a1918563c29f3a504baad931b352669ef2e4ee --- /dev/null +++ b/marker2/ds9/EFTA00206906/EFTA00206906.md @@ -0,0 +1,101 @@ +To: (USAFLS)" + +Subject: RE: Jane Does U.S. (re Jeffrey Epstein) - Litigation Hold + +Date: Tue, 16 Nov 2010 21:11:33 +0000 + +Importance: Normal + +CEOS is the Child Exploitation and Obscenity Section at DOJ in Washington. That is where and work, too. + +Thursday would be fine. Just let me know what time so I can block it out on my schedule. + +Assistant U.S. Attorney + +Fax + +From: (USAFLS) + +Sent: Tuesday, November 16, 2010 4:07 PM + +To: S. (USAFLS + +Cc: (USAFLS); M=M (USAFLS) + +Subject: RE: Jane Does I U.S. (re Jeffrey Epstein) - Litigation Hold + +Thank you very much I think I have in Court that were not under seal. already as I saw her name on some documents that were filed + +I will be in your office on Thursday so perhaps we can meet IF you are available. I am participating in an interview at 1:00 that should last 3 hours or so. + +I was thinking that now that you are back, we should also send a litigation hold letter to the FBI and the police. Was there any FBI attorney contact on this matter. If not, I can address the letter to the head of the section if you have that name. If you have some time on Thursday, perhaps we can meet. I can leave earlier and get up there. + +What is CEOS? + +Thanks! + +J + +From: (USAFLS) + +Sent: Tuesday, November 16, 2010 3:38 PM + +Hi — I have attached the two signed documents for your files. I have a series of large stored e-mail backup files but when I tried to access some of them a few months ago when this first started heating back up, they were empty. I mentioned it to but then I got busy with something else. Some of those items were also pdf'd and burned to CD or put on the main server, so all may not be lost, but IT may have to do some digging. + +When I sent you the bunch of names earlier I forgot to include the following: + +(attorney at CEOS in DC) + +(counsel for Epstein) + +(victim coordinator at FBI in West Palm Beach) + +Thank you. + +« File: 20101117044620.pdf » + +« File: 20101117044557.pdf » + +Assistant U.S. Attorney + +Fax + +From: (USAFLS) + +Sent: Tuesday, November 16, 2010 2:09 PM + +To: USAFLS); USAFLS); USAFLS); .(USAFLS) + +(USAFLS); Cc: (USAFLS); (USAFLS) + +Subject: Jane Does U.S. (re Jeffrey Epstein) - Litigation Hold + +Importance: High + +This email is a follow-up to my communication of Nov. 2 regarding a Litigation Hold in the above-referenced case. Please read and acknowledge your receipt and agreement to the terms of the attached letter. Kindly complete and sign the form accompanying the letter + +Please return the originals of both documents to me at your earliest convenience. + +Thanks very much. + +From: (USAFLS) + +Sent: Tuesda November 02, 2010 5:48 PM + +To: USAFLS), (USAFLS); (USAFLS); + +« File: Re.Jeffrey Epstein.Jane Does i U.S. - 11.2.2010 JAW Lit Hold Ltr to Individual in USAO.SD.Fla.pdf » « File: Re.Jeffrey Epstein.Jane Does I U.S. - Typable 3-13.300.003 Attachment.l.pdf » + +As a follow-up to your recent meeting concerning the above-referenced case, I write this letter in my capacity as the Electronic Discovery Coordinator within the Civil Division of the United States Attorney's Office for the Southern District of Florida (USAO-SDFLA) to advise you of the USAO-SDFLA's legal obligation to preserve documents and data relevant to the lawsuit and to enlist your assistance in this regard. + +I request that you please read and acknowledge your receipt and agreement to the terms of this letter. I also ask that you please complete and sign the form accompanying this letter. 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I think I have Twiler already as I saw her name on some documents that were filed in Court that were not under seal. + +I will be in your office on Thursday so perhaps we can meet IF you are available. I am participating in an interview at 1:00 that should last 3 hours or so. + +I was thinking that now that you are back, we should also send a litigation hold letter to the FBI and the police. Was there any FBI attorney contact on this matter. If not, I can address the letter to the head of the section if you have that name. If you have some time on Thursday, perhaps we can meet. I can leave earlier and get up there. + +What is CEOS? + +Thanks! + +J + +[REDACTED] ----- +**Sent:** Tuesday, November 16, 2010 3:38 PM + +[REDACTED] +**Subject:** RE: Jane Does ¶ U.S. (re Jeffrey Epstein) - Litigation Hold + +[REDACTED] -- I have attached the two signed documents for your files. I have a series of large stored e-mail backup files but when I tried to access some of them a few months ago when this first started heating back up, they were empty. I mentioned it to Ricky Vidarte but then I got busy with something else. Some of those items were also pdf'd and burned to CD or put on the main server, so all may not be lost, but IT may have to do some digging. + +When I sent you the bunch of names earlier I forgot to include the following: + +[REDACTED] + +Gerald Lefcourt (counsel for Epstein) + +[REDACTED] (victim coordinator at FBI in West Palm Beach) + +Thank you. + +<< File: 20101117044620.pdf >> + +Sent: Tuesday, November 16, 2010 2:09 PM + +Subject: Jane Does U.S. (re Jeffrey Epstein) - Litigation Hold Importance: High + +This email is a follow-up to my communication of Nov. 2 regarding a Litigation Hold in the above-referenced case. Please read and acknowledge your receipt and agreement to the terms of the attached letter. Kindly complete and sign the form accompanying the letter + +Please return the originals of both documents to me at your earliest convenience. + +Thanks very much. + +James + +PM + +Subject: Jane Does I U.S. (re Jeffrey Epstein) - Litigation Hold Importance: High + +« File: Re.Jeffrey Epstein.Jane Does I U.S. - 11.2.2010 JAW Lit Hold Ltr to Individual in USAO.SD.Fla.pdf » « File: Re.Jeffrey Epstein.Jane Does. U.S. - Typable 3-13.300.003 Attachment.l.pdf » + +As a follow-up to your recent meeting concerning the above-referenced case, I write this letter in my capacity as the Electronic Discovery Coordinator within the Civil Division of the United States Attorney's Office for the Southern District of Florida (USAO-SDFLA) to advise you of the USAO-SDFLA's legal obligation to preserve documents and data relevant to the lawsuit and to enlist your assistance in this regard. + +I request that you please read and acknowledge your receipt and agreement to the terms of this letter. I also ask that you please complete and sign the form accompanying this letter. 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Paul + +Paul G. Cassell + +[REDACTED] + +[REDACTED] + +**Sent:** Tuesday, November 30, 2010 4:28 PM + +**To:** Paul Cassell; Brad Edwards + +[REDACTED] + +**Subject:** RE: Revised Joint Statement of Facts - 3 PM Weds? + +Paul, + +Wednesday at 3:00 p.m. is fine for me. I am at (305) 961-9320. Marie's number is (561) 209-1047. I can probably dial in Marie from my end. + +[REDACTED] + +**From:** Paul Cassell [mailto:cassellp@law.utah.edu] + +**Sent:** Tuesday, November 30, 2010 6:08 PM + +[REDACTED] + +**Subject:** RE: Revised Joint Statement of Facts - 3 PM Weds? + +[REDACTED] + +Sorry it has taken me a day to get back to you. + +Sent: Monday, November 22, 2010 9:24 AM + +To: Paul Cassell. Brad Edwards + +Subject: Revised Joint Statement of Facts + +Paul and Brad, + +Attached please find a revised Joint Statement of Facts, which indicates what the government agrees is factually correct and relevant to the resolution of this case. I switched the first two paragraphs, to indicate that the FBI was investigating Epstein for various offenses. We deleted the reference to Epstein "committing" the offenses because he was neither convicted or charged, with any violation of federal law. Even when the DOJ publicly announces an indictment being returned, we note that the accused enjoys the presumption of innocence. + +We are also checking the hearing transcript to determine whether what you claim was said by the government is accurate. + +There are a number of inaccuracies in your November 21, 2010 e-mail that I need to address. You claim that "more than two years since we proposed a set of facts to you ... all without any answers." Paragraph 1. This is not correct. After Brad provided the proposed statement of facts on July 17 and 21, 2008, I sent him a letter on July 25, 2008, explaining that the government believed 18 U.S.C. 3771(a)(5) was not triggered until an offense was charged in United States District Court. We also stated that, in the government's view, the relevant facts were: (1) there are no charges in district court filed against Jeffrey Epstein; and (2) Epstein entered pleas of guilty in Florida State Court on June 30, 2008, was sentenced, and is now imprisoned in Palm Beach County. On July 29, 2008, the government filed a Notice to Court Regarding Absence of Need for Evidentiary Hearing, explaining the government's position that only two relevant facts were necessary to decide whether the government had any obligation under 18 U.S.C. 3771(a)(5). I think this constitutes an answer to the proposed statement of facts offered by the petitioners in July 2008. + +You claim that most of your proposed facts are based upon e-mails written by the U.S. Attorney's Office emails. Rather than include dueling reasonable interpretations in a Statement of Facts, perhaps you can show us the e-mails and we can agree that they are authentic. Each party can argue what is a reasonable interpretation/inference in their respective legal memoranda. + +The government was prepared to meet with you as early as November 16, 2010, after Marie returned from her annual leave on November 13, and I returned from Columbia, South Carolina, on November 12. However, you wanted to have an agreed statement of facts before having a meeting with the Executive Division, so the meeting was postponed. + +Your e-mail states that you and Brad are available between December 9 and 17. I will schedule a meeting here in Miami during that period. Thank you. + +![](_page_2_Picture_1.jpeg) + +«viam\_Proposed Joint Statement of Facts.docx>> \ No newline at end of file diff --git a/marker2/ds9/EFTA00206912/EFTA00206912.metadata.json b/marker2/ds9/EFTA00206912/EFTA00206912.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..6512446175dc2de805fdd0115d7773ef230ecc66 --- /dev/null +++ b/marker2/ds9/EFTA00206912/EFTA00206912.metadata.json @@ -0,0 +1,124 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206912.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 3750, + "elapsed_seconds": 5.5, + "image_assets": [ + "_page_2_Picture_1.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 52 + ], + [ + "Span", + 37 + ], + [ + "Line", + 19 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 64 + ], + [ + "Line", + 32 + ], + [ + "Text", + 9 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 7 + ], + [ + "Line", + 4 + ], + [ + "Text", + 2 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206912" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206912/_page_2_Picture_1.jpeg b/marker2/ds9/EFTA00206912/_page_2_Picture_1.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..7a8fc86d943f49671a9c92a9d559de38bd40a12b --- /dev/null +++ b/marker2/ds9/EFTA00206912/_page_2_Picture_1.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:535a02dfc2145a2dd8ba34602d96a775e6bbc3e62ca2f533d7747576d99c9f32 +size 3058 diff --git a/marker2/ds9/EFTA00206915/EFTA00206915.md b/marker2/ds9/EFTA00206915/EFTA00206915.md new file mode 100644 index 0000000000000000000000000000000000000000..1852067ec9e28788885b33521864cf3ee93ac05f --- /dev/null +++ b/marker2/ds9/EFTA00206915/EFTA00206915.md @@ -0,0 +1,141 @@ +To: " (USAFLS)" + +Subject: RE: Jane Does U.S. (re Jeffrey Epstein) - Litigation Hold + +Date: Tue, 16 Nov 2010 21:29:32 +0000 + +Importance: Normal + +Do you know how long it takes to get from the Miami Office to your office? (When I go up for Court hearings they are usually very early in the morning and I leave before dawn from my house...). + +I am thinking of leaving here at 10, it should take me about an hour and a half or more I suspect to get to your office. So, perhaps if we meet when I get there around 11:30, we can meet for a short while. + +I think we are in good shape as far as my end of things are concerned. Thanks for the heads-up as far as the back-up and for copying and on your email. I will follow-up with + +James + +Assistant United States Attorney + +Office of the United States Attorney + +Southern District of Florida + +99 N.E. 4th Street, Suite 300 + +Miami, Florida 33132 + +(o) + +From USAFLS) + +Sent: Tuesday, November 16, 2010 4:12 PM + +To:- (USAFLS) + +Subject: RE: Jane Does I U.S. (re Jeffrey Epstein) - Litigation Hold + +CEOS is the Child Exploitation and Obscenity Section at DOJ in Washington. That is where( and work, too. + +Thursday would be fine. Just let me know what time so I can block it out on my schedule. + +Assistant U.S. Attorney + +Fax + +From: (USAFLS) + +Sent: Tuesda November 16, 2010 4:07 PM + +To (USAFLS) + +Cc: (USAFLS); (USAFLS) + +Subject: RE: Jane Does.. U.S. (re Jeffrey Epstein) - Litigation Hold + +Thank you very much Marie. I think I have Twiler already as I saw her name on some documents that were filed in Court that were not under seal. + +I will be in your office on Thursday so perhaps we can meet IF you are available. I am participating in an interview at 1:00 that should last 3 hours or so. + +I was thinking that now that you are back, we should also send a litigation hold letter to the FBI and the police. Was there any FBI attorney contact on this matter. If not, I can address the letter to the head of the section if you have that name. If you have some time on Thursday, perhaps we can meet. I can leave earlier and get up there. + +What is CEOS? + +Thanks! + +J + +From (USAFLS) + +Sent: Tuesda November 16, 2010 3:38 PM + +To: (USAFLS) + +Cc: (USAFLS); (USAFLS) + +Subject: RE: Jane Does. U.S. (re Jeffrey Epstein) - Litigation Hold + +Hi James — I have attached the two signed documents for your files. I have a series of large stored e-mail backup files but when I tried to access some of them a few months ago when this first started heating back up, they were empty. I mentioned it to but then I got busy with something else. Some of those items were also pdf'd and burned to CD or put on the main server, so all may not be lost, but IT may have to do some digging. + +When I sent you the bunch of names earlier I forgot to include the following: + +(attorney at CEOS in DC) + +Gerald Lefcourt (counsel for Epstein) + +(victim coordinator at FBI in West Palm Beach) + +Thank you. + +« File: 20101117044620.pdf » + +« File: 20101117044557.pdf » + +500 S. Australian Ave, Suite 400 + +West Palm Beach, FL 33401 + +Fax + +From: (USAFLS) + +Sent: Tuesda November 16, 2010 2:09 PM + +To: (USAFLS); (USAFLS); a (USAFLS); (USAFLS) + +Cc: . (USAFLS) (USAFLS); U A ) + +Subject: lane Does r U.S. (re Jeffrey Epstein) - Litigation Hold + +Importance: High + +This email is a follow-up to my communication of Nov. 2 regarding a Litigation Hold in the above-referenced case. Please read and acknowledge your receipt and agreement to the terms of the attached letter. Kindly complete and sign the form accompanying the letter + +Please return the originals of both documents to me at your earliest convenience. + +Thanks very much. + +From: (USAFLS) + +Sent: Tuesday, November 02, 2010 5:48 PM + +To: . (USAFLS); USAFLS); (USAFLS); (USAFLS); + +Cc: (USAFLS); USAFLS) + +Subject: Jane Does U.S. (re Jeff Lion Hold + +Importance: High + +« File: Re.Jeffrey Epstein.Jane Does • U.S. - 11.2.2010 JAW Lit Hold Ltr to Individual in USAO.SD.Fla.pdf » « File: Re.Jeffrey Epstein.Jane Does I. U.S. - Typable 3-13.300.003 Attachment.l.pdf » + +As a follow-up to your recent meeting concerning the above-referenced case, I write this letter in my capacity as the Electronic Discovery Coordinator within the Civil Division of the United States Attorney's Office for the Southern District of Florida (USAO-SDFLA) to advise you of the USAO-SDFLA's legal obligation to preserve documents and data relevant to the lawsuit and to enlist your assistance in this regard. + +I request that you please read and acknowledge your receipt and agreement to the terms of this letter. I also ask that you please complete and sign the form accompanying this letter. Please return the originals of both documents to me by November 9, 2010. + +Should you have any questions, please let me know. + +99 N.E. 4th Street, Suite 300 + +Miami, Florida 33132 + +(0) \ No newline at end of file diff --git a/marker2/ds9/EFTA00206915/EFTA00206915.metadata.json b/marker2/ds9/EFTA00206915/EFTA00206915.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..c0d0977ed2880c24d3500949c82ad7f7df414c0a --- /dev/null +++ b/marker2/ds9/EFTA00206915/EFTA00206915.metadata.json @@ -0,0 +1,144 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206915.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 4, + "chars": 4773, + "elapsed_seconds": 1.57, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 59 + ], + [ + "Line", + 29 + ], + [ + "Text", + 27 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 67 + ], + [ + "Line", + 34 + ], + [ + "Text", + 26 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 76 + ], + [ + "Line", + 37 + ], + [ + "Text", + 26 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 3, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 9 + ], + [ + "Text", + 5 + ], + [ + "Line", + 5 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206915" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206919/EFTA00206919.md b/marker2/ds9/EFTA00206919/EFTA00206919.md new file mode 100644 index 0000000000000000000000000000000000000000..82060ca05498292c8ce053aae581d5b213ef5e92 --- /dev/null +++ b/marker2/ds9/EFTA00206919/EFTA00206919.md @@ -0,0 +1,89 @@ +![](_page_0_Picture_138.jpeg) + +*United States Attorney +Southern District of Florida* + +99 N.E. 4 Street +Miami, FL 33132 +305.961.9290 + +November 2, 2010 + +Via E-Mail + +**Privileged Communication** + +Wifredo A. Ferrer, United States Attorney + +[REDACTED] +Wendy A. Joselbus, ALISA, Civil Chief + +[REDACTED] + +Office of the United States Attorney +Southern District of Florida +99 NE 4th Street +Miami, Florida 33132 + +Re: **Litigation Hold re:** + +**Jane Does #1 and #2** | **United States, Case No.: 08-80736-CIV-** +**MARRA/Johnson AND Jeffrey Epstein** + +As a follow-up to your recent meeting concerning the above-referenced case, I write this letter in my capacity as the Electronic Discovery Coordinator within the Civil Division of the United States Attorney's Office for the Southern District of Florida (USAO-SDFLA). I write to advise you of the USAO-SDFLA's legal obligation to preserve documents and data relevant to the lawsuit and to enlist your assistance in this regard. + +The USAO-SDFLA is required by law to take all reasonable steps to preserve all documents and data relating to the claims set forth in the Victim's Emergency Petition for Enforcement of Crime Victim's Rights Act, 18 USC Section 3771 (DE 1) ("Victim's Petition") in Case No.: 9:08-cv-80736-Marra/Johnson in the Southern District of Florida, filed on July 7, 2008. Based upon the facts set forth in the Court filings that are unsealed, I recommend that the Federal Bureau of Investigation (F.B.I.) and the Palm Beach Police Department also be requested to preserve any documents that they may have that are relevant to the Claims asserted in the above-referenced lawsuit. + +I request that you please read and acknowledge your receipt and agreement to the terms of this letter. I also ask that you please complete and sign the form accompanying this letter. Please return the originals of both documents to me by November 9, 2010. + +With respect to the claims asserted in the litigation, in the Victim's Petition (DE 1), Jane Doe # 1 brought claims against the United States for alleged violation of her rights under the Crime Victim's Rights Act ("CVRA"). The Jane Doe #1 petitioner alleges that she was the victim of federal crimes committed by Jeffrey Epstein, including sex trafficking of children by fraud in violation of 18 USC § 1591, use of interstate commerce to entice a minor to commit + +prostitution in violation of 18 USC § 2422 and wire fraud in violation of 18 USC § 1343. DE 1 at ¶ 1. The Victim's Petition further alleges that in violation of the CVRA, Jane Doe #1 was not consulted with respect to the USAO-SDFLA's negotiations with Epstein (DE 1 at ¶ ¶ 3-6). The "Jane Doe #1 and Jane Doe # 2 Status Report and Response to Court's Order to Show Lack of Prosecution" (DE 41) argues that "there [was] an orchestrated decision [between the "U.S. Attorney's Office and Epstein] to deny the [Jane Doe Petitioners] their rights." DE 41 at 1. The Status Report alludes to communications between the USAO-SDFLA and counsel for Jeffrey Epstein "that [i]s highly relevant to the treatment of Jane Doe #1 and Jane Doe #2 in the criminal justice system – namely, correspondence between the [USAO-SDFLA] and legal counsel for Jeffrey Epstein during the negotiations surrounding the non-prosecution agreement" and the USAO-SDFLA and counsel for the Jane Does, on numerous matters related to Jeffrey Epstein, including contacts with AUSAs "Marie [REDACTED] and Dexter Lee." DE 41 at 3. + +The Government's filings frame the issue before the Court as to whether the "Government was obligated, under 18 U.S.C. § 3771(a)(5), to confer with petitioners prior to entering into an agreement with Jeffrey Epstein, which permitted the pending State of Florida prosecution to go forward, so long as Epstein agreed to certain conditions." Government's Notice To Court Regarding Absence of Need for Evidentiary Hearing. DE 17. The Government argues there are two relevant facts which will permit the Court to resolve the legal issue: (1) there are no criminal charges in the United States District Court, Southern District of Florida, filed against Jeffrey Epstein; and (2) Epstein entered pleas of guilty in Florida State Court on June 30, 2008, was sentenced, and is now imprisoned in Palm Beach County. DE 17. The Government's Response to the Victim's Petition ("Government's Response") notes that in 2006, Jeffrey Epstein was charged in the 15th Judicial Circuit Court in and for Palm Beach County, Florida with felony solicitation of prostitution. DE 13 at 1. The Response further notes that Epstein was not charged in the Southern District of Florida. DE 13 at 1-2. The Declaration of A. Marie [REDACTED] indicates that "in the summer of 2007, Mr. Epstein and the [USAO-SDFLA] entered into negotiations to resolve the investigation. At that time, Mr. Epstein had been charged by the State of Florida with solicitation of prostitution, in violation of Florida Statutes § 796.07." DE 14. The Declaration also details the communications that occurred when a victim was identified, including notification letters that were sent. DE 14. Attached to that Declaration are copies of redacted letters provided to victims "C.W.", "T.M.", and "S.R." by AUSA [REDACTED] and the FBI's Victim-Witness Specialist Twiller Smith. DE 14. In addition, appended to the Declaration are AUSA [REDACTED] letters to the victim's counsel, Bradley J. Edwards, Esq. DE 14. Special Agent Nesbitt [REDACTED], F.B.I. is copied on AUSA [REDACTED] letters and Special Agent [REDACTED] and [REDACTED] are referenced in certain letters to Mr. Edwards. DE 14. Moreover, Epstein's counsel, Jack Goldberger, Esq. is copied on letters to Mr. Edwards. I also note that the Supplemental Declaration of A. Marie [REDACTED] (DE 35) notes the existence of a September 2007 Non-Prosecution Agreement, an October 2007 Addendum and a letter dated December 19, 2007 from the U.S. Attorney to Attorney Lilly Ann Sanchez, Counsel to Jeffrey Epstein (DE 35 at ¶ 3).1 + +1 I assume those involved in the above-referenced litigation, have copies of the relevant court filings, but if you desire any of the unsealed filings, let me know. + +Included in this preservation order are all Documents and data, including electronically stored information ("ESI"), relating to the claims. The Victim's Petition alleges that in July 2008, negotiations were taking place that led to a Non-Prosecution Agreement. However, it appears from AUSA Villafaña's Declaration that during the summer of 2007, negotiations between Epstein and the USAO-SDFLA commenced that led to the September 2007 Non-Prosecution Agreement. It would therefore appear that the logical time frame to preserve evidence is at least May 1, 2007 and/or as early as the commencement of the negotiations leading to the September 2007 Non-Prosecution Agreement and through the present. + +"Documents and data" as used herein means not only paper copies of documents, but electronically stored information ("ESI"), to include email, audio recordings, videotape, instant messages, word processing files, spreadsheets, databases, calendars, telephone logs, contact manager information, Internet usage files, and all other electronically stored information maintained, created, and/or received by the USAO-SDFLA or any of its employees and/or agents. "Sources" include all paper documents, computer hard drives and other electronic storage media (e.g., CDs/DVDs, thumb drives, etc.), laptop computers, PDAs, Blackberry devices, and any other location where paper documents or electronic data is stored. Sources of potentially relevant information may also include personal computers or personal email accounts you use or have access to at home, or anywhere else. Also, relevant electronic data may be located on inaccessible storage media, such as backup tapes, which must be preserved as well, if an identical copy is not found elsewhere. + +In order to comply with its legal obligations, the USAO-SDFLA must immediately preserve all existing documents and data relevant to the claim/investigation described above and suspend deletion, overwriting, or any other possible destruction of unique, potentially relevant information. Effective immediately, all routine destruction efforts under USAO-SDFLA's existing document management and email policies are suspended for all information relevant to the above-referenced lawsuit. + +Guidance on how to preserve relevant documents and data should be directed to ~~Inquiry Victim~~ IT-Manager at [REDACTED] on whom I am copying this letter. If you have any questions on how to comply with this directive, please contact Jacquie at extension 9218. + +Electronically stored information is an important and irreplaceable source of discovery and/or evidence in this matter. You must take every reasonable step to preserve this information until further notice. Failure to do so could result in severe penalties against the USAO-SDFLA and you. Intentional destruction or deletion of any document or data relevant to the lawsuit will not be tolerated by the USAO-SDFLA and could expose you to criminal sanctions. + +I will contact those of you with more detailed information on the claims to ensure that I have the names of all relevant individuals for the Litigation Hold. In addition, in accordance with DOJ guidelines, you will be contacted in the future for an update on your preservation efforts and to answer any questions you may have. In the interim, if this correspondence is unclear, please contact me at extension 9290, for any assistance you may require. + +In accordance with Department of Justice guidelines, please sign and date a copy of this letter in the space provided below as an acknowledgment that you have received, read, + +Re: Jane Does #1 and #21. United States Case No.: 9:08-cv-80736-KAM November 2, 2010 Page -4- + +## Privileged Communication + +and agree to comply with the preservation instructions contained in this letter. Please also complete, date and shot the attached form (Note — for your convenience. I have made sure that you can type in the date and click in any relevant boxes). I request that you return to me the originals containing your signatures by November 9, 2010. If you wish, you can also send to me scanned copies of your letters. + +Should you have any questions, please feel free contact me. + +Regards. + +JAW/attachments + +CC: ft • II t. + +WIFREDO A. FERRER UNITED STATES ATTORNEY + +By: + +![](_page_3_Picture_7.jpeg) + +## Acknowledgment of Receipt of Litigation Hold Letter: + +I acknowledge that I have received and read the Litigation Hold letter dated November 2. 2010 regarding Jane Does #1 and #2I United States. Case No.: 08-80736-CIV-MARRA/Johnson and 1 have taken and agree to continue to take all reasonable steps necessary to preserve the documents and data as instructed in the letter and Form appended thereto. + +Dated: the day of November. 2010 + +Signature + +Printed Name of Signatory \ No newline at end of file diff --git a/marker2/ds9/EFTA00206919/EFTA00206919.metadata.json b/marker2/ds9/EFTA00206919/EFTA00206919.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..0c6bc925b89fabd86a89c12a5b25bb51537e9bac --- /dev/null +++ b/marker2/ds9/EFTA00206919/EFTA00206919.metadata.json @@ -0,0 +1,229 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206919.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 4, + "chars": 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+Importance: Normal + +--- + +**This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended.** + +**\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\*** Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +**Notice of Electronic Filing** + +The following transaction was entered by Ackerman, Joseph on 11/1/2010 at 8:47 PM EDT and filed on 11/1/2010 + +Case Name: Doe ¶ Epstein + +Case Number: [9:08-cv-80893-KAM](#) + +Filer: Jeffrey Epstein + +WARNING: CASE CLOSED on 07/20/2010 + +Document Number: [223](#) + +**Docket Text:** + +**RESPONSE/REPLY to [222] Order, [214] Defendant's MOTION for Protective Order and Objection to Disclosure of Certain Documents with Integrated Memorandum of Law MOTION for Leave to File, [217] Response to Motion, Reply to Edwards' Response to Epstein's Motion for Protective Order by Jeffrey Epstein. (Ackerman, Joseph)** + +9:08-cv-80893-KAM Notice has been electronically mailed to: + +[REDACTED], [REDACTED] + +Bradley James Edwards [REDACTED], [REDACTED] + +Jack Alan Goldberger [REDACTED], [REDACTED] + +Katherine Warthen Ezell [REDACTED], [REDACTED] + +Lilly [REDACTED], [REDACTED] + +9:08-cv-80893-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1 + +The following document(s) are associated with this transaction: + +# Document description:Main Document + +Original filename:n/a + +#### Electronic document Stamp: + +[STAMP dcecfStamp\_ID=1105629215 [Date=11/1/2010] [FileNumber=8157162-0 ] [32040f4f31801fed8fc0afb4addfc40edfc2529305ccf2e2949d59aee3341e7ad6d 014917blb5b5422c290ea9d09478bd4fd15fDef6b123aa70fcd21c53845b3]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00206923/EFTA00206923.metadata.json b/marker2/ds9/EFTA00206923/EFTA00206923.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..bacc118597574872c0024e24441b422d0dab93b7 --- /dev/null +++ b/marker2/ds9/EFTA00206923/EFTA00206923.metadata.json @@ -0,0 +1,185 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206923.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2372, + "elapsed_seconds": 7.71, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 309.42 + ], + [ + 181.76399999999998, + 309.42 + ], + [ + 181.76399999999998, + 323.19 + ], + [ + 30.6, + 323.19 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 452.79 + ], + [ + 99.756, + 452.79 + ], + [ + 99.756, + 464.93999999999994 + ], + [ + 30.6, + 464.93999999999994 + ] + ] + }, + { + "title": "Document description:Main Document", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 31.212, + 117.44999999999999 + ], + [ + 231.72769165039062, + 117.44999999999999 + ], + [ + 231.72769165039062, + 132.603515625 + ], + [ + 31.212, + 132.603515625 + ] + ] + }, + { + "title": "Electronic document Stamp:", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 31.212, + 144.99 + ], + [ + 183.31948852539062, + 144.99 + ], + [ + 183.31948852539062, + 159.3170166015625 + ], + [ + 31.212, + 159.3170166015625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 70 + ], + [ + "Text", + 44 + ], + [ + "Line", + 35 + ], + [ + "SectionHeader", + 6 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 22 + ], + [ + "Line", + 11 + ], + [ + "Text", + 5 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206923" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206925/EFTA00206925.md b/marker2/ds9/EFTA00206925/EFTA00206925.md new file mode 100644 index 0000000000000000000000000000000000000000..6d48a14808815f6a0e85a92363abc35cd5e2db28 --- /dev/null +++ b/marker2/ds9/EFTA00206925/EFTA00206925.md @@ -0,0 +1,66 @@ +To: + +Cc: + +subject: Re: Jane Does I U.S. (re Jeffrey Epstein) - Litigation Hold - Additional + +Date: Thu, 04 Nov 2010 14:19:29 +0000 + +Importance: Normal + +P.s. I think you have to take your start date back much further -- 2005 or 2006. + +From: + +Sent: Tuesda November 02 2010 06:01 PM + +To: + +Cc: Subject: RE: Jane Does U.S. (re Jeffrey Epstein) - Litigation Hold - Additional + +Good Afternoon: + +In furtherance of the Lit Hold materials I sent to you, please know that I have to inform the National Preservation Officer at EOUSA in Washington as well as (here in the S.D. Fla) of the Lit Hold and inform them of key names. + +To that end, I gathered from the unsealed Court filings the names set forth below. Please let me know if there are any other names that should be identified. Please let me knos. first name. + +I will also need the names of the victims that would be Jane Doe # 1 and Jane Doe #2 for preservation purposes. This information will be kept confidential. If the USAO-SDFLA Lit Hold efforts are ever the subject of discovery, we can redact the victim names...as was done in the letters filed with AUSA Villafafia's first declaration. + +Also, I will need your assistance in preparing letters to the FBI and Palm Beach P.D. to urge them to place a Hold on any documents that they may have....unless you advise that a hold is already in place. + +Finally, please let me know if the Lit Hold Time Frame I suggested is correct, or if it should commence with an earlier date. + +- (Jane Doe Petitioner in Civil action ???) +- (Jane Doe Petitioner in Civil action ???) +- (Jane Doe Petitioner in Civil action ???) +- Bradley J. Edwards, Esq, Counsel for +- Paul G. Cassell, Counsel +- Jay C. Howell, Counsel for 99 + +- James Eisenberg, Esq., Original counsel foa 9999 +- Jeffrey Epstein, Defendant in state criminal action and party to USAO-SDFLA Non-Prosecution Agreement +- Lilly Ann Sanchez, Counsel For Epstein +- Jack Goldberger, Counsel for Epstein +- Assistant United States Attorney +- Special Agent, F.B.I. +- Special Agent F.B.I. +- 1M, Assistant United States Attorney +- Federal Bureau of Investigation ("FBI") +- Ile FBI Victim Specialist +- Palm Beach Florida Police Department + +From: Sent: Tuesday, November 02, 2010 5:48 PM To: Cc: Subj : ane oes re e rey Importance: High + +« File: Re.Jeffrey Epstein.Jane Does I U.S. - 11.2.2010 JAW Lit Hold Ltr to Individual in USAO.SD.Fla.pdf » « File: Re.Jeffrey Epstein.Jane Does I U.S. - Typable 3-13.300.003 Attachment.l.pdf » + +As a follow-up to your recent meeting concerning the above-referenced case, I write this letter in my capacity as the Electronic Discovery Coordinator within the Civil Division of the United States Attorney's Office for the Southern District of Florida (USAO-SDFLA) to advise you of the USAO-SDFLA's legal obligation to preserve documents and data relevant to the lawsuit and to enlist your assistance in this regard. + +I request that you please read and acknowledge your receipt and agreement to the terms of this letter. I also ask that you please complete and sign the form accompanying this letter. Please return the originals of both documents to me by November 9, 2010. + +Should you have any questions, please let me know. + +Assistant United States Attorney + +Office of the United States Attorney + +![](_page_2_Picture_2.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00206925/EFTA00206925.metadata.json b/marker2/ds9/EFTA00206925/EFTA00206925.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1fd5b3c21ba5574ac64fa9b4d8a250da0cbbe167 --- /dev/null +++ b/marker2/ds9/EFTA00206925/EFTA00206925.metadata.json @@ -0,0 +1,124 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206925.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 3291, + "elapsed_seconds": 1.45, + "image_assets": [ + "_page_2_Picture_2.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 70 + ], + [ + "Line", + 33 + ], + [ + "Text", + 17 + ], + [ + "ListItem", + 6 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 72 + ], + [ + "Line", + 32 + ], + [ + "ListItem", + 11 + ], + [ + "Text", + 8 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Picture", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206925" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206925/_page_2_Picture_2.jpeg b/marker2/ds9/EFTA00206925/_page_2_Picture_2.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..fe77fa0ebdf1adbf591a378f69c54f6a7adc441f --- /dev/null +++ b/marker2/ds9/EFTA00206925/_page_2_Picture_2.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:d951829a01d2dd7410aa24462a6df7c209acaca116087a9a9065399c410224be +size 4647 diff --git a/marker2/ds9/EFTA00206928/EFTA00206928.md b/marker2/ds9/EFTA00206928/EFTA00206928.md new file mode 100644 index 0000000000000000000000000000000000000000..323193da82eb1b029259805dc69ccdb760a7ac41 --- /dev/null +++ b/marker2/ds9/EFTA00206928/EFTA00206928.md @@ -0,0 +1,50 @@ +To: ' (USAFLS)" < >, Brad Edwards <1 + +Cc: ' (USAFLS)" + +Subject: RE: Revised Joint Statement of Facts + +Date: Wed, 24 Nov 2010 17:27:51 +0000 + +Importance: Normal + +Dear + +Thanks for giving us a proposed statement of facts from the Government. It immediately raises many question for us, including: + +- 1. We notice that you have objected to a number of our facts that are based -- word-for-word -- on e-mails prepared by the Government. You mention that you would like tosee these e-mails. has a full copy of what we were sent by Epstein's counsel. And, of course, these are all the Government e-mails to begin with. +- 2. Given that you have copies all of these emails, can you agree to all the facts reflected by the e-mails? We really don't understand the basis for your objection to our facts quoting THE GOVERNMENT'S e-mails? Is there really some dispute about these facts? +- 3. As you and know, the emails in our possession were, improperly, redacted by Epstein's attronehys to include only the government's half of the conversation. Will you provide us with the other half of these converations? +- 4. Our previous e-mail to you, we requested a copy of various documents in your possession, including (for example) the reports of interviews of our clients. Your responsive e-mail did not reply to that question at all. Will you provide a copy of these materials? +- 5. Our previous message to you -- indeed, our messages dating back to October -- requested that you provide an outline of what you believe is the proper procedure for resolving our client's claims. In your view, do we need to file a new civil complaint? Can we file in the nature of our summary judgment motion in our existing case -- the procedure I have followed in our courts around the country? You have not responded -- just we needed to take two years to get you to respond regarding your statement of facts. (We understood, as you recounted in your previous e-mail, that in about August 2008 you reversed your position on working with us to draft a statement of facts and have, for the last two years (until October 2010) taken the view that you would not work with us to get a statement of facts put together.) What is your position on the appropriate procedural device? +- 6. It appears that we are going to have a number of things to hammer out. We would like to set up a conference call to work through some of the points of disagreement. Good days for us are Nov. 30, Dec. 1, and Dec. 2 -- what times those dahys are good for you (and =?) to discuss. + +We look forward to discussing all these issues with you soon. Paul Cassell, Co-Counsel for Jane Doe, + +Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law Quinney College of Law at the University of Utah 332 S. 1400 E. , Room 101 Salt Lake City, UT 84112.0730 (801) 585-5202 (phone) (801) 581-6897 (fax) + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidenital. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the sender by reply electronic mail and delete the original message. Thank you. + +To: Paul Cassell; Brad Edwards + +Cc: . (USAFLS) + +Subject: Revised Joint Statement of Facts + +Paul and Brad, + +Attached please find a revised Joint Statement of Facts, which indicates what the government agrees is factually correct and relevant to the resolution of this case. I switched the first two paragraphs, to indicate that the FBI was investigating Epstein for various offenses. + +We deleted the reference to Epstein "committing" the offenses because he was neither convicted or charged, with any violation of federal law. Even when the DOJ publicly announces an indictment being returned, we note that the accused enjoys the presumption of innocence. + +We are also checking the hearing transcript to determine whether what you claim was said by the government is accurate. + +There are a number of inaccuracies in your November 21, 2010 e-mail that I need to address. You claim that "more than two years since we proposed a set of facts to you ... all without any answers." Paragraph 1. This is not correct. After Brad provided the proposed statement of facts on July 17 and 21, 2008, I sent him a letter on July 25, 2008, explaining that the government believed 18 U.S.C. 3771(a) (5) was not triggered until an offense was charged in United States District Court. We also stated that, in the government's view, the relevant facts were: (1) there are no charges in district court filed against Jeffrey Epstein; and (2) Epstein entered pleas of guilty in Florida State Court on June 30, 2008, was sentenced, and is now imprisoned in Palm Beach County. On July 29, 2008, the government filed a Notice to Court Regarding Absence of Need for Evidentiary Hearing, explaining the government's position that only two relevant facts were necessary to decide whether the government had any obligation under 18 U.S.C. 3771(a)(5). I think this constitutes an answer to the proposed statement of facts offered by the petitioners in July 2008. + +You claim that most of your proposed facts are based upon e-mails written by the U.S. Attorney's Office e-mails. Rather than include dueling reasonable interpretations in a Statement of Facts, perhaps you can show us the e-mails and we can agree that they are authentic. Each party can argue what is a reasonable interpretation/inference in their respective legal memoranda. + +The government was prepared to meet with you as early as November 16, 2010, after returned from her annual leave on November 13, and I returned from Columbia, South Carolina, on November 12. However, you wanted to have an agreed statement of facts before having a meeting with the Executive Division, so the meeting was postponed. + +Your e-mail states that you and Brad are available between December 9 and 17. I will schedule a meeting here in Miami during that period. Thank you. + +«viam\_Proposed Joint Statement of Facts.docx» \ No newline at end of file diff --git a/marker2/ds9/EFTA00206928/EFTA00206928.metadata.json b/marker2/ds9/EFTA00206928/EFTA00206928.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d4e2b40d9ae352d490b0ba0945c3ba88cb715ce1 --- /dev/null +++ b/marker2/ds9/EFTA00206928/EFTA00206928.metadata.json @@ -0,0 +1,92 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206928.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 6160, + "elapsed_seconds": 1.05, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 85 + ], + [ + "Line", + 43 + ], + [ + "Text", + 11 + ], + [ + "ListItem", + 6 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 61 + ], + [ + "Line", + 31 + ], + [ + "Text", + 14 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206928" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206930/EFTA00206930.md b/marker2/ds9/EFTA00206930/EFTA00206930.md new file mode 100644 index 0000000000000000000000000000000000000000..d638f71e08bf405ec36830a7ba660c95a5d5c265 --- /dev/null +++ b/marker2/ds9/EFTA00206930/EFTA00206930.md @@ -0,0 +1,17 @@ +Subject: RE: Emails in possession of Cassell and Edwards + +Date: Thu, 28 Oct 2010 21:42:46 +0000 + +Importance: Normal + +Thanks =. Would you mind sending them to If I were smarter I'd create one of those folders in my e-mail directory so they don't take up room b Cyndee knows how to do it. Thanks. + +Nummummumminiar + +Sent: Thursday, October 28, 2010 4:03 PM + +); Lee, Dexter (USAFLS) + +Subject: Emails in possession of Cassell and Edwards + +Ben and Dexter — You had asked earlier about the emails that Cassell and Edwards have. Before Epstein's attorneys produced them to Cassell and Edwards, they gave some items to me for review. I don't know if it is the complete production, but I still have those items electronically. They are very large. Do you want me to send them to one of your assistants to avoid clogging your email boxes? It is several emails with large pdfs attached. \ No newline at end of file diff --git a/marker2/ds9/EFTA00206930/EFTA00206930.metadata.json b/marker2/ds9/EFTA00206930/EFTA00206930.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..71550edc4b6832bd9f0e5e90f2e09625904fa1b2 --- /dev/null +++ b/marker2/ds9/EFTA00206930/EFTA00206930.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206930.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 874, + "elapsed_seconds": 0.49, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 31 + ], + [ + "Line", + 15 + ], + [ + "Text", + 9 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206930" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206931/EFTA00206931.md b/marker2/ds9/EFTA00206931/EFTA00206931.md new file mode 100644 index 0000000000000000000000000000000000000000..7a2948175be46a5fb0737bdda4adb43e96486a91 --- /dev/null +++ b/marker2/ds9/EFTA00206931/EFTA00206931.md @@ -0,0 +1,11 @@ +Subject: Emails in possession of Cassell and Edwards + +Date: Thu, 28 Oct 2010 20:03:21 +0000 + +Importance: Normal + +You had asked earlier about the emails that Cassell and Edwards have. Before Epstein's attorneys pr uced them to Cassell and Edwards, they gave some items to me for review. I don't know if it is the complete production, but I still have those items electronically. They are very large. Do you want me to send them to one of your assistants to avoid clogging your email boxes? It is several emails with large pdfs attached. + +ite 400 + +01 \ No newline at end of file diff --git a/marker2/ds9/EFTA00206931/EFTA00206931.metadata.json b/marker2/ds9/EFTA00206931/EFTA00206931.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..38ccfbde232435c7bf2d723defe19263eca9ab17 --- /dev/null +++ b/marker2/ds9/EFTA00206931/EFTA00206931.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206931.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 548, + "elapsed_seconds": 0.4, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 21 + ], + [ + "Line", + 11 + ], + [ + "Text", + 6 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206931" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206932/EFTA00206932.md b/marker2/ds9/EFTA00206932/EFTA00206932.md new file mode 100644 index 0000000000000000000000000000000000000000..e58aab0c9e7ebf91bb272777464e453b35f1475a --- /dev/null +++ b/marker2/ds9/EFTA00206932/EFTA00206932.md @@ -0,0 +1,21 @@ +**To:** "[REDACTED]" + +**Subject:** I sent a total of 8 emails + +**Date:** Fri, 29 Oct 2010 00:43:43 +0000 + +**Importance:** Normal + +--- + +Hi [REDACTED] – These are the emails re Epstein. Some of those 8 email contain multiple emails within. Please let me know if you have any trouble opening any of them. + +Do you still have the big correspondence notebooks in case [REDACTED] or Willy need them? + +Thanks! + +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] \ No newline at end of file diff --git a/marker2/ds9/EFTA00206932/EFTA00206932.metadata.json b/marker2/ds9/EFTA00206932/EFTA00206932.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..5852854f8708ad5249145ac5ee292970eee95103 --- /dev/null +++ b/marker2/ds9/EFTA00206932/EFTA00206932.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206932.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 465, + "elapsed_seconds": 2.56, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 19 + ], + [ + "Text", + 18 + ], + [ + "Line", + 10 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206932" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206933/EFTA00206933.md b/marker2/ds9/EFTA00206933/EFTA00206933.md new file mode 100644 index 0000000000000000000000000000000000000000..077bd5bf09ecd131837ed3e4da59f8a457e19507 --- /dev/null +++ b/marker2/ds9/EFTA00206933/EFTA00206933.md @@ -0,0 +1,23 @@ +![](_page_0_Picture_34.jpeg) + +**Subject:** RE: Epstein -- FYI + +**Date:** Thu, 28 Oct 2010 21:43:29 +0000 + +**Importance:** Normal + +--- + +Got it. Thanks. + +![](_page_0_Picture_39.jpeg) + +**Sent:** Thursday, October 28, 2010 3:45 PM + +![](_page_0_Picture_41.jpeg) + +**Subject:** Epstein -- FYI + +[REDACTED] – I am sure that you know this, but the person with the most historical knowledge of Epstein who is still in Miami is [REDACTED]. He came in at the end and was another person tasked to do an “independent review” of my work product. + +![](_page_0_Picture_44.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00206933/EFTA00206933.metadata.json b/marker2/ds9/EFTA00206933/EFTA00206933.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..575acc42ca82a25327594a03c62f132bc6db63a1 --- /dev/null +++ b/marker2/ds9/EFTA00206933/EFTA00206933.metadata.json @@ -0,0 +1,63 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206933.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 559, + "elapsed_seconds": 2.53, + "image_assets": [ + "_page_0_Picture_34.jpeg", + "_page_0_Picture_39.jpeg", + "_page_0_Picture_41.jpeg", + "_page_0_Picture_44.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 17 + ], + [ + "Text", + 15 + ], + [ + "Line", + 8 + ], + [ + "Picture", + 4 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206933" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206933/_page_0_Picture_34.jpeg b/marker2/ds9/EFTA00206933/_page_0_Picture_34.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..e580a958fd021767e3b41f9ca5ec3dd345a6480d --- /dev/null +++ b/marker2/ds9/EFTA00206933/_page_0_Picture_34.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:1c5a3c04f1efe11d419146544f629bdcf508c9a2aa05ca365549a4a48115a10f +size 6369 diff --git a/marker2/ds9/EFTA00206933/_page_0_Picture_39.jpeg b/marker2/ds9/EFTA00206933/_page_0_Picture_39.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..ec60de25577a91114c9fb24f28225a97fa1a1d74 --- /dev/null +++ b/marker2/ds9/EFTA00206933/_page_0_Picture_39.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:651341d98bcd4ecaa57ef754cb694c488949cfb11ffd7b0dc05f1841f434f59b +size 3285 diff --git a/marker2/ds9/EFTA00206933/_page_0_Picture_41.jpeg b/marker2/ds9/EFTA00206933/_page_0_Picture_41.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..be87904540d3578e74871a545b37e8016fb6f2a2 --- /dev/null +++ b/marker2/ds9/EFTA00206933/_page_0_Picture_41.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:4d4d3ff407a2563490a65dd692f5e1598cb33a97cb068dac65a6a9b42f0fb8ec +size 2228 diff --git a/marker2/ds9/EFTA00206933/_page_0_Picture_44.jpeg b/marker2/ds9/EFTA00206933/_page_0_Picture_44.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..46f569a691bf0ea6d504104868091e4936135e1a --- /dev/null +++ b/marker2/ds9/EFTA00206933/_page_0_Picture_44.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:e4ccb7771327536baca1c0395997cbe6a0f95adf518d8878a0e0e4f6bb0702a8 +size 6720 diff --git a/marker2/ds9/EFTA00206934/EFTA00206934.md b/marker2/ds9/EFTA00206934/EFTA00206934.md new file mode 100644 index 0000000000000000000000000000000000000000..819a6232583290cfa7b064c3fe6dc5f90b04c99f --- /dev/null +++ b/marker2/ds9/EFTA00206934/EFTA00206934.md @@ -0,0 +1,29 @@ +![](_page_0_Picture_49.jpeg) + +**Subject:** Re: I sent a total of 8 emails + +**Date:** Fri, 29 Oct 2010 01:41:33 +0000 + +**Importance:** Normal + +--- + +Yes we have two sets. I will get on these asap. G'nite + +![](_page_0_Picture_54.jpeg) + +**Sent:** Thursday, October 28, 2010 08:43 PM + +![](_page_0_Picture_56.jpeg) + +**Subject:** I sent a total of 8 emails + +![](_page_0_Picture_58.jpeg) + +These are the emails re Epstein. Some of those 8 email contain multiple emails within. Please let me know if you have any trouble opening any of them. + +Do you still have the big correspondence notebooks in case Ben or Willy need them? + +Thanks! + +![](_page_0_Picture_62.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00206934/EFTA00206934.metadata.json b/marker2/ds9/EFTA00206934/EFTA00206934.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f341dcf735a1abdd154aee2c6859d6527a03b1cb --- /dev/null +++ b/marker2/ds9/EFTA00206934/EFTA00206934.metadata.json @@ -0,0 +1,64 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206934.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 654, + "elapsed_seconds": 2.85, + "image_assets": [ + "_page_0_Picture_49.jpeg", + "_page_0_Picture_54.jpeg", + "_page_0_Picture_56.jpeg", + "_page_0_Picture_58.jpeg", + "_page_0_Picture_62.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 26 + ], + [ + "Text", + 19 + ], + [ + "Line", + 12 + ], + [ + "Picture", + 5 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206934" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206934/_page_0_Picture_49.jpeg b/marker2/ds9/EFTA00206934/_page_0_Picture_49.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..edfc43629b25ead73931a7eb2ddd0eebec71c78c --- /dev/null +++ b/marker2/ds9/EFTA00206934/_page_0_Picture_49.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:f5ec939982f91b1437e10e426c21beee844da0fb40985bf12fc0301db0ad9faa +size 5221 diff --git a/marker2/ds9/EFTA00206934/_page_0_Picture_54.jpeg b/marker2/ds9/EFTA00206934/_page_0_Picture_54.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..e988d8f4c7b93b38c581bbc0701e83c0bedb7a33 --- /dev/null +++ b/marker2/ds9/EFTA00206934/_page_0_Picture_54.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:d964d8f3c8dfb293546ccd3cbe4ef7796f256a2a479e5d20007911c03dabd204 +size 2366 diff --git a/marker2/ds9/EFTA00206934/_page_0_Picture_56.jpeg b/marker2/ds9/EFTA00206934/_page_0_Picture_56.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..c155441eae5c728e0fc374b6a13b8ba292bb9542 --- /dev/null +++ b/marker2/ds9/EFTA00206934/_page_0_Picture_56.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:bc7fcb10d8b87fedce589651aa3d7713c933c915244b27afd4c4f044b00a5e3e +size 2392 diff --git a/marker2/ds9/EFTA00206934/_page_0_Picture_58.jpeg b/marker2/ds9/EFTA00206934/_page_0_Picture_58.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..3b09e27fabdeeda3400c96249f0a492a96501a87 --- /dev/null +++ b/marker2/ds9/EFTA00206934/_page_0_Picture_58.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:84ac98eb61419e1c49e751dac7eb95c863d7a0e584d3d864ad0b983bea1ac5d2 +size 1339 diff --git a/marker2/ds9/EFTA00206934/_page_0_Picture_62.jpeg b/marker2/ds9/EFTA00206934/_page_0_Picture_62.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..808f4188692615b6a02ae81a39c3402fcd55e390 --- /dev/null +++ b/marker2/ds9/EFTA00206934/_page_0_Picture_62.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:14947c346109c9c5822a26a6446f21e13083576ab5aadf8ce678fc0910fb1410 +size 6883 diff --git a/marker2/ds9/EFTA00206935/EFTA00206935.md b/marker2/ds9/EFTA00206935/EFTA00206935.md new file mode 100644 index 0000000000000000000000000000000000000000..6a9b421c6695cfc00b9044e54298d842d25f82aa --- /dev/null +++ b/marker2/ds9/EFTA00206935/EFTA00206935.md @@ -0,0 +1,66 @@ +USAO System - Microsoft Outlook: usao system - evoip: + +# USER LITIGATION HOLD NOTICE AND CERTIFICATION FORM + +#### PRIVACY ACT PROTECTED + +### I. NOTICE + +Please be advised that, by and through this Notice, we, the United States Attorney's Office for the Southern District of Florida ("USAO"), have instituted a "Litigation Hold" in connection with the claims set forth in lone Does nand #21 United States, Case No.: 08.80736-CIV-MARRA/Johnson regarding alleged violation of the petitioners' rights under the Crime Victim's Rights Act ("CVRA"). + +To institute this Litigation Hold, we are implementing preservation procedures regarding any and all records, data, or other information, whether they exist in paper form or as electronically stored information ("ESI"), within the USAO's possession, custody or control relating to the Complaint/Claims (collectively, "Information"). The USAO's obligation to preserve this Information pertains not only to paper copies, or "hard copies" (whether in draft or final, partial or complete, versions), but also to ESI in its originally-created, or "native" format, as it exists on any computer system (whether it be on the USAO's system or your personal computer), as well as removable or portable electronic storage media. Specific examples of Information subject to this Litigation Hold include, but are not limited to, e-mails and other electronic communications, word processing documents, records, spreadsheets, databases, calendars, telephone logs, internet usage files, network access information, and information on other kinds of media, including PDAs (such as Palm Pilots, BlackBerries, and cell phones), thumb drives, CDs, as well as digital voicemail and text messages. + +Because the USAO must take reasonable steps to preserve such Information in whatever form it has been created and maintained, the USAO's Lit Hold Coordinator and Systems Manager must coordinate with all those who may have such Information. We therefore require your assistance to both identify and preserve any and all Information relating to the Complaint/Claims, whether or not the Information is ultimately discoverable. Furthermore, we must confirm that you understand and accept your preservation obligations under this Litigation Hold. + +Accordingly, you are required to take the two following steps: (1) Identify to us all such Information and where it resides (in Section II below); and (2) Certify having received notice of this litigation Hold and understanding and accepting your preservation obligations under this Litigation Hold (in Section Ill below). [NOTE: While seeking to identify all such Information, please refrain to the maximum extent possible from opening emails/files you believe to be relevant.( + +## II. IDENTIFY ALL INFORMATION SUBJECT TO THE LITIGATION HOLD + +Please identify all locations where the Information described above may exist. CHECK ALL THAT APPLY + +Hord Copy Documents: X Printed Emails )4 Case Fiks/Logs O Calendars/Appointment Books 'Other + +X Email messages isi Calendar Items ,k, Tasks O Telephone Data + +O Notes s ti—Pcrbtle-Polders— \*Contacts '.PST Files ("Archive") O Office Communicator + +(continued on next page) + +(continued from previous page) + +WAD System — Network Doto documents/files and folders residing an network drives(: + +,Personal (N, H & M) Drive Document/Files/Folders AShared Files/Folders LIONs/AlcatrazNSA-5 + +0 Inter- and Intra-net 0 Other + +WAO System — Mobile PINISMS: USAO System — Clossified/Soeciol Doto: + +)R(Blackberry/Other 0 Document/Files/Folders/Other + +Non-Network Data documents/files and folders residing on local hard drives and thumb drives): + +Local (C & D) Drives X Portable Medla/Thumb Drives 0 Deleted Items (Recycle Bin) + +Personal Non-Network Data (located or residing somewhere other than the t/5.4OSystemt + +0 Document/Files/Folders 0 Internet A Email Messages 0 Portable Media/Thumb Drives + +0 PDAs/Other + +## III. CERTIFICATION + +By this Notice and Certification, I acknowledge that I have received, understand, and accept my obligations to preserve any and all Information (as defined above) I may have now, as well as all such Information I may subsequently receive, create or modify. I further understand and accept that my continuing Litigation Hold obligations require that I preserve all such Information in "native" format and, conversely, that I not delete or destroy any such Information until I receive formal written notice that this Litigation Hold is discontinued. To fulfill these continuing obligations, I will undertake the necessary steps to preserve this Information, be it "hard copy" and/or ESI, in coordination with the USAO's Lit Hold Coordinator and Systems Manager. + +••• + +Please be advised that failure to preserve and retain this Information may result in sanctions and/or implicate professional conduct rules. Consequently, if you are unsure whether certain information should be preserved, err on the side of caution and preserve the information until you have spoken to the USAO's Lit Hold Coordinator about it. If you have any questions about whether to preserve certain ESI, or its native formatting, please contact the USAO's Lit Hold Coordinator or Systems Manager. + +Please sign below to acknowledge you have read this Notice and Certification and understand and accept your preservation obligations, then return the executed copy to the USAO's Lit Hold Coordinator. Thank you. + +| U |

[Redacted]

| | +|-----|-------------------------------------------------------------------------------------------------------------------------------|--| +| D |

[Redacted]

| | +| cc: |

USAO Lit Hold Coordinator
National Preservation Officer
USAO Systems Manager

| | + +INFORMATION CONTAINED IN THIS FORM MAY CONSTITUTE PRIVATE, CONFIDENTIAL AND/OR SENSITIVE, AS WELL AS PERHAPS ALSO PRIVILEGED AND/OR OTHERWISE PROTECTED, INFORMATION \ No newline at end of file diff --git a/marker2/ds9/EFTA00206935/EFTA00206935.metadata.json b/marker2/ds9/EFTA00206935/EFTA00206935.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f8ccf5ef89fe746585d9de6ce8f468bc190a0dde --- /dev/null +++ b/marker2/ds9/EFTA00206935/EFTA00206935.metadata.json @@ -0,0 +1,220 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206935.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 6129, + "elapsed_seconds": 1.79, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "USER LITIGATION HOLD NOTICE AND CERTIFICATION FORM", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 140.14800000000002, + 82.62 + ], + [ + 476.7920837402344, + 82.62 + ], + [ + 476.7920837402344, + 97.55859375 + ], + [ + 140.14800000000002, + 97.55859375 + ] + ] + }, + { + "title": "PRIVACY ACT PROTECTED", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 244.188, + 110.97 + ], + [ + 371.7740783691406, + 110.97 + ], + [ + 371.7740783691406, + 123.59613037109375 + ], + [ + 244.188, + 123.59613037109375 + ] + ] + }, + { + "title": "I. NOTICE", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 61.81200000000001, + 136.07999999999998 + ], + [ + 117.11160278320312, + 136.07999999999998 + ], + [ + 117.11160278320312, + 149.09613037109375 + ], + [ + 61.81200000000001, + 149.09613037109375 + ] + ] + }, + { + "title": "II. IDENTIFY ALL INFORMATION SUBJECT TO THE LITIGATION HOLD", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 67.932, + 483.57 + ], + [ + 372.8791809082031, + 483.57 + ], + [ + 372.8791809082031, + 497.09613037109375 + ], + [ + 67.932, + 497.09613037109375 + ] + ] + }, + { + "title": "III. 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Ferrer, United States Attorney + +Re: Grouphous First Assistant U.S. Attorney + +Wifredo A. Ferrer, United States Attorney + +[Redacted text block] + +Office of the United States Attorney +Southern District of Florida +99 NE 4th Street +Miami, Florida 33132 + +Re: **Litigation Hold re:** + +**Jane Does #1 and #2** United States, Case No.: 08-80736-CIV- +MARRA/Johnson AND Jeffrey Epstein + +As a follow-up to your recent meeting concerning the above-referenced case, I write this letter in my capacity as the Electronic Discovery Coordinator within the Civil Division of the United States Attorney's Office for the Southern District of Florida (USAO-SDFLA). I write to advise you of the USAO-SDFLA's legal obligation to preserve documents and data relevant to the lawsuit and to enlist your assistance in this regard. + +The USAO-SDFLA is required by law to take all reasonable steps to preserve all documents and data relating to the claims set forth in the Victim's Emergency Petition for Enforcement of Crime Victim's Rights Act, 18 USC Section 3771 (DE 1) ("Victim's Petition") in Case No.: 9:08-cv-80736-Marra/Johnson in the Southern District of Florida, filed on July 7, 2008. Based upon the facts set forth in the Court filings that are unsealed, I recommend that the Federal Bureau of Investigation (F.B.I.) and the Palm Beach Police Department also be requested to preserve any documents that they may have that are relevant to the Claims asserted in the above-referenced lawsuit. + +I request that you please read and acknowledge your receipt and agreement to the terms of this letter. I also ask that you please complete and sign the form accompanying this letter. Please return the originals of both documents to me by November 9, 2010. + +With respect to the claims asserted in the litigation, in the Victim's Petition (DE 1), Jane Doe # 1 brought claims against the United States for alleged violation of her rights under the Crime Victim's Rights Act ("CVRA"). The Jane Doe #1 petitioner alleges that she was the victim of federal crimes committed by Jeffrey Epstein, including sex trafficking of children by fraud in violation of 18 USC § 1591, use of interstate commerce to entice a minor to commit + +prostitution in violation of 18 USC § 2422 and wire fraud in violation of 18 USC § 1343. DE 1 at ¶1. The Victim's Petition further alleges that in violation of the CVRA, Jane Doe #1 was not consulted with respect to the USAO-SDFLA's negotiations with Epstein (DE 1 at ¶¶3-6). The "Jane Doe #1 and Jane Doe # 2 Status Report and Response to Court's Order to Show Lack of Prosecution" (DE 41) argues that "there [was] an orchestrated decision [between the "U.S. Attorney's Office and Epstein] to deny the [Jane Doe Petitioners] their rights." DE 41 at 1. The Status Report alludes to communications between the USAO-SDFLA and counsel for Jeffrey Epstein "that [i]s highly relevant to the treatment of Jane Doe #1 and Jane Doe #2 in the criminal justice system – namely, correspondence between the [USAO-SDFLA] and legal counsel for Jeffrey Epstein during the negotiations surrounding the non-prosecution agreement" and the USAO-SDFLA and counsel for the Jane Does, on numerous matters related to Jeffrey Epstein, including contacts with AUSAs "Marie Villafaña and Dexter Lee." DE 41 at 3. + +The Government's filings frame the issue before the Court as to whether the "Government was obligated, under 18 U.S.C. § 3771(a)(5), to confer with petitioners prior to entering into an agreement with Jeffrey Epstein, which permitted the pending State of Florida prosecution to go forward, so long as Epstein agreed to certain conditions." Government's Notice To Court Regarding Absence of Need for Evidentiary Hearing. DE 17. The Government argues there are two relevant facts which will permit the Court to resolve the legal issue: (1) there are no criminal charges in the United States District Court, Southern District of Florida, filed against Jeffrey Epstein; and (2) Epstein entered pleas of guilty in Florida State Court on June 30, 2008, was sentenced, and is now imprisoned in Palm Beach County. DE 17. The Government's Response to the Victim's Petition ("Government's Response") notes that in 2006, Jeffrey Epstein was charged in the 15th Judicial Circuit Court in and for Palm Beach County, Florida with felony solicitation of prostitution. DE 13 at 1. The Response further notes that Epstein was not charged in the Southern District of Florida. DE 13 at 1-2. The Declaration of A. Marie Villafaña indicates that "in the summer of 2007, Mr. Epstein and the [USAO-SDFLA] entered into negotiations to resolve the investigation. At that time, Mr. Epstein had been charged by the State of Florida with solicitation of prostitution, in violation of Florida Statutes § 796.07." DE 14. The Declaration also details the communications that occurred when a victim was identified, including notification letters that were sent. DE 14. Attached to that Declaration are copies of redacted letters provided to victims "C.W.", "T.M.", and "S.R." by AUSA Villafaña and the FBI's Victim-Witness Specialist Twiller Smith. DE 14. In addition, appended to the Declaration are AUSA Villafaña's letters to the victim's counsel, Bradley J. Edwards, Esq. DE 14. Special Agent Nesbitt Kuyrkendall, F.B.I. is copied on AUSA Villafaña's letters and Special Agent Richards and Kuyrkendall are referenced in certain letters to Mr. Edwards. DE 14. Moreover, Epstein's counsel, Jack Goldberger, Esq. is copied on letters to Mr. Edwards. I also note that the Supplemental Declaration of A. Marie Villafaña (DE 35) notes the existence of a September 2007 Non-Prosecution Agreement, an October 2007 Addendum and a letter dated December 19, 2007 from the U.S. Attorney to Attorney Lilly Ann Sanchez , Counsel to Jeffrey Epstein (DE 35 at ¶3).1 + +1 I assume those involved in the above-referenced litigation, have copies of the relevant court filings, but if you desire any of the unsealed filings, let me know. + +Included in this preservation order are all Documents and data, including electronically stored information ("ESI"), relating to the claims. The Victim's Petition alleges that in July 2008, negotiations were taking place that led to a Non-Prosecution Agreement. However, it appears from AUSA Villafaña's Declaration that during the summer of 2007, negotiations between Epstein and the USAO-SDFLA commenced that led to the September 2007 Non-Prosecution Agreement. It would therefore appear that the logical time frame to preserve evidence is at least May 1, 2007 and/or as early as the commencement of the negotiations leading to the September 2007 Non-Prosecution Agreement and through the present. + +"Documents and data" as used herein means not only paper copies of documents, but electronically stored information ("ESI"), to include email, audio recordings, videotape, instant messages, word processing files, spreadsheets, databases, calendars, telephone logs, contact manager information, Internet usage files, and all other electronically stored information maintained, created, and/or received by the USAO-SDFLA or any of its employees and/or agents. "Sources" include all paper documents, computer hard drives and other electronic storage media (e.g., CDs/DVDs, thumb drives, etc.), laptop computers, PDAs, Blackberry devices, and any other location where paper documents or electronic data is stored. Sources of potentially relevant information may also include personal computers or personal email accounts you use or have access to at home, or anywhere else. Also, relevant electronic data may be located on inaccessible storage media, such as backup tapes, which must be preserved as well, if an identical copy is not found elsewhere. + +In order to comply with its legal obligations, the USAO-SDFLA must immediately preserve all existing documents and data relevant to the claim/investigation described above and suspend deletion, overwriting, or any other possible destruction of unique, potentially relevant information. Effective immediately, all routine destruction efforts under USAO-SDFLA's existing document management and email policies are suspended for all information relevant to the above-referenced lawsuit. + +Guidance on how to preserve relevant documents and data should be directed to Jacquie Varela, IT-Manager at [Jacquie.Varela@usdoj.gov](mailto:Jacquie.Varela@usdoj.gov) on whom I am copying this letter. If you have any questions on how to comply with this directive, please contact Jacquie at extension 9218. + +Electronically stored information is an important and irreplaceable source of discovery and/or evidence in this matter. You must take every reasonable step to preserve this information until further notice. Failure to do so could result in severe penalties against the USAO-SDFLA and you. Intentional destruction or deletion of any document or data relevant to the lawsuit will not be tolerated by the USAO-SDFLA and could expose you to criminal sanctions. + +I will contact those of you with more detailed information on the claims to ensure that I have the names of all relevant individuals for the Litigation Hold. In addition, in accordance with DOJ guidelines, you will be contacted in the future for an update on your preservation efforts and to answer any questions you may have. In the interim, if this correspondence is unclear, please contact me at extension 9290, for any assistance you may require. + +In accordance with Department of Justice guidelines, please sign and date a copy of this letter in the space provided below as an acknowledgment that you have received, read. + +Re: Jane Does #1 and #2 I. United States Case No.: 9:08-cv-80736-KAM November 2, 2010 Page -4- + +## Privileged Communication + +and agree to comply with the preservation instructions contained in this letter. Please also complete, date and sign the attached form (Note — for your convenience. I have made sure that you can type in the date and click in any relevant boxes). I request that you return to me the originals containing your signatures by November 9, 2010. If you wish, you can also send to me scanned copies of your letters. + +Should you have any questions, please feel free contact me. + +Regards, + +JAW/attachments + +cc: + +![](_page_3_Picture_10.jpeg) + +WIFREDO A. FERRER UNITED STATES ATTORNEY + +By: + +![](_page_3_Picture_7.jpeg) + +## Acknowledgment of Receipt of Litigation Hold Letter: + +I acknowledge that I have received and read the Litigation Hold letter dated November 2, 2010 regarding Jane Does #1 and Itli United States, Case No.: 08-80736-CP/-MARRA/Johnson and I have taken and agree to continue to take all reasonable steps necessary to preserve the documents and data as instructed in the letter and Form appended there + +Dated: the KOAday of November, 2010 + +![](_page_3_Picture_14.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00206937/EFTA00206937.metadata.json b/marker2/ds9/EFTA00206937/EFTA00206937.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..2d5538c89dad3135c9f5bfcaee1e6136dfcf8610 --- /dev/null +++ b/marker2/ds9/EFTA00206937/EFTA00206937.metadata.json @@ -0,0 +1,231 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206937.pdf", + "engine": { + 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b/marker2/ds9/EFTA00206941/EFTA00206941.md @@ -0,0 +1,41 @@ +To: Paul Cassell + +Subject: RE: CVRA Case -- Epstein -- Moving Things Along + +Date: Sun, 21 Nov 2010 20:27:00 +0000 + +Importance: Normal + +Dear + +Brad and I are writing to express our serious concern about how things are progressing on this CVRA case. This note is prompted by the fact that it has now been nearly a month since we proposed a new, specific statement of facts to you (a full draft was e-mail to you on October 23) — and, indeed, more than two years since we proposed a set of facts to you ... all without any answers. + +This latest letter is also required by the fact that I hadn't heard from Dexter for some time about how the Government's response to our proposed statement of facts was coming. We had hoped to reach agreement with you on the facts in advance of the October 27 filing date. We were advised, at the last minute, that was not possible. We have continued the last several weeks to try and achieve a statement of facts, all the while being put off. Finally, I called Dexter on the morning on November 15, and Dexter told me that I should have something by the end of that day. But here we are — six days later — no statement of facts ... and, more troubling, not even the courtesy of a call letting Brad and me know what the status is or what the plans are and what caused the delay. (And remember that you were prepared to argue back in October — before Judge Marra peremptorily struck down the argument — that we had somehow delayed too long in moving the case forward!) + +In the mean time, our clients continue to be very eager to move forward with this case and reach a resolution. One of our clients is constantly asking for the status on this case and we have had to tell her that the U.S. Attorney's Office is putting us off and has not given us any roadmap or time table for a resolution. + +In light of all this, Brad and I cannot have this case delayed any further. Accordingly, we are writing to give you notice now that we will be filing our motion for finding of a violation of the CVRA no later than Friday, December 17, 2010. + +Before we are forced to file, we would like to meet with someone there who has the authority to try and reach a resolution — specifically the U.S. Attorney. Brad and I are free between December 9 and December 17. However, as indicated repeatedly before, we do not believe a meeting would be productive if we are still haggling over the details of what happened. Therefore, before we would take the time for a meeting (and I would fly across the country), we need to have the statement of facts nailed down. + +Most of our proposed facts are now supported by hard, documentary evidence — specifically e-mails written by the U.S. Attorney's Office. We continue to ask you to simply stipulate to all those facts. In a few instances, we have proposed our interpretation of the facts. If you disagree, we propose proceeding as follows: "The victims believe the reasonable inference is xxxxx; the Government believes the reasonable inference is yyyyy." + +We are also wondering about the best way to get access to any documents that you are reviewing in connection with preparing the facts. Given the length of time it has taken you to get back to us, we assume that you are reviewing many documents. We would like to see all those documents, and are prepared to enter any appropriate protective order or other agreement that would facilitate this. In particular, we would like to see all documents regarding our three clients any discussion of providing victim notification to them specifically or all victims collectively, and all documents regarding the underlying criminal case against Epstein and the Government's decision to enter into a non-prosecution agreement three years ago. These events took place several years ago. Our understanding is that there + +is no pending criminal case against Epstein — at least with regard to our three clients — so there should be no basis for resisting production of these documents at this time. + +Finally, as you know, back in October, there was the suggestion that we had to file some kind of civil complaint to move our case forward. I have been involved in CVRA litigation around the country, and have not seen that device used before. But — again — it has been more than a month now and we have not heard back from you on our request to be told precisely what procedures you think should be put in place to resolve our dispute. + +This case has been pending for far too long. Brad and I believe an expeditious resolution would be best for all concerned. We would like to work with you to achieve this. But if we have to go it alone, our obligation to zealously represent our clients requires us to do no less. + +Thank you for your prompt attention to these issues. + +Sincerely, + +/s/ Paul Cassell + +Brad Edwards + +Civil Justice Attorney + +an, P.L. to 2 \ No newline at end of file diff --git a/marker2/ds9/EFTA00206941/EFTA00206941.metadata.json b/marker2/ds9/EFTA00206941/EFTA00206941.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..dc808e8f5d8f4616a224dd7549ec997e60dc48e5 --- /dev/null +++ b/marker2/ds9/EFTA00206941/EFTA00206941.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206941.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 4869, + "elapsed_seconds": 0.88, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 83 + ], + [ + "Line", + 42 + ], + [ + "Text", + 13 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 34 + ], + [ + "Line", + 17 + ], + [ + "Text", + 10 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206941" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206943/EFTA00206943.md b/marker2/ds9/EFTA00206943/EFTA00206943.md new file mode 100644 index 0000000000000000000000000000000000000000..4ab46c9090827ad426711b2a271cd9b4730f109c --- /dev/null +++ b/marker2/ds9/EFTA00206943/EFTA00206943.md @@ -0,0 +1,180 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA + +Case No. 08-80736-Civ-MarrahIohnson + +JANE DOES #1 and #2 + +UNITED STATES + +## JOINT STATEMENT OF UNDISPUTED FACTS + +The parties hereby stipulate and agree that the following facts are not in dispute and may be accepted as true: + +I. [1[In 2006, at the request of the Palm Beach Police Department, the Federal Bureau of Investigation ("FBI") opened an investigation into allegations that Jeffrey Epstein ("Epstein") and his personal assistants had used facilities of interstate commerce to induce young girls between the ages of thirteen and seventeen to engage in prostitution, among other offenses. The case was presented to the United States Attorney's Office for the Southern District of Florida, which accepted the case for investigation. The Palm Beach County State Attorney's Office was also investigating the-ease Epstein. See Declaration of Bradley J. Edwards, Esq. at && 1-2 (hereinafter "Edwards Declaration"). + +2. [21 The allegations investigated by the FBI included claims that, Ibletween about 2001 and 2006, defendant Jeffrey Epstein (a-bi4iienaiee-svith-aigedfteant-pelitieal-eenneetiens)-sexually abuseel4nese-than-40 enticed into prostitution minor girls at his mansion in West Palm Beach, Florida, and elsewhere. Among the girls he senually-alstised was suspected of enticing were Jane Doe #1 and Jane Doe #2. Because Epstein, through others, used a means of interstate commerce and knowingly traveled in interstate commerce to engage in this conduct, to-abuse Jane Doc ill and Jane Doe 112 (and the other victims), he was investigated for committing committed-violations of federal law, specifically repeated violations of 18 U.S.C. § 2422. + +The-FBI-determined-that-beth-Jane-Dee-#4-ana--Jane-Dee42-wereatietints-ef--semal-iissaults by-Epstein-while-they-weremtiners-beginning-when-they-were-appreximately-fearteen-years-ec age-and-appreximately-thineeniems-ef-age-resp ards-Deelaratien-at-s-1 + +4. On about June 7, 2007, FBI agents hand-delivered to Jane Doe #1 a standard-c-V-RA-victim notification letter. See Edwards Declaration, Exhibit "A." The notification promises that the Justice Department would makes its "best efforts" to protect Jane Doe #1's rights, including "[t]he reasonable right to confer with the attorney for the United States in the case" and "to be reasonably heard at any public proceeding in the district court involving . . . plea . . . ." The notification further explained that "[a]t this time, your case is under investigation." That notification meant that the FBI had identified Jane Doe #1 as a potential victim of a federal offense. and-as-semeene-preteeted-by-the + +5. On about August 11, 2007, Jane Doe #2 received a standard CVRA victim notification letter. See Edwards Declaration, Exhibit "B." The notification promised that the Justice Department would makes its "best efforts" to protect Jane Doe #2's rights, including "Mlle reasonable right to confer with the attorney for the United States in the case" and "to be reasonably heard at any public proceeding in the district court involving ... plea ...." The notification further explained that "[a]t this time, your case is under investigation." That notification meant that the FBI had identified Jane Doe #2 as a potential victim of a federal offense. and-as-semeene-preteeted-by the CVRA. + +6. Early-in During the investigation, the FBI agents and the Assistant U.S. Attorney had-several meetings met with Jane Doe #1. Jane Doe #2 was represented by counsel that was paid for by + +the criminal target Epstein and, accordingly, all contact was made through that attorney. **Jane Doe #2** was openly hostile to the investigation, and told investigators that she was not a victim of any offense, that Epstein was an “awesome man,” and that she would consider marrying Epstein. **Jane Doe #2** actively avoided law enforcement’s attempts to secure her cooperation with the investigation and contacted other potential witnesses and victims to advise them against cooperating with the authorities. Edwards Declaration at & 5. + +7. In and around September 2007, plea discussions took place between Jeffrey Epstein, represented by numerous attorneys (including lead criminal defense counsel Jay Lefkowitz), and the U.S. Attorney’s office for the Southern District of Florida.[,] represented—primarily—by Assistant U.S. Attorney A. Marie [REDACTED].—The plea discussions generally began from the premise that Epstein would plead guilty at least one federal felony offense surrounding his sexual assaults of more than 40 minor girls. From there, the numerous defense attorneys progressively negotiated more favorable plea terms so that Epstein would ultimately plead These plea negotiations eventually resulted in Epstein pleading guilty to only two state court felony offenses with a recommendation of 18 months’ imprisonment. and would serve only county jail time. Many of the negotiations are reflected in e-mails between Lefkowitz and [REDACTED]. Copies Parts of the correspondence are attached as Exhibit J to the Edwards Declaration accompanying this filing (hereinafter cited as “U.S. Attorney’s Correspondence” and referenced by Bates number stamp).1 Because Epstein has moved to keep these documents from the public, they are at this time filed under seal with the Court. + +--- + +1 Through diligent efforts, e- Counsel for Jane Doe #1 and Jane Doe #2 received copies of half of the e-mail correspondence (the half reflecting [REDACTED] communications to defense counsel) via discovery requests served upon counsel for Epstein in connection with Jane Doe #1 and Jane Doe #2’s civil suits against Epstein on about June 30, 2010. See Edwards Declaration at & &20-22. + +8. At the time of plea discussions, AUSA **Willafana had drafted** the U.S. Attorney's Office had an 82-page prosecution memorandum outlining numerous federal sexual offenses committed by Epstein, and had prepared **drafted** a 53-page indictment, for numerous federal offenses. U.S. Attorney's Correspondence at 4. + +9. In September 2007, Assistant U.S. Attorney (AUSA) A. Marie [REDACTED], in an effort to avoid prosecuting Epstein for his numerous sexual offenses against children, proposed to Epstein's attorneys that rather than plea to any charges relating to him molesting children; Epstein should instead plead to a single assault charge involving a telephone call made by Epstein while he was on his private jet. During the telephone call, Epstein warned his personal assistant, Lesley Groff, against turning over documents and electronic evidence responsive to a subpoena issued by a federal grand jury in the Southern District of Florida investigating Epstein's sex offenses. U.S. Attorney's Correspondence at 49, 58. + +10. The correspondence also shows that AUSA [REDACTED] was interested in finding a place to conclude a plea bargain that would effectively keep the victims from learning what was happening through the press. She wrote in an e-mail to defense counsel: "On an 'avoid the press' note, I believe that Mr. Epstein's airplane was in Miami on the day of the Ms. Groff telephone call. If he was in Mimi-Dade County at the time, then I can file the charge in the District Court in Miami, which will hopefully cut the press coverage significantly." — U.S. Attorney's Correspondence at 29. — Ms. [REDACTED] was aware that most of the victims of Epstein, including Jane Doe #1 and Jane Doe #2, resided outside the Miami area. + +11. On about September 24, 2007, Assistant U.S. Attorney A. Marie [REDACTED] sent an e-mail to Jay Lefkowitz, criminal defense counsel for Epstein, regarding the agreement, a **copy of which is attached hereto as Exhibit \_\_\_. Due to the confidentiality clause in the Agreement,** + +the e-mail stated: that the Government and Epstein's counsel would negotiate between themselves about what information would be disclosed to the victims about the agreement: + +Thank you, Jay. I have forwarded your message only to Alex [Acosta], Andy, and Roland. I don't anticipate it going any further than that. When I receive the originals, I will sign and return one copy to you. The other will be placed in the ease file, which will be kept confidential since it also contains identifying information about the girls. + +When we reach an agreement about the attorney representative for the girls, we can discuss what I can tell him and the girls about the agreement. I know that Andy promised Chief Reiter an update when a resolution was achieved. . . . Rolando is calling, but Rolando knows not to tell Chief Reiter about the money issue, just about what crimes Mr. Epstein is pleading guilty to and the amount of time that has been agreed to. *Rolando also is telling Chief Reiter not to disclose the outcome to anyone.* + +U.S. Attorney's Correspondence at 153 (emphases added). + +42. On about September 25, 2007, AUSA ██████████ sent an e-mail to Lefkowitz, a copy of which is attached hereto as Exhibit \_\_. stating: "And can we have a conference call to discuss what I may disclose to . . . the girls regarding the agreement." U.S. Attorney's Correspondence at 156. + +43. On about September 26, 2007, AUSA. ██████████ sent an e-mail to Lefkowitz, a copy of which is attached hereto as Exhibit \_\_. in which she stated: "Hi Jay—Can you give me a call at 561-209-[xxxx] this morning? I am meeting with the agents and want to give them their marching orders regarding what they can tell the girls." U.S. Attorney's Correspondence at 359. The reasonable inference is that the "marching orders" agreed to between the Government and Epstein's defense counsel was that no mention would be made of the non-prosecution agreement between the U.S. Attorney's Office and Epstein, as no subsequent mention was made to the victims of the non-prosecution agreement. + +14. On about September 27, 2007, Assistant U.S. Attorney A. Marie ██████████ sent an e-mail to Lefkowitz regarding an attorney who was under discussion to be a representative of victims of Epstein civil litigation, a copy of which is attached hereto as Exhibit \_\_\_. revealed to an attorney (Bert Oeariz), who was under discussion to be a representative of victims of Epstein's sexual abuse in civil litigation, that the government was in the process of reaching a non-prosecution agreement with Epstein. An e-mail confirming these disclosures stated: "Bert's firm has raised a number of good questions about how they are going to get paid." U.S. Attorney's Correspondence at 161. The e-mail went on to state: "I told Bert that as part of our agreement we (the federal government) are not going to indict Mr. Epstein, but give him an idea of the charges that we had planned to bring as related to 18 USC 2255." *Id.* The e-mail also asked permission from Epstein's counsel to send to Oeariz a copy of parts of the plea agreement: "With respect to question 2 [a question from Oeariz regarding "[w]hen will it be possible to see the plea agreement so that we understand exactly what Epstein concedes to in the civil case?], do I have your permission to send Bert just that section of the plea agreement that applies to the damages claims (I would recommend sending paragraphs 7 through 10, or at least 7 and 8)?" *Id.* 15. On about September 25, 2007, ASUA AUSA ██████████ sent a letter to Jay Lefkowitz that stated: in which she suggested that the victims should be represented by someone who was not an experienced personal injury attorney: "They [the other lawyers under consideration] are all very good personal injury lawyers, but I have concerns about whether there would be an inherent tension because they may feel that they might make more money . . . if they proceed outside the terms of the plea agreement. (Sorry — I just have a bias against plaintiffs' attorneys.)" U.S. Attorney's Correspondence at 157. ██████████ continued to push Oeariz as the best choice, in part + +because it would reduce publicity: “One nice thing about Bert [Oeariz] is that he is in Miami where teher has been almost no coverage of the case.” *Id.* + +16. In a letter later sent by Jay Lefkowitz to the U.S. Attorney for the Southern District of Florida, Lefkowitz stated that ASUA [REDACTED] had “assiduously” hidden from him the fact that Bert Oeariz was a friend of [REDACTED] boyfriend. U.S. Attorney’s Correspondence at 267. Lefkowitz also stated that [REDACTED] had misleadingly used the term “friend” rather than the more accurate term “boyfriend” to describe who had recommended Oeariz. *Id.* at 268. Lefkowitz further stated the [REDACTED] boyfriend had a business relationship with Oeariz and that the boyfriend would have financially benefitted from the presumably lucrative referral of sexual assault cases against Epstein to Oeariz. On December 13, 2007, [REDACTED] wrote a letter to Lefkowitz to deny these accusations. In the letter, [REDACTED] stated: “. . . I am surprised by your allegations regarding my role because I thought that we had worked very well together in resolving this dispute. I also am surprised because I feel that I bent over backwards to keep in mind the effect that the agreement would have on Mr. Epstein and to make sure that you (and he) understood the repercussions of the agreement.” *Id.* + +17. On about September 24, 2007, Epstein and the U.S. Attorney’s Office reached an agreement whereby the United States would defer federal prosecution in favor of prosecution by the State of Florida. Epstein and the U.S. Attorney’s Office accordingly entered into a “Non-Prosecution Agreement” (NPA) reflecting their agreement. Most significantly, the NPA gave Epstein a promise that he would not be prosecuted for a series of federal felony offenses involving the enticement into prostitution of a large number of minor girls. involving his sexual abuse of more than 30 minor girls. The NPA instead allowed Epstein to plead guilty to two state felony offenses for solicitation of prostitution and procurement of minors for + +prostitution. The NPA also set up a procedure whereby a victim of Epstein's sexual abuse could obtain an attorney representative to proceed with a civil claim against Epstein, provided that the victim agreed to proceed exclusively under 18 U.S.C. § 2255 (i.e., **which** provided that the **each** victim **would recover** agreed to seek no more less than \$150,000 in damages against Epstein – an amount that Epstein argued later was limited to **no more than** \$50,000). *See* Edwards Declaration, Exhibit "C" (copy of the non-prosecution agreement). The agreement was signed by Epstein and his legal counsel, as well as the U.S. Attorney's Office, on about September 24, 2007. + +18. A provision in the non-prosecution agreement made the agreement **confidential secret**. In particular, the agreement stated: "The parties anticipate that this agreement will not be made part of any public record. If the United States receives a Freedom of Information Act request or any compulsory process commanding the disclosure of the agreement, it will provide notice to Epstein before making the disclosure." By entering into such a confidentiality agreement, the U.S. Attorney's Office put itself in a position that notifying the crime victims (including Jane Doe #1 and Jane Doe #2) of the non-prosecution agreement would violate terms of the agreement—specifically the confidentiality provision. Accordingly, from September 24, 2007 through at least June 2008—a period of more than nine months—the U.S. Attorney's Office did not notify any of the victims of the existence of the non-prosecution agreement. + +19. A reasonable inference from the evidence is that the U.S. Attorney's Office wanted the non-prosecution agreement kept from public view because of the intense public criticism that would have resulted from allowing a politically connected billionaire who had sexually abused more than 40 minor girls to escape from federal prosecution with only a county court jail + +sentence and because of the possibility that the victims could have objected to the agreement in court and prevented its consummation. + +20. The Non-Prosecution Agreement that had been entered into between the U.S. Attorney's Office and Epstein was subsequently modified by an October 2007 Addendum and a December 19, 2007, letter from the U.S. Attorney to Attorney Lilly Ann Sanchez. *See* Supplemental Declaration of A. Marie [REDACTED], doc. #35, at 1; U.S. Attorney's Correspondence at 234-37. The U.S. Attorney's Office did not notify any of the victims of the existence of these modifications of the agreement through at least June 2008—a period of more than six months. On about August 14, 2008, Epstein's defense counsel told the U.S. Attorney's Office that they did not consider the December 19, 2007, letter to be operative. *Id.* + +21. In October 2007, shortly after the initial plea agreement was signed, Jane Doe #1 was contacted to be advised regarding the resolution of the investigation. On October 26, 2007, Special Agents E. Nesbitt Kuyrkendall and Jason Richards met in person with Jane Doe #1. The Special Agents explained that Epstein would plead guilty to state charges, he would be required to register as a sex offender for life, and he had made certain concessions related to the payment of damages to the victims, including Jane Doe #1. During this meeting, **the agents explained that this would end the federal investigation of the case and no federal charges would be filed.** the Special Agents did not explain that an agreement had already been signed that precluded any prosecution of Epstein for federal charges. The agents could not have revealed this part of the non-prosecution agreement without violating the terms of the non-prosecution agreement. Whether the agents themselves had been informed of the existence of the non-prosecution agreement by the U.S. Attorney's Office is not certain. Because the plea agreement + +had already been reached with Epstein, the agents made no attempt to secure Jane Doe #1's view on the proposed resolution of the case.—Edwards Declaration at & 7 + +22. Jane Doe #1's perception of the explanation provided by the Special Agents was that only the State part of the Epstein investigation had been resolved, and that the federal investigation would continue, possibly leading to a federal prosecution. Edwards Declaration at & 8. + +23. On about November 27, 2007, Assistant U.S. Attorney Jeff Sloman sent an e-mail to Jay Lefkowitz, defense counsel for Epstein, a **copy of which is attached hereto as Exhibit \_\_\_**. The e-mail stated:—that the U.S. Attorney's Office had an obligation to notify the victims about the plea agreement: + +*The United States has a statutory obligation (Justice for All Act of 2004) to notify the victims of the anticipated upcoming events and their rights associated with the agreement entered into by the United States and Mr. Epstein in a timely fashion. Tomorrow will make one full week since you were formally notified of the selection. I must insist that the vetting process come to an end. Therefore, unless you provide me with a good faith objection to Judge Davis's selection [as special master for selecting legal counsel for victim pursuing claims against Epstein] by COB tomorrow, November 28, 2007, I will authorize the notification of the victims. Should you give me the go-head on Podhurst and Josephsberg selection by COB tomorrow, I will simultaneously send you a draft of the letter. I intend to notify the victims by letter after COB Thursday, November 29th.—* + +U.S. Attorney's Correspondence at 255 (emphasis rearranged): + +24. On about November 29, 2007, Assistant U.S. Attorney A. Marie ██████████ sent a draft of a crime victim notification letter to Jay Lefkowitz, defense counsel for Jeffrey Epstein. The notification letter explained: "I am writing to inform you that the federal investigation of Jeffrey Epstein has been completed, and Mr. Epstein and the U.S. Attorney's Office have reached an agreement containing the following terms . . ." The letter then went on to explain that Epstein would plead guilty to two state offenses and receive an 18 month sentence. The letter did not explain that, as part of the agreement with Epstein, the Justice Department had previously agreed + +not to prosecute Epstein for any of the numerous federal offenses that had been committed. U.S. Attorney's Correspondence at 256-59. + +25. Apparently because of concerns from Epstein's attorneys, **Because Epstein's attorneys sought higher review of the enforceability of the Non-Prosecution Agreement**, the U.S. Attorney's Office never sent the proposed victim notification letter discussed in the previous paragraph to the victims. Instead, a misleading letter stating that the case was "currently under investigation" (described below) was sent in January 2008 and May 2008. At no time before reaching non-prosecution agreement did the Justice Department contact any victims, including for example Jane Doe #1, about their views on the non-prosecution. + +26. On about December 6, 2007, Jeffrey H. Sloman, First Assistant U.S. Attorney sent a letter to Jay Lefkowitz, a copy of which is attached hereto as Exhibit \_\_. noting the U.S. Attorney's Office's legal obligations to keep victims informed of the status of plea negotiations with Epstein. The letter stated: + +Finally, let me address your objections to the draft Victim Notification Letter. You write that you don't understand the basis for the Office's belief that it is appropriate to notify the victims. Pursuant to the "Justice for All Act of 2004," [another name from the CVRA] crime victims are entitled to: "The right to reasonable, accurate, and timely notice of any public court proceeding . . . involving the crime" and the right not to be excluded from any such public court proceeding . . . " 18 U.S.C. § 3771(a)(2) & (3). Section 3771 also commands that "employees of the Department of Justice . . . engaged in the detection, investigation, or prosecution of crime shall make their best efforts to see that crime victims are notified of, and accorded, the rights described in subection (a)." 18 U.S.C. § 3771(e)(1). . . . + +Our Non-Prosecution Agreement resolves the federal investigation by allowing Mr. Epstein to plead to a state offense. *The victims identified through the federal investigation should be appropriately informed, and our Non-Prosecution Agreement does not require the U.S. Attorney's Office to forego its legal obligation.* + +U.S. Attorney's Correspondence at 191-92 (emphasis added). + +27. Despite this recognition of its obligation to keep victims "appropriately informed" about the non-prosecution agreement, the U.S. Attorney's Office did not follow through and inform the victims of the non-prosecution agreement. To the contrary, as discussed below, it continued to tell the victims that the case was "under investigation." Edwards Declaration at & 4 and & 12. + +28. On December 13, 2007, A. Marie [REDACTED] sent a letter to Jay Lefkowitz, defense counsel for Epstein, , a copy of which is attached hereto as Exhibit \_\_\_, rebutting charges that had apparently been made against her by the Epstein defense. The letter stated that a federal indictment against Epstein "was postponed for more than five months to allow you and Mr. Epstein's other attorneys to make presentations to the Office to convince the Office not to prosecute." The letter also recounted that "You and I spent hours negotiating the terms [of the non-prosecution agreement], including 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. Lourie, Menchel, Sloman, and Acosta in the negotiations at various times." U.S. Attorney's Correspondence at 269: + +29. The December 13, 2007, letter also reveals that the Justice Department stopped making victim notifications because of objections from Epstein's criminal defense counsel: "Three victims were notified shortly after the signing of the Non-Prosecution Agreement of the general terms of the Agreement. You raised objections to any victim notification, and no further notifications were done." U.S. Attorney's Correspondence at 270 (emphasis added): + +30. Following the signing of the Agreement and the modifications thereto, Epstein's performance was delayed while he sought higher level review within the Department of Justice. *See* U.S. Attorney's Correspondence *passim*. + +31. On January 10, 2008, Jane Doe #1 and Jane Doe #2 received letters from the FBI advising them that "*[t]his case is currently under investigation.* This can be a lengthy process and we request you[r] continued patience while we conduct a thorough investigation." *See* Doc. #14 (attachments 3 and 4 to declaration of A. Marie [REDACTED]) (emphasis added). The statement in the notification letter was false. The case was not currently "under investigation." To the contrary, the case had been resolved by the non-prosecution agreement entered into by Epstein and the U.S. Attorney's Office discussed previously. Moreover, the FBI did not notify Jane Doe #1 or Jane Doe #2 that a plea agreement had been reached previously, and that part of the agreement was a non-prosecution agreement with the U.S. Attorney's Office for the Southern District of Florida. Edwards Declaration at & 9. + +32. In early 2008, Jane Doe #1 and Jane Doe #2 came to believe that criminal prosecution of Epstein was extremely important. They also desired to be consulted by the FBI and/or other representatives of the federal government about the prosecution of Epstein. In light of the letters that they had received around January 10, they believed that a criminal investigation of Epstein was on going and that they would be contacted before the federal government reached any final resolution of that investigation. Edwards Declaration at & 10. + +33. On about February 25, 2008, Assistant U.S. Attorney Sloman sent an e-mail to Jay Lefkowitz, a copy of which is attached hereto as Exhibit \_\_. Epstein's criminal defense counsel, explaining that the Justice Department's Child Exploitation Obsecurity Section (CEOS) had agreed to review Epstein's objections to the proposed plea agreement that had been reached with the U.S. Attorney's Office for the Southern District of Florida. The letter indicated that, should CEOS reject Epstein's objections to the agreement, then "Mr. Epstein shall have one week to abide by the terms and conditions of the September 24, 2007 Agreement as amended by + +letter from United States Attorney Acosta to Jay Lefkowitz.” U.S. Attorneys Correspondence at 290-91. + +34. In about April 2008, Jane Doe #1 contacted the FBI because Epstein's counsel was attempting to take her deposition and private investigators were harassing her. Assistant U.S. Attorney A. Marie [REDACTED] secured pro bono counsel to represent Jane Doe #1. Pro bono counsel was able to assist Jane Doe #1 in avoiding the improper deposition. AUSA [REDACTED] secured pro bono counsel by contacting Meg Garvin, Esq. of the the National Crime Victims' Law Center in Portland, Oregon, which is based in the Lewis & Clark College of Law. During the call, Ms. Garvin was not advised that a non-prosecution agreement had been reached. + +35. On May 30, 2008, another of Mr. Edwards's clients who was recognized as an **a potential victim of** Epstein victim by the U.S. Attorney's Office, received a letter from the FBI advising her that “*[t]his case is currently under investigation*. This can be a lengthy process and we request your continued patience while we conduct a thorough investigation.” The statement in the notification letter was false. The case was not currently “under investigation.” To the contrary, the case had been resolved by the non-prosecution agreement entered into by Epstein and the U.S. Attorney's Office discussed previously. Edwards Declaration at & 12. + +36. In mid-June 2008, Mr. Edwards contacted AUSA [REDACTED] to inform her that he represented Jane Doe #1 and, later, Jane Doe #2. Mr. Edwards asked to meet to provide information about the federal crimes committed by Epstein, hoping to secure a significant federal indictment against Epstein. AUSA [REDACTED] and Mr. Edwards discussed the possibility of federal charges being filed. At the end of the call, AUSA [REDACTED] asked Mr. Edwards to send any information that he wanted considered by the U.S. Attorney's Office in determining whether to file federal charges. Because of the confidentiality provision that existed in the plea + +agreement, Mr. Edwards was not informed that previously, in September 2007, the U.S. Attorney's Office had reached an agreement not to file federal charges. Mr. Edwards was also not informed that resolution of the criminal matter was imminent. Edwards Declaration at & 13. + +37. On Friday, June 27, 2008, at approximately 4:15 p.m., AUSA [REDACTED] received a copy of Epstein's proposed state plea agreement and learned that the plea was scheduled for 8:30 a.m., Monday, June 30, 2008. AUSA [REDACTED] and the Palm Beach Police Department attempted to provide notification to victims in the short time that Epstein's counsel had provided. Attorney Edwards was called to provide notice to his clients regarding the hearing. AUSA [REDACTED] did not tell Attorney Edwards that the guilty pleas in state court would bring an end to the possibility of federal prosecution pursuant to the plea agreement. Edwards Declaration at & 14. AUSA [REDACTED] strongly encouraged Attorney Edwards and his client to attend and address the Court at sentencing if they so desired. + +38. On June 30, 2008, AUSA [REDACTED] sent an e-mail to Jack Goldberger, criminal defense counsel for Epstein, a copy of which is attached hereto as Exhibit \_\_. that stated: "Jack: The FBI has received several calls regarding the Non-Prosecution Agreement. I do not know whether the title of the document was disclosed when the Agreement was filed under seal, but the FBI and our office are declining comment if asked." U.S. Attorney's Correspondence at 321. + +39. On July 3, 2008, Mr. Edwards sent to AUSA [REDACTED] a letter. See Affidavit of Bradley J. Edwards, Esq., at 15 (attachment 2). In the letter, Mr. Edwards indicated his client's desire that federal charges be filed against defendant Epstein. In particular, he wrote on behalf of his clients: "We urge the Attorney General and our United States Attorney to consider the fundamental import of the vigorous enforcement of our Federal laws. We urge you to move forward with the traditional indictments and criminal prosecution commensurate with the crimes + +Mr. Epstein has committed, and we further urge you to take the steps necessary to protect our children from this very dangerous sexual predator.” When Mr. Edwards wrote this letter, he was still unaware that a non-prosecution agreement had been reached with Epstein[.] – a fact that continued to be concealed from him (and the victims) by the U.S. Attorney’s Office. Mr. Edwards first saw a reference to the NPA on or after July 9, 2008, when the Government filed its responsive pleading to Jane Doe’s emergency petition. That pleading was the first public mention of the non-prosecution agreement and the first disclosure to Mr. Edwards (and thus to Jane Doe #1 and Jane Doe #2) of the possible existence of a non-prosecution agreement. Edwards Declaration at & 15. + +40. On July 9, 2008, AUSA [REDACTED] sent a victim notification to Jane Doe #1 via her attorney, Bradley Edwards. Edwards Declaration, Exhibit “H.” That notification contains a written explanation of some of the terms of the agreement between Epstein and the U.S. Attorney’s Office. A full copy of the terms was not provided. A notification was not provided to Jane Doe #2 because the agreement limited Epstein’s liability to victims whom the United States was prepared to name in an indictment. As a result, Jane Doe #2 never received a notification a letter about the agreement. The notification did not mention the non-prosecution agreement with the U.S. Attorney’s Office. Edwards Declaration at & 16. + +41. On July 9, 2008, AUSA [REDACTED] filed a sworn declaration with the Court in connection with the case (doc. #14). The declaration purported to recount limit parts of the non-prosecution agreement and stated that “these provisions were discussed” with several victims, including Jane Doe #1. *Id.* at 4. + +42. On July 11, 2008, the Court held a hearing on Jane Doe #1 and Jane Doe #2’s Emergency Petition for Enforcement of Rights. During the hearing, the Government conceded that Jane Doe + +#1 and Jane Doe #2 were “victims” within the meaning of the Crime Victim’s Rights Act. Tr. at 14-15. + +43. During the July 11 hearing, the Court and the parties discussed the fact that the petition should not be treated as an “emergency” petition because there was not any particular rush to ruling on it. Tr. at 24-25.—The Court further discussed a need to “hav[e] a complete record, and this is going to be an issue that’s ... going to go to the Eleventh Circuit, [s] it] may be better to have a complete record as to what your position is and the government’s is as to what actions were taken.—And I don’t know if I have enough information, based on Ms. Villafana’s affidavit or I need additional information.—And because it is not an emergency, I don’t have to do something quickly, we can play it b[y] ear and make this into a more complete record for the court of appeals.”—Tr. at 25-26.—Counsel for Jane Doe #1 and Jane Doe #2 explained: “... Your Honor is correct in stating that it is not an emergency and it doesn’t need to happen today. And, I will confer with the government on this and if evidence needs to be taken, it [can] be taken at a later date. It doesn’t seem like there will be any prejudice to any party [from delay].”—Tr. at 26.—The hearing concluded: “So I’ll let both of you confer about whether there is a need for any additional evidence to be presented. Let me know one way or the other. If there is, we’ll schedule a hearing. If there isn’t and you want to submit some additional stipulated information, do that, and then I’ll take care of this in due course.”—Tr. at 32.—The Court then adjourned, taking the victims’ petition under advisement. + +44. The U.S. Attorney’s Office and the victims then attempted to reach a stipulated set of facts underlying the case.—The U.S. Attorney’s Office set a proposed set of facts, and the victims sent a counter-proposal.—Rather than respond to the victims’ counter-proposal, however, the U.S. Attorney’s Office suddenly reversed course. (Doc. #19 at 2).—On July 29, 2008, it filed a Notice + +to Court Regarding Absence of Need for Evidentiary Hearing (doc. #17). The Government took the position that, because no federal criminal charges had been filed in the Southern District of Florida, no additional evidence was required to decide the petition before the Court. + +45. On August 1, 2008, Jane Doe #1 and Jane Doe #2 filed (doc. #19) a response to the Government's "Notice." In the response, Jane Doe #1 and Jane Doe #2 gave a proposed statement of facts surrounding the case. The proposed statement of fact was based on the information available to the victims at that time. The proposed statement of facts highlighted the fact that the Government had signed a non-prosecution agreement containing an express confidentiality provision, which prevented the Government from disclosing the agreement to them and other victims. *Id.* at 5. The response also noted that the Court had taken the victims' petition under advisement. The response further noted that the Government had not attempted to work with the victims to draft a full set of undisputed facts and had refused the victims' efforts to obtain documents relevant to the case. *Id.* at 9. The victims response also requested that the Court direct the Government to confer with the victims regarding the undisputed facts of the case, produce the non-prosecution agreement at issue in the case, and produce an FBI Report of Interview with Jane Doe #1. The response also requested that the Court enter judgment for the victims' finding a violation of rights and schedule a hearing on the appropriate remedy. *Id.* at 14. + +46. On August 14, 2008, the Court held a hearing on the case. During that hearing, the U.S. Attorney's Office conceded "we do feel bound by the confidentiality provision such that we could not voluntarily disclose this non-prosecution agreement without court order compelling us to do so." Tr. at 8. The Office went on to further concede that it could not justify depriving the victims of the opportunity to see the agreement. *Id.* at 14. The hearing concluded without any schedule or deadlines being put in place. + +47. On October 9, 2008, Bradley J. Edwards, counsel for Jane Doe #1 and Jane Doe #2, sent a letter to counsel for the U.S. Attorney's Office in this case advising that two possibly false statements had been made to the Court in the July 9th sworn declaration of AUSA [REDACTED]. See Oct. 9, 2008, Letter from Bradley J. Edwards to Marie [REDACTED] at 1, Edwards Declaration, Attachment "I." First, while Ms. [REDACTED] had described a term as being part of the plea agreement with Epstein, that term later became defunct, at least in the view of Epstein's attorneys (and apparently acceded to by the U.S. Attorney's Office). Second, Ms. [REDACTED] had said that "four victims [including Jane Doe #1] were contacted and these provisions were discussed," it was not clear what provisions had in fact been discussed. + +48. On December 22, 2008, AUSA Marie [REDACTED] filed a supplemental affidavit, "correcting" the statement made in her July 8, 2008, declaration about the terms of the plea agreement (doc. #35). The supplemental affidavit stated that "part 3" of the agreement with defendant Epstein was, in the view Epstein' legal counsel, no longer operative. The supplemental affidavit, however, did not clarify what terms of the agreement had been discussed. + +49. On April 9, 2009, counsel for Jane Doe #1 and Jane Doe #2 sent to the Court in this case (via the PACER system) a notice of a change of law firm affiliation. Doc. #37. + +50. In approximately May 2009, counsel for Jane Doe #1 and Jane Doe #2 propounded discovery requests in both state and federal civil cases against Epstein, seeking to obtain correspondence between Epstein and prosecutors regarding his plea agreement—information that the U.S. Attorney's Office was unwilling to provide to Jane Doe #1 and Jane Doe #2. Epstein refused to produce that information, and extended litigation to obtain the materials followed. Edwards Declaration at & 20. + +51. Because of this extended litigation, Jane Doe #1 and Jane Doe #2 did not have access to important correspondence demonstrating a violation of their rights until June 30, 2010. On that day, counsel for Epstein sent to Bradley J. Edwards, Esq., legal counsel for Jane Doe #1 and Jane Doe #2, approximately 358 pages of e-mail correspondence between his legal counsel and the U.S. Attorney's Office for the Southern District of Florida regarding the plea agreement that had been negotiated between them. — *See* Edwards Declaration, Attachment "J." These e-mails disclosed for the first time the extreme and unusual steps that had been taken by the U.S. Attorney's Office to avoid prosecuting Epstein and to avoid having the victims in the case learn about the non-prosecution agreement that had been reached between Epstein and the Government. — Litigation continues to this day to obtain the correspondence regarding the *state* prosecution and regarding what Epstein's attorneys said in the correspondence with the prosecutors. — Edwards Declaration at & 22 + +52. In mid-July 2010, Jane Doe #1 and Jane Doe #2 settled their civil lawsuits against Mr. Epstein. Notice of this fact was promptly provided to the Court. — Edwards Declaration at xxx. + +53. On September 8, 2010, the Court entered an order stating that "[a]n examination of the docket reveals that no activity has taken place in this case since April of 2009. In light of the underlying settlements between the victims and Mr. Epstein, it is hereby ordered and adjudged that this case is closed." — Doe. #38. + +54. Promptly on the heels of this administrative order, on September 13, 2010, Jane Doe #1 and Jane Doe #2 filed a notice that they "intend to make subsequent filing in the case shortly. They accordingly request administrative reopening of the case and, if the Court deems it advisable, a scheduling conference with the U.S. Attorney's Office regarding the case." — Doe. #39 at 1. They further advised the Court that their settlements with Jeffrey Epstein in no way affected "their + +determination to move forward with the above-captioned CVRA action against a different entity—the U.S. Attorney’s Office for the Southern District of Florida.” *Id.* at 2. The pleading further advised that “[i]f the Court wishes to proceed to an expeditious conclusion to this Case, Jane Doe #1 and Jane Doe #2 have no objection to the Court setting up an expedited schedule for proceeding on the case.” *Id.* The pleading further advised that the reason the victims had not filed for summary judgment in the case was that they had been attempting to secure correspondence between the U.S. Attorney’s Office and Epstein to corroborate their argument that the Office had violated their rights. They noted that they had just secured half of that correspondence two months earlier. *Id.* at 2. The victim asked that, “if the Court deems it advisable, that a scheduling conference be set for this case.” + +55. At all times material to this statement of facts, it would have been practical and feasible for federal government to inform Jane Doe #1 and Jane Doe #2 of the details of the proposed non-prosecution agreement with Epstein, including in particular the fact that the agreement barred any federal criminal prosecution. Edwards Declaration at & 26. + +SO AGREED AND STIPULATED TO, THIS \_\_\_\_\_ DAY OF DECEMBER, 2010. + +\_\_\_\_\_ +BRADLEY J. EDWARDS +COUNSEL FOR PLAINTIFFS + +WIFREDO A. 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Epstein Notice (Other) + +Date: Tue, 12 Jan 2010 22:38:23 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered by Pike, Michael on 1/12/2010 at 5:38 PM EST and filed on 1/12/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80119-KAM + +Filer: Jeffrey Epstein + +Document Number:447 + +## Docket Text: + +NOTICE by Jeffrey Epstein re [443] Response/Reply (Other), Response/Reply (Other), [431] Defendant's MOTION to Compel Presidential Women's Center to Comply with Subpoenas Duces Tecum Notice of Withdrawal of Defendant, Epstein's, Motions to Compel (DE 431 and DE 443) (Pike, Michael) + +9:08-cv-80119-KAN1 Notice has been electronically mailed to: + +Adam D. Horowitz ahorowitz@sexabuseattomey.com + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Isidro Manuel Garcia isidrogarcia®bellsouth.net + +Jack Alan Goldberger jagesq@bellsouth.net, nalanis®agwpa.com + +Jack Patrick Hill jph@searcylaw.com, clw®searcylaw.com, kmc@searcylaw.com, s.slater@searcylaw.com, sas@searcylaw.com, vat@searcylaw.com + +Paul G. Cassell cassellp@law.utah.edu + +Richard Horace Willits lawyenvillits@aol.com, reelrhw@hotmail.com + +Robert C. Josefsberg tjosefsberg@podhurst.com, amann@podhurst.com, bertpatton®podhurst.com, mestrada@podhurst.com + +Robert Deweese Critton , Jr rcrit@bciclaw.com, bobbie@bciclaw.com + +Stuart S. Merrnelstein ssm@sexabuseattorney.com, jarbour®sexabuseattomey.com, Irivera@sexabuseattomey.com + +9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be pt (n ided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +Martin G. Weinberg 20 Park Plaza Boston, MA 02116 + +The following document(s) are associated with this transaction: + +Document description:Main Document + +Original filenamem/a + +Electronic document Stamp: + +[STAMP dcecfStamp\_IT 1105629215 [Date=1/12/2010] [FileNumber=7147688-0 ] [ 10463 fd9de696f6ec112cf8c9912ab9b433c854c le2ae510d60397069b4b77c29ee 42cd5d07fc3c54f45ee9dc79ab3f637fbd928124effl 7e5b22c0f2c4dd0bd]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00206968/EFTA00206968.metadata.json b/marker2/ds9/EFTA00206968/EFTA00206968.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..a733a97c93b2c70015b14a870acafa3c36ace097 --- /dev/null +++ b/marker2/ds9/EFTA00206968/EFTA00206968.metadata.json @@ -0,0 +1,135 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206968.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2914, + "elapsed_seconds": 1.2, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 308.61 + ], + [ + 185.391357421875, + 308.61 + ], + [ + 185.391357421875, + 323.9470520019531 + ], + [ + 30.6, + 323.9470520019531 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 422.82 + ], + [ + 101.52233123779297, + 422.82 + ], + [ + 101.52233123779297, + 438.3170471191406 + ], + [ + 30.6, + 438.3170471191406 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 69 + ], + [ + "Line", + 35 + ], + [ + "Text", + 23 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 43 + ], + [ + "Line", + 21 + ], + [ + "Text", + 13 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206968" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206970/EFTA00206970.md b/marker2/ds9/EFTA00206970/EFTA00206970.md new file mode 100644 index 0000000000000000000000000000000000000000..3832860f37806929dc13f602f705f596c733e054 --- /dev/null +++ b/marker2/ds9/EFTA00206970/EFTA00206970.md @@ -0,0 +1,69 @@ +To: "flsd\_cmecf notice@flsd.uscourts.gov" + +Subject: Activity in Case 9:08-cv-80119-ICAM Doe I. Epstein Notice of Striking + +Date: Tue, 12 Jan 2010 22:35:34 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered by Pike, Michael on 1/12/2010 at 5:35 PM EST and filed on 1/12/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80119-KAM + +Filer: Jeffrey Epstein + +Document Number:446 + +## Docket Text: + +NOTICE of Striking [445] Notice (Other) filed by Jeffrey Epstein Notice to Strike 445 by Jeffrey Epstein (Pike, Michael) + +9:08-cv-80119-ICAM Notice has been electronically mailed to: + +Adam D. Horowitz ahorowitz@sexabuseattomey.com + +Ann Marie C. Villafana ann.marie.c.villafana@usdoj.gov + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Isidro Manuel Garcia isidrogarcia®bellsouth.net + +Jack Alan Goldberger jagesq@bellsouth.net, nalanis®agwpa.com + +Jack Patrick Hill jph@searcylaw.com, clw@searcylaw.com, lcmc@searcylaw.com, s.slater@searcylaw.com, sas®searcylaw.com, vat@searcylaw.com + +Jeffrey Marc Herman jherman@hermanlaw.com + +Richard Horace Willits lawyerwillits@aol.com, reelrhw@hotmail.com + +Robert C. Josefsberg rjosefsberg@podhurst.com, amann@podhurst.com, bertpatton®podhurst.com, mestrada@podhurst.com + +Robert Deweese Critton , Jr rcrit@bciclaw.com, bobbie@bciclaw.com + +Stuart S. Mennelstein ssm@sexabuseattorney.com, jarbour®sexabuseattomey.com, Irivera@sexabuseattomey.com + +9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +Martin G. Weinberg 20 Park Plaza Boston, MA 02116 + +The following document(s) are associated with this transaction: + +Document description:Main Document + +Original filenamem/a + +Electronic document Stamp: + +[STAMP dcecfStamp\_11: 1105629215 [Date=1/12/2010] [FileNumber=7147673-0 ] [858bff5e6b0e2f71916db218e716b10336ca925a7cbca94257fa8a689ba21f1 8495 fld19909246d376c345e822dabc714e05f432285322b2acb5db9a6c2c4ead]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00206970/EFTA00206970.metadata.json b/marker2/ds9/EFTA00206970/EFTA00206970.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..2cbb6bebaa59465667b6d548fce5f61d67041a64 --- /dev/null +++ b/marker2/ds9/EFTA00206970/EFTA00206970.metadata.json @@ -0,0 +1,135 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206970.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2812, + "elapsed_seconds": 1.27, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 308.61 + ], + [ + 185.88690185546875, + 308.61 + ], + [ + 185.88690185546875, + 324.3170471191406 + ], + [ + 30.6, + 324.3170471191406 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 422.82 + ], + [ + 101.65031433105469, + 422.82 + ], + [ + 101.65031433105469, + 438.6035461425781 + ], + [ + 30.6, + 438.6035461425781 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 69 + ], + [ + "Line", + 35 + ], + [ + "Text", + 25 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 39 + ], + [ + "Line", + 20 + ], + [ + "Text", + 12 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206970" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206972/EFTA00206972.md b/marker2/ds9/EFTA00206972/EFTA00206972.md new file mode 100644 index 0000000000000000000000000000000000000000..349947e09572cea253519d58630a1ea126c00aa8 --- /dev/null +++ b/marker2/ds9/EFTA00206972/EFTA00206972.md @@ -0,0 +1,19 @@ +From: (USAFLS)" alMIN> + +To: c > + +Subject: Epstein + +Date: Tue, 12 Jan 2010 15:22:29 +0000 + +Importance: Normal + +Attachments: 20100111143503.pdf + +Hi Barbara — This was just sent to me by someone in my office. In light of other instances where Mr. Epstein's counsel has falsely represented that something was agreed to, I just wanted to check with you to make certain that you were aware of, and joined in, the motion. Can you let me know? + +Thank you. (And Congratulations on your promotion!) + +«20100111143503.r:0(P> + +![](_page_0_Picture_9.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00206972/EFTA00206972.metadata.json b/marker2/ds9/EFTA00206972/EFTA00206972.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..3726426f506bdcb91017b586964c9949c262c7b9 --- /dev/null +++ b/marker2/ds9/EFTA00206972/EFTA00206972.metadata.json @@ -0,0 +1,60 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206972.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 541, + "elapsed_seconds": 0.55, + "image_assets": [ + "_page_0_Picture_9.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 25 + ], + [ + "Line", + 12 + ], + [ + "Text", + 9 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206972" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206972/_page_0_Picture_9.jpeg b/marker2/ds9/EFTA00206972/_page_0_Picture_9.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..ab9f47ff0f52a605172d8e5b6d8428ce06620e6e --- /dev/null +++ b/marker2/ds9/EFTA00206972/_page_0_Picture_9.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:c8e9e4fd6975d6a518b7f0ed6b98d754b2e368971566198a3200a094d2ee4676 +size 8879 diff --git a/marker2/ds9/EFTA00206973/EFTA00206973.md b/marker2/ds9/EFTA00206973/EFTA00206973.md new file mode 100644 index 0000000000000000000000000000000000000000..396005d4a3db0f187882a6c25b11531da40baf6c --- /dev/null +++ b/marker2/ds9/EFTA00206973/EFTA00206973.md @@ -0,0 +1,69 @@ +IN THE CIRCUIT COURT OF THE FIFTEENTH +JUDICIAL CIRCUIT IN AND FOR PALM BEACH +COUNTY, FLORIDA - CRIMINAL DIVISION + +CASE NO: 2058 CF 93781 AXX (H) + +STATE OF FLORIDA + +vs. + +Jeffrey E Poster +Defendant. + +**FILED** +Circuit Criminal Department + +DEC 18 2009 + +SHARON R. BOCK +Clerk & Comptroller +Palm Beach County + +Agreed +ORDER ON MOTION O' Motion for travel + +THIS MATTER comes before the Court upon O' motion for travel. +The Court, having been made aware that both counsel have agreed to said motion. +Accordingly, it is hereby: + +ORDERED and ADJUDGED that O' motion is seated under +The following conditions: O' triel is weekdays only, no weekend +his triel for any stop my include - 1 overnight only, the +O' triel must be reviewed and approved by The O' probation +Officer Ramon ~~Bloom~~ 48 hours in advance + +DONE and ORDERED in Chambers, West Palm Beach, Palm Beach County, +Florida, this \_\_\_\_\_ day of 12/12/09 + +![]() + +## IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, INAND FOR PALM BEACH COUNTY, FLORIDA + +CASE NO. 2008CF009381A + +STATE OF FLORIDA + +vs. + +JEFFREY EPSTEIN, + +Defendant. + +## MOTION FOR AUTHORIZATION TO TRAVEL + +COMES NOW the Defendant, JEFFREY EPSTEIN, by and through his undersigned attorney and moves this Honorable Court to enter an Order authorizing the Defendant's travel for business purposes related to ongoing litigation. In support thereof the Defendant would state as follows: + +- 1. The Defendant has been on community control since July 22, 2009. +- 2. The Defendant has beer in complete compliance with his conditions of community control since being placed on supervision. +- 3. The Defendant was given permission to travel to New York on December 3,2009 for the purposes of meeting with his attorney, Harry Susman. +- 4. After being granted permission, the Defendant arranged his travel plans with his community control officer, Carmen Sloane, and traveled to New York in complete compliance with the rules set forth by his community control officer. 5 The Defendant needs to travel out of state for additional meetings with his attorneys to continue to review documents. See letter from Harry Susman attached hereto as Exhibit NA". +- 6. Given the Defendant's complete compliance with the terms of supervision since being placed on community control on July 22, 2009, the Defendant's community control + +officer, Carmen Sloane; has no objection to the Defendant being given permission to travel for purposes related to his ongoing litigation as long as the dates and times of travel are cleared in advance and approved by his community control officer. + +WHEREFORE, the Defendant moves this Honorable Court to enter an Order authorizing the Defendant to travel for business purposes related to ongoing litigation as long as it is approved in advance by his community control officer. + +I HEREBY CERTIFY that a copy of the foregoing has been furnished by fax and mail to Barbara Burns, Esquire, State Attorney's Office, 401 North Dixie Highway, West Palm Beach, Florida 33401 and to Carmen Sloane, Department of Corrections, 3444 South Congress Avenue, Lake Worth, Flor da 33461, this 16th day of December, 2009. + +> GOLDBERGER, ESQ. At rbbfy, Goldberger & Weiss, P.A. 2 Australian Avenue South ite 1400 est Palm Beach, Florida 33401 (561) 659-08300 Florida Bar No. 262013 \ No newline at end of file diff --git a/marker2/ds9/EFTA00206973/EFTA00206973.metadata.json b/marker2/ds9/EFTA00206973/EFTA00206973.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..c0e3af9edda34e29d597acc7e530f95972056640 --- /dev/null +++ b/marker2/ds9/EFTA00206973/EFTA00206973.metadata.json @@ -0,0 +1,192 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206973.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 3320, + "elapsed_seconds": 4.84, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA - CRIMINAL DIVISION", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 249.696, + 84.24 + ], + [ + 495.7200000000001, + 84.24 + ], + [ + 495.7200000000001, + 135.27 + ], + [ + 249.696, + 135.27 + ] + ] + }, + { + "title": "IN THE CIRCUIT COURT OF THE FIFTEENTH \nJUDICIAL CIRCUIT, INAND FOR PALM BEACH \nCOUNTY, FLORIDA", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 245.57000732421875, + 76.80389404296875 + ], + [ + 497.5559999999999, + 76.80389404296875 + ], + [ + 497.5559999999999, + 115.54852294921875 + ], + [ + 245.57000732421875, + 115.54852294921875 + ] + ] + }, + { + "title": "MOTION FOR AUTHORIZATION TO TRAVEL", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 175.64399999999998, + 249.48 + ], + [ + 416.1075744628906, + 249.48 + ], + [ + 416.1075744628906, + 264.42852783203125 + ], + [ + 175.64399999999998, + 264.42852783203125 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 25 + ], + [ + "PageFooter", + 3 + ], + [ + "SectionHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 53 + ], + [ + "Line", + 27 + ], + [ + "Text", + 6 + ], + [ + "ListItem", + 5 + ], + [ + "SectionHeader", + 2 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 41 + ], + [ + "Line", + 19 + ], + [ + "Text", + 5 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206973" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206976/EFTA00206976.md b/marker2/ds9/EFTA00206976/EFTA00206976.md new file mode 100644 index 0000000000000000000000000000000000000000..1a48a84ecbad340f68bf92cdb7ff0cb7ed02a7ad --- /dev/null +++ b/marker2/ds9/EFTA00206976/EFTA00206976.md @@ -0,0 +1,31 @@ +To: ' + +Subject: RE: Epstein + +Date: Tue, 12 Jan 2010 15:41:32 +0000 + +Importance: Normal + +Yes, I was aware. The Judge was going to allow him to travel to New York to meet with attorneys on his civil lawsuits. I wanted restrictions and got them. + +From: (USAFLS) I + +Sent Tuesda January 12, 2010 10:22 AM + +To: + +Subject: Epstein + +Hi --This was just sent to me by someone in my office. In light of other instances where Mr. Epstein's counsel has falsely represented that something was agreed to, I just wanted to check with you to make certain that you were aware of, and joined in, the motion. Can you let me know? + +Thank you. (And Congratulations on your promotion!) + +«20100111143503.pdf» + +Assistant U.S. Attorney + +500 E. Broward Blvd, 7th Floor + +Ft Lauderdale. FL 33394 + +Please note: Florida has a very broad public records law. Most written communications to or from state officials regarding slate business are public records available to the public and media upon request. Your e-mail communications may therefore be subject to public disclosure. \ No newline at end of file diff --git a/marker2/ds9/EFTA00206976/EFTA00206976.metadata.json b/marker2/ds9/EFTA00206976/EFTA00206976.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..0a8a35691a9b1612615ffe6c7a5b7407c38fe3e9 --- /dev/null +++ b/marker2/ds9/EFTA00206976/EFTA00206976.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206976.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1045, + "elapsed_seconds": 0.9, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 45 + ], + [ + "Line", + 22 + ], + [ + "Text", + 20 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206976" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206977/EFTA00206977.md b/marker2/ds9/EFTA00206977/EFTA00206977.md new file mode 100644 index 0000000000000000000000000000000000000000..fb838dfee8e9024048257cd4cd39b4a66bd63807 --- /dev/null +++ b/marker2/ds9/EFTA00206977/EFTA00206977.md @@ -0,0 +1,19 @@ +Subject: RE: B.B. Jeffrey Epstein + +Date: Fri, 22 Jan 2010 21:11:20 +0000 + +Importance: Normal + +Can you please call me regarding this correspondence. I left a message for you at your office. Thank you. + +Spencer T. Kuvin + +561-515-1400 + +skuvin©leopoldkuvin.com + +Subject: B.B. I Jeffrey Epstein + +Dear Mr. Kuvin — A response to your letter is attached. + +<<20100122 Kuvin Ltr re Reiter Deposition.pdf» \ No newline at end of file diff --git a/marker2/ds9/EFTA00206977/EFTA00206977.metadata.json b/marker2/ds9/EFTA00206977/EFTA00206977.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e811282b1a9c9cd883391c91ff90669d3bf9df54 --- /dev/null +++ b/marker2/ds9/EFTA00206977/EFTA00206977.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206977.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 394, + "elapsed_seconds": 0.57, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 24 + ], + [ + "Line", + 12 + ], + [ + "Text", + 11 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206977" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206978/EFTA00206978.md b/marker2/ds9/EFTA00206978/EFTA00206978.md new file mode 100644 index 0000000000000000000000000000000000000000..0059dade60f054578a95f74780102d21536b592a --- /dev/null +++ b/marker2/ds9/EFTA00206978/EFTA00206978.md @@ -0,0 +1,67 @@ +From: To: + +Subject: Activity in Case 9:08-cv-80119-ICAM Doe Epstein Notification of Ninety Days Expiring + +Date: Fri, 22 Jan 2010 20:48:19 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered by Edwards, Bradley on 1/22/2010 at 3:48 PM EST and filed on 1/22/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80119-KAM + +Filer: Jane Doe + +Document Number: 453 + +Docket Text: + +Notification of Ninety Days Expiring by Jane Doe (Edwards, Bradley) + +9:08-cv-80119-ICAM Notice has been electronically mailed to: + +Adam D. Horowitz ahorowitz@sexabuseattomey.com + +Bradley James Edwards + +Isidro Manuel Garcia is + +Jack Alan Goldberger + +Jack Patrick Hill hill@ s + +Jeffrey Marc Herman jh + +**Richard Horace Willits** + +**Robert C. Josefsbe** + +**Robert Deweese Critton ,** + +**Stuart S. Mermelstein s** + +9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +Martin . Weinbe + +The following document(s) are associated with this transaction: + +## Document description:Main Document + +Original filenamem/a + +## Electronic document Stamp: + +[STAMP dcecfStamp\_if 1105629215 [Date=1/22/2010] [FileNumber=7181395-0 ] [49055318elledad8960f0fldf109251cea05c6824250838355df65689ae36acd015 b5bbcbl5d07b9a2476f48062d545ae519595f242dd36fe68e494610db259f]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00206978/EFTA00206978.metadata.json b/marker2/ds9/EFTA00206978/EFTA00206978.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..6991de966590b19fd36bb1f94105066e487cc2a4 --- /dev/null +++ b/marker2/ds9/EFTA00206978/EFTA00206978.metadata.json @@ -0,0 +1,162 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206978.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2129, + "elapsed_seconds": 1.21, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 31.212, + 309.42 + ], + [ + 184.3336639404297, + 309.42 + ], + [ + 184.3336639404297, + 324.23358154296875 + ], + [ + 31.212, + 324.23358154296875 + ] + ] + }, + { + "title": "Document description:Main Document", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 31.212, + 319.95000000000005 + ], + [ + 231.73399353027344, + 319.95000000000005 + ], + [ + 231.73399353027344, + 335.2330322265625 + ], + [ + 31.212, + 335.2330322265625 + ] + ] + }, + { + "title": "Electronic document Stamp:", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 31.212, + 347.49 + ], + [ + 183.34019470214844, + 347.49 + ], + [ + 183.34019470214844, + 361.93353271484375 + ], + [ + 31.212, + 361.93353271484375 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 68 + ], + [ + "Line", + 34 + ], + [ + "Text", + 24 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 34 + ], + [ + "Line", + 16 + ], + [ + "Text", + 10 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206978" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206980/EFTA00206980.md b/marker2/ds9/EFTA00206980/EFTA00206980.md new file mode 100644 index 0000000000000000000000000000000000000000..302c206b7f733fa4a740bb93bae1ff68bebf9691 --- /dev/null +++ b/marker2/ds9/EFTA00206980/EFTA00206980.md @@ -0,0 +1,3 @@ +From: Sent: To: Cc: Subject: Yesterday's Letter Roy BLACK Thursday. 1 2010 2:59 PM SAFLS) + +Dear On second thought my letter yesterday went too far in one respect. So that there is no misunderstanding of the last paragraph of yesterday's letter, our concern is not that the attorney representative in fact has used the threat of a breach as leverage to get his fees, only that there exists the legitimate concern that the agreement could be so used and the reality that any concern about such use significantly and unfairly burdens Mr Epstein's right to resort to the courts to resolve outstanding legal issues regarding the criteria for payment and the amount of payment owed. I hope this clarifies our concern in this one area. Thanks Roy \ No newline at end of file diff --git a/marker2/ds9/EFTA00206980/EFTA00206980.metadata.json b/marker2/ds9/EFTA00206980/EFTA00206980.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..4ab03b5d891737d224dd28a25ebf30b7a3fafa90 --- /dev/null +++ b/marker2/ds9/EFTA00206980/EFTA00206980.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206980.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 739, + "elapsed_seconds": 0.31, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 33 + ], + [ + "Line", + 17 + ], + [ + "Text", + 3 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206980" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206981/EFTA00206981.md b/marker2/ds9/EFTA00206981/EFTA00206981.md new file mode 100644 index 0000000000000000000000000000000000000000..431c93d84a764fd40dfb47c89d3dacdfd9d124ce --- /dev/null +++ b/marker2/ds9/EFTA00206981/EFTA00206981.md @@ -0,0 +1,30 @@ +**To:** [REDACTED] + +**Subject:** RE: he who must not be named + +**Date:** Sun, 24 Jan 2010 15:47:48 +0000 + +**Importance:** Normal + +--- + +Yes. I read it. I was reading to EJ the quote from the lawyer who asked about what was more traumatic – the 3 abortions or the time spent with Epstein. He then said, “is anyone else quoted in the article?” and I looked down and saw that I was quoted in the article. It was a fun morning for me. + +[REDACTED] +Assistant U.S. Attorney + +500 S. Australian Ave, Suite 400 + +West Palm Beach, FL 33401 + +--- + +**From:** [REDACTED] + +**Sent:** Sunday, January 24, 2010 10:08 AM + +**To:** [REDACTED] + +**Subject:** he who must not be named + +The morning Palm Beach Post has a front page article on Epstein and the victims. If only we could turn back the hands of time!!!! K \ No newline at end of file diff --git a/marker2/ds9/EFTA00206981/EFTA00206981.metadata.json b/marker2/ds9/EFTA00206981/EFTA00206981.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..5d5153d875a28a5b9691bd49718f555e1060c607 --- /dev/null +++ b/marker2/ds9/EFTA00206981/EFTA00206981.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206981.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 792, + "elapsed_seconds": 3.75, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 34 + ], + [ + "Text", + 29 + ], + [ + "Line", + 17 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206981" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206982/EFTA00206982.md b/marker2/ds9/EFTA00206982/EFTA00206982.md new file mode 100644 index 0000000000000000000000000000000000000000..0f18c869a93573cf3daac950e3b349499ef33623 --- /dev/null +++ b/marker2/ds9/EFTA00206982/EFTA00206982.md @@ -0,0 +1,49 @@ +To: "flsd\_cmecf notice@flsd.uscourts.gov" + +Subject: Activity in Case 9:08-cv-80232-KAM Doe No. 3 I. Epstein Motion for Sanctions + +Date: Thu, 14 Jan 2010 16:33:55 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered on 1/14/2010 at 11:33 AM EST and filed on 1/13/2010 + +Case Name: Doe No. 3 Epstein + +Case Number: 9:08-cv-80232-KAM + +Filer: Jeffrey Epstein + +Document Number: 137(No document attached) + +## Docket Text: + +MOTION for Sanctions and Incorporated Memorandum of Law by Jeffrey Epstein. DOCKET CORRECTION: SECOND PART OF DE 1450] (tp) + +9:08-cv-80232-KAM Notice has been electronically mailed to: + +Adam D. Horowitz ahorowitz@sexabuseattomey.com + +Ann Marie C. Villafana ann.marie.c.villafana@usdoj.gov + +Jack Alan Goldberger jagesq@bellsouth.net, nalanis®agwpa.com + +Jeffrey Marc Herman jherman@hermanlaw.com + +Michael James Pike MPike@bciclaw.com, bobbie@bciclaw.com, jcadwell@bciclaw.com + +Robert Deweese Critton , Jr rcrit@bciclaw.com, bobbie@bciclaw.com + +Stuart S. Mermelstein ssm@sexabuseattorney.com, jarbow@sexabuseattomey.com, Irivera@sexabuseattomey.com + +9:08-cv-80232-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: \ No newline at end of file diff --git a/marker2/ds9/EFTA00206982/EFTA00206982.metadata.json b/marker2/ds9/EFTA00206982/EFTA00206982.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..bbfb933231c01f3a4f2d328c0c848fb4f6503bf0 --- /dev/null +++ b/marker2/ds9/EFTA00206982/EFTA00206982.metadata.json @@ -0,0 +1,105 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206982.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 2059, + "elapsed_seconds": 1.15, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 308.61 + ], + [ + 184.3336639404297, + 308.61 + ], + [ + 184.3336639404297, + 324.23358154296875 + ], + [ + 30.6, + 324.23358154296875 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 422.82 + ], + [ + 101.65031433105469, + 422.82 + ], + [ + 101.65031433105469, + 438.6035461425781 + ], + [ + 30.6, + 438.6035461425781 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 69 + ], + [ + "Line", + 35 + ], + [ + "Text", + 24 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206982" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206983/EFTA00206983.md b/marker2/ds9/EFTA00206983/EFTA00206983.md new file mode 100644 index 0000000000000000000000000000000000000000..36c325b7f32f1c23dae232543075979b00c8b849 --- /dev/null +++ b/marker2/ds9/EFTA00206983/EFTA00206983.md @@ -0,0 +1,95 @@ +To: "flsd\_cmecf notice®flsd.uscourts.gov" + +Subject: Activity in Case 9:08-cv-80119-ICAM Doe I Epstein Response to Motion + +Date: Wed, 13 Jan 2010 22:13:04 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the C1VUECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered by Pike, Michael on 1/13/2010 at 5:13 PM EST and filed on 1/13/2010 + +Case Name: Doe Epstein + +Case Number: 9:08-cv-80119-KAM + +Filer: Jeffrey Epstein + +Document Number:450 + +## Docket Text: + +RESPONSE to Motion re [444] Plaintiffs MOTION for Sanctions MOTION for Protective Order and Incorporated Memorandum of Law and Defendant's Motion for Sanctions with Incorporated Memorandum of Law filed by Jeffrey Epstein. Replies due by 1/25/2010. (Attachments: # (1) Exhibit A, # (2) Exhibit B, # (3) Exhibit C)(Pike, Michael) + +9:08-cv-80119-KAM Notice has been electronically mailed to: + +Adam D. Horowitz ahorowitz@sexabuseattorney.com + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Isidro Manuel Garcia isidrogarcia@bellsouth.net + +Jack Alan Goldberger jagesq@bellsouth.net, nalanis@agwpa.com + +Jack Patrick Hill jph@searcylaw.com, clw@searcylaw.com, lcmc@searcylaw.com, s.slater@searcylaw.com, sas@searcylaw.com, vat@searcylaw.com + +Paul G. Cassell cassellp@law.utah.edu + +Richard Horace Willits lawyenvillits@aol.com, reelrhw@hotmail.com + +Robert C. Josefsberg tjosefsberg@podhurst.com, amann@podhurst.com, bertpatton®podhurst.com, mestrada@podhurst.com + +Robert Deweese Critton , Jr rcrit@bciclaw.com, bobbie@bciclaw.com + +Stuart S. Merrnelstein ssm@sexabuseattorney.com, jarbout®sexabuseattomey.com, Irivera@sexabuseattomey.com + +9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be pt (n ided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +Martin G. Weinberg + +20 Park Plaza + +Boston, MA 02116 + +The following document(s) are associated with this transaction: + +Document description:Main Document + +Original filename:n/a + +Electronic document Stamp: + +[STAMP dcecfStamp\_11: 1105629215 [Date=1/13/2010] [FileNumber=7151940-0 ] [4fc4017a88221d5d7d164dc0989f29728533f0a50a4b59bb62c5965afe57e22a525 738aca9e6e7a69da94f95e6c2bca04f273b05dd27ce904957a8d40ca5aabc]] + +Document description:Exhibit A + +Original filename:n/a + +Electronic document Stamp: + +[STAMP dcecfStamp\_11: 1105629215 [Date=1/13/2010] [FileNumber=7151940-1 ] [54cc2e62ce4ebedfcced730cd613013 cedcldb93 c77c le5b6692b968179cbd5be2d cf8b1cfe902e9c8598ba52cfde9a49e0c4ba85b647e02583ac98bbdbb3bc7]] + +Document description:Exhibit B + +Original filename:n/a + +Electronic document Stamp: + +[STAMP dcecfStamp\_11:: 1105629215 [Date=1/13/2010] [FileNumber=7151940-2 ] [15f2d6830f108f07e8350aa5592be99cdb55761f887f36362550249dbcbcA6986ad 62dbf2b739f8b42615de07f6c2bdbdf27c49875578ed8d621275bc3a5fe21]] + +Document description:Exhibit C + +Original filename:n/a + +Electronic document Stamp: + +[STAMP dcecfStamp\_11: 1105629215 [Date=1/13/2010] [FileNumber=7151940-3 ] [7af3ed5a5db16490b130e15e72996ff49adc40023d8edfcle876b63d39ac095c73f ce29ca92372f701f252a73c72d922d1774e79548d339e3f4b4d592f6871bb]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00206983/EFTA00206983.metadata.json b/marker2/ds9/EFTA00206983/EFTA00206983.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..5bc9e518b8fd395543410044739f0020520dfbad --- /dev/null +++ b/marker2/ds9/EFTA00206983/EFTA00206983.metadata.json @@ -0,0 +1,135 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206983.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 3841, + "elapsed_seconds": 1.28, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 308.61 + ], + [ + 185.88690185546875, + 308.61 + ], + [ + 185.88690185546875, + 324.3170471191406 + ], + [ + 30.6, + 324.3170471191406 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 422.82 + ], + [ + 101.52233123779297, + 422.82 + ], + [ + 101.52233123779297, + 438.3170471191406 + ], + [ + 30.6, + 438.3170471191406 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 73 + ], + [ + "Line", + 35 + ], + [ + "Text", + 23 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 80 + ], + [ + "Line", + 39 + ], + [ + "Text", + 27 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206983" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206985/EFTA00206985.md b/marker2/ds9/EFTA00206985/EFTA00206985.md new file mode 100644 index 0000000000000000000000000000000000000000..b9e6180e16e0cd1d35dc74219774e84b4df3a249 --- /dev/null +++ b/marker2/ds9/EFTA00206985/EFTA00206985.md @@ -0,0 +1,7 @@ +Subject: he who must not be named + +Date: Sun, 24 Jan 2010 15:07:57 +0000 + +Importance: Normal + +The morning Palm Beach Post has a front page article on Epstein and the victims. If only we could turn back the hands of time!!!! K \ No newline at end of file diff --git a/marker2/ds9/EFTA00206985/EFTA00206985.metadata.json b/marker2/ds9/EFTA00206985/EFTA00206985.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..0958d3d7d5dca07e250020259172497f73e180c6 --- /dev/null +++ b/marker2/ds9/EFTA00206985/EFTA00206985.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206985.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 225, + "elapsed_seconds": 0.29, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 14 + ], + [ + "Line", + 6 + ], + [ + "Text", + 4 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206985" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206986/EFTA00206986.md b/marker2/ds9/EFTA00206986/EFTA00206986.md new file mode 100644 index 0000000000000000000000000000000000000000..aef1a2668fdc0ce7a8bad7b3f47ca2a3df33811e --- /dev/null +++ b/marker2/ds9/EFTA00206986/EFTA00206986.md @@ -0,0 +1,59 @@ +To: "flsd\_cmecf notice®flsd.uscourts.gov" + +Subject: Activity in Case 9:08-cv-80811-ICAM C.M.A. I Epstein et al Order Dismissing Case + +Date: Mon, 25 Jan 2010 14:44:44 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered on 1/25/2010 at 9:44 AM EST and filed on 1/25/2010 + +Case Name: C.M.A. I Epstein et al + +Case Number: 9:08-cv-80811-KAM + +Filer: + +WARNING: CASE CLOSED on 01/25/2010 + +Document Number: 176 + +## Docket Text: + +ORDER DISMISSING CASE with prejudice. All pending motions are denied as moot. This case is CLOSED. Signed by Judge Kenneth A. Marra on 1/22/2010. (ir) + +9:08-cv-80811-KAM Notice has been electronically mailed to: + +Bruce Reinhart ecf®brucereinhartlaw.com + +Jack Alan Goldberger jagesq@bellsouth.net, nalanis®agwpa.com + +Jack Patrick Hill jph@searcylaw.com, clw@searcylaw.com, kmc@searcylaw.com, s.slater@searcylaw.com, sas®searcylaw.com, vat@searcylaw.com + +Katherine Warthen Ezell KEzell@podhurst.com, mestrada@podhurst.com + +Michael James Pike MPike@bciclaw.com, bobbie@bciclaw.com, jcadwell@bciclaw.com + +Robert C. Josefsberg rjosefsberg@podhurst.com, amann@podhurst.com, bertpatton®podhurst.com, mestrada@podhurst.com + +9:08-cv-80811-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +The following document(s) are associated with this transaction: + +Document description:Main Document + +Original filename:n/a + +Electronic document Stamp: + +[STAMP dcecfStamp\_11 1105629215 [Date=1/25/2010] [FileNumber=7184408-0 ] [2d78962e19278626eef8cc1703e833eccedffa8f4918f2233a62ba1933b217c5cb3 99Icbaa379d0b33c20980a556ca0f940defl al 3ccac9d8b6f0eadb2d87794]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00206986/EFTA00206986.metadata.json b/marker2/ds9/EFTA00206986/EFTA00206986.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..31b33d044b650c64783ca6be26217149fd7b2e57 --- /dev/null +++ b/marker2/ds9/EFTA00206986/EFTA00206986.metadata.json @@ -0,0 +1,135 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206986.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2496, + "elapsed_seconds": 1.19, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 308.61 + ], + [ + 184.74722290039062, + 308.61 + ], + [ + 184.74722290039062, + 324.23358154296875 + ], + [ + 30.6, + 324.23358154296875 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 438.21000000000004 + ], + [ + 101.65031433105469, + 438.21000000000004 + ], + [ + 101.65031433105469, + 453.6035461425781 + ], + [ + 30.6, + 453.6035461425781 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 69 + ], + [ + "Line", + 35 + ], + [ + "Text", + 24 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 23 + ], + [ + "Line", + 11 + ], + [ + "Text", + 7 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206986" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206988/EFTA00206988.md b/marker2/ds9/EFTA00206988/EFTA00206988.md new file mode 100644 index 0000000000000000000000000000000000000000..6caa859617e0ab100050c5619d01db85de1aaa9f --- /dev/null +++ b/marker2/ds9/EFTA00206988/EFTA00206988.md @@ -0,0 +1,19 @@ +![](_page_0_Picture_0.jpeg) + +Subject: Epstein, Part IV + +Date: Sun, 24 Jan 2010 16:20:17 +0000 + +Importance: Normal + +A tt achment s: 20100124\_PB\_Post\_Article.pdf + +When it rains, it pours . . . . + +This was on the front page of the Palm Beach Post today. It makes me very glad that I am no longer in civil practice, because I am amazed at how low these civil lawyers are allowed to go. This also increases my concern about releasing the names of the additional potential victims because of what Epstein's lawyers may do to them. + +And when do I get to tell someone that I did not "craft" this deal? + +<<20100124 PB Post Article df>> + +![](_page_0_Picture_9.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00206988/EFTA00206988.metadata.json b/marker2/ds9/EFTA00206988/EFTA00206988.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..abcdc07cd4d96c78f0472c6c491d6ab9e05796bb --- /dev/null +++ b/marker2/ds9/EFTA00206988/EFTA00206988.metadata.json @@ -0,0 +1,61 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206988.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 658, + "elapsed_seconds": 0.56, + "image_assets": [ + "_page_0_Picture_0.jpeg", + "_page_0_Picture_9.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 27 + ], + [ + "Line", + 11 + ], + [ + "Text", + 8 + ], + [ + "Picture", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206988" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206988/_page_0_Picture_0.jpeg b/marker2/ds9/EFTA00206988/_page_0_Picture_0.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..809a49e25dc70fc269c71d94c7e880fda4727cb0 --- /dev/null +++ b/marker2/ds9/EFTA00206988/_page_0_Picture_0.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:84d9e07cd188a6568610ba555209cc943490ee7f25882413656553842ee86f2b +size 10447 diff --git a/marker2/ds9/EFTA00206988/_page_0_Picture_9.jpeg b/marker2/ds9/EFTA00206988/_page_0_Picture_9.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..40017c600bbe9953373839f5d5d64ef4f9c797e1 --- /dev/null +++ b/marker2/ds9/EFTA00206988/_page_0_Picture_9.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:4d9a05e32e20a1a4f257b9d5ed2908254efdb9843640b41f1ed374f35e597d71 +size 6812 diff --git a/marker2/ds9/EFTA00206989/EFTA00206989.md b/marker2/ds9/EFTA00206989/EFTA00206989.md new file mode 100644 index 0000000000000000000000000000000000000000..7129aa3f08ccf804db9c3cc1b8906974d77093dc --- /dev/null +++ b/marker2/ds9/EFTA00206989/EFTA00206989.md @@ -0,0 +1,47 @@ +To: "flsd\_cmecf notice®flsd.uscourts.gov" + +Subject: Activity in Case 9:08-cv-80232-KAM Doe No. 3 1 Epstein Clerks Notice of Docket Correction - Chambers and Clerks + +Date: Thu, 14 Jan 2010 16:38:53 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered on 1/14/2010 at 11:38 AM EST and filed on 1/14/2010 + +Case Name: Doe No. 3 1 Epstein + +Case Number: 9:08-cv-80232-KAM + +Filer: + +Document Number: 138(No document attached) + +Docket Text: + +Clerks Notice of Docket Correction re [137] MOTION for Sanctions. Document Filed in Wrong Case; Document restricted and docket text modified. Document refiled in correct case # 08CV80119-KAM. (tp) + +9:08-cv-80232-KAM Notice has been electronically mailed to: + +Adam D. Horowitz ahorowitzQ4sexabuseattorney.com + +Jack Alan Goldberger jagesq@bellsouth.net, nalanis®agwpa.com + +Jeffrey Marc Herman jherman@hermanlaw.com + +Michael James Pike MPike@bciclaw.com, bobbie@bciclaw.com, jcadwell@bciclaw.com + +Robert Deweese Critton , Jr rcrit@bciclaw.com, bobbie@bciclaw.com + +Stuart S. Mermelstein ssm@sexabuseattoney.com, jarbour@sexabuseattomey.com, Irivera@sexabuseattorney.com + +9:08-cv-80232-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: \ No newline at end of file diff --git a/marker2/ds9/EFTA00206989/EFTA00206989.metadata.json b/marker2/ds9/EFTA00206989/EFTA00206989.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..c3cabf606d81c7be381b659fc241045cc8f2719f --- /dev/null +++ b/marker2/ds9/EFTA00206989/EFTA00206989.metadata.json @@ -0,0 +1,112 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206989.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2097, + "elapsed_seconds": 1.09, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 321.57000000000005 + ], + [ + 184.37722778320312, + 321.57000000000005 + ], + [ + 184.37722778320312, + 338.1035461425781 + ], + [ + 30.6, + 338.1035461425781 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 79 + ], + [ + "Line", + 34 + ], + [ + "Text", + 23 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 6 + ], + [ + "Line", + 3 + ], + [ + "Text", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206989" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206991/EFTA00206991.md b/marker2/ds9/EFTA00206991/EFTA00206991.md new file mode 100644 index 0000000000000000000000000000000000000000..ecce10fa9aa4edad7e05c4da55aea2db1200dab0 --- /dev/null +++ b/marker2/ds9/EFTA00206991/EFTA00206991.md @@ -0,0 +1,37 @@ +From: To: (USAFLS)" + +Subject: Re: Epstein + +Date: Thu, 07 Jan 2010 14:29:05 +0000 + +Importance: Normal + +Not me. Felice Anos. + +From: To: Sent: Wed Jan 06 19:48:43 2010 Subject: RE: Epstein + +Hi s and — Happy New Year! I hope you all had a nice break. Have you heard back from the Professor with a date. am going to be in Miami on 1/13 for a debriefing in the morning, so if we could do our meeting that afternoon, it would be great. + +Assistant U.S. Attorney + +500 S. Australian Ave, Suite 400 + +West Palm Beach, FL 33401 + +Phone + +Fax + +From: MINIMISMOMM Sent: Monday, December 21, 2009 5:15 PM To: Subject: Epstein + +Met with Alan Dershowitz: + +- 1. He asked for us to terminate his community control/supervision early. I said no. I said that we would also object to any attempt to transfer his supervision to Jeff's Island. +- 2. He wants assurance that the Government won't indict him for a "minor" breach. He gave a few examples of a "minor" breach: 1) Josefsberg wants \$2 million as a fee — they think it is unreasonable; and 2) Epstein wants to swim in his pool. I said we weren't going to modify the deferred prosecution agreement; however, I said that the Office — through the chain of command would evaluate any alleged breach but we're not trying to play "gotcha" with him. +- 3. He claims "but he could be wrong" that provided Brad Edwards with names of "victims" who were not on the original victim list. I said that was ridiculous. + +4. Since I refused to agree to his requests, he asked to meet with us and me - to try to reduce Jeffrey's anxiety level that we looking for ways to breach the agreement . I said we could meet after the New Year. + +Let me know if you have any scheduling conflicts for the first or second week of January. Thanks, + +![](_page_1_Picture_2.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00206991/EFTA00206991.metadata.json b/marker2/ds9/EFTA00206991/EFTA00206991.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..11c41ecad284fd4942790351c63855fb47435b7a --- /dev/null +++ b/marker2/ds9/EFTA00206991/EFTA00206991.metadata.json @@ -0,0 +1,98 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206991.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1773, + "elapsed_seconds": 0.78, + "image_assets": [ + "_page_1_Picture_2.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 72 + ], + [ + "Line", + 33 + ], + [ + "Text", + 14 + ], + [ + "ListItem", + 3 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 9 + ], + [ + "Line", + 5 + ], + [ + "Text", + 2 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206991" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206991/_page_1_Picture_2.jpeg b/marker2/ds9/EFTA00206991/_page_1_Picture_2.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..a19b7b25573c887f2b956c9fd20c27ae4cb66d74 --- /dev/null +++ b/marker2/ds9/EFTA00206991/_page_1_Picture_2.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:6935bd88264e4eea723cb23f88775d7e3713570697884022b30c2d363c7c62b5 +size 1394 diff --git a/marker2/ds9/EFTA00206993/EFTA00206993.md b/marker2/ds9/EFTA00206993/EFTA00206993.md new file mode 100644 index 0000000000000000000000000000000000000000..593e6f65411f042cbcf74c94ece1a862c65db8d4 --- /dev/null +++ b/marker2/ds9/EFTA00206993/EFTA00206993.md @@ -0,0 +1,39 @@ +**From:** "[REDACTED] (USAFLS)" <[REDACTED]> +**To:** "[REDACTED] (USAFLS)" <[REDACTED]>, "[REDACTED] (USAFLS)" +<[REDACTED]> +**Subject:** RE: Epstein +**Date:** Thu, 07 Jan 2010 00:48:43 +0000 + +**Importance:** Normal + +--- + +Hi [REDACTED] and [REDACTED] – Happy New Year! I hope you all had a nice break. Have you heard back from the Professor with a date? I am going to be in Miami on 1/13 for a debriefing in the morning, so if we could do our meeting that afternoon, it would be great. + +[REDACTED] + +Assistant U.S. Attorney + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +--- + +**From:** [REDACTED] (USAFLS) +**Sent:** Monday, December 21, 2009 5:15 PM +**To:** [REDACTED]. (USAFLS); [REDACTED] (USAFLS) +**Subject:** Epstein + +Met with Alan Dershowitz: + +1. 1. He asked for us to terminate his community control/supervision early. I said no. I said that we would also object to any attempt to transfer his supervision to Jeff's Island. +2. 2. He wants assurance that the Government won't indict him for a "minor" breach. He gave a few examples of a "minor" breach: 1) Josefsberg wants \$2 million as a fee – they think it is unreasonable; and 2) Epstein wants to swim in his pool. I said we weren't going to modify the deferred prosecution agreement; however, I said that the Office – through the chain of command – would evaluate any alleged breach but we're not trying to play "gotcha" with him. +3. 3. He claims "but he could be wrong" that [REDACTED] provided Brad Edwards with names of "victims" who were not on the original victim list. I said that was ridiculous. +4. 4. Since I refused to agree to his requests, he asked to meet with us - [REDACTED], [REDACTED], [REDACTED] and me - to try to reduce Jeffrey's anxiety level that we looking for ways to breach the agreement. I said we could meet after the New Year. + +![](_page_1_Picture_0.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00206993/EFTA00206993.metadata.json b/marker2/ds9/EFTA00206993/EFTA00206993.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f0c1c03f1199f2ef599f759d9fe952aa52980e3a --- /dev/null +++ b/marker2/ds9/EFTA00206993/EFTA00206993.metadata.json @@ -0,0 +1,90 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206993.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1856, + "elapsed_seconds": 6.99, + "image_assets": [ + "_page_1_Picture_0.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 61 + ], + [ + "Line", + 30 + ], + [ + "Text", + 22 + ], + [ + "ListGroup", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 3 + ], + [ + "Line", + 2 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206993" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206993/_page_1_Picture_0.jpeg b/marker2/ds9/EFTA00206993/_page_1_Picture_0.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..1311ed1331c7e2adb59c7462ac9988fd3152bed4 --- /dev/null +++ b/marker2/ds9/EFTA00206993/_page_1_Picture_0.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:62c347511ea7eca57d3054ba955f5e80d3ff2c0bc5228d72b86c9d7d3f48819a +size 1076 diff --git a/marker2/ds9/EFTA00206995/EFTA00206995.md b/marker2/ds9/EFTA00206995/EFTA00206995.md new file mode 100644 index 0000000000000000000000000000000000000000..47ef60b1df88546187b44043428d9145d9f46841 --- /dev/null +++ b/marker2/ds9/EFTA00206995/EFTA00206995.md @@ -0,0 +1,13 @@ +Subject: Re: Question re Epstein stuff + +Date: Fri, 22 Jan 2010 19:34:10 +0000 + +Importance: Normal + +Not totally sure on his first release date! Defnte on the early release due to work release good behavior! I believe it was the female case agent that he was assigned while incarcerated!! I will research on Mon! + +Sent: Fri Jan 22 14:09:04 2010 + +Subject: Question re Epstein stuff + +Do you remember the name of the person whom you spoke with at the Sheriff's Office about calculating JE's good time? I recall that he was supposed to be released in November 2009, but earned additional "good time" while on work release, which resulted in him getting out in July. Is that correct? \ No newline at end of file diff --git a/marker2/ds9/EFTA00206995/EFTA00206995.metadata.json b/marker2/ds9/EFTA00206995/EFTA00206995.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e8e3caf6853719751203e6cdcd578bef12eeabda --- /dev/null +++ b/marker2/ds9/EFTA00206995/EFTA00206995.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206995.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 676, + "elapsed_seconds": 0.43, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 24 + ], + [ + "Line", + 11 + ], + [ + "Text", + 7 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206995" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206996/EFTA00206996.md b/marker2/ds9/EFTA00206996/EFTA00206996.md new file mode 100644 index 0000000000000000000000000000000000000000..8a8b535cab3f7c894baddce508f9965fdcda51dc --- /dev/null +++ b/marker2/ds9/EFTA00206996/EFTA00206996.md @@ -0,0 +1,90 @@ +From: To: + +Subject: Activity in Case 9:08-cv-80119-ICAM Doe I. Epstein Motion for Sanctions + +Date: Mon, 04 Jan 2010 19:23:49 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +# Notice of Electronic Filing + +The following transaction was entered by Horowitz, Adam on 1/4/2010 at 2:23 PM EST and filed on 1/4/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80119-KAM + +Filer: Jane Doe + +Document Number:444 + +# Docket Text: + +Plaintiff's MOTION for Sanctions, MOTION for Protective Order and Incorporated Memorandum of Law by Jane Doe. (Attachments: # (1) Exhibit A, # (2) Exhibit B)(Horowitz, Adam) + +9:08-cv-80119-ICAM Notice has been electronically mailed to: + +Adam D. Horowitz ahorowitz@sexabuseattomey.com + +Bradley James Edwards + +Isidro Manuel Garcia isid + +Jack Alan Goldberger jag + +Jack Patrick Hill jph@se sas@searcylaw.com, vat@s + +Jeffrey Marc Herman jhei + +Richard Horace Will + +Robert C. Josefsberg +mestrada@podhurst. + +Robert Deweese Crit + +Stuart S. Mermelstein + +**9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.:** + +Martin G. Weinberg + +The following document(s) are associated with this transaction: + +**Document description:**Main Document + +**Original filename:**n/a + +**Electronic document Stamp:** + +[STAMP dcecfStamp\_ID=1105629215 [Date=1/4/2010] [FileNumber=7115350-0] +[7db6567bab81e30c6eb2aa7aa4b2572514d172b9ea6efadbfe587aa56656b4dbea18 +e9bbd3e4679a9da36e8de68a36ab6d976115ba3773817499a676bc2f0d61]] + +**Document description:**Exhibit A + +**Original filename:**n/a + +**Electronic document Stamp:** + +[STAMP dcecfStamp\_ID=1105629215 [Date=1/4/2010] [FileNumber=7115350-1] +[6582f54eebfa137fb547feaf45a773464d1d0b0a7cffa01bc60429fdd4bbb8437703 +cff8e2ac11e3a305d4e30c9686f123155945170548f8cf4652bdbb38bf92]] + +**Document description:**Exhibit B + +**Original filename:**n/a + +**Electronic document Stamp:** + +[STAMP dcecfStamp\_ID=1105629215 [Date=1/4/2010] [FileNumber=7115350-2] +[2db00248f6f36c09cdb1ef326430655a59fc276bfe76cff796c8308792a21f40d6c4 +e866af3bd05268fc69670555c86105d6bbf1d7db920e18cf4c472475d9fe]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00206996/EFTA00206996.metadata.json b/marker2/ds9/EFTA00206996/EFTA00206996.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..239b9e000aceec221e3e425eb8814000b2b13a3b --- /dev/null +++ b/marker2/ds9/EFTA00206996/EFTA00206996.metadata.json @@ -0,0 +1,131 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206996.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2869, + "elapsed_seconds": 6.18, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 308.61 + ], + [ + 184.3336639404297, + 308.61 + ], + [ + 184.3336639404297, + 324.23358154296875 + ], + [ + 30.6, + 324.23358154296875 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 422.82 + ], + [ + 101.52233123779297, + 422.82 + ], + [ + 101.52233123779297, + 438.3170471191406 + ], + [ + 30.6, + 438.3170471191406 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 69 + ], + [ + "Line", + 34 + ], + [ + "Text", + 25 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 31 + ], + [ + "SectionHeader", + 9 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00206996" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00206998/EFTA00206998.md b/marker2/ds9/EFTA00206998/EFTA00206998.md new file mode 100644 index 0000000000000000000000000000000000000000..c193c6bf0e86aafebdf42482f7c59bef89511fea --- /dev/null +++ b/marker2/ds9/EFTA00206998/EFTA00206998.md @@ -0,0 +1,16 @@ +**To:** [REDACTED] + +**Subject:** Jeffrey Epstein + +**Date:** Mon, 04 Jan 2010 18:44:21 +0000 + +**Importance:** Normal + +--- + +Hi [REDACTED] – You and I traded voicemails and emails several months ago about a child exploitation case with target Jeffrey Epstein. There has been a new development in the case, and I am hoping that you are still interested in investigating the case. Can you give me a call when you have a chance? + +[REDACTED] +**Assistant U.S. Attorney** + +![](_page_0_Picture_46.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00206998/EFTA00206998.metadata.json b/marker2/ds9/EFTA00206998/EFTA00206998.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..8134c816f73490e054db11e85428b117315b6cbb --- /dev/null +++ b/marker2/ds9/EFTA00206998/EFTA00206998.metadata.json @@ -0,0 +1,60 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00206998.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 494, + "elapsed_seconds": 2.51, + "image_assets": [ + "_page_0_Picture_46.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + 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46 FAX +Email: mexperton@skynet.be +011 32 474 95 0073 Belgian Cel- +lular +011 33 607 26 9785 French Cel- +lular +01133144014401 Berlioz +France +[Redacted] Berlioz France + +**Gerard** +23 / 01 / 500 / 546 / 000 + +**Hotel Crillon** +10 Place de la Concorde +Paris, France 75008 +331 44 71 1500 + +**Hotel Raffael** +4428 0028 + +**Junot, Philippe** +509 Madison Avenue +New York, NY + +Email: [Redacted] +(Hm)1 +75008 Paris + +[Redacted] Berlioz +[Redacted] Berlioz France + +**L'Amiljean** +Rue de Varene +Zeme +Rue de Varene + +**L'Arc** +Rue Pulsite +33 1 4500 4500 + +**L'Arpege** +00 33 1 4551 4733 + +**La Merlot** +Rue de la cherche midi + +**La Poste** +00 33 1 4280 6616 +9 rue Peronaid + +**Lagardere, Betty** +75007 Paris + +[Redacted] + +**Lawyers** +[Redacted] Stephane Coulaux +[Redacted] Stephane Coulaux +[Redacted] Geraldine Talavena + +**Le Telegraphe** +00 33 14015 0665 +Rue Lille + +Geme + +**Le Voltaire** +Madame Lemercier +[Redacted] (4) +[Redacted] (h) + +**Maid** 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New Mex* + Suite 400 + 1120 Paseo De Peralta + Santa Fe, NM 87503 + [REDACTED] + +**King, Rhonda** +*Rhonda & King Realty* + [REDACTED] + Stanley, New Mexico 87056 + [REDACTED] + [REDACTED] + +**Massage - New Mexico** + [REDACTED] + +[REDACTED] + +**Richardson, Bill** + [REDACTED] + [REDACTED] (p) + office direct + Sec agent w/Gov + +**Santa Fe Institute** + 1399 Hyda Park Road + Santa Fe, NM 87501 + [REDACTED] + +**Singleton, Dr. & Mrs.** + San Cristobal Ranch + Lane, NM 87540 + [REDACTED] + +**RM** + Aboff Shelley + 001 407 333 2338 + 001561 333 9517 + [REDACTED] + +**Cowley, Dick** + [REDACTED] +**Domb, Sam** + [REDACTED] + New York, NY + +**Hatsuhana (Japanese)** +17 East 48th Street +0101 212 355 3345 + +**Helmsley Palace** +0101 212 888 7000 + +**Il Cantinori** +32 East 10 (at Broadway) + +**Il Tre Merli** + +Houston Street +West Broadway +891 7098 + +**Isabelle's** +359 Columbus Avenue +0101 212 724 2100 + +**Jour et Nult** +[REDACTED] + +**Klinger, Georgette** + +**Le Club** +86th (2-3) + +**Le Comptoir** +227 East 67th Street +New York, NY 10021 + +**Lowell Hotel** +Fund Charttounian-contact +28 East 63rd St. +New York, NY +212 319 4230 + +**Madison Gourmet** +212 288 8276(68) +212 737 3331(64) + +**Madison Towers** +22 E. 38th Street +(Corner of Madison & 38th) +3rd floor +New York, NY +001 212 665 7155 + +**Madre, Le** +168 West 18th +New York, NY +001 212 727 8022 + +**Mark Hotel** +New York, NY +212 744 4300 + +**Massage - California** + +[REDACTED] +**McMullan, Patrick** +Photographer + +**Mayfair Regent** +65th bet Park/Mad +001 212 288 0800 + +**Mercer Kitchen** +99 Prince +001 212 966 5454 +001 212 966 010(f) + +**Morgan Hotel** +001 212 686 0300 + +**Mr Chow** +[REDACTED] + +*The New Albany County Club* + +New Albany Country Club +1 Club Lane +New Albany, Columbus OH +43054 +614-939-6500 +614-939-8525 (f) + +Newcombe, Timothy W. +(Tim) +Newcombe Electronic Systems +2328 Arlington Ave. +Columbus, OH 43221 (h) +9005 Antares Avenue +Columbus, OH 43240 +(h) +(c) +Voice Mail +(hf) + +Larry Esq. + +New York NY 10001 + +P.O. Box 830 +Send Point, NY 11050 + +Florida + +(h) +(h) +Florida +(hf) +(w) + +781 209 4327 (W) +617 496 3999 (W) +617 496 4629 work fax +617 496 4737 Doreen (assistant) + +Oatman, Bob +Professive Operation +R.L. Oatman & Associates, Inc. +600 Fairmount Avenue +Suite 101 + +Towson, MD 21286 +(w) +(h) +(h) +(h) +(h) +(h) +(h) +(h) +(h) +(h) +Office MD +Fax MD +(p) +Janice Oatman + +[Redacted] + +Ovitz, Michael +Addick Monograph Group + +Beverly Hills, CA 80212 + +Email: mi- + +[Redacted] + +[Redacted] assina/Ovitz as- +330-251-9900 Portable in NY +NY Apt. +Bitz's pager +me +cell +ach +pan +5 boat ph +975 boat ph +147 boat ph +answer. + +Packer, Mark +Canastel's +c/o Motorcycle Equities Inc + +[Redacted] +(w) +(w) +venue # 14E +10021 +Canastel's Miami +(p) +(h) + +Pagano, Joe + +Aspen +CO 81611 +[Redacted] +[Redacted] open home array +open Fax + +[Redacted] Office +ID [Redacted] +[Redacted] P +Joe Timporary # @ +Santa Monica +Office Fax + +Perdman, Itzhak + +[Redacted] NY Apart- +536-324-1941 +[Redacted] NY Apart- +[Redacted] -595-2483 Private Line + +Pete +Pilot +561 350 6766 + +PILOT INFORMATION + +Hyperion Air or JEGE +1514 Perimeter Road +Suite 105A +West Palm Beach, FL 33406 +[Redacted] (w) +[Redacted] (h) +[Redacted] Washinton-Signa- +ture Fl. 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+Subject: Black Book Pages 2.pdf [Epstein] + +Date: Thu, 21 Jan 2010 16:26:30 +0000 + +Importance: Normal + +Attachments: Black\_Book\_Pages\_2.pdf + +Hi everyone — I never heard back from the AUSA in New York, but I would like to follow up on this issue soon, if we could. I am meeting with the attorney for the "butler" today to do a preliminary discovery conference. These are the relevant pages from the "little black book." The handwritten notes are the butler's. There is no specific list for New York, and I didn't want to scan in the whole book. After you have a chance to take a look, let me know if you would like to do a conference call. Thank you. + +<> \ No newline at end of file diff --git a/marker2/ds9/EFTA00207007/EFTA00207007.metadata.json b/marker2/ds9/EFTA00207007/EFTA00207007.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e679cf4ed9a005fb768c6082533fbd0f82d247b6 --- /dev/null +++ b/marker2/ds9/EFTA00207007/EFTA00207007.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207007.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 745, + "elapsed_seconds": 0.46, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 27 + ], + [ + "Line", + 14 + ], + [ + "Text", + 8 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207007" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207008/EFTA00207008.md b/marker2/ds9/EFTA00207008/EFTA00207008.md new file mode 100644 index 0000000000000000000000000000000000000000..220ab5e43969068c477b1d6fca6f95e454c546e9 --- /dev/null +++ b/marker2/ds9/EFTA00207008/EFTA00207008.md @@ -0,0 +1,592 @@ +[Redacted text block] + +[Redacted text block] + +[Redacted text block] + +[Redacted text block] + +[Redacted text block] + +![](_page_0_Picture_26.jpeg) + +[Redacted text block] + +Mr. Karin or +[Redacted] Mr. [Redacted] +[Redacted] Mr. [Redacted] +[Redacted] Mr. Tourteau +[Redacted] Mr. [Redacted] +[Redacted] Mr. [Redacted] +[Redacted] Mr. Beistan cell +(alarm) [Redacted] Mr. [Redacted] +[Redacted] Mr. [Redacted] +[Redacted] Mr. Domenichini (einclinity) +[Redacted] Mr. Domenichini +cell (electric) [Redacted] Mr. Lafond (a/c, +near numerous) [Redacted] Mr. Lafond +cell (a/c, heat plumb) [Redacted] Mr. Lafond +[Redacted] Mr. Pasquer +cell (a/c, heat plumb) [Redacted] Mr. Santos + +**Experton, Marie Joseph** +*Pertoz & Co.* + +[Redacted text block] + +**Hotel Crillon** + +**Hotel Raffael** + +**Junot, Philippe** + +[Redacted text block] + +**L'Amiljean** + +[Redacted text block] + +**Gerard** + +[Redacted text block] + +**L'Arc** + +[Redacted text block] + +**L'Arpege** + +**La Merlot** + +**La Poste** + +**Lagardere, Betty** + +[Redacted text block] + +**Lawyers** + +[Redacted text block] + +Stephane Coulaud +Stephane Coulaud +Geraldine Talavera + +**Le Telegraphe** + +[Redacted text block] + +**Le Voltaire** +**Madame Lemercier** + +[Redacted text block] + +**Maid** + +[Redacted text block] + +Faiza +(Jeanmarie's Burlet's) +Faiza's cell +Anne-France + +**Massage - Paris** + +![](_page_1_Picture_33.jpeg) + +![](_page_1_Picture_34.jpeg) + +[Redacted] + +Massage A - Island +[Redacted] +[Redacted] +[Redacted] +[Redacted] +[Redacted] +[Redacted] + +![](_page_1_Picture_37.jpeg) + +Sanchez, Carlos + +![](_page_1_Picture_39.jpeg) + +Moseley, Brian +[Redacted] +[Redacted] + +Roberts, Theresa + +![](_page_1_Picture_42.jpeg) + +Tropical Shipping + +![](_page_1_Picture_44.jpeg) + +Water Taxi + +Romualdez, Daniel + +![](_page_1_Picture_47.jpeg) + +**ISRAEL** + +Eshed, Elisa + +![](_page_1_Picture_50.jpeg) + +Evani Duud Efrat + +![](_page_1_Picture_52.jpeg) + +Gil Avi + +![](_page_1_Picture_54.jpeg) + +Gutman, Arik + +![](_page_1_Picture_56.jpeg) + +Gutman, Arik + +![](_page_1_Picture_58.jpeg) + +Jerusalem Hyatt + +![](_page_1_Picture_60.jpeg) + +Neima, Yakhof + +![](_page_1_Picture_62.jpeg) + +Olmert, Ehud + +![](_page_1_Picture_64.jpeg) + +**ITALY (I)** + +Torne di Pisa + +![](_page_1_Picture_67.jpeg) + +Train Info + +**JEFFREY (J)** +301 East 66th St. +Front Desk +301 East 66th Street +New York, NY 10021 +Apt. For Models + +**KENYA (K)** + +**Muthalga Club** + +**KINNERTON** + +**Airport Transfers** + +**Charlie** + +**Chelsea Police Station** + +**Coles, Alan** + +Registered Ostropath + +![](_page_2_Picture_43.jpeg) + +**Drivers** + +Las Wallace +Les (n) +Les (h) +Ray Perkins (p) +Walter (p) +Walter (p) + +**Entwistle Isl** + +**Hair Assocs** + +**Harrods Limited** + +**Harvey Nichols** + +**Holland & Holland** + +**Jackson Stops** + +**John Hobbs Ltd.** + +**La Famiglia** + +**Martin Tlm/Debbie Stewart** +Grosvenor Estate + +0207-838 9130 2nd Line +0771 423 6573 Range Rover +07785 77 1552 (p) + +**Martine** + +**Massage - UK (a)** + +**Minicabs** + +**Nags Head** +Kavin & Valerie + +**O'Neil Nessa** + +**Oping** + +**Outred, Anthony** + +**Police 24 hours** + +**Maxwell, Ghislaine** + +44 Kinnerton Street +London, England SW1X 8ES +0207-838 9128(f) +0207-838 9129(h) + +Email: 2512 "2" #218 +(Hm)fedex package to: Simon Ed- +wards + +Alexander Marrin Global Markets +Alexander Hse, 9-11 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(Japanese)** + +[REDACTED] + +**Klinger, Georgette** + +[REDACTED] + +**Helmsley Palace** + +[REDACTED] + +**Le Club** + +[REDACTED] + +**Il Cantinori** + +[REDACTED] + +**Le Comptoir** + +[REDACTED] + +**Il Tre Merli** + +[REDACTED] + +**Lowell Hotel** +Fired Chartounlen-contact + +[REDACTED] + +**Isabelle's** + +[REDACTED] + +**Madison Gourmet** + +[REDACTED] + +**Jour et Nuit** + +[REDACTED] + +**Karen Pets** + +[REDACTED] + +**Madison Towers** + +[REDACTED] + +**Madre, Le** + +[REDACTED] + +**Mark Hotel** + +[REDACTED] + +**Massage - California** + +[REDACTED] + +[REDACTED] + +**Mayfair Regent** + +[REDACTED] + +**McMullan, Patrick** + +Photographer + +**Mercer Kitchen** + +[REDACTED] + +**Morgan Hotel** + +[REDACTED] + +**Mr Chow** + +[REDACTED] + +Country Committee +Tim Newcombe + +New Albany Country Club + +![](_page_6_Picture_33.jpeg) + +![](_page_6_Picture_34.jpeg) + +Oatman, Bob +Professive Operation + +![](_page_6_Picture_36.jpeg) + +Newcombe, Timothy W. +(Tim) + 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9:08-cv-80119-ICAM Doe I. Epstein Motion for Sanctions + +Date: Thu, 14 Jan 2010 16:40:24 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered on 1/14/2010 at 11:40 AM EST and filed on 1/13/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80119-KAM + +Filer: Jeffrey Epstein + +Document Number: 451(No document attached) + +## Docket Text: + +MOTION for Sanctions and Incorporated Memorandum of Law by Jeffrey Epstein. DOCKET CORRECTION - SECOND PART OF DOCUMENT [450] (tp) + +9:08-cv-80119-KAM Notice has been electronically mailed to: + +Adam D. Horowitz ahorowitz@sexabuseattomey.com + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Isidro Manuel Garcia isidrogarcia®bellsouth.net + +Jack Alan Goldberger jagesq@bellsouth.net, nalanis@agwpa.com + +Jack Patrick Hill jph@searcylaw.com, clw®searcylaw.com, lcmc@searcylaw.com, s.slater@searcylaw.com, sas®searcylaw.com, vat@searcylaw.com + +Jeffrey Marc Herman jherman@hermanlaw.com + +Richard Horace Willits lawyerwillits@aol.com, reelrhw@hotmail.com + +Robert C. Josefsberg rjosefsberg@podhurst.com, amann@podhurst.com, bertpatton®podhurst.com, mestrada@podhurst.com + +Robert Deweese Critton , Jr rcrit@bciclaw.com, bobbie@bciclaw.com + +Stuart S. Mennelstein ssm@sexabuseattorney.com, jarbow®sexabuseattomey.com, Irivera@sexabuseattomey.com + +9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +Martin G. Weinberg 20 Park Plaza Boston, MA 02116 \ No newline at end of file diff --git a/marker2/ds9/EFTA00207015/EFTA00207015.metadata.json b/marker2/ds9/EFTA00207015/EFTA00207015.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e2cb13d8580e60292d276c36cfdd404829c6badd --- /dev/null +++ b/marker2/ds9/EFTA00207015/EFTA00207015.metadata.json @@ -0,0 +1,135 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207015.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2412, + "elapsed_seconds": 1.19, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 308.61 + ], + [ + 185.391357421875, + 308.61 + ], + [ + 185.391357421875, + 323.9470520019531 + ], + [ + 30.6, + 323.9470520019531 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 422.82 + ], + [ + 101.52233123779297, + 422.82 + ], + [ + 101.52233123779297, + 438.3170471191406 + ], + [ + 30.6, + 438.3170471191406 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 67 + ], + [ + "Line", + 34 + ], + [ + "Text", + 24 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 25 + ], + [ + "Line", + 13 + ], + [ + "Text", + 7 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207015" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207017/EFTA00207017.md b/marker2/ds9/EFTA00207017/EFTA00207017.md new file mode 100644 index 0000000000000000000000000000000000000000..afa547aeceba9665999bd66225f32239563da390 --- /dev/null +++ b/marker2/ds9/EFTA00207017/EFTA00207017.md @@ -0,0 +1,31 @@ +To:' (USAFLS + +Subject: RE: Epstein, Part I + +Date: Fri, 22 Jan 2010 17:13:12 +0000 + +Importance: Normal + +It's good to go. + +From: (USAFLS) + +Sent: Frida January 22, 2010 11:56 AM + +To: USAFLS • (USAFLS); (USAFLS); (USAFLS); (USAFLS); . (FBI) + +Subject: Epstein, Part I + +Hi everyone. It is going to be an Epstein kind of day. Here is part I. + +A couple of weeks ago, I forwarded a letter that I received from Spencer Kuvin (Ted Leopold's partner), who represents several of the Epstein victims, along with a proposed response. I received some comments back from Dexter, which I have incorporated. + +Can or • take a look and give me a final okay and I will get this out today? I have attached both Kuvin's letter and my proposed response. + +« File: 20100104 Kuvin-Villafana Ltr001.pdf » « File: 20100122 Kuvin Ltr re Reiter Deposition.wpd » + +You will soon receive parts 2 and 3. Part 2 relates to a new letter from Roy Black and Part 3 relates to the Paul Cassell/Brad Edwards hunt for the "Black Book." + +Thank you. + +Assistant U.S. Attorney \ No newline at end of file diff --git a/marker2/ds9/EFTA00207017/EFTA00207017.metadata.json b/marker2/ds9/EFTA00207017/EFTA00207017.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..288f837fb2bacfe285d2fc5acc314dcc1747d7fd --- /dev/null +++ b/marker2/ds9/EFTA00207017/EFTA00207017.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207017.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1029, + "elapsed_seconds": 1.0, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 48 + ], + [ + "Line", + 23 + ], + [ + "Text", + 22 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207017" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207018/EFTA00207018.md b/marker2/ds9/EFTA00207018/EFTA00207018.md new file mode 100644 index 0000000000000000000000000000000000000000..0a3075be8346c005c1251d7dc46e6f1daaaa01e3 --- /dev/null +++ b/marker2/ds9/EFTA00207018/EFTA00207018.md @@ -0,0 +1,7 @@ +Subject: Yesterday's Letter + +Date: Thu, 21 Jan 2010 19:59:14 +0000 + +Importance Normal + +On second thought my letter yesterday went too far in one respect. So that there is no misunderstanding of the last paragraph of yesterday's letter, our concern is not that the attorney representative in fact has used the threat of a breach as leverage to get his fees, only that there exists the legitimate concern that the agreement could be so used and the reality that any concern about such use significantly and unfairly burdens Mr Epstein's right to resort to the courts to resolve outstanding legal issues rega 1St • • eria for payment and the amount of payment owed. I hope this clarifies our concern in this one area. Thanks \ No newline at end of file diff --git a/marker2/ds9/EFTA00207018/EFTA00207018.metadata.json b/marker2/ds9/EFTA00207018/EFTA00207018.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..4322bbe3259e65dfdd128b0c29c5b086136098eb --- /dev/null +++ b/marker2/ds9/EFTA00207018/EFTA00207018.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207018.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 721, + "elapsed_seconds": 0.32, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 21 + ], + [ + "Line", + 10 + ], + [ + "Text", + 4 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207018" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207019/EFTA00207019.md b/marker2/ds9/EFTA00207019/EFTA00207019.md new file mode 100644 index 0000000000000000000000000000000000000000..d38e62a3164d17a7062c4503b554e0715821d8a0 --- /dev/null +++ b/marker2/ds9/EFTA00207019/EFTA00207019.md @@ -0,0 +1,17 @@ +![](_page_0_Picture_1.jpeg) + +LEOPOLD-KUVIN., CONSUMER JUSTICE ATTORNEYS + +January 4, 2010 + +![](_page_0_Picture_4.jpeg) + +Re: B.B.'. JEFFREY EPSTEIN OUR FILE NO.: 080303 + +Dear Ms. Villafana: + +After taking the deposition of Police Chief, it came to our attention that apparently a computer which was initially seized during the search warrant conducted on Mr. Epstein's home was returned by the FBI to a private investigator employed by Mr. Epstein. We would like to determine who this computer was returned to, and when it was returned. It would assist us greatly if you could check your records to determine when, and if, this was ever done. Additionally, according to the sworn testimony of Chief Reiter, his department was provided with a letter containing a list of potential victims of Mr. Epstein. This letter contained language pursuant to a previously unknown Federal Statute which apparently directed him to destroy the letter after reading it. We hereby request that your office advise what Statute or Code that letter was referring to. Finally, we would like to schedule the depositions of cm oraa:ai Au— ONINNIMINININONSIMPINISIIIIMISION. Please let me know who we need to direct our subpoenas to in order to schedule these depositions. + +I appreciate your immediate attention to this matter. Should you have any additional questions about these issues, please do not hesitate to contact me at once. + +STK:mlb \ No newline at end of file diff --git a/marker2/ds9/EFTA00207019/EFTA00207019.metadata.json b/marker2/ds9/EFTA00207019/EFTA00207019.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..4f8ac33213ab9f5ee195bcc57c9b5f400a53a108 --- /dev/null +++ b/marker2/ds9/EFTA00207019/EFTA00207019.metadata.json @@ -0,0 +1,65 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207019.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1416, + "elapsed_seconds": 0.79, + "image_assets": [ + "_page_0_Picture_1.jpeg", + "_page_0_Picture_4.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 67 + ], + [ + "Line", + 25 + ], + [ + "Text", + 9 + ], + [ + "PageFooter", + 3 + ], + [ + "Picture", + 2 + ], + [ + "PageHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207019" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207019/_page_0_Picture_1.jpeg b/marker2/ds9/EFTA00207019/_page_0_Picture_1.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..d387c9b4443c89b36e4ec8b71c500ee807cbaa3a --- /dev/null +++ b/marker2/ds9/EFTA00207019/_page_0_Picture_1.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:bd30ceb2e26d4053c361bec63ee842f027c6243c6b35cb5924d6c05d8c77b2d0 +size 2635 diff --git a/marker2/ds9/EFTA00207019/_page_0_Picture_4.jpeg b/marker2/ds9/EFTA00207019/_page_0_Picture_4.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..c5903586f77dd49c0daf8c074b08c15410bfa0d9 --- /dev/null +++ b/marker2/ds9/EFTA00207019/_page_0_Picture_4.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:e278965bd22141f8eb09c420e5d8b75415ff2d651591ad0115a5633681a68178 +size 6328 diff --git a/marker2/ds9/EFTA00207020/EFTA00207020.md b/marker2/ds9/EFTA00207020/EFTA00207020.md new file mode 100644 index 0000000000000000000000000000000000000000..fa9fe4cce3b27fcd8c9b7182e1a52e5a52c0dc80 --- /dev/null +++ b/marker2/ds9/EFTA00207020/EFTA00207020.md @@ -0,0 +1,45 @@ +From: ' &lt; To:' Subject: Activity in Case 9:08-cv-80811-KAM Date: Fri, 08 Jan 2010 14:12:42 +0000 v. Epstein et al Notice of Hearing + +Importance: Normal + +This is an automatic e-mail message generated by the CMIECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +## U.S. District Court + +## Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered on 1/8/2010 at 9:12 AM EST and filed on 1/8/2010 + +Case Name: v. Epstein et al + +Case Number: 9:08-cv-80811-KAM + +Filer: + +Document Number: 174(No document attached) + +## Docket Text: + +NOTICE RESETTING TIME OF CALENDAR CALL: Calendar Call set for 2/19/2010 09:15 AM in West Palm Beach Division before Judge Kenneth A. Marra. (ir) + +9:08-cv-80811-KAM Notice has been electronically mailed to: + +Bruce Reinhart + +Jack Alan Goldberger f + +. la Patrick + +Katherine Warthen Ezell + +Michael James Pike + +Richard Horace Willits + +Robert C.Josefsberg + +9:08-cv-80811-ICAM Notice has not been delivered electronically to those listed below and will be provided by other means. 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Jeffrey Epstein + +**Date:** Fri, 22 Jan 2010 19:55:26 +0000 + +**Importance:** Normal + +**Attachments:** 20100122\_Kuvin\_Ltr\_re\_Reiter\_Deposition.pdf + +--- + +Dear Mr. Kuvin – A response to your letter is attached. + +<<20100122 Kuvin Ltr re Reiter Deposition.pdf>> + +[REDACTED] +**Assistant U.S. Attorney** + +![](_page_0_Picture_50.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00207022/EFTA00207022.metadata.json b/marker2/ds9/EFTA00207022/EFTA00207022.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..4c20f10f42db1e4dbef1423b917a08a50800f3ee --- /dev/null +++ b/marker2/ds9/EFTA00207022/EFTA00207022.metadata.json @@ -0,0 +1,60 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207022.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 393, + "elapsed_seconds": 2.43, + "image_assets": [ + "_page_0_Picture_50.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 20 + ], + [ + "Span", + 19 + ], + [ + "Line", + 10 + ], + [ + "PageFooter", + 2 + ], + [ + "Picture", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207022" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207022/_page_0_Picture_50.jpeg b/marker2/ds9/EFTA00207022/_page_0_Picture_50.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..b1d03bc3865cfa57c9f1a1cf295a09aa57ea5727 --- /dev/null +++ b/marker2/ds9/EFTA00207022/_page_0_Picture_50.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:725cf1f833e3258105d642850d97f66ed7ea78ffa77f7dd868cde02dae7609cc +size 3975 diff --git a/marker2/ds9/EFTA00207023/EFTA00207023.md b/marker2/ds9/EFTA00207023/EFTA00207023.md new file mode 100644 index 0000000000000000000000000000000000000000..168153e7986f8affb7bde28b2213c4248f686c43 --- /dev/null +++ b/marker2/ds9/EFTA00207023/EFTA00207023.md @@ -0,0 +1,29 @@ +![](_page_0_Picture_0.jpeg) + +United States Attorney Southern District of Florida + +500 South Australian Ave., Suite 400 iVest Palm Beach, FL 33401 (561)8204711 Facsimile: (561) 820-8777 + +January 22, 2010 + +## VIA ELECTRONIC MAIL + +Spencer T. Kuvin, Esq. Leopold-Kuvin, P.A. 2925 PGA Boulevard Suite 200 Palm Beach Gardens, FL 33410 + +Re: Jeffrey Epstein/B.B. + +Dear Mr. Kuvin: + +Thank you for your letter regarding the deposition of Mr. Reiter. I have not received or reviewed a copy of Mr. Reiter's deposition, so I do not know the substance of his testimony. + +In response to your questions, no computer was seized from Mr. Epstein's home, and the FBI did not return any computer equipment to Mr. Epstein, or any lawyer or investigator working for Mr. Epstein. While Chief of Police, Mr. Reiter was provided with a copy of the list of identified victims that was provided to Mr. Epstein via his attorneys. A cover sheet provided that the document should be treated as confidential, pursuant to Title 18, United States Code, Section 3509(d) and Florida Law. Mr. Reiter was not instructed to destroy the letter by the U.S. Attorney's Office, although he may have decided to do so of his own accord. + +Regarding your proposed subpoenas, a federal official's testimony cannot be authorized without first complying with their employing agency's Touhy regulations. See United States ex reL Touhy Ragen, 340 U.S. 462, 468 (1951); 5 U.S.C. § 301. The regulations related to the Federal Bureau of Investigation can be found at 28 C.F.R. §§ 16.21, et seq. Requests for documents are normally handled through FOIA requests. Agency counsel for the FBI handles those types of requests. + +By: + +Sincerely, + +Jeffrey H. Sloman United States Attorney + +A. 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Epstein et al Stipulation of Dismissal + +Date: Fri, 22 Jan 2010 20:05:43 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +# U.S. District Court + +## Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered by Pike, Michael on 1/22/2010 at 3:05 PM EST and filed on 1/22/2010 + +Case Name: C.M.A. I Epstein et al + +Case Number: 9:08-cv-80811-KAM + +Filer: Jeffrey Epstein + +Document Number: 175 + +## Docket Text: + +STIPULATION of Dismissal with Prejudice by Jeffrey Epstein. (Attachments: # (1) Text of Proposed Order Proposed Order)(Pike, Michael) + +9:08-cv-80811-KAM Notice has been electronically mailed to: + +Bruce Reinhart + +Jack Alan Goldberger + +Jack Patrick Hill + +Katherine Warthen Ezell + +Michael James Pike + +Richard Horace Willits + +Robert C. Josefsbe + +9:08-cv-80811-ICAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +The following document(s) are associated with this transaction: + +### Document description:Main Document + +Original filename:n/a + +#### Electronic document Stamp: + +[STAMP dcecfStamp\_11 1105629215 [Date=1/22/2010] [FileNumber=7180960-0 ] [3faOcebe48c2209c46141e6bc71a627d25d854d65a741fl8cb9abcObc4e96c49fcf 6e9d2620e10877e5f28a5f9cf67954c996ed9971270042612e27186d8caed]] + +Document description:Text of Proposed Order Proposed Order + +### Original filename:n/a + +### Electronic document Stamp: + +[STAMP dcecfStamp\_11: 1105629215 [Date=1/22/2010] [FileNumber=7180960-1 ] [2e6316511cbfe89874db5abba 14432 fcb6a3581a6319587331b136e6963a5470edc 7fb5376d9a24f087441f4b429c7ca06eef7c3d6189a8b5a195773dc4efb4a]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00207024/EFTA00207024.metadata.json b/marker2/ds9/EFTA00207024/EFTA00207024.metadata.json new file mode 100644 index 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FW: Confidential + +Date: Mon, 25 Jan 2010 14:47:06 +0000 + +Importance: Normal + +Attachments: 20100111143503.pdf + +Please cal to coordinate a meeting at your convenience. I'll let you decide who else to invite. Thanks, + +U + +From: Alan Dershowitz [mailto: + +Sent: Saturday, January 23, 2010 11:33 AM + +Cc: Alan Dershowitz + +Subject: Confidential + +Dear Jeffrey: + +I hope this note finds you well. On January 11, 2010, I sent you the attached e-mail, following up on our discussion in December. I trust you received it. I am now back in miami. I realize you are very busy . I would very much appreciate it ,if you could provide some available dates so that Roy , Marty, and I can sit with you and your team. + +Cordially, + +From: Alan Dershowitz Sent: Mon 1/11/2010 2:25 PM + +January 11, 2010 + +Dear Jeffrey: + +Happy New Year. I hope this note finds you and your family well. When I met with you, we agreed to try to schedule a meeting at the beginning of the new year. In the meantime, I'm sure you're aware that the state circuit court had issued an order authorizing Jeffrey Epstein to travel. I attach the order for your convenience. I'm back in Boston now for a few days but I look forward to meeting with you in the near future. + +Cordially, + +Alan \ No newline at end of file diff --git a/marker2/ds9/EFTA00207026/EFTA00207026.metadata.json b/marker2/ds9/EFTA00207026/EFTA00207026.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..75fc6d682ac40b8bd3a02335b12cefb5dd2b8c9f --- /dev/null +++ b/marker2/ds9/EFTA00207026/EFTA00207026.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207026.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1242, + "elapsed_seconds": 0.89, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 59 + ], + [ + "Line", + 27 + ], + [ + "Text", + 20 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207026" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207027/EFTA00207027.md b/marker2/ds9/EFTA00207027/EFTA00207027.md new file mode 100644 index 0000000000000000000000000000000000000000..f29750539322e46a5a0e9bfeb2c9e6440645c73f --- /dev/null +++ b/marker2/ds9/EFTA00207027/EFTA00207027.md @@ -0,0 +1,70 @@ +IN THE CIRCUIT COURT OF THE FIFTEENTH +JUDICIAL CIRCUIT IN AND FOR PALM BEACH +COUNTY, FLORIDA - CRIMINAL DIVISION + +CASE NO: 2058 CF 93781 AXX (H) + +STATE OF FLORIDA + +vs. + +Jeffrey E Poster +Defendant. + +**FILED** +Circuit Criminal Department + +DEC 18 2009 + +SHARON R. BOCK +Clerk & Comptroller +Palm Beach County + +Agreed +ORDER ON MOTION O' Motion for travel + +THIS MATTER comes before the Court upon O' motion for travel. +The Court, having been made aware that both counsel have agreed to said motion. +Accordingly, it is hereby: + +ORDERED and ADJUDGED that O' motion is seated under +The following conditions: O' triel is weekdays only, no weekend +his triel for any step my include - 1 overnight only, The +O' triel must be reviewed and compared by The O' probation +Officer [REDACTED] 48 hours in advance + +DONE and ORDERED in Chambers, West Palm Beach, Palm Beach County, +Florida, this \_\_\_\_\_ day of 12/12/09 + +[Signature] +Circuit Court Judge + +## IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, INAND FOR PALM BEACH COUNTY, FLORIDA + +CASE NO. 2008CF009381A + +STATE OF FLORIDA + +vs. + +JEFFREY EPSTEIN, + +Defendant. + +## MOTION FOR AUTHORIZATION TO TRAVEL + +COMES NOW the Defendant, JEFFREY EPSTEIN, by and through his undersigned attorney and moves this Honorable Court to enter an Order authorizing the Defendant's travel for business purposes related to ongoing litigation. In support thereof the Defendant would state as follows: + +- 1. The Defendant has been on community control since July 22, 2009. +- 2. The Defendant has beer in complete compliance with his conditions of community control since being placed on supervision. +- 3. The Defendant was given permission to travel to New York on December 3,2009 for the purposes of meeting with his attorney, Harry Susman. +- 4. After being granted permission, the Defendant arranged his travel plans with his community control officer, and traveled to New York in complete compliance with the rules set forth by his community control officer. 5 The Defendant needs to travel out of state for additional meetings with his attorneys to continue to review documents. See letter from Harry Susman attached hereto as Exhibit NA". +- 6. Given the Defendant's complete compliance with the terms of supervision since being placed on community control on July 22, 2009, the Defendant's community control + +officer [REDACTED] has no objection to the Defendant being given permission to travel for purposes related to his ongoing litigation as long as the dates and times of travel are cleared in advance and approved by his community control officer. + +WHEREFORE, the Defendant moves this Honorable Court to enter an Order authorizing the Defendant to travel for business purposes related to ongoing litigation as long as it is approved in advance by his community control officer. + +I HEREBY CERTIFY that a copy of the foregoing has been furnished by fax and mail to [REDACTED] Esquire, State Attorney's Office, [REDACTED] Palm Beach, Florida 33401 and to [REDACTED] Department of Corrections, [REDACTED] [REDACTED] Lake Worth, Florida 33461, this 16th day of December, 2009. + +![]() \ No newline at end of file diff --git a/marker2/ds9/EFTA00207027/EFTA00207027.metadata.json b/marker2/ds9/EFTA00207027/EFTA00207027.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..2dbfcd459aa3265ea77d691d89fbedb5f626c7b3 --- /dev/null +++ b/marker2/ds9/EFTA00207027/EFTA00207027.metadata.json @@ -0,0 +1,192 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207027.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 3149, + "elapsed_seconds": 4.86, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA - CRIMINAL DIVISION", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 249.696, + 84.24 + ], + [ + 495.7200000000001, + 84.24 + ], + [ + 495.7200000000001, + 135.27 + ], + [ + 249.696, + 135.27 + ] + ] + }, + { + "title": "IN THE CIRCUIT COURT OF THE FIFTEENTH \nJUDICIAL CIRCUIT, INAND FOR PALM BEACH \nCOUNTY, FLORIDA", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 245.412, + 76.80389404296875 + ], + [ + 497.5559999999999, + 76.80389404296875 + ], + [ + 497.5559999999999, + 115.54852294921875 + ], + [ + 245.412, + 115.54852294921875 + ] + ] + }, + { + "title": "MOTION FOR AUTHORIZATION TO TRAVEL", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 175.64399999999998, + 249.48 + ], + [ + 416.1075744628906, + 249.48 + ], + [ + 416.1075744628906, + 264.42852783203125 + ], + [ + 175.64399999999998, + 264.42852783203125 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 25 + ], + [ + "PageFooter", + 3 + ], + [ + "SectionHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 53 + ], + [ + "Line", + 27 + ], + [ + "Text", + 6 + ], + [ + "ListItem", + 5 + ], + [ + "SectionHeader", + 2 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 30 + ], + [ + "Line", + 14 + ], + [ + "Text", + 10 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207027" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207030/EFTA00207030.md b/marker2/ds9/EFTA00207030/EFTA00207030.md new file mode 100644 index 0000000000000000000000000000000000000000..8815e288728d8313bf1413f8b1078a630bd56b0d --- /dev/null +++ b/marker2/ds9/EFTA00207030/EFTA00207030.md @@ -0,0 +1,25 @@ +![]()**Date:** Mon, 25 Jan 2010 18:12:57 +0000 + +**Importance:** Normal + +--- + +I let Miami know when we are available. When I get a final date, I will let you know. + +![](_page_0_Picture_63.jpeg) + +![]()**Sent:** Monday, January 25, 2010 1:04 PM + +![]()Tomorrow is my only conflict but if it can not be changed I will see what I can do! Let me know! + +![](_page_0_Picture_68.jpeg) + +**Sent:** Mon Jan 25 10:24:30 2010 + +![]()In response – Are you available Tuesday (tomorrow) or Thursday afternoon of this week to go to Miami to meet with Dershowitz? If not, how about Monday, Tuesday, or Wednesday of next week? + +Thanks. + +![](_page_0_Picture_73.jpeg) + +![](_page_0_Picture_74.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00207030/EFTA00207030.metadata.json b/marker2/ds9/EFTA00207030/EFTA00207030.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..dc42b9de514962fa3d856ab50be1676b8dc61d3e --- /dev/null +++ b/marker2/ds9/EFTA00207030/EFTA00207030.metadata.json @@ -0,0 +1,63 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207030.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 673, + "elapsed_seconds": 3.24, + "image_assets": [ + "_page_0_Picture_63.jpeg", + "_page_0_Picture_68.jpeg", + "_page_0_Picture_73.jpeg", + "_page_0_Picture_74.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 30 + ], + [ + "Text", + 27 + ], + [ + "Line", + 13 + ], + [ + "Picture", + 4 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207030" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207030/_page_0_Picture_63.jpeg b/marker2/ds9/EFTA00207030/_page_0_Picture_63.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..275c489d9c32c287491364a719aa2745015727b4 --- /dev/null +++ b/marker2/ds9/EFTA00207030/_page_0_Picture_63.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:faef55001bbc3022c1fe57f12004d6398893469da1ef7802c828fe28bfabefee +size 4321 diff --git a/marker2/ds9/EFTA00207030/_page_0_Picture_68.jpeg b/marker2/ds9/EFTA00207030/_page_0_Picture_68.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..70dc3cff6bc7e585e22dac0a8ad3aab2b4f3b7c2 --- /dev/null +++ b/marker2/ds9/EFTA00207030/_page_0_Picture_68.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:d35f4a8fbe1da59cb94fe28e868b3bafd780f63770e367c0d8d9d0bf6fe138cb +size 4290 diff --git a/marker2/ds9/EFTA00207030/_page_0_Picture_73.jpeg b/marker2/ds9/EFTA00207030/_page_0_Picture_73.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..b93c102abc98547e4a6976cb284f995b3e4121ce --- /dev/null +++ b/marker2/ds9/EFTA00207030/_page_0_Picture_73.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:67fb0ebb614ace51f79dd7b19e16fdffa712dacea75594133391f3c7f2c65c37 +size 9467 diff --git a/marker2/ds9/EFTA00207030/_page_0_Picture_74.jpeg b/marker2/ds9/EFTA00207030/_page_0_Picture_74.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..4bc30a0e790405f4148df656e5308a510235ea29 --- /dev/null +++ b/marker2/ds9/EFTA00207030/_page_0_Picture_74.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:16a9c43fc81e93d402b7711f37346844296a0e9bdeacb34e77cdb7b76ae718e1 +size 974 diff --git a/marker2/ds9/EFTA00207031/EFTA00207031.md b/marker2/ds9/EFTA00207031/EFTA00207031.md new file mode 100644 index 0000000000000000000000000000000000000000..e505be244872b6c0a861bda94a8d8bee50a468bc --- /dev/null +++ b/marker2/ds9/EFTA00207031/EFTA00207031.md @@ -0,0 +1,34 @@ +**To:** [REDACTED] + +**Subject:** Re: Epstein Mtg + +**Date:** Mon, 25 Jan 2010 18:03:38 +0000 + +**Importance:** Normal + +--- + +Tomorrow is my only conflict but if it can not be changed I will see what I can do! Let me know! + +--- + +**From:** [REDACTED] + +**To:** [REDACTED] + +**Sent:** Mon Jan 25 10:24:30 2010 + +**Subject:** Epstein Mtg + +Hi [REDACTED] – Are you available Tuesday (tomorrow) or Thursday afternoon of this week to go to Miami to meet with [REDACTED] If not, how about Monday, Tuesday, or Wednesday of next week? + +Thanks. + +[REDACTED] +**Assistant U.S. Attorney** + +**500 E. Broward Blvd, 7th Floor** + +**Ft Lauderdale, FL 33394** + +![](_page_0_Picture_83.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00207031/EFTA00207031.metadata.json b/marker2/ds9/EFTA00207031/EFTA00207031.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..91612fa97bce0e3876b827b9bbad6fcd5185d16f --- /dev/null +++ b/marker2/ds9/EFTA00207031/EFTA00207031.metadata.json @@ -0,0 +1,60 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207031.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 663, + "elapsed_seconds": 3.5, + "image_assets": [ + "_page_0_Picture_83.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 33 + ], + [ + "Text", + 32 + ], + [ + "Line", + 17 + ], + [ + "PageFooter", + 2 + ], + [ + "Picture", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207031" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207031/_page_0_Picture_83.jpeg b/marker2/ds9/EFTA00207031/_page_0_Picture_83.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..9e15e83781e8f0b515b4788a9109780cc980f655 --- /dev/null +++ b/marker2/ds9/EFTA00207031/_page_0_Picture_83.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:e3c2570bbb85454ed2aa9cc7ee583414cb02398b02a47567428c94a52338dd13 +size 3549 diff --git a/marker2/ds9/EFTA00207032/EFTA00207032.md b/marker2/ds9/EFTA00207032/EFTA00207032.md new file mode 100644 index 0000000000000000000000000000000000000000..b6aa178de913d7442b6b94cebf322b11567e0988 --- /dev/null +++ b/marker2/ds9/EFTA00207032/EFTA00207032.md @@ -0,0 +1,29 @@ +![](_page_0_Picture_0.jpeg) + +![](_page_0_Picture_1.jpeg) + +From: Paul Cassell [mailto:cassellp@law.utah.edu] + +Sent: Monday, January 25 2010 4:52 PM + +Cc: dave\_brannon@fd.org + +Subject: Rodriguez Victims Are Asserting Their Rights Under the Crime Victims Rights Act + +Dear Ms + +![](_page_0_Picture_7.jpeg) + +I attach a letter for your consideration and look forward to talking to you at your earliest convenience. If you cannot reach me on my office phone, my cell phone is 801-201-8271. Thanks! + +Salt Lake City, UT 84112-0730 + +Voice: 801-585-5202 + +Fax: 801-581-6897 + +Email: cassellp@law.utah.edu + +http://www.law.uta h.eduiprofilesidefa ult.a sp?Pe rsonlD=57&na m e= Ca ss e II Paul + +CONFIDENTIAL: This electronic message - along with any/all attachments - is confidential. This message is intended only for the use of the addressee. If you are not the intended recipient, the person responsible to deliver it to the intended recipient, you may not use, disseminate, distribute or copy this communication. If you have received this message in error, please immediately notify the sender by reply electronic mail and delete the original message. 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Cassell, Esq. + +332 S. 1400 E., Room 101 + +Salt Lake City, UT 84112 + +(801) 585-5202 (phone) + +(801) 581-6897 (facsimile) + +E-mail: cassellpOlaw.utah.edu + +January 25, 2010 + +Re: United States g Alfredo Rodriquez, No. 9:09-MJ-08308-LRJ-1 + +I am writing to assert the rights of my clients as victims in the above-captioned case. + +It have tried to reach you several times by telephone, but have thus far been unsuccessful. You may already be treating my clients as victims. But in the interests of avoiding any confusion and to make sure that they don't miss notice of any future events in this criminal case, I am writing to formally notify you that my three clients (whose names are known to the government and who are identified in court pleadings as LM., E.W. and Jane Doe) are all asserting their rights under the Crime Victims Rights Act, 18 U.S.C. § 3771. As you know from another case we have worked on together, the CVRA protects all those who have been "directly and proximately harmed" as the result of the commission of a federal offense. 18 U.S.C. § 3771(e). My three clients were all pursuing civil discovery in the civil cases that Mr. Rodriguez obstructed by corruptly concealing a document with extremely important information in it that would help them prove their case (the so-called "black book"). + +My clients would like to exercise all of their rights under the Crime Victims' Rights Act, 18 U.S.C. § 3771, including the right to be notified of court events, to confer with the prosecutor as necessary, to be treated with fairness, and (if there is a conviction in this matter) to be heard at sentencing. As you know, the relevant case law gives crime victims the right to confer with prosecutors regarding any plea bargain that might be reached in cases such as this, even before an indictment has been filed. See, e.g., In re Dean, 527 F.3d 391 (5th Cir. 2008) (finding the Government violated the CVRA in not conferring with victims in case before filing a complaint and related plea agreement). + +I would like to speak with you about their rights as soon as possible. My clients have a right to "confer with you under the CVRA. In particular, my clients are concerned about their right to be treated with fairness protected under the CVRA. 18 U.S.C. § 3771(a)(8). As you know, the Government currently has in its possession the black book, which contains vital information for my clients in + +connection with their civil suits. According to the criminal complaint in this matter, Mr. Rodriguez has described this information as the "Holy Grail" or "Golden Nugget" regarding their cases. If Mr. Rodriguez had not obstructed justice and had properly complied with their lawful deposition and document requests properly made in the course of civil discovery, they would now have that black book. They need a copy of this "Holy Grail" so that they can effectively pursue their efforts to obtain civil justice. They trust that, as part of protecting their right to fairness, the Government will do everything reasonably in its power to get it to them. + +Time is of the essence. The discovery deadlines for my clients begin closing on April 2, 2010. If they do not get the black book substantially before then, other attorneys and I may well be blocked from following up all of the hundreds of discovery leads that the black book apparently contains. + +My clients would also ask you to reach any plea agreement in this case that takes account of the seriousness of the offenses committed by Mr. Rodriguez. If things continue to stand the way they do today—with my clients unable to see the black book — it is quite clear that Mr. Rodriguez has committed an obstruction of justice offense that involves "substantial interference with the administration of justice." U.S.S.G. § 211.2(2). As things stand today, the April 2 discovery cutoff is apparently going to pass without giving them access to the names hundreds of victims who could corroborate their claims and, more important, provide ironclad proof that they have been the victims of a RICO enterprise. Motions to dismiss all of the RICO claim filed by my clients are currently pending in state and federal court. If these motions are granted, it could potentially result in my clients losing millions of dollars in damages and costs which they would have otherwise been able to obtain. + +If the case proceeds to a sentencing phase, I would request your office's help in communicating to the court the above mentioned victim impact information. + +Thanks in advance for adding my client's names into your victim notification system. I will be happy to receive the notifications on their behalf at the above address. And thank you in advance for calling me quickly to confer so that we can discuss how to treat these victims fairly and minimize any effects of the defendant's crimes. I know your office's great reputation (as well as your own) for working closely with victims. I look forward to working with you to see how best to protect my clients' rights in this case. + +Sincerely, + +/5/ Paul G. Cassell + +Paul G. Cassell, Esq. + +cc: David B. Brannon, Esq. (via e-mail Dave\_Brannon@fd.org) \ No newline at end of file diff --git a/marker2/ds9/EFTA00207034/EFTA00207034.metadata.json b/marker2/ds9/EFTA00207034/EFTA00207034.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..90e1381fb3f71f710857bbb1cdb314e87a998e1a --- /dev/null +++ b/marker2/ds9/EFTA00207034/EFTA00207034.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207034.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 5155, + "elapsed_seconds": 0.89, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 63 + ], + [ + "Line", + 31 + ], + [ + "Text", + 12 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 65 + ], + [ + "Line", + 33 + ], + [ + "Text", + 9 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207034" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207036/EFTA00207036.md b/marker2/ds9/EFTA00207036/EFTA00207036.md new file mode 100644 index 0000000000000000000000000000000000000000..7a7c68012443134657ce2d8cc196cc84a7ff2052 --- /dev/null +++ b/marker2/ds9/EFTA00207036/EFTA00207036.md @@ -0,0 +1,35 @@ +To: + +Subject: RE: + +Date: Tue, 26 Jan 2010 16:21:45 , 0000 + +Importance: Normal + +That was far more about Lothrop (the mention of Skeet Shooting) than me. + +You and I are one with the peeps — pick up basketball and all. + +Assistant U.S. Attorney + +500 E. Broward Blvd, 7th Floor + +Ft Lauderdale, FL 33394 + +From + +Sent: Tuesda Janus 26, 2010 10:32 AM + +To: ) + +Subject: FW: + +From: + +Sent: Tuesda Janus 26, 2010 10:26 AM + +To: + +Subject: + +Last week, I went skeet shooting with former Town of Palm Beach Police Chief and he told me how impressed he was with in the Epstein case. He told me that when it is over he would like to talk to her. \ No newline at end of file diff --git a/marker2/ds9/EFTA00207036/EFTA00207036.metadata.json b/marker2/ds9/EFTA00207036/EFTA00207036.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..ee3c2547a2f7c47bc757d8615258b7476730aa92 --- /dev/null +++ b/marker2/ds9/EFTA00207036/EFTA00207036.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207036.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 624, + "elapsed_seconds": 1.03, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 44 + ], + [ + "Text", + 22 + ], + [ + "Line", + 21 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207036" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207037/EFTA00207037.md b/marker2/ds9/EFTA00207037/EFTA00207037.md new file mode 100644 index 0000000000000000000000000000000000000000..44467e5d50b2e3586afaee4887c3fe8c31fbd29a --- /dev/null +++ b/marker2/ds9/EFTA00207037/EFTA00207037.md @@ -0,0 +1,85 @@ +From: ' .. To:' ' + +Subject: Activity in Case 9:08-cv-80119-KAM Doe I. Epstein Response to Motion + +Date: Mon, 01 Feb 2010 22:51:13 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +# U.S. District Court + +#### Southern District of Florida + +#### Notice of Electronic Filing + +The following transaction was entered by Horowitz, Adam on 2/1/2010 at 5:51 PM EST and filed on 2/1/2010 + +Case Name: Doe v. Epstein + +Case Number: 9:08-cv-80119-KAM + +Filer: Jane Doe + +Document Number:456 + +## Docket Text: + +RESPONSE to Motion re [451] MOTION for Sanctions and Reply in Support of Plaintiff's Motion for Sanctions filed by Jane Doe. Replies due by 2/11/2010. (Attachments: # (1) Exhibit A, # (2) Exhibit B)(Horowitz, Adam) + +9:08-cv-80119-KAM Notice has been electronically mailed to: + +Adam D. Horowitz + +M I. + +Bradley James Edwards + +Isidro Manuel Garcia + +Jack Alan Goldberger i + +Jack Patrick Hill + +Paul G. Cassell + +Richard Horace Willits + +Robert C. Josefsbe + +Robert Deweese Critton , Jr + +Stuart S. Merrnelstein + +9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at I + +Martin G. Weinberg 20 Park Plaza Boston, MA 02116 + +The following document(s) are associated with this transaction: + +## Document description:Main Document + +Original filename:n/a + +# Electronic document Stamp: + +[STAMP dceciStamp\_11-2 1105629215 [Date=2/1/2010] [FileNumber=7215667-0) [4ec7a00dd5e219d71c4aa3d65c3 a2b0af2c 19a7e0d847 f7033d06ca4a00fl 41 ftb14 ca72c479563e926eelf6595646e21f71 ea0c0e50848356b7f12e6lfd43d2]] + +## Document description:Exhibit A + +Original filename:n/a + +#### Electronic document Stamp: + +[STAMP dcecfStamp\_11 1105629215 [Date=2/1/2010] [FileNumber=7215667-1] [8743d421d77c450c74408fd8c5c8a029cbdc684dae5e5c97e890269643e9f3407779 04823d5c2f08944a915d5f6b3bfa95f32926e2da5a3c5b386e60fcc40b7c]] + +## Document description:Exhibit B + +Original filename:n/a + +# Electronic document Stamp: + +[STAMP dcecfStamp\_11 1105629215 [Date=2/1/2010] [FileNumber=7215667-2] [975 c9cb5e909799967e9fbb87d3eb654a74ad 19876001 f0ddb7e7c364 f3 cdc6a0d6e 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PB\_Post\_Article\_re\_arraignment.pdf + +Just FYI. + +«PB Post Article re arraignment.pdf» \ No newline at end of file diff --git a/marker2/ds9/EFTA00207039/EFTA00207039.metadata.json b/marker2/ds9/EFTA00207039/EFTA00207039.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..2fe7edab41aca777b5a05e84a6432b1ceaee6ad5 --- /dev/null +++ b/marker2/ds9/EFTA00207039/EFTA00207039.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207039.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 248, + "elapsed_seconds": 0.49, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + 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SREEINICK SCOTT A. KORNSPAN LARRY A. STUMPF MARIA NEYRA JACKIE. PERCZEK MARK A.J. SHAPIRO JARED LOPEZ + +## BLACK SREBNICK KORNSPAN & STUMPF \_PA= + +January 20, 2010 + +![](_page_0_Picture_5.jpeg) + +JESSICA FONSECA-NADP.R KATHLEEN P. PHILLIPS AARON ANTHON MARCOS BEATON. JR. MATTHEW P. O'BRIEN JENIFER J. SOULIKIAS NOAH Fox + +E-Mail: iffilack4RoyBlack.com + +RE: Jeffrey Epstein + +Dear Marie: + +We are now facing a difficult issue about the attorney's fees in the civil cases brought against Mr. Epstein related to your prior criminal investigation. I broached this subject with you on the phone a couple of weeks ago, but I could see our discussion was not fruitful at that time. Since we could not come to any agreement on how to handle this, we must proceed ahead based on our understanding of the non-prosecution agreement. + +Mr. Epstein has paid the attorney representative \$526,000 and accepts his obligation under the NPA to pay additional reasonable legal fees that precede litigation claims under 17C of the Addendum. However we believe that the request by the attorney representative for over \$1.5M additional fees is both unreasonable and outside the Addendum's criteria for payment. + +Litigation may ensue since we have been unable to resolve these matters through an agreement. We never contemplated that the legal fee agreement would result in a bill for \$2.1M when the Addendum was entered. We understand you and Jay had different views on whether an attorney representative could both sue Epstein for some clients and remain as counsel to settle other cases. We believe that the attorney representative could either settle the cases and be paid hourly or litigate and be paid out of the judgment, but not both. The language of the NPA is in need of legal construction regarding whether Epstein's obligations end when + +the attorney representative brings a lawsuit for any of his clients - a matter that a court should settle free from any consideration that initiating litigation to resolve this outstanding issue would be perceived as a breach. + +Just to be sure, Mr. Epstein will pay whatever fees a court determines are owed and we only want assurance that litigating the legal and factual issues over such liability will be consistent with and not violate the NPA. We don't think it is the government's position that Epstein must simply pay any bill he receives, regardless of the amount and type of work done, particularly one for \$2.1M. So we have no alternative but to go to court to resolve this issue. We are sending you this letter because the attorney representative is using the threat of a breach as leverage to get his fees. I don't believe the government's power to indict and incarcerate should be used to assist a private lawyer in collecting an exorbitant legal fee. Thus we are putting you on notice, and asking that if you disagree with our legal opinion that a suit is not in conflict with the NPA, to tell us without delay. + +Cordially yours, + +MW:RC:RB/wg + +Martin G. Weinberg, Esq. Robert D. 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I have conferred with members of my office regarding the issues that you have raised. + +First, with respect to your request that your clients be considered victims in the case against Mr. Rodriguez, as I stated to you in our earlier discussion, our office does not routinely investigate or prosecute cases based upon a person's failure to obey a civil subpoena for two reasons: the office would be overwhelmed with such referrals, and it would raise allegations that the government was interfering with civil litigation and/or using its law enforcement powers to assist a particular attorney or civil litigant. Accordingly, Mr. Rodriguez is being prosecuted for obstructing the federal grand jury investigation of Mr. Epstein and the victim of that crime is the United States. + +Second, with respect to your request as to how best to proceed to obtain a copy of the items seized from Mr. Rodriguez, those items remain in the custody of the FBI, which is where they would have been if Mr. Rodriguez had turned them over to law enforcement during the federal grand jury investigation. Since your discovery period is still open, you can issue a subpoena to the FBI, and their counsel will respond accordingly, including addressing the privacy concerns and "rape shield law" concerns that we discussed over the telephone. + +In case you need the number for your records, the Court File No. for U.S.. Alfredo Rodriguez is 10-CR-80015- MARRA/HOPKINS. + +![](_page_0_Picture_9.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00207042/EFTA00207042.metadata.json b/marker2/ds9/EFTA00207042/EFTA00207042.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..ab5a7fa7a292eee695056ea1e446f3404434c914 --- /dev/null +++ b/marker2/ds9/EFTA00207042/EFTA00207042.metadata.json @@ -0,0 +1,60 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207042.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1682, + "elapsed_seconds": 0.57, + "image_assets": [ + "_page_0_Picture_9.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 43 + ], + [ + "Line", + 22 + ], + [ + "Text", + 9 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207042" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207042/_page_0_Picture_9.jpeg b/marker2/ds9/EFTA00207042/_page_0_Picture_9.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..916ae77583584f1539a506fa3aa2f0ee30c8835c --- /dev/null +++ b/marker2/ds9/EFTA00207042/_page_0_Picture_9.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:b455af1ab130d75a8157bb883572b457a95a2004b0b111f36f8bb272fd82a471 +size 10671 diff --git a/marker2/ds9/EFTA00207043/EFTA00207043.md b/marker2/ds9/EFTA00207043/EFTA00207043.md new file mode 100644 index 0000000000000000000000000000000000000000..82546e709132464856317de0b185a1306144e11f --- /dev/null +++ b/marker2/ds9/EFTA00207043/EFTA00207043.md @@ -0,0 +1,9 @@ +Subject: Epstein Meeting + +Date: Tue, 26 Jan 2010 18:34:22 +0000 + +Importance: Normal + +Is scheduled for Monday, February 15t at 1:00 in Miami. Can you check with should go? and see who, if anyone else, + +![](_page_0_Picture_4.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00207043/EFTA00207043.metadata.json b/marker2/ds9/EFTA00207043/EFTA00207043.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..aee9358ab0033925dfd796d4d21df1ab406147de --- /dev/null +++ b/marker2/ds9/EFTA00207043/EFTA00207043.metadata.json @@ -0,0 +1,60 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207043.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 228, + "elapsed_seconds": 0.37, + "image_assets": [ + "_page_0_Picture_4.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 13 + ], + [ + "Line", + 7 + ], + [ + "Text", + 4 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207043" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207043/_page_0_Picture_4.jpeg b/marker2/ds9/EFTA00207043/_page_0_Picture_4.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..df4efbce11cd3d36bbe9254d1c24a90d1468f3c3 --- /dev/null +++ b/marker2/ds9/EFTA00207043/_page_0_Picture_4.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:1543acaad13c18084fed88c7e77c12f8b43a0b6c4bff17197418eb25eee63987 +size 13454 diff --git a/marker2/ds9/EFTA00207044/EFTA00207044.md b/marker2/ds9/EFTA00207044/EFTA00207044.md new file mode 100644 index 0000000000000000000000000000000000000000..64a2b862824368e5a4ea09cf2c8a4d84f489366d --- /dev/null +++ b/marker2/ds9/EFTA00207044/EFTA00207044.md @@ -0,0 +1,45 @@ +Subject: RE: Press Coverage re Op Stolen Globe/Epstein + +Date: Tue, 26 Jan 2010 16:48:35 +0000 + +Importance: Normal + +I think in the last email I sent on Friday night I said, "when it rains, it pours." For Marie, "when it rains, Marie gets struck by lightning." + +A IIIInfa a,. + +Assistant U.S. Attorney + +500 E. Broward Blvd, 7th Floor + +Ft Lauderdale, FL 33394 + +954-660-5946 + +From: iiM.MMINENN Sent: Tuesday, January 26, 2010 11:47 AM + +To: Subj t." : : ms LW'/ t AAe p to Ien Globe/Epstein + +What a charmed existence you lead! + +From: + +Sent: Tuesday, January 26, 2010 10:21 AM + +To: (USAdLS); Carcq, Rolrido (USAFLS); Lee) Dexter (USAI-LS) + +Cc: + +Subject: Press Coverage re Op Stolen Globe/Epstein + +I have suspicions about who tipped off the press given my recent back and forth with some of the plaintiffs' attorneys, but in any event, this appeared in this morning's Palm Beach Post. + +Drew — Can we set up the meeting with the AUSAs in California and New Mexico some time soon? + +« File: ex-epstein-worker-faces.pdf » + +Thank you. + +Assistant U.S. Attorney + +~~-ann,marie,evillafana@usdoj.gov-~~ \ No newline at end of file diff --git a/marker2/ds9/EFTA00207044/EFTA00207044.metadata.json b/marker2/ds9/EFTA00207044/EFTA00207044.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e78d9a65961b1d3fc2f7a352d647edc5e5327621 --- /dev/null +++ b/marker2/ds9/EFTA00207044/EFTA00207044.metadata.json @@ -0,0 +1,76 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207044.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1084, + "elapsed_seconds": 1.86, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 82 + ], + [ + "Line", + 31 + ], + [ + "Text", + 26 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 4 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207044" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207046/EFTA00207046.md b/marker2/ds9/EFTA00207046/EFTA00207046.md new file mode 100644 index 0000000000000000000000000000000000000000..d17b3a193a24233794639ee2f8690ab4dd2c14b0 --- /dev/null +++ b/marker2/ds9/EFTA00207046/EFTA00207046.md @@ -0,0 +1,19 @@ +Subject: RE: Press Coverage re Op Stolen Globe/Epstein + +Date: Tue, 26 Jan 2010 16:46:59 +0000 + +Importance: Normal + +What a charmed existence you lead! + +Subject: Press Coverage re Op Stolen Globe/Epstein + +I have suspicions about who tipped off the press given my recent back and forth with some of the plaintiffs' attorneys, but in any event, this appeared in this morning's Palm Beach Post. + +Drew — Can we set up the meeting with the AUSAs in California and New Mexico some time soon? + +« File: ex-epstein-worker-faces.pdf » + +Thank you. + +![](_page_0_Picture_9.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00207046/EFTA00207046.metadata.json b/marker2/ds9/EFTA00207046/EFTA00207046.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..44b119d0e6ae1db6e9002be5e4660317b164dcc7 --- /dev/null +++ b/marker2/ds9/EFTA00207046/EFTA00207046.metadata.json @@ -0,0 +1,60 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207046.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 563, + "elapsed_seconds": 0.61, + "image_assets": [ + "_page_0_Picture_9.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 22 + ], + [ + "Line", + 11 + ], + [ + "Text", + 9 + ], + [ + "PageFooter", + 2 + ], + [ + "Picture", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207046" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207046/_page_0_Picture_9.jpeg b/marker2/ds9/EFTA00207046/_page_0_Picture_9.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..61275372239db0ef6868c8ea91ae5c82c3bfe34d --- /dev/null +++ b/marker2/ds9/EFTA00207046/_page_0_Picture_9.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:8aa159285ace31d48c2c897c165228a7dfd9d541cc468e86f871d6a2ef18c5c2 +size 9477 diff --git a/marker2/ds9/EFTA00207047/EFTA00207047.md b/marker2/ds9/EFTA00207047/EFTA00207047.md new file mode 100644 index 0000000000000000000000000000000000000000..8da3585589be14e2cf79c7c51b4fc7fc622bc462 --- /dev/null +++ b/marker2/ds9/EFTA00207047/EFTA00207047.md @@ -0,0 +1,21 @@ +**To:** Dave Brannon [REDACTED] + +**Subject:** Rodriguez Plea Agreement.pdf + +**Date:** Wed, 27 Jan 2010 19:28:24 +0000 + +**Importance:** Normal + +**Attachments:** Rodriguez\_Plea\_Agreement.pdf + +--- + +Hi Dave – Here you go. Can you double-check that I don't have any mistakes? Thanks. + +<> + +[REDACTED] + +Assistant U.S. Attorney + +[REDACTED] \ No newline at end of file diff --git a/marker2/ds9/EFTA00207047/EFTA00207047.metadata.json b/marker2/ds9/EFTA00207047/EFTA00207047.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1a253ea41c3e6a143c06bf3d295153807c89c454 --- /dev/null +++ b/marker2/ds9/EFTA00207047/EFTA00207047.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207047.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 363, + "elapsed_seconds": 2.41, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 22 + ], + [ + "Span", + 19 + ], + [ + "Line", + 10 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207047" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207048/EFTA00207048.md b/marker2/ds9/EFTA00207048/EFTA00207048.md new file mode 100644 index 0000000000000000000000000000000000000000..9d7e2d55bc2e5811d68fe9ac13deaa8d02910ae4 --- /dev/null +++ b/marker2/ds9/EFTA00207048/EFTA00207048.md @@ -0,0 +1,96 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA + +CASE NO. + +UNITED STATES OF AMERICA + +vs. + +ALFREDO RODRIGUEZ, + +Defendant. / + +## PLEA AGREEMENT + +The United States of America and Alfredo Rodriguez (hereinafter referred to as the "defendant") enter into the following agreement: + +- 1. The Charge to Which the Defendant Is Pleading Guilty: The defendant agrees to plead guilty to the sole count of the Information, which charges that, from at least as early as January 18, 2007, through on or about November 3, 2009, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendant did corruptly conceal a record, document, or other object, with the intent to impair the object's availability for use in an official proceeding, that is proceedings before a federal grand jury, and otherwise corruptly obstructed and impeded said official proceeding; in violation of Title 18, United States Code, Section 1512(c). +- 2. The Elements of the Offense of Conviction: The elements of the offense of obstruction of justice, in violation of Title 18, United States Code, Section 1512(c), are as + +follows: + +First, that the defendant concealed a record, document, or other object with the intent to impair the object's availability for use in an official proceeding, or otherwise obstructed or impeded that proceeding; + +Second, that the defendant did so "corruptly," that is, wrongfully and with improper purpose; and + +"Third, that the defendant's conduct had a relationship in time, causation or logic with the official proceeding, that is, that the endeavor had the natural and probable effect of interfering with the due administration of justice. + +3. Statutory Penalties: The defendant understands and acknowledges that, as to the charge contained in the Information, the Court may impose a maximum sentence of twenty (20) years' imprisonment to be followed by a term of supervised release of up to three (3) years, and may impose a fine of up to \$250,000. The defendant also understands that, in addition to any term of imprisonment and supervised release and/or any fine that is imposed, the Court may order him to pay restitution to any victim of his offense, as required by law. The defendant understands and acknowledges that a violation of the terms of his supervised release can result in additional criminal penalties. + +4. Special Assessment: The defendant further understands and acknowledges that, in addition to the sentence imposed under paragraph 3 of this Agreement, a special assessment in the amount of \$100 will be imposed. The defendant agrees that any special assessment imposed shall be paid at the time of sentencing. + +5. Applicability of Sentencing Guidelines: The defendant is aware that the sentence will be imposed by the Court after considering the Federal Sentencing Guidelines and Policy Statements (hereinafter "Sentencing Guidelines"). The defendant acknowledges and understands that the Court will compute an advisory sentence under the Sentencing Guidelines and that the applicable guidelines will be determined by the Court relying in part on the results of a Pre-Sentence Investigation by the Court's Probation Office, which investigation will commence after the entry of the defendant's guilty plea. The defendant is also aware that, under certain circumstances, the Court may depart from the advisory sentencing guideline range that it has computed, and may raise or lower that advisory sentence under the Sentencing Guidelines. The defendant further understands that the Court is required to consider the advisory guideline range determined under the sentencing guidelines, but is not bound to impose that sentence; the Court is permitted to tailor the ultimate sentence in light of other statutory concerns, and such sentence may be either more severe or less severe than the Sentencing Guidelines' advisory sentence. Knowing these facts, the defendant understands and acknowledges that the Court has the authority to impose any sentence within and up to the statutory maximum authorized by law for the offense identified in paragraph 1 and that the defendant cannot withdraw his guilty plea solely as a result of the sentence imposed. + +6. Rights Waived by Pleading Guilty:The defendant understands that by pleading guilty, he knowingly and voluntarily waives the following rights: + +- a. the right to plead not guilty and to persist in a plea of not guilty; + +- the right to a speedy and public trial before a jury of his peers; the right to the effective assistance of counsel at trial, including, if the defendant could not afford an attorney, the right to have the Court appoint an attorney for the defendant; +- d. the right at trial to be presumed innocent until guilt has been proven beyond a reasonable doubt by the United States; +- e. the right at trial to confront and cross-examine witnesses against the defendant; +- f. the right to compel or subpoena the testimony of witnesses and other evidence to present at trial; +- g. the right at trial to testify or to remain silent, and the right that such silence could not be used against the defendant; + - h. the right to challenge the sufficiency of the Information; and + - i. the right to appeal any pretrial rulings or a finding of guilt. + +7. Government's Right to Disclose Information to the Court: The Office of the United States Attorney for the Southern District of Florida (hereinafter "Office") reserves the right to inform the Court and the Probation Office of all facts pertinent to the sentencing process, including all relevant information concerning the offenses committed, whether charged or not, as well as concerning the defendant and the defendant's background. Subject only to the express terms of any agreed-upon sentencing recommendations contained in this Agreement, this Office further reserves the right to make any recommendation as to the quality and quantity of punishment. + +8. Acceptance of Responsibility: The United States and the defendant agree that. although not binding on the Probation Office or the Court, they will jointly recommend that the Court should reduce by two levels the sentencing guideline level applicable to the defendant's offense, pursuant to Section 3E1.1 of the Sentencing Guidelines, based upon the defendant's recognition and affirmative acceptance of personal responsibility. If at the time of sentencing the defendant's offense level is determined to be 16 or greater, and the defendant complies with the requirements of Section 3E1.1, the government will make a motion requesting an additional one-level decrease pursuant to Section 3E1.1(b) of the Sentencing Guidelines, stating that the defendant has assisted authorities in the investigation or prosecution of his own misconduct by timely notifying authorities of his intention to enter a plea of guilty, thereby permitting the government to avoid preparing for trial and permitting the government and the Court to allocate their resources efficiently. + +9. Limitation on Joint Sentencing Recommendations: The defendant understands and agrees that the United States will not be required to make the motion and sentencing recommendation set forth in paragraph (8) if the defendant: (a) fails or refuses to make a full, accurate and complete disclosure to the Probation Office of the circumstances surrounding the relevant offense conduct; (b) is found to have misrepresented facts to the government prior to entering this plea agreement; (c) commits any misconduct after entering into this plea agreement, including but not limited to committing a state or federal offense, violating any term of release, or making false statements or misrepresentations to any governmental entity + +or official; or (d) fails to abide by the terms of the side agreement between the defendant and this Office. + +10. Factual Proffer: The defendant, his counsel, and the United States further agree that, had this case proceeded to trial, the United States would have introduced the following evidence, which is sufficient to support a plea of guilty and proves beyond a reasonable doubt that the defendant is guilty of the charge contained in the Information. + +a. The defendant was formerly employed as a property manager by Jeffrey Epstein ("Epstein"), and lived and worked at Epstein's residence in Palm Beach, Florida, in the Southern District of Florida, in 2004 and 2005. + +b. In 2006, the defendant was interviewed by members of the Town of Palm Beach Police Department regarding allegations of illicit sexual conduct between Epstein and several minor females. On January 18, 2007, Special Agents of the Federal Bureau of Investigation also interviewed the defendant in connection with a federal grand jury investigation of Epstein's criminal activity. The defendant was asked by law enforcement to produce any information or evidence in his possession related to Epstein's criminal activity. The defendant also was provided with contact information for FBI Special Agents and was asked to contact them if he remembered or discovered any further information. + +c. In July and August 2009, the defendant was subpoenaed to appear for deposition in connection with several civil lawsuits filed against Epstein by minor female victims of his criminal conduct. The subpoenas called for the defendant to appear and produce documents related to Epstein. The defendant appeared for deposition but did not produce any documents. + +d. Beginning in August 2009, after the conclusion of the second deposition, the defendant contacted a cooperating witness (CW) and informed the CW that he had additional information that he had not previously disclosed to any law enforcement agency or any of the civil attorneys, including lists of "hundreds" of additional victims and their telephone numbers. The defendant agreed to turn this information over to the CW in exchange for \$50,000. The CW tried to convince the defendant to turn over the material voluntarily, but the defendant refused. The CW then approached law enforcement. During a consensually monitored telephone call on October 28, 2009, the CW told the defendant that he would be contacted by an associate of the CW regarding the purchase of the material. The "associate" was, in fact, an undercover Special Agent of the Federal Bureau of Investigation ("UCE"). + +e. On October 29, 2009, the UCE contacted the defendant via telephone. The defendant again explained that he would only turn over the information in exchange for monetary compensation. During the conversation, the defendant admitted that he knew that the information was relevant to the FBI's criminal investigation and was called for by the investigation. The defendant explained that he had not turned over the information to the FBI because: (1) it was his "property" and he should be compensated for it; and (2) he was afraid that Epstein would make him "disappear" or otherwise harm him, and the information was his "insurance policy." + +1. On November 3, 2009, the defendant met with the UCE at a + +predetermined location. During the meeting, the defendant produced a small bound book and several sheets of legal pad paper containing hand-written notes. The defendant discussed in detail the information contained within the book, which he admitted removing from Epstein's home without Epstein's permission, and identified important information to the UCE. In addition, the defendant admitted that he had previously lied to the FBI during the course of the federal criminal investigation of Epstein. The defendant asked the UCE about the \$50,000.00, took possession of the money, and began counting it. The defendant was then detained for Obstruction of Official Proceedings, in violation of Title 18, United States Code, Section 1512(c), and questioned. After Miranda warnings were administered by agents, the defendant waived his rights and signed a written waiver of those rights. The defendant admitted that he had the documents and book in his possession and had never turned them over to local law enforcement or the FBI. In addition, the defendant advised he had witnessed naked girls whom he believed were minors at the pool area of Epstein's home, knew that his former employer was engaging in sexual contact with underage girls, and had viewed pornographic images of underage girls on computers in Epstein's home. + +g. The items that the defendant attempted to sell to the UCE were reviewed by an FBI Special Agent involved in the federal grand jury investigation of Epstein. As the defendant had described, the items contained information material to the Epstein investigation, including names of material witnesses and additional victims. The items also would have corroborated testimony of victims already identified. Had the items been produced in response to the inquiries of the state or federal authorities, or if the defendant had + +contacted the federal authorities at any time after his initial interview to produce these items, the materials would have been presented to the federal grand jury. + +11. No Promises or Representations Regarding Ultimate Sentence: The defendant is aware that the sentence has not yet been determined by the Court. The defendant also is aware that any estimate of the probable sentencing range or sentence that the defendant may receive, whether that estimate comes from the defendant's attorney, the government, or the probation office, is a prediction, not a promise, and is not binding on the government, the probation office, or the Court. The defendant understands further that any recommendation that the government makes to the Court as to sentencing, whether pursuant to this agreement or otherwise, is not binding on the Court and the Court may disregard the recommendation in its entirety. The defendant acknowledges that no one has promised or guaranteed what sentence the Court will impose. The defendant understands and acknowledges, as previously acknowledged in paragraph 5 above, that the defendant may not withdraw his plea based upon (a) the Court's decision not to accept a sentencing recommendation made by the defendant and/or the government, or (b) the fact that he received an incorrect estimate of the sentence that he would receive, whether that estimate came from his attorney. the United States, and/or the Probation Office. + +12. Voluntariness of Plea: The defendant agrees that he has entered into this Plea Agreement freely and voluntarily, and that no threats or promises, other than the promises contained in this written Plea Agreement, were made to induce the defendant to enter his plea of guilty. + +13. Consent to Forfeiture/Disposal/Destruction of Items: The defendant agrees to forfeit all interests in any items seized during the course of this investigation, whether the defendant currently owns, has previously owned, or over which the defendant currently, or has in the past, exercised control, directly or indirectly. Defendant agrees to hold the United States, its agents, and employees harmless from any claims whatsoever in connection with the forfeiture, seizure, or destruction of property covered by this agreement. The defendant agrees that this property may be destroyed or disposed of in accordance with the policies and procedures of the custodial agency. The defendant further agrees to waive all constitutional and statutory challenges in any manner (including direct appeal, habeas corpus, or any other means) to any destruction or disposal of property carried out in accordance with this Plea Agreement on any grounds, including that the forfeiture constitutes an excessive fine or punishment. Defendant acknowledges that all property covered by this agreement is subject to forfeiture as property involved in illegal conduct giving rise to forfeiture. + +14. Appeal Waiver: The defendant is aware that Title 18, United States Code, Section 3742 affords the defendant the right to appeal the sentence imposed in this case. Acknowledging this, in exchange for the undertakings made by the United States in this plea agreement, the defendant hereby waives all rights conferred by Section 3742 to appeal any sentence imposed, including any restitution order, or to appeal the manner in which the sentence was imposed, unless the sentence exceeds the maximum permitted by statute or is the result of an upward departure and/or a variance from the guideline range that the court establishes at sentencing. The defendant further understands that nothing in this agreement shall affect the government's right and/or duty to appeal as set forth in Title 18, United States Code, Section 3742(b). However, if the United States appeals the defendant's sentence pursuant to Section 3742(b), the defendant shall be released from the above waiver of appellate rights. By signing this agreement, the defendant acknowledges that he has discussed the appeal waiver set forth in this agreement with his attorney. The defendant further agrees, together with the United States, to request that the district court enter a specific finding that the defendant's waiver of his right to appeal the sentence to be imposed in this case was knowing and voluntary. + +15. Entire Agreement: This is the entire agreement and understanding between the United States and the defendant. There are no other agreements, promises, representations, or understandings unless contained in a side letter from the United States Attorney's Office executed by all panics and counsel prior to the change of plea. + +> JEFFREY H. SLOMAN UNITED STATES ATTORNEY + +Date: By: + +ASSISTANT UNITED STATES ATTORNEY + +Date: By: + +Date: By: + +ALFREDO RODRIGUEZ, DEFENDANT + +DAVE LEE BRANNON, ESQ. 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9:08-cv-80119-ICAM Doe I. Epstein Order + +Date: Thu, 28 Jan 2010 13:46:23 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the C1VUECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered on 1/28/2010 at 8:46 AM EST and filed on 1/27/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80119-KAM + +Filer: + +Document Number: 455 + +## Docket Text: + +ORDER Affirming Magistrate Judge Johnson's Discovery Order; denying [3271 Appeal of Magistrate Judge Decision to District Court filed by Jane Doe. Signed by Judge Kenneth A. Marra on 1/27/2010. (asl) + +9:08-cv-80119-KAM Notice has been electronically mailed to: + +Adam D. Horowitz ahorowitz@sexabuseattorney.com + +Ann Marie C. Villafana ann.marie.c.villafana@usdoj.gov + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Isidro Manuel Garcia isidrogarcia®bellsouth.net + +Jack Alan Goldberger jagesq®bellsouth.net, nalanis®agwpa.com + +Jack Patrick Hill jph@searcylaw.com, clw@searcylaw.com, kmc@searcylaw.com, s.slater@searcylaw.com, sas@searcylaw.com, vat@searcylaw.com + +Paul G. Cassell cassellp@law.utah.edu + +Richard Horace Willits lawyenvillits@aol.com, reelrhw@hotmail.com + +Robert C. Josefsberg rjosefsberg@podhurst.com, amann@podhurst.com, bertpatton®podhurst.com, mestrada@podhurst.com + +Robert Deweese Critton , Jr rcrit@bciclaw.com, bobbie@bciclaw.com + +Stuart S. Mermelstein ssm@sexabuseattomey.com, jarbout®sexabuseattomey.com, Irivera@sexabuseattomey.com + +9:08-cv-80119-1CAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +Martin G. Weinberg 20 Park Plaza Boston, MA 02116 + +The following document(s) are associated with this transaction: + +Document description:Main Document + +Original filename:n/a + +Electronic document Stamp: + +[STAMP dcecfStamp\_1E 1105629215 [Date=1/28/2010] [FileNumber=7199590-0 ] [09cb05dc068bfb64b868f49008e4429f52a654dea719ad35d7634b6f68920bc1e24 Ifl7ef29b9902a2068b337449fda962547d4e8dd25bd614606410f760ca8f]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00207059/EFTA00207059.metadata.json b/marker2/ds9/EFTA00207059/EFTA00207059.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..7b69679776a8256d509eb7f4a4f5fa8711ce0c22 --- /dev/null +++ b/marker2/ds9/EFTA00207059/EFTA00207059.metadata.json @@ -0,0 +1,135 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207059.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2841, + "elapsed_seconds": 1.24, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 308.61 + ], + [ + 185.88690185546875, + 308.61 + ], + [ + 185.88690185546875, + 324.3170471191406 + ], + [ + 30.6, + 324.3170471191406 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 422.82 + ], + [ + 101.52233123779297, + 422.82 + ], + [ + 101.52233123779297, + 438.3170471191406 + ], + [ + 30.6, + 438.3170471191406 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 70 + ], + [ + "Line", + 35 + ], + [ + "Text", + 24 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 41 + ], + [ + "Line", + 21 + ], + [ + "Text", + 13 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207059" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207061/EFTA00207061.md b/marker2/ds9/EFTA00207061/EFTA00207061.md new file mode 100644 index 0000000000000000000000000000000000000000..aab799c505ba2218d5d273ca8766ac5f88542018 --- /dev/null +++ b/marker2/ds9/EFTA00207061/EFTA00207061.md @@ -0,0 +1,55 @@ +To: "flsd\_cmecf notice@flsd.uscourts.gov" + +Subject: Activity in Case 9:08-cv-80893-KAM Doe 1 Epstein Notification of Ninety Days Expiring + +Date: Wed, 27 Jan 2010 20:34:28 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered by Pike, Michael on 1/27/2010 at 3:34 PM EST and filed on 1/27/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80893-KAM + +Filer: Jeffrey Epstein + +Document Number: 124 + +## Docket Text: + +Notification of Ninety Days Expiring by Jeffrey Epstein re [87] Defendant's MOTION to Dismiss [38] Amended Complaint filed by Jeffrey Epstein (Pike, Michael) + +9:08-cv-80893-KAM Notice has been electronically mailed to: + +Ann Marie C. Villafana ann.marie.c.villafana@usdoj.gov + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Jack Alan Goldberger jagesq@bellsouth.net, nalanis®agwpa.com + +Michael James Pike MPike@bciclaw.com, bobbie@bciclaw.com, jcadwell@bciclaw.com + +Paul G. Cassell cassellp@law.utah.edu + +Robert Deweese Critton , Jr rcrit@bciclaw.com, bobbie@bciclaw.com + +9:08-cv-80893-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. 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Here it is. + +<> \ No newline at end of file diff --git a/marker2/ds9/EFTA00207063/EFTA00207063.metadata.json b/marker2/ds9/EFTA00207063/EFTA00207063.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..9229514089abded1e25718eb49c65882d8816e51 --- /dev/null +++ b/marker2/ds9/EFTA00207063/EFTA00207063.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207063.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 261, + "elapsed_seconds": 0.45, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 19 + ], + [ + "Line", + 9 + ], + [ + "Text", + 8 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207063" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207064/EFTA00207064.md b/marker2/ds9/EFTA00207064/EFTA00207064.md new file mode 100644 index 0000000000000000000000000000000000000000..705fdb51db8b9ef9019b651409de3cf63c8af050 --- /dev/null +++ b/marker2/ds9/EFTA00207064/EFTA00207064.md @@ -0,0 +1,47 @@ +![](_page_0_Picture_0.jpeg) + +## U.S. Department of Justice + +United States Attorney Southern District of Florida + +500 E. Broward Boulevard. 7th Floor Ft. Lauderdale, FL 33394 (954)660-5946 + +February 2010 + +Dave Lee Brannon, Esq. Federal Public Defender's Office 450 Australian Avenue, Suite 500 West Palm Beach, FL 33401 + +Re: OrSal + +Dear Mr. Brannon: + +This letter (hereinafter referred to as the "side letter") contains additional terms of the plea agreement between the United States Attorney's Office for the Southern District of Florida (hereinafter referred to as "this Office") and your client, Alfredo Rodriguez (hereinafter referred to as "the defendant"). + +The defendant agrees that he shall cooperate fully with this Office by: + +(a) providing truthful and complete information and testimony, and producing documents, records and other evidence, when called upon by this Office or any other United States Attorney's Office, whether in interviews, before a grand jury, or at any trial or other court proceeding, specifically by providing documents and information and testifying truthfully and completely regarding Jeffrey Epstein and any co-conspirator(s) of Jeffrey Epstein; and + +(b) appearing at such grand jury proceedings, hearings, trials, and other judicial proceedings, and at meetings, as may be required by this Office or any other United States Attorney's Office. + +This Office reserves the right to evaluate the nature and extent of the defendant's cooperation and to make the defendant's cooperation, or lack thereof, known to the court at the time of sentencing. If in the sole and unreviewable judgment of this Office the defendant's cooperation is of such quality and significance to the investigation or prosecution + +DAVE LEE BRANNON, ESQ. SIDE-LETTER AGREEMENT RE ALFREDO RODRIGUEZ PAGE 2 + +of other criminal matters as to warrant the court's downward departure from the advisory sentence calculated under the Sentencing Guidelines, this Office may at or before sentencing make a motion consistent with the intent of Section 5K1.1 of the Sentencing Guidelines prior to sentencing, or Rule 35 of the Federal Rules of Criminal Procedure subsequent to sentencing, reflecting that the defendant has provided substantial assistance and recommending that the defendant's sentence be reduced from the advisory sentence suggested by the Sentencing Guidelines. The defendant acknowledges and agrees, however, that nothing in this Agreement may be construed to require this Office to file any such motion(s) and that this Office's assessment of the nature, value, truthfulness, completeness, and accuracy of the defendant's cooperation shall be binding insofar as the appropriateness of this Office's filing of any such motion is concerned. + +The defendant understands and acknowledges that the Court is under no obligation to grant the motion(s) referred to in this agreement should the government exercise its discretion to file any such motion. The defendant also understands and acknowledges that any decision to reduce the defendant's sentence based upon his cooperation lies exclusively with the Court and that the Court is under no obligation to reduce the defendant's sentence because of the defendant's cooperation. + +Sincerely, + +JEFFREY H. SLOMAN UNITED STATES ATTORNEY + +Date: By: + +![](_page_1_Picture_7.jpeg) + +Date: By: + +DAVE LEE BRANNON, ESQ. ATTORNEY FOR DEFENDANT + +Date: By: + +!%LI CUL) Al/LJAILIAJ CL. ULVL1NLlt1.1N I \ No newline at end of file diff --git a/marker2/ds9/EFTA00207064/EFTA00207064.metadata.json b/marker2/ds9/EFTA00207064/EFTA00207064.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..90f1a17fc99087305406cece4d7be77d76cd0def --- /dev/null +++ b/marker2/ds9/EFTA00207064/EFTA00207064.metadata.json @@ -0,0 +1,123 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207064.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 3440, + "elapsed_seconds": 0.88, + "image_assets": [ + "_page_0_Picture_0.jpeg", + "_page_1_Picture_7.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "U.S. Department of Justice", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 162.18, + 51.84 + ], + [ + 305.44921875, + 51.84 + ], + [ + 305.44921875, + 67.61248779296875 + ], + [ + 162.18, + 67.61248779296875 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 65 + ], + [ + "Line", + 32 + ], + [ + "Text", + 11 + ], + [ + "Picture", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 63 + ], + [ + "Line", + 31 + ], + [ + "Text", + 13 + ], + [ + "PageFooter", + 2 + ], + [ + "Picture", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207064" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207064/_page_0_Picture_0.jpeg b/marker2/ds9/EFTA00207064/_page_0_Picture_0.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..b1d91fb768615b75ceaef175e6f1d2a4a3478015 --- /dev/null +++ b/marker2/ds9/EFTA00207064/_page_0_Picture_0.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:e2d4fbf93279cbd9c5b1d4740c6c4ad73d8b708fc59979f9af01ebd0ed455b42 +size 10413 diff --git a/marker2/ds9/EFTA00207064/_page_1_Picture_7.jpeg b/marker2/ds9/EFTA00207064/_page_1_Picture_7.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..6114e16c3a924bdc32cb5ca7a7c565837924b766 --- /dev/null +++ b/marker2/ds9/EFTA00207064/_page_1_Picture_7.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:005b30717e72bcbbf7d0f3bf0f3560d8ba9fbbf820b7276d0bdc3ec0476ac34f +size 5814 diff --git a/marker2/ds9/EFTA00207066/EFTA00207066.md b/marker2/ds9/EFTA00207066/EFTA00207066.md new file mode 100644 index 0000000000000000000000000000000000000000..68e8d74eff711697d6e724a3cd797f3986d7228b --- /dev/null +++ b/marker2/ds9/EFTA00207066/EFTA00207066.md @@ -0,0 +1,13 @@ +Subject: Re: Epstein Meeting + +Date: Tue, 26 Jan 2010 18:38:15 +0000 + +Importance: Normal + +10-4! + +Sent: Tue Jan 26 13:34:22 2010 + +Subject: Epstein Meeting + +Is scheduled for Monday, February 15t at 1:00 in Miami. Can you check with Mike and see who, if anyone else, should go? \ No newline at end of file diff --git a/marker2/ds9/EFTA00207066/EFTA00207066.metadata.json b/marker2/ds9/EFTA00207066/EFTA00207066.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..9543925be7481cac512476c37c834f2cac249150 --- /dev/null +++ b/marker2/ds9/EFTA00207066/EFTA00207066.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207066.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 273, + "elapsed_seconds": 0.43, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 19 + ], + [ + "Line", + 9 + ], + [ + "Text", + 7 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207066" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207067/EFTA00207067.md b/marker2/ds9/EFTA00207067/EFTA00207067.md new file mode 100644 index 0000000000000000000000000000000000000000..498d7856498e7af8d77dfb296fc05c05b7ad6af9 --- /dev/null +++ b/marker2/ds9/EFTA00207067/EFTA00207067.md @@ -0,0 +1,69 @@ +To: "flsd\_cmecf notice®flsd.uscourts.gov" + +Subject: Activity in Case 9:08-cv-80119-ICAM Doe I. Epstein Notice (Other) + +Date: Wed, 03 Feb 2010 20:52:36 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered by Pike, Michael on 2/3/2010 at 3:52 PM EST and filed on 2/3/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80119-KAM + +Filer: Jeffrey Epstein + +Document Number:459 + +## Docket Text: + +NOTICE by Jeffrey Epstein Re-Notice (Date Change Only) of independent Medical Examination of Plaintiff, Jane Doe #7 (Pike, Michael) + +9:08-cv-80119-ICAM Notice has been electronically mailed to: + +Adam D. Horowitz ahorowitz@sexabuseattomey.com + +Ann Marie C. Villafana ann.marie.c.villafana@usdoj.gov + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Isidro Manuel Garcia isidrogarcia®bellsouth.net + +Jack Alan Goldberger jagesq®bellsouth.net, nalanis®agwpa.com + +Jack Patrick Hill jph@searcylaw.com, clw@searcylaw.com, lcmc@searcylaw.com, s.slater@searcylaw.com, sas®searcylaw.com, vat@searcylaw.com + +Jeffrey Marc Herman jherman@hermanlaw.com + +Richard Horace Willits lawyerwillits@aol.com, reelrhw@hotmail.com + +Robert C. Josefsberg rjosefsberg@podhurst.com, amann@podhurst.com, bertpatton®podhurst.com, mestrada@podhurst.com + +Robert Deweese Critton , Jr rcrit@bciclaw.com, bobbie@bciclaw.com + +Stuart S. Mennelstein ssm@sexabuseattorney.com, jarbour®sexabuseattomey.com, Irivera@sexabuseattomey.com + +9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +Martin G. Weinberg 20 Park Plaza Boston, MA 02116 + +The following document(s) are associated with this transaction: + +Document description:Main Document + +Original filenamem/a + +Electronic document Stamp: + +[STAMP dcecfStamp\_11: 1105629215 [Date=213/2010] [FileNumber=7223796-0] [9297 fedde9a3668 I d474b2defa65H765d41714203c4bb958b6fef4061b3bcaa40cf fa3b76c31c973885dfe49341.378b0756ecd9c6de6a0ae16566cf8eb04292]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00207067/EFTA00207067.metadata.json b/marker2/ds9/EFTA00207067/EFTA00207067.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..c80032f2673049b9c695a8d873c8c4ced1c9eb46 --- /dev/null +++ b/marker2/ds9/EFTA00207067/EFTA00207067.metadata.json @@ -0,0 +1,135 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207067.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2817, + "elapsed_seconds": 1.25, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 308.61 + ], + [ + 185.88690185546875, + 308.61 + ], + [ + 185.88690185546875, + 324.3170471191406 + ], + [ + 30.6, + 324.3170471191406 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 422.82 + ], + [ + 101.65031433105469, + 422.82 + ], + [ + 101.65031433105469, + 438.6035461425781 + ], + [ + 30.6, + 438.6035461425781 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 69 + ], + [ + "Line", + 35 + ], + [ + "Text", + 25 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 39 + ], + [ + "Line", + 20 + ], + [ + "Text", + 12 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207067" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207069/EFTA00207069.md b/marker2/ds9/EFTA00207069/EFTA00207069.md new file mode 100644 index 0000000000000000000000000000000000000000..421cfde1393241ae4d2378029a37df4a167299e2 --- /dev/null +++ b/marker2/ds9/EFTA00207069/EFTA00207069.md @@ -0,0 +1,61 @@ +From: " ge c l > To: ' - - 11 ci + +Subject: Activity in Case 9:08-cv-80119-ICAM Doe I. Epstein Clerks Notice of Docket Correction and Instruction to Filer - Attorney + +Date: Tue, 02 Feb 2010 18:47:55 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CMIECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered on 2/2/2010 at 1:47 PM EST and filed on 2/2/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80 11 9-ICAM + +Filer: + +Document Number: 458(No document attached) + +Docket Text: + +Clerks Notice to Filer re [456] Response to Motion. Two or More Document Events Filed as One; ERROR - Only one event was selected by the Filer but more than one event was applicable to the document filed. The docket entry was corrected by the Clerk. It is not necessary to refile this document but in the future, the Filer must select all applicable events. (tp) + +9:08-cv-80119-ICAM Notice has been electronically mailed to: + +Adam D. Horowitz + +M U + +Bradley James Edwards + +Isidro Manuel Garcia + +Jack Alan Goldberger i + +Katherine Warthen Ezell + +Michael James Pike + +Paul G. Cassell + +Richard Horace Willits + +Robert I. Josefsberg + +Robert Deweese Critton , Jr + +Stuart S. Merrnelstein + +9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1 + +Martin G. Weinberg 20 Park Plaza Boston, MA 02116 \ No newline at end of file diff --git a/marker2/ds9/EFTA00207069/EFTA00207069.metadata.json b/marker2/ds9/EFTA00207069/EFTA00207069.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b75752a5abeaeb353aa1e381b9656e89564e00da --- /dev/null +++ b/marker2/ds9/EFTA00207069/EFTA00207069.metadata.json @@ -0,0 +1,112 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207069.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2112, + "elapsed_seconds": 1.07, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 31.212, + 322.38 + ], + [ + 184.37722778320312, + 322.38 + ], + [ + 184.37722778320312, + 338.10357666015625 + ], + [ + 31.212, + 338.10357666015625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 79 + ], + [ + "Line", + 38 + ], + [ + "Text", + 22 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 29 + ], + [ + "Line", + 14 + ], + [ + "Text", + 10 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207069" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207071/EFTA00207071.md b/marker2/ds9/EFTA00207071/EFTA00207071.md new file mode 100644 index 0000000000000000000000000000000000000000..4e528099377bfd88bad9684f4532fd4269caca39 --- /dev/null +++ b/marker2/ds9/EFTA00207071/EFTA00207071.md @@ -0,0 +1,71 @@ +From: "cmecfautosender®flsd.uscourts.gov" + +To: "flsd\_cmecf notice®flsd.uscourts.gov" + +Subject: Activity in Case 9:08-cv-80119-ICAM Doe I. Epstein Notice (Other) + +Date: Wed, 03 Feb 2010 21:46:23 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the C1VUECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered by Pike, Michael on 2/3/2010 at 4:46 PM EST and filed on 2/3/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80119-1CAM + +Filer: Jeffrey Epstein + +Document Number:461 + +## Docket Text: + +NOTICE by Jeffrey Epstein Re-Notice (Date & Location Change) of Independent Medical Examination of Plaintiff, Jane Doe #7 (Pike, Michael) + +9:08-cv-80119-ICAM Notice has been electronically mailed to: + +Adam D. Horowitz ahorowitz@sezabuseattomey.com + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Isidro Manuel Garcia isidrogarcia@bellsouth.net + +Jack Alan Goldberger jagesq@bellsouth.net, nalanis@agwpa.com + +Jack Patrick Hill jph@searcylaw.com, clw@searcylaw.com, kmc@searcylaw.com, s.slater@searcylaw.com, sas@searcylaw.com, vat@searcylaw.com + +Jeffrey Marc Herman jherman@hermanlaw.com + +Richard Horace Willits lawyerwillits@aol.com, reelrhw@hotmail.com + +Robert C. Josefsberg rjosefsberg@podhurst.com, amann@podhurst.com, bertpatton®podhurst.com, mestrada@podhurst.com + +Robert Deweese Critton , Jr rcrit@bciclaw.com, bobbie@bciclaw.com + +Stuart S. Mennelstein ssm@sexabuseattorney.com, jarbour®sexabuseattomey.com, Irivera@sexabuseattomey.com + +9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +Martin G. Weinberg + +![](_page_1_Picture_7.jpeg) + +The following document(s) are associated with this transaction: + +## Document description:Main Document + +Original filenamem/a + +## Electronic document Stamp: + +[STAMP dcecfStamp\_11: 1105629215 [Date=2/3/2010] [FileNumber=7224328-0] [8efe15aI12442a1afld87b7fb0eb2059cdd02edfb8e7eedc2dc0fb8ed03a83ca158e 9c9a508a5aa4b6af7917fc0611ce8634bf841:422d6766930elae54ff496a]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00207071/EFTA00207071.metadata.json b/marker2/ds9/EFTA00207071/EFTA00207071.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..461e0f659ab03ddc06bb276034a081cb817caa5a --- /dev/null +++ b/marker2/ds9/EFTA00207071/EFTA00207071.metadata.json @@ -0,0 +1,191 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207071.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2849, + "elapsed_seconds": 1.52, + "image_assets": [ + "_page_1_Picture_7.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 307.79999999999995 + ], + [ + 184.3336639404297, + 307.79999999999995 + ], + [ + 184.3336639404297, + 324.23358154296875 + ], + [ + 30.6, + 324.23358154296875 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 422.82 + ], + [ + 101.65031433105469, + 422.82 + ], + [ + 101.65031433105469, + 438.6035461425781 + ], + [ + 30.6, + 438.6035461425781 + ] + ] + }, + { + "title": "Document description:Main Document", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 31.212, + 319.95000000000005 + ], + [ + 232.20684814453125, + 319.95000000000005 + ], + [ + 232.20684814453125, + 334.8170471191406 + ], + [ + 31.212, + 334.8170471191406 + ] + ] + }, + { + "title": "Electronic document Stamp:", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 31.212, + 347.49 + ], + [ + 183.31948852539062, + 347.49 + ], + [ + 183.31948852539062, + 361.8170471191406 + ], + [ + 31.212, + 361.8170471191406 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 67 + ], + [ + "Line", + 34 + ], + [ + "Text", + 24 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 35 + ], + [ + "Line", + 18 + ], + [ + "Text", + 10 + ], + [ + "SectionHeader", + 2 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207071" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207071/_page_1_Picture_7.jpeg b/marker2/ds9/EFTA00207071/_page_1_Picture_7.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..88067e37e50ffc6038d6c52fe3a477ab2579931b --- /dev/null +++ b/marker2/ds9/EFTA00207071/_page_1_Picture_7.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:9c8fb6363ebe450f6e68f5b24663359d579e0229243be0463eab3f92b0b140ad +size 2538 diff --git a/marker2/ds9/EFTA00207073/EFTA00207073.md b/marker2/ds9/EFTA00207073/EFTA00207073.md new file mode 100644 index 0000000000000000000000000000000000000000..9134eb095df039aee080197bd9804acefb29c4bb --- /dev/null +++ b/marker2/ds9/EFTA00207073/EFTA00207073.md @@ -0,0 +1,75 @@ +To: "flsd\_cmecf notice@flsd.uscourts.gov" + +Subject: Activity in Case 9:08-cv-80119-ICAM Doe I. Epstein Notice of Striking + +Date: Wed, 03 Feb 2010 21:45:08 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CMIECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered by Pike, Michael on 2/3/2010 at 4:45 PM EST and filed on 2/3/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80119-KAM + +Filer: Jeffrey Epstein + +Document Number:460 + +Docket Text: + +NOTICE of Striking [459] Notice (Other) filed by Jeffrey Epstein by Jeffrey Epstein (Pike, Michael) + +9:08-cv-80119-ICAM Notice has been electronically mailed to: + +Adam D. Horowitz ahorowitz@sexabuseattorney.com + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Isidro Manuel Garcia isidrogarcia®bellsouth.net + +Jack Alan Goldberger jagesq@bellsouth.net, nalanis®agwpa.com + +Jack Patrick Hill jph@searcylaw.com, clw@searcylaw.com, kmc@searcylaw.com, s.slater@searcylaw.com, sas®searcylaw.com, vat@searcylaw.com + +Jeffrey Marc Herman jherman@hermanlaw.com + +Richard Horace Willits lawyerwillits@aol.com, reelrhw@hotmail.com + +Robert C. Josefsberg rjosefsberg@podhurst.com, amann@podhurst.com, bertpatton®podhurst.com, mestrada@podhurst.com + +Robert Deweese Critton , Jr rcrit@bciclaw.com, bobbie@bciclaw.com + +Stuart S. Mennelstein ssm@sexabuseattorney.com, jarbour®sexabuseattomey.com, Irivera@sexabuseattomey.com + +9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +Martin G. Weinberg + +20 Park Plaza + +Boston, MA 02116 + +The following document(s) are associated with this transaction: + +Document description:Main Document + +Original filename:n/a + +Electronic document Stamp: + +[STAMP dcecfStamp\_ID= 1105629215 [Date=2/3/2010] [FileNumber=7224310-0] + +[5c956c28033bfffe52441545662e3561a35a7b5d59104aaab0413cb919fad717c195 + +0146644eb2be8dcdf5cdc3131573aed694f6dd8cddelb8b33a856e35d436]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00207073/EFTA00207073.metadata.json b/marker2/ds9/EFTA00207073/EFTA00207073.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f490f53a9d25b325a6b35516663642e8a6371b29 --- /dev/null +++ b/marker2/ds9/EFTA00207073/EFTA00207073.metadata.json @@ -0,0 +1,112 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207073.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2732, + "elapsed_seconds": 1.47, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 308.61 + ], + [ + 184.3336639404297, + 308.61 + ], + [ + 184.3336639404297, + 324.23358154296875 + ], + [ + 30.6, + 324.23358154296875 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 67 + ], + [ + "Line", + 34 + ], + [ + "Text", + 25 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 39 + ], + [ + "Line", + 20 + ], + [ + "Text", + 16 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207073" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207075/EFTA00207075.md b/marker2/ds9/EFTA00207075/EFTA00207075.md new file mode 100644 index 0000000000000000000000000000000000000000..2c1995f754eb89b912b05769dc7ca728811c94a7 --- /dev/null +++ b/marker2/ds9/EFTA00207075/EFTA00207075.md @@ -0,0 +1,75 @@ +To: "fisd\_cmecf noticegfisd.uscourts.gov" + +Subject: Activity in Case 9:08-cv-80119-KAM Doe I Epstein Order + +Date: Thu, 04 Feb 2010 19:27:35 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered on 2/4/2010 at 2:27 PM EST and filed on 2/4/2010 + +Case Name: Doe l Epstein + +Case Number: 9:08-cv-R0119-KAM + +Filer: + +Document Number:462 + +## Docket Text: + +OMNIBUS ORDER DENYING [211] Plaintiff's MOTION to Compel Answers to Request for Admissions filed by Jane Doe, DENYING [M] Plaintiffs MOTION to Compel Answers to Interrogatories filed by Jane Doe, DENYING [196] Plaintiffs MOTION to Compel Answers to Plaintiffs Interrogatories filed by Jane Doe, GRANTING IN PART AND DENYING IN PART [210] Plaintiffs MOTION to Compel Responses to Request for Production filed by Jane Doe, GRANTING IN PART AND DENYING IN PART [194] Plaintiffs MOTION to Compel Response to Plaintiffs Request for Production filed by Jane Doe, DENYING [195] Plaintiffs MOTION to Compel Response to Plaintiffs Request for Admissions filed by Jane Doe, Motions terminated: [211] Plaintiffs MOTION to Compel Answers to Request for Admissions filed by Jane Doe, [M] Plaintiffs MOTION to Compel Answers to Interrogatories filed by Jane Doe, [210] Plaintiffs MOTION to Compel Responses to Request for Production filed by Jane Doe. Signed by Magistrate Judge Linnea R. Johnson on 2/4/2010. (sa) + +9:08-cv-80119-KAM Notice has been electronically mailed to: + +Adam D. Horowitz ahorowitzgsexabuseattorney.com + +Jack Patrick Hill jph@searcylaw.com, clw@searcylaw.com, kmc@searcylaw.com, s.slater@searcylaw.com, sas@searcylaw.com, vat@searcylaw.com + +Jeffrey Marc Herman jherman@hermanlaw.com + +Katherine Warthen Ezell ICEzell@podhurst.com, mestrada@podhurst.com + +Michael James Pike MPike@bciclaw.com, bobbie@bciclaw.com, jcadwell@bciclaw.com + +Paul G. Cassell cassellp@law.utah.edu + +Richard Horace Willits lawyenvillits@aol.com, reelrhw@hotmail.com + +Robert C. Josefsberg rjosefsberg@podhurst.com, amann@podhurst.com, bertpatton®podhurst.com, mestrada@podhurst.com + +Robert Deweese Critton , Jr rcrit@bciclaw.com, bobbie@bciclaw.com + +Stuart S. Mermelstein ssm@sexabuseattomey.com, jarbout@sexabuseattomey.com, Irivera@sexabuseattomey.com + +9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +Martin G. Weinberg + +20 Park Plaza + +Boston, MA 02116 + +The following document(s) are associated with this transaction: + +Document description:Main Document + +Original filename:n/a + +Electronic document Stamp: + +[STAMP dcecfStamp\_11: 1105629215 [Date=2/4/2010] [FileNumber=7227692-0] + +[7839a3d298daa90483f8d499bc349ea2b41de91f6a7bb99238ea0b249d92009be03d + +32c19742fb4f6ff7c138c3e14fa5829ec957d 1205Ief6e27a7239e4571d3]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00207075/EFTA00207075.metadata.json b/marker2/ds9/EFTA00207075/EFTA00207075.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d423f586d19b6a4ff4132570c408ae3c3af8a0f0 --- /dev/null +++ b/marker2/ds9/EFTA00207075/EFTA00207075.metadata.json @@ -0,0 +1,135 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207075.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 3594, + "elapsed_seconds": 1.12, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 308.61 + ], + [ + 185.4475860595703, + 308.61 + ], + [ + 185.4475860595703, + 324.31707763671875 + ], + [ + 30.6, + 324.31707763671875 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 422.82 + ], + [ + 101.52233123779297, + 422.82 + ], + [ + 101.52233123779297, + 438.3170471191406 + ], + [ + 30.6, + 438.3170471191406 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 75 + ], + [ + "Line", + 38 + ], + [ + "Text", + 19 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 51 + ], + [ + "Line", + 26 + ], + [ + "Text", + 21 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207075" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207077/EFTA00207077.md b/marker2/ds9/EFTA00207077/EFTA00207077.md new file mode 100644 index 0000000000000000000000000000000000000000..2d8be4a41dcaaace20046131581a54d36efd3aeb --- /dev/null +++ b/marker2/ds9/EFTA00207077/EFTA00207077.md @@ -0,0 +1,26 @@ +To: "KATHERINE W. EZELL" + +Subject: RE: Epstein--NPA + +Date: Tue, 16 Feb 2010 23:46:18 +0000 + +Importance: Normal + +Attachments: Signed\_epstein\_addendum\_10\_30.pdf + +Here is the signed addendum. I looked through my electronic files but couldn't find that original wi my signature on it. The original document is up in WPB and I won't be up there until Friday. Can you wait until then? + +As to question 2, I believe that Lilly was in Florida (Miami), I was in Florida (WPB), and the others were in New York, but I don't know that for certain. I was the last to sign. + +You are welcome. Have a good night. + +Cc: ROBERT C. JOSEFSBERG; Amy Ederi + +Subject: Epstein--NPA + +Hi Marie, I know you are busy and hate to bother you, but I have a question and a request. + +- 1) Request—Can you provide me with ( pdf) copies of the signature pages of the NPA that contain your signature or that of anyone else on behalf of the United States Attorney. We have "umpteen" copies of the NPA, but cannot find any that contain that signature to either the Non-Prosecution Agreement or the Addendum. +- 2) Question—Where were the various signers of the NPA when they signed it, i.e., West Palm Beach, Miami, etc., and who and where was the last signer. (I am assuming that would have been you)? + +I hope all is well. Thank you as always, Kathy \ No newline at end of file diff --git a/marker2/ds9/EFTA00207077/EFTA00207077.metadata.json b/marker2/ds9/EFTA00207077/EFTA00207077.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..9204b51b728e81c1be312f4861b825a3261009cf --- /dev/null +++ b/marker2/ds9/EFTA00207077/EFTA00207077.metadata.json @@ -0,0 +1,62 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207077.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1335, + "elapsed_seconds": 0.69, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 43 + ], + [ + "Line", + 21 + ], + [ + "Text", + 13 + ], + [ + "ListItem", + 2 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207077" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207078/EFTA00207078.md b/marker2/ds9/EFTA00207078/EFTA00207078.md new file mode 100644 index 0000000000000000000000000000000000000000..180ea2d17f8322ce4caac036621406d1ccf5aae3 --- /dev/null +++ b/marker2/ds9/EFTA00207078/EFTA00207078.md @@ -0,0 +1,77 @@ +IN RE: + +**INVESTIGATION OF** + +**JEFFREY EPSTEIN** + +\_\_\_\_\_/ + +**ADDENDUM TO THE NON-PROSECUTION AGREEMENT** + +IT APPEARING that the parties seek to clarify certain provisions of page 4, paragraph 7 of the Non-Prosecution Agreement (hereinafter "paragraph 7"), that agreement is modified as follows: + +1. 7A. The United States has the right to assign to an independent third-party the responsibility for consulting with and, subject to the good faith approval of Epstein's counsel, selecting the attorney representative for the individuals identified under the Agreement. If the United States elects to assign this responsibility to an independent third-party, both the United States and Epstein retain the right to make good faith objections to the attorney representative suggested by the independent third-party prior to the final designation of the attorney representative. +2. 7B. The parties will jointly prepare a short written submission to the independent third-party regarding the role of the attorney representative and regarding Epstein's Agreement to pay such attorney representative his or her regular customary hourly rate for representing such victims subject to the provisions of paragraph C, infra. +3. 7C. Pursuant to additional paragraph 7A, Epstein has agreed to pay the fees of the attorney representative selected by the independent third party. This provision, however, shall not obligate Epstein to pay the fees and costs of contested litigation filed against him. Thus, if after consideration of potential settlements, an attorney representative elects to file a contested lawsuit pursuant to 18 U.S.C. s 2255 or elects to pursue any other contested remedy, the paragraph 7 obligation of the Agreement to pay the costs of the attorney representative, as opposed to any statutory or other obligations to pay reasonable attorneys fees and costs such as those contained in s 2255 to bear the costs of the attorney representative, shall cease. + +By signing this Addendum, Epstein asserts and certifies that the above has been read and explained to him. Epstein hereby, sates that he understands the clarifications to the Non-Prosecution Agreement and agrees to comply with them. + +Dated: /Oh 0 /07 + +Dated: / 14 fi rl- + +Dated: + +Dated: + +R. ALEXANDER ACOSTA UNITED STATES ATTORNEY + +By:4 ... + +GERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN + +LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR JEFFREY EPSTEIN + +By signing this Addendum, Epstein asserts and certifies that the above has been read and explained to him. Epstein hereby states that he understands the clarifications to the Non-Prosecution Agreement and agrees to comply with them. + +> R. ALEXANDER ACOSTA UNITED STATES ATTORNEY + +Dated: /0/3 0%7 + +Dated: + +Dated: + +Dated: + +By: A. MARIE VILLAFARA ASSISTANT U.S. ATTORNEY + +JEFFREY EPSTEIN + +D LEFCO IC ESQ. COUNSEL TO JEFF Y EPSTEIN + +LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR JEFFREY EPSTEIN + +By signing this Addendum, Epstein asserts and certifies that the above has been read and explained to him. Epstein hereby states that he understands the clarifications to the Non-Prosecution Agreement and agrees to comply with them. + +R. ALEXANDER ACOSTA +UNITED STATES ATTORNEY + +Dated: 10/30/07 + +By: + +![]()Dated: \_\_\_\_\_ + +\_\_\_\_\_ +JEFFREY EPSTEIN + +Dated: \_\_\_\_\_ + +\_\_\_\_\_ +GERALD LEFCOURT, ESQ. +COUNSEL TO JEFFREY EPSTEIN + +Dated: 10-29-07 + +![]() \ No newline at end of file diff --git a/marker2/ds9/EFTA00207078/EFTA00207078.metadata.json b/marker2/ds9/EFTA00207078/EFTA00207078.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..70bf7f20c42a00e4fcaf7b4155a0d02d20d81555 --- /dev/null +++ b/marker2/ds9/EFTA00207078/EFTA00207078.metadata.json @@ -0,0 +1,183 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207078.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 4, + "chars": 3355, + "elapsed_seconds": 7.08, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "INVESTIGATION OF", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 98.53200000000001, + 140.13 + ], + [ + 202.572, + 140.13 + ], + [ + 202.572, + 151.47 + ], + [ + 98.53200000000001, + 151.47 + ] + ] + }, + { + "title": "_____/ ADDENDUM TO THE NON-PROSECUTION AGREEMENT", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 98.53200000000001, + 206.54999999999998 + ], + [ + 377.604, + 206.54999999999998 + ], + [ + 377.604, + 218.70000000000002 + ], + [ + 98.53200000000001, + 218.70000000000002 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 6 + ], + [ + "SectionHeader", + 4 + ], + [ + "ListGroup", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 33 + ], + [ + "Line", + 15 + ], + [ + "Text", + 11 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 36 + ], + [ + "Line", + 18 + ], + [ + "Text", + 10 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 3, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 22 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207078" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207082/EFTA00207082.md b/marker2/ds9/EFTA00207082/EFTA00207082.md new file mode 100644 index 0000000000000000000000000000000000000000..afc9cf9b5401873f7ca70bad195bb1fe3bd362a8 --- /dev/null +++ b/marker2/ds9/EFTA00207082/EFTA00207082.md @@ -0,0 +1,77 @@ +To: "flsd\_cmecf notice®flsd.uscourts.gov" + +Subject: Activity in Case 9:08-cv-80119-ICAM Doe I. Epstein Notice (Other) + +Date: Fri, 05 Feb 2010 21:17:50 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the C1VUECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered by Pike, Michael on 2/5/2010 at 4:17 PM EST and filed on 2/5/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80119-KAM + +Filer: Jeffrey Epstein + +Document Number: 463 + +Docket Text: + +NOTICE by Jeffrey Epstein re [414] Order Notice of Filing Joint Agreed Order (Attachments: # (1) Text of Proposed Order Joint Agreed Order)(Pike, Michael) + +9:08-cv-80119-ICAM Notice has been electronically mailed to: + +Adam D. Horowitz ahorowitz@sexabuseattomey.com + +Ann Marie C. Villafana ann.marie.c.villafana@usdoj.gov + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Isidro Manuel Garcia isidrogarcia@bellsouth.net + +Jack Alan Goldberger jagesq@bellsouth.net, nalanis@agwpa.com + +Jack Patrick Hill jph@searcylaw.com, clw@searcylaw.com, lcmc@searcylaw.com, s.slater@searcylaw.com, sas@searcylaw.com, vat@searcylaw.com + +Jeffrey Marc Herman jherman@hermanlaw.com + +Richard Horace Willits lawyerwillits@aol.com, reelrhw@hotmail.com + +Robert C. Josefsberg rjosefsberg@podhurst.com, amann@podhurst.com, bertpatton®podhurst.com, mestrada@podhurst.com + +Robert Deweese Critton , Jr rcrit@bciclaw.com, bobbie@bciclaw.com + +Stuart S. Mennelstein ssm@sexabuseattorney.com, jarbour@sexabuseattomey.com, Irivera@sexabuseattomey.com + +9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +Martin G. Weinberg 20 Park Plaza Boston, MA 02116 + +The following document(s) are associated with this transaction: + +Document description:Main Document + +Original filenamem/a + +Electronic document Stamp: + +[STAMP dcecfStamp\_11: 1105629215 [Date=2/5/2010] [FileNumber=7233018-0] [4526cfd00cfdfbd7750c727365a29e937b4bbc8b9 I 4c82db3c1 eab900d42008cf809 96131fb9e554e9ee5b748e66a94d593 I e96062f2eb7f8d9567f7877ab2d23]] + +Document description:Text of Proposed Order Joint Agreed Order + +Original Iilename:n/a + +Electronic document Stamp: + +[STAMP dcecfStamp\_11: 1105629215 [Date=2/5/2010] [FileNumber=7233018-1] [9561be7824309becb8386feelc18c8b92c4 f8ea9b550874d090edfi50541168dbb2ad 63672a I 3cd395191d734c8a52a0d70e5232c891a0labl2ce89145b8224a4]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00207082/EFTA00207082.metadata.json b/marker2/ds9/EFTA00207082/EFTA00207082.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..ce05a67d8da925e07cdaeff178845543b81e83c8 --- /dev/null +++ b/marker2/ds9/EFTA00207082/EFTA00207082.metadata.json @@ -0,0 +1,112 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207082.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 3168, + "elapsed_seconds": 1.29, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 308.61 + ], + [ + 184.3336639404297, + 308.61 + ], + [ + 184.3336639404297, + 324.23358154296875 + ], + [ + 30.6, + 324.23358154296875 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 69 + ], + [ + "Line", + 35 + ], + [ + "Text", + 26 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 51 + ], + [ + "Line", + 26 + ], + [ + "Text", + 16 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207082" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207084/EFTA00207084.md b/marker2/ds9/EFTA00207084/EFTA00207084.md new file mode 100644 index 0000000000000000000000000000000000000000..29cbac18f7a015f7c88232f59fbcee72129dc80d --- /dev/null +++ b/marker2/ds9/EFTA00207084/EFTA00207084.md @@ -0,0 +1,57 @@ +From: ' II< To:' ' < + +Subject: Activity in Case 9:08-cv-80232-KAM Doe No. 3 I Epstein Order on Motion to Compel + +Date: Fri, 05 Feb 2010 14:59:30 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CIVUECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered on 2/5/2010 at 9:59 AM EST and filed on 2/5/2010 + +Case Name: Doe No. 31 Epstein + +Case Number: 9:08-cv-80232-KAM + +Filer: + +Document Number: 139 + +## Docket Text: + +ORDER Denying as Moot [51] Motion to Compel Answers To Interrogatories and Production of Documents. Signed by Magistrate Judge Linnea R. Johnson on 2/5/2010. (sa) + +9:08-cv-80232-KAM Notice has been electronically mailed to: + +Adam D. Horowitz + +M I. + +Jack Alan Goldberger • + +Jeffrey Marc Herman • + +Michael James Pike + +Robert Deweese Critton , Jr + +Stuart S. Mermelstein + +9:08-cv-80232-ICAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1 + +Document description:Main Document + +Original filename:n/a + +Electronic document Stamp: + +[STAMP dcecfStamp\_11: 1105629215 [Date=215/2010] [FileNumber=7230164-0] [6b75b07770e0eb45b8dda9091979920103e66df8824c9a096433c189b9e468401cbc 8c2ae3a36e65c047b0347a8291b94f5a805913edc7fdf638dcla228ce5e4]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00207084/EFTA00207084.metadata.json b/marker2/ds9/EFTA00207084/EFTA00207084.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..5071a4cf315994ef0cf877bef651c44fa8d59f8b --- /dev/null +++ b/marker2/ds9/EFTA00207084/EFTA00207084.metadata.json @@ -0,0 +1,135 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207084.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1964, + "elapsed_seconds": 1.14, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 308.61 + ], + [ + 184.3336639404297, + 308.61 + ], + [ + 184.3336639404297, + 324.23358154296875 + ], + [ + 30.6, + 324.23358154296875 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 422.82 + ], + [ + 101.52233123779297, + 422.82 + ], + [ + 101.52233123779297, + 438.3170471191406 + ], + [ + 30.6, + 438.3170471191406 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 71 + ], + [ + "Line", + 34 + ], + [ + "Text", + 23 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 15 + ], + [ + "Line", + 8 + ], + [ + "Text", + 5 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207084" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207086/EFTA00207086.md b/marker2/ds9/EFTA00207086/EFTA00207086.md new file mode 100644 index 0000000000000000000000000000000000000000..ea643c619a5bb1a4180b4597b3430a9729a48ae3 --- /dev/null +++ b/marker2/ds9/EFTA00207086/EFTA00207086.md @@ -0,0 +1,21 @@ +From: "ME MEIMIN> + +To:' + +Subject: Epstein + +Date: Tue, 09 Feb 2010 17:16:32 +0000 + +Importance: Normal + +Hi — We were just asked about our position on early termination of community control and/or transfer of Mr. Epstein to regular probation. I obviously am not well versed in how your programs work. I was looking over Chapter 948 and I was wondering whether Mr. Epstein was ever evaluated for treatment under 948.31, since he was convicted of "exploitation of a child ... for prostitution." I know the statute was enacted after he pled guilty, but it doesn't seem like there should be an Ex Post Facto issue since it isn't a punitive measure. + +Do you know whether he has completed "the sanctions imposed in the community control plan"? I don't want to give a position one way or the other if he isn't even eligible for modification or termination. + +Thank you. + +Assistant U.S. Attorney + +500 E. Broward Blvd, 7th Floor + +Ft Lauderdale, FL 33394 \ No newline at end of file diff --git a/marker2/ds9/EFTA00207086/EFTA00207086.metadata.json b/marker2/ds9/EFTA00207086/EFTA00207086.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d50f737d46144507ec38bd7c017e8b5f77366c77 --- /dev/null +++ b/marker2/ds9/EFTA00207086/EFTA00207086.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207086.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 940, + "elapsed_seconds": 0.7, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 35 + ], + [ + "Line", + 17 + ], + [ + "Text", + 14 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207086" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207087/EFTA00207087.md b/marker2/ds9/EFTA00207087/EFTA00207087.md new file mode 100644 index 0000000000000000000000000000000000000000..64079ee0e23a096a115b7eb0e0349137574a6665 --- /dev/null +++ b/marker2/ds9/EFTA00207087/EFTA00207087.md @@ -0,0 +1,77 @@ +To: "flsd\_cmecf notice@flsd.uscourts.gov" + +Subject: Activity in Case 9:08-cv-80119-ICAM Doe I. Epstein Motion for Extension of Time to File + +Date: Tue, 09 Feb 2010 14:18:26 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +### Notice of Electronic Filing + +The following transaction was entered by Pike, Michael on 2/9/2010 at 9:18 AM EST and filed on 2/9/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80119-KAM + +Filer: Jeffrey Epstein + +Document Number:464 + +# Docket Text: + +Defendant's MOTION for Extension of Time to File an Appeal Pursuant to Rule 4, in Connection with this Court's Order Dated February 4, 2010 (DE 462) by Jeffrey Epstein. (Attachments: # (1) Text of Proposed Order Proposed Order)(Pike, Michael) + +9:08-cv-80119-ICAM Notice has been electronically mailed to: + +Adam D. Horowitz ahorowitz@sexabuseattorney.com + +Ann Marie C. Villafana ann.marie.c.villafana@usdoj.gov + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Isidro Manuel Garcia isidrogarcia®bellsouth.net + +Jack Alan Goldberger jagesq@bellsouth.net, nalanis®agwpa.com + +Jack Patrick Hill jph@searcylaw.com, clw®searcylaw.com, lcmc@searcylaw.com, s.slater@searcylaw.com, sas®searcylaw.com, vat@searcylaw.com + +Paul G. Cassell cassellp@law.utah.edu + +Richard Horace Willits lawyenvillits@aol.com, reelrhw@hotmail.com + +Robert C. Josefsberg rjosefsberg@podhurst.com, amann@podhurst.com, bertpatton®podhurst.com, mestrada@podhurst.com + +Robert Deweese Critton , Jr rcrit@bciclaw.com, bobbie@bciclaw.com + +Stuart S. Mermelstein ssm@sexabuseattomey.com, jarbout@sexabuseattomey.com, Irivera@sexabuseattomey.com + +9:08-cv-80119-1CAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +Martin G. Weinberg 20 Park Plaza Boston, MA 02116 + +The following document(s) are associated with this transaction: + +# Document description:Main Document + +Original filename:n/a + +#### Electronic document Stamp: + +[STAMP dcecfStamp\_11: 1105629215 [Date=2/9/2010] [FileNumber=723975 I-0] [7 fla2aeda2a9a7 fl 19277561ef7be8d886d1deecfcic82d931643261fa43f7109021 49263d8284b4fa5116963048422f255bb36335c902fbflf28a0fbOa62d9e]] + +Document description:Text of Proposed Order Proposed Order + +### Original filenamem/a + +#### Electronic document Stamp: + +[STAMP dcecfStamp\_IT2 1105629215 [Date=2/9/2010] [FileNumber=723975 I -1] [9665292b7ab7614ece91044408bcafe2cbae74bb84d40e87bf5e67532ab6398a244f la749d9ba14066beObb2b9ecad2191339213 14287033 dd27cca8e9637f46]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00207087/EFTA00207087.metadata.json b/marker2/ds9/EFTA00207087/EFTA00207087.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..43bd62777c15e1ad3c0829f6dbbe789a40a0d603 --- /dev/null +++ b/marker2/ds9/EFTA00207087/EFTA00207087.metadata.json @@ -0,0 +1,231 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207087.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 3286, + "elapsed_seconds": 1.23, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 308.61 + ], + [ + 184.3336639404297, + 308.61 + ], + [ + 184.3336639404297, + 324.23358154296875 + ], + [ + 30.6, + 324.23358154296875 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 422.82 + ], + [ + 101.65031433105469, + 422.82 + ], + [ + 101.65031433105469, + 438.6035461425781 + ], + [ + 30.6, + 438.6035461425781 + ] + ] + }, + { + "title": "Document description:Main Document", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 31.212, + 332.90999999999997 + ], + [ + 231.73399353027344, + 332.90999999999997 + ], + [ + 231.73399353027344, + 348.7330322265625 + ], + [ + 31.212, + 348.7330322265625 + ] + ] + }, + { + "title": "Electronic document Stamp:", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 31.212, + 360.45000000000005 + ], + [ + 183.70465087890625, + 360.45000000000005 + ], + [ + 183.70465087890625, + 375.7330322265625 + ], + [ + 31.212, + 375.7330322265625 + ] + ] + }, + { + "title": "Original filenamem/a", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 31.212, + 427.68 + ], + [ + 145.65615844726562, + 427.68 + ], + [ + 145.65615844726562, + 443.2330322265625 + ], + [ + 31.212, + 443.2330322265625 + ] + ] + }, + { + "title": "Electronic document Stamp:", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 31.212, + 441.45000000000005 + ], + [ + 183.70465087890625, + 441.45000000000005 + ], + [ + 183.70465087890625, + 456.7330322265625 + ], + [ + 31.212, + 456.7330322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 69 + ], + [ + "Line", + 35 + ], + [ + "Text", + 24 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 53 + ], + [ + "Line", + 27 + ], + [ + "Text", + 13 + ], + [ + "SectionHeader", + 4 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207087" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207089/EFTA00207089.md b/marker2/ds9/EFTA00207089/EFTA00207089.md new file mode 100644 index 0000000000000000000000000000000000000000..77b78c29a57c9b37ee4b5764a0c5a896edb0d9f5 --- /dev/null +++ b/marker2/ds9/EFTA00207089/EFTA00207089.md @@ -0,0 +1,19 @@ +To: + +Cc: + +Subject: Epstein Response + +Date: Tue, 09 Feb 2010 17:52:22 +0000 + +Importance: Normal + +Attachments: 20100209S\_Ltr\_to\_Black.wpd + +Hi all — Here is a proposed response. In addition to substance, please let me know whether you agree with sending a copy of the letter to Mr. Josefsberg. Thanks. + +«20100209 Mr Ltr to Black.wpd>> + +Assistant U.S. Attorney + +Ft Lauderdale, FL 33394 \ No newline at end of file diff --git a/marker2/ds9/EFTA00207089/EFTA00207089.metadata.json b/marker2/ds9/EFTA00207089/EFTA00207089.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..553ac46c1dcc32a11c1c7f44b8a8976ac723f3dd --- /dev/null +++ b/marker2/ds9/EFTA00207089/EFTA00207089.metadata.json @@ -0,0 +1,50 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207089.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 384, + "elapsed_seconds": 0.55, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 26 + ], + [ + "Line", + 13 + ], + [ + "Text", + 12 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207089" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207090/EFTA00207090.md b/marker2/ds9/EFTA00207090/EFTA00207090.md new file mode 100644 index 0000000000000000000000000000000000000000..d9589371e6090f2642e3ab8e67623de5e22e3f62 --- /dev/null +++ b/marker2/ds9/EFTA00207090/EFTA00207090.md @@ -0,0 +1,13 @@ +To: Roy BLACK + +Subject: 20100211 to Black.pdf + +Date: Thu, 11 Feb 2010 16:36:12 +0000 + +Importance: Normal + +Attachments: 20100211aLtr to\_Black.pdf + +Dear Roy: I have attached a response to your letter. Thank you. + +«20100211M to Black.pdt>> \ No newline at end of file diff --git a/marker2/ds9/EFTA00207090/EFTA00207090.metadata.json b/marker2/ds9/EFTA00207090/EFTA00207090.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..261b105235938e41c21c75beb6abbd5732d00dbd --- /dev/null +++ b/marker2/ds9/EFTA00207090/EFTA00207090.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207090.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 259, + "elapsed_seconds": 0.42, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 16 + ], + [ + "Line", + 8 + ], + [ + "Text", + 7 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207090" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207091/EFTA00207091.md b/marker2/ds9/EFTA00207091/EFTA00207091.md new file mode 100644 index 0000000000000000000000000000000000000000..401bc3b624d955666acc21d717401a65388a27b1 --- /dev/null +++ b/marker2/ds9/EFTA00207091/EFTA00207091.md @@ -0,0 +1,37 @@ +![](_page_0_Picture_0.jpeg) + +## C.S. Department of Justice + +United States Attorney Southern District of Florida + +5001 Australian Ave, Ste 400 West Palm Beach, FL 33401 (561) 820-8711 Facsimile: (561) 820.8777 + +February 11, 2010 + +## DELIVERY BY ELECTRONIC MAIL + +Roy Black, Esq. Black Srebnick Kornspan & Stumpf P.A. 201 S. Biscayne Blvd, Suite 1300 Miami, FL 33131 + +Re: Jeffrey Epstein + +Dear Mr. Black: + +Thank you for meeting with our Office last week. During our discussion, you and your colleagues raised three issues: (1) whether our Office would consider it a breach of the Non-Prosecution Agreement for Mr. Epstein to file suit against the victim's attorney-representative relating to the amount of attorney's fees; (2) whether our Office would consider it a breach of the Non-Prosecution Agreement for Mr. Epstein to argue that he has no liability for claims raised exclusively under 18 U.S.C. § 2255 as to any of the victims on the identified list; and (3) whether our Office would have any objection to Mr. Epstein applying for early termination of his community control. + +As we have told you before, our Office cannot give advisory opinions as to what will and will not be a breach of the Non-Prosecution Agreement. Furthermore, as to the first item, your colleagues admitted that efforts to reach an agreement with Robert Josefsberg regarding the amount of fees owed have not been completed. Similarly, as to the second item, your colleagues admitted that there are no currently pending cases arising exclusively under 18 U.S.C. § 2255 as to any of the victims on the identified list. Given that these matters may never arise and, if they do arise, there will be innumerable legal and factual issues that have not been shared with our Office, we again decline to provide any advisory opinions. As discussed during the meeting, the purpose of having the parties and a Special Master involved at the beginning of the process in the selection of the attorney-representative was to avoid dealing with this issue at the end of the process. As with all matters related to the Agreement, we expect that Mr. Epstein will act in good faith and comply with the letter and spirit of the NPA. + +As to the third item, we have reviewed your letter to Mr. Sloman of February 8, 2010. While Mr. Acosta did state in his letter of December 19, 2007, that he did not believe that the Office was obligated to notify the victims identified through the federal investigation of proceedings occurring in state court, the U.S. Department of Justice's position may have changed in the interim in light of internal guidance regarding prosecutors' obligations pursuant to 18 U.S.C. § 3771, 42 U.S.C. § 10607, and Fed. R. Crim. P. 60 (effective December 1, 2008). + +In light of Mr. Acosta's prior statements to Mr. Epstein's counsel that Mr. Epstein would be eligible for any benefit available to other similarly-situated state defendants, the Office agrees that Mr. Epstein may apply for early termination or modification of community control in accordance with Fl. Stat. §§ 948.05 and 948.10(4), assuming that Mr. Epstein has completed "the sanctions imposed in the community control plan." The Office takes no position regarding such an application; it is entirely within the discretion of the State Attorney's Office and the Palm Beach County Circuit Court Judge as to whether it is in "the best interests of justice and the welfare of society" to allow Mr. Epstein to terminate prematurely his community control. Mr. Epstein and his counsel may not make a representation to the State Attorney's Office, the Court, or any victim that the U.S. Attorney's Office agrees with, joins in, or does not oppose such a motion. In light of prior erroneous statements in court filings, we respectfully request that a copy of any court filing be provided to our office. + +If such a motion is made, in accordance with your proposal, the U.S. Attorney's Office will notify the federal victims that the application was filed and, if a hearing is scheduled, the date, time, and location of such hearing. The communication will consist merely of a notification and will neither encourage nor discourage attendance or submission of materials related to the application. + +Sincerely, + +Jeffrey H. Sloman United States Attorney + +![](_page_1_Picture_6.jpeg) + +cc: Jeffrey H. 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Epstein Notice (Other) + +Date: Thu, 18 Mar 2010 15:04:32 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered by Mermelstein, Stuart on 3/18/2010 at 11:04 AM EDT and filed on 3/18/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80119-KAM + +Filer: Jane Doe + +Document Number:490 + +## Docket Text: + +NOTICE by Jane Doe re [469] MOTION to Compel Compliance with Subpoena MOTION for Contempt against Alfredo Rodriguez, and Incorporated Memorandum of Law (Mermelstein, Stuart) + +9:08-cv-80119-KAM Notice has been electronically mailed to: + +Adam D. Horowitz ahorowitz@sexabuseattomey.com + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Isidro Manuel Garcia isidrogarcia®bellsouth.net + +Jack Alan Goldberger jagesq@bellsouth.net, nalanis®agwpa.com + +Jack Patrick Hill jph@searcylaw.com, clw@searcylaw.com, kmc@searcylaw.com, s.slater@searcylaw.com, sas®searcylaw.com, vat@searcylaw.com + +Paul G. Cassell cassellp@law.utah.edu + +Richard Horace Willits lawyenvillits@aol.com, reelrhw@hotmail.com + +Robert C. Josefsberg tjosefsberg@podhurst.com, amann@podhurst.com, bertpatton®podhurst.com, mestrada@podhurst.com + +Robert Deweese Critton , Jr rcrit@bciclaw.com, bobbie@bciclaw.com + +Stuart S. Merrnelstein ssm@sexabuseattorney.com, jarbour®sexabuseattomey.com, Irivera@sexabuseattomey.com + +9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be pt (n ided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +Martin G. Weinberg 20 Park Plaza Boston, MA 02116 + +The following document(s) are associated with this transaction: + +Document description:Main Document + +Original filename:n/a + +Electronic document Stamp: + +[STAMP dcecfStamp\_11: 1105629215 [Date=3/18/2010] [FileNumber=7372823-0 ] [1907e571125e082a4512a49daf2b7233683e8c756bcfad40532d830a06bce8b990c cd49e7660d5b438e49acc529e7e517622bce5c22cfa5f38a5f85a3bac8596]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00207093/EFTA00207093.metadata.json b/marker2/ds9/EFTA00207093/EFTA00207093.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1dee34810c8c8068607f2329f89894be7ff4061f --- /dev/null +++ b/marker2/ds9/EFTA00207093/EFTA00207093.metadata.json @@ -0,0 +1,135 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207093.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2801, + "elapsed_seconds": 1.46, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 308.61 + ], + [ + 184.33041381835938, + 308.61 + ], + [ + 184.33041381835938, + 324.363037109375 + ], + [ + 30.6, + 324.363037109375 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 436.59000000000003 + ], + [ + 101.58597564697266, + 436.59000000000003 + ], + [ + 101.58597564697266, + 451.93353271484375 + ], + [ + 30.6, + 451.93353271484375 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 72 + ], + [ + "Line", + 35 + ], + [ + "Text", + 23 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 43 + ], + [ + "Line", + 21 + ], + [ + "Text", + 13 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207093" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207095/EFTA00207095.md b/marker2/ds9/EFTA00207095/EFTA00207095.md new file mode 100644 index 0000000000000000000000000000000000000000..738bd05e4b7dfa1b739e2fc2f6b8ee5c4eb43f00 --- /dev/null +++ b/marker2/ds9/EFTA00207095/EFTA00207095.md @@ -0,0 +1,77 @@ +To: "flsd\_cmecf notice@flsd.uscourts.gov" + +Subject: Activity in Case 9:08-cv-80119-ICAM Doe I. Epstein Motion for Reconsideration + +Date: Mon, 15 Mar 2010 21:51:21 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the C1VUECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered by Pike, Michael on 3/15/2010 at 5:51 PM EDT and filed on 3/15/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80119-KAM + +Filer: Jeffrey Epstein + +Document Number:488 + +## Docket Text: + +Defendant's MOTION for Reconsideration re [480] Order on Motion to Compel and/or Request for Rule 4 Review and Appeal of Portions of the Magistrate's Order by Jeffrey Epstein. (Attachments: # (1) Exhibit A)(Pike, Michael) + +9:08-cv-80119-ICAM Notice has been electronically mailed to: + +Adam D. Horowitz ahorowitz@sexabuseattomey.com + +Ann Marie C. Villafana ann.marie.c.villafana@usdoj.gov + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Isidro Manuel Garcia isidrogarcia®bellsouth.net + +Jack Alan Goldberger jagesq®bellsouth.net, nalanis®agwpa.com + +Jack Patrick Hill jph@searcylaw.com, clw®searcylaw.com, kmc@searcylaw.com, s.slater@searcylaw.com, sas®searcylaw.com, vat@searcylaw.com + +Paul G. Cassell cassellp@law.utah.edu + +Richard Horace Willits lawyenvillits@aol.com, reelrhw@hotmail.com + +Robert C. Josefsberg rjosefsberg@podhurst.com, amann@podhurst.com, bertpatton®podhurst.com, mestrada@podhurst.com + +Robert Deweese Critton , Jr rcrit@bciclaw.com, bobbie@bciclaw.com + +Stuart S. Mermelstein ssm@sexabuseattomey.com, jarbour®sexabuseattomey.com, Irivera@sexabuseattomey.com + +9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +Martin G. Weinberg 20 Park Plaza Boston, MA 02116 + +The following document(s) are associated with this transaction: + +Document description:Main Document + +Original filename:n/a + +Electronic document Stamp: + +[STAMP dcecfStamp\_11: 1105629215 [Date=3/15/2010] [FileNumber=7361516-0 ] [384a8e8721021bbd3408ffd34b44272aced1c2313560c493dc108a26880775c5f42 299a2ca445222f7731a6d371ce5521ffelf1397c4a58bc4d8900173f47ebb]] + +Document description:Exhibit A + +Original ffienamem/a + +Electronic document Stamp: + +[STAMP dcecfStamp\_11 1105629215 [Date=3/15/2010] [FileNumber=7361516-1 ] [2c6e35f8964450f2746b4b8792a47baf1148eca923848 1 ble9b444743affifd5bbc4 dba404da65eddaf5bb7e95d1811c8a915759b5e46584e6474043a000bfd9a]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00207095/EFTA00207095.metadata.json b/marker2/ds9/EFTA00207095/EFTA00207095.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..665e4eb85c5c7c3d85e7ab199df426e1abcced7a --- /dev/null +++ b/marker2/ds9/EFTA00207095/EFTA00207095.metadata.json @@ -0,0 +1,135 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207095.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 3209, + "elapsed_seconds": 1.3, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 308.61 + ], + [ + 185.88690185546875, + 308.61 + ], + [ + 185.88690185546875, + 324.3170471191406 + ], + [ + 30.6, + 324.3170471191406 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 422.82 + ], + [ + 101.52233123779297, + 422.82 + ], + [ + 101.52233123779297, + 438.3170471191406 + ], + [ + 30.6, + 438.3170471191406 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 69 + ], + [ + "Line", + 35 + ], + [ + "Text", + 24 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 53 + ], + [ + "Line", + 27 + ], + [ + "Text", + 17 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207095" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207097/EFTA00207097.md b/marker2/ds9/EFTA00207097/EFTA00207097.md new file mode 100644 index 0000000000000000000000000000000000000000..85a0250b8a79aff1a241f6942001ba7962139409 --- /dev/null +++ b/marker2/ds9/EFTA00207097/EFTA00207097.md @@ -0,0 +1,67 @@ +From: "cmecfautosender®flsd.uscourts.gov" + +To: "flsd\_cmecf notice®flsd.uscourts.gov" + +Subject: Activity in Case 9:08-cv-80119-ICAM Doe I. Epstein Motion to Compel + +Date: Wed, 17 Mar 2010 15:44:19 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the C1VUECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +# Notice of Electronic Filing + +The following transaction was entered by Horowitz, Adam on 3/17/2010 at 11:44AM EDT and filed on 3/17/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80119-KAM + +Filer: Jane Doe + +Document Number: 489 + +# Docket Text: + +Plaintiff's MOTION to Compel Production of Jane Doe Nos. 2-7's Sworn Statements to FBI investigators and Incorporated Memorandum of Law by Jane Doe. Responses due by 4/5/2010 (Attachments: # (1) Exhibit A, # (2) Exhibit B - Proposed Order)(Horowitz, Adam) + +9:08-cv-80119-KAM Notice has been electronically mailed to: + +![](_page_0_Picture_18.jpeg) + +![]()**Document description:**Main Document + +**Original filename:**n/a + +**Electronic document Stamp:** + +[STAMP dcecfStamp\_ID=1105629215 [Date=3/17/2010] [FileNumber=7368377-0 +] [5b82827c00e813b603e1d37edb294380b825a5b541e8d197ade962b9d5f53c02325 +929ddbbe7812e44dd0ffb5ff839f3838573e1d03b8bd0276c8f02daf374f1]] + +**Document description:**Exhibit A + +**Original filename:**n/a + +**Electronic document Stamp:** + +[STAMP dcecfStamp\_ID=1105629215 [Date=3/17/2010] [FileNumber=7368377-1 +] [8fb7af5ea1d0fd411ee5126649daf3cf85c7b09fd42a96b177c61c7de38cb9f1191 +e3008223614ddcb93d385eef41261d2e4c12ce0ebf815b5a62deeae66b8ad]] + +**Document description:**Exhibit B - Proposed Order + +**Original filename:**n/a + +**Electronic document Stamp:** + +[STAMP dcecfStamp\_ID=1105629215 [Date=3/17/2010] [FileNumber=7368377-2 +] [0d5e69c1d18822683258613976130ea2e3da209d734dd6a7e911e8ddb76a91bde1b +758a8a036c7a3caa3fcccc084a30bdd8f5bd9ce00c7ed8bec9a76c92950a3]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00207097/EFTA00207097.metadata.json b/marker2/ds9/EFTA00207097/EFTA00207097.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..46b01b9a18b24d5721e074ddaa2aa3c8d06cb248 --- /dev/null +++ b/marker2/ds9/EFTA00207097/EFTA00207097.metadata.json @@ -0,0 +1,137 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207097.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2565, + "elapsed_seconds": 4.32, + "image_assets": [ + "_page_0_Picture_18.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 308.61 + ], + [ + 184.33041381835938, + 308.61 + ], + [ + 184.33041381835938, + 324.363037109375 + ], + [ + 30.6, + 324.363037109375 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 436.59000000000003 + ], + [ + 101.648193359375, + 436.59000000000003 + ], + [ + 101.648193359375, + 452.2330322265625 + ], + [ + 30.6, + 452.2330322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 53 + ], + [ + "Line", + 27 + ], + [ + "Text", + 16 + ], + [ + "SectionHeader", + 2 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 20 + ], + [ + "SectionHeader", + 6 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207097" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207097/_page_0_Picture_18.jpeg b/marker2/ds9/EFTA00207097/_page_0_Picture_18.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..c70704556cfb6555a1183c80ae97a86e53be67e2 --- /dev/null +++ b/marker2/ds9/EFTA00207097/_page_0_Picture_18.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:dc5af5384a23283302d4aab1eb458987c018f474748766fb5faa39236a2d6051 +size 24280 diff --git a/marker2/ds9/EFTA00207099/EFTA00207099.md b/marker2/ds9/EFTA00207099/EFTA00207099.md new file mode 100644 index 0000000000000000000000000000000000000000..098425d4e2879b4d808771eaaf0c1b4648c350ba --- /dev/null +++ b/marker2/ds9/EFTA00207099/EFTA00207099.md @@ -0,0 +1,69 @@ +From: ' .. < > To:' " < + +Subject: Activity in Case 9:08-cv-80119-ICAM Doe I. Epstein Order on Motion for Extension of Time to File Response/Reply + +Date: Wed, 24 Mar 2010 14:57:20 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CIVUECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered on 3/24/2010 at 10:57 AM EDT and filed on 3/24/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80119-KAM + +Filer: + +Document Number: 500 + +Docket Text: + +ORDER Granting [495] Motion for Extension of Time to File Reply. Reply due by 3/26/2010.. Signed by Magistrate Judge Linnea R. Johnson on 3/24/2010. (sa) + +9:08-cv-80119-KAM Notice has been electronically mailed to: + +Adam D. Horowitz + +M I. + +Bradley James Edwards + +Isidro Manuel Garcia + +Jack Alan Goldberger i + +Jack Patrick Hill + +Paul G. Cassell + +Richard Horace Willits + +Robert 1. Josefsberg + +Robert Deweese Critton , Jr + +Stuart S. Mermelstein + +9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1 + +Martin G. 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Epstein Set Motion and R&R Deadlines/Hearings + +Date: Thu, 25 Mar 2010 19:08:46 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered on 3/25/2010 at 3:08 PM EDT and filed on 3/24/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80119-KAM + +Filer: + +Document Number: No document attached + +## Docket Text: + +Set/Reset Deadlines as to [477] Defendant's MOTION for Reconsideration. Responses due by 3/26/2010. (See DE# [500].) (wc) + +9:08-cv-80119-ICAM Notice has been electronically mailed to: + +Adam D. Horowitz ahorowitz@sexabuseattomey.com + +Ann Marie C. Villafana ann.marie.c.villafana@usdoj.gov + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Isidro Manuel Garcia isidrogarcia®bellsouth.net + +Jack Alan Goldberger jagesq®bellsouth.net, nalanis®agwpa.com + +Jack Patrick Hill jph@searcylaw.com, clw@searcylaw.com, kmc@searcylaw.com, s.slater@searcylaw.com, sas@searcylaw.com, vat@searcylaw.com + +Jeffrey Marc Herman jherman@hermanlaw.com + +Richard Horace Willits lawyerwillits@aol.com, reelrhw@hotmail.com + +Robert C. Josefsberg rjosefsberg@podhurst.com, amann@podhurst.com, bertpatton®podhurst.com, mestrada@podhurst.com + +Robert Deweese Critton , Jr rcrit@bciclaw.com, bobbie@bciclaw.com + +Stuart S. Mennelstein ssm@sexabuseattorney.com, jarbow®sexabuseattomey.com, Irivera@sexabuseattomey.com + +9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +Martin G. Weinberg 20 Park Plaza Boston, MA 02116 \ No newline at end of file diff --git a/marker2/ds9/EFTA00207101/EFTA00207101.metadata.json b/marker2/ds9/EFTA00207101/EFTA00207101.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..eb5c33a93c8931748184e698c92730a2dff64409 --- /dev/null +++ b/marker2/ds9/EFTA00207101/EFTA00207101.metadata.json @@ -0,0 +1,135 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207101.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2454, + "elapsed_seconds": 1.22, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 308.61 + ], + [ + 184.3336639404297, + 308.61 + ], + [ + 184.3336639404297, + 324.23358154296875 + ], + [ + 30.6, + 324.23358154296875 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 422.82 + ], + [ + 101.52233123779297, + 422.82 + ], + [ + 101.52233123779297, + 438.3170471191406 + ], + [ + 30.6, + 438.3170471191406 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 70 + ], + [ + "Line", + 35 + ], + [ + "Text", + 25 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 25 + ], + [ + "Line", + 13 + ], + [ + "Text", + 7 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207101" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207103/EFTA00207103.md b/marker2/ds9/EFTA00207103/EFTA00207103.md new file mode 100644 index 0000000000000000000000000000000000000000..3ea33815fd9914cb1ee2881435ecec8875a8781f --- /dev/null +++ b/marker2/ds9/EFTA00207103/EFTA00207103.md @@ -0,0 +1,9 @@ +To: "cmecfautosender@flsd.uscourts.gov" + +Subject: Out of Office AutoReply: Activity in Case 9:08-cv-80119-KAM Doe . Epstein Extension of Time to File Response/Reply + +Date: Thu, 18 Mar 2010 19:09:31 +0000 + +Importance: Normal + +I will be in court this afternoon and will have only limited access to email. If the matter is urgent, please contact my assistant, Fran Prager. 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Epstein Extension of Time to File Response/Reply + +Date: Thu, 18 Mar 2010 19:08:15 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered by Pike, Michael on 3/18/2010 at 3:08 PM EDT and filed on 3/18/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80119-KAM + +Filer: Jeffrey Epstein + +Document Number:491 + +## Docket Text: + +Defendant's MOTION for Extension of Time to File Response/Reply as to [485] Response in Opposition to Motion" to Defendant's Motion for Reconsideration and/or Request for Rule 4 Appeal by Jeffrey Epstein. (Attachments: # (1) Text of Proposed Order Proposed Order)(Pike, Michael) + +9:08-cv-80119-ICAM Notice has been electronically mailed to: + +Adam D. Horowitz + +Ann Marie C. Villafana + +Bradley James Edwards + +Isidro Manuel Garcia + +Jack Alan Goldberger + +Jack Patrick Hill + +Jeffrey Marc Herman + +Michael James Pike + +Paul G. Cassell + +Richard Horace Willits + +Robert C. Josefsberg + +Robert Deweese Critton , Jr + +Stuart S. Mermelstein + +9:08-cv-80119-1CAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +Martin G. Weinberg 20 Park Plaza Boston, MA 02116 + +The following document(s) are associated with this transaction: + +Document description:Main Document + +Original filename:rile + +Electronic document Stamp: + +[STAMP dcect-Stampit 1105629215 [Date=3/18/2010] [FileNumber=7374664-0 ] [95dc77014f9f6a52dc63d3955ee0fd9a0le9c25b52ffbd5dIld8ba09f0bf9bbfl 58 3447dc82d2ec575c41fa06fb6a05cd6f8fdf0502f8a7d67a9e9140128e65d]] + +Document description:Text of Proposed Order Proposed Order + +Original filename:rila + +Electronic document Stamp: + +[STAMP dcecfStamp\_1T2 1105629215 [Date=3/18/2010] [FileNumber=7374664-1 ] [3383668684d4a78c77b24e2482028ac196175cb67c8131f61dde3fd1293b62d6106 bf63531e35f24bc780bfa6a44cc4da59c17efbee8923636a8cc4864b43e4f]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00207104/EFTA00207104.metadata.json b/marker2/ds9/EFTA00207104/EFTA00207104.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..db2ab6954e289bf416619255f5ca8694de2157ae --- /dev/null +++ b/marker2/ds9/EFTA00207104/EFTA00207104.metadata.json @@ -0,0 +1,135 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207104.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2777, + "elapsed_seconds": 1.17, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 321.57000000000005 + ], + [ + 184.79776000976562, + 321.57000000000005 + ], + [ + 184.79776000976562, + 338.10357666015625 + ], + [ + 30.6, + 338.10357666015625 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 436.59000000000003 + ], + [ + 101.65031433105469, + 436.59000000000003 + ], + [ + 101.65031433105469, + 452.1035461425781 + ], + [ + 30.6, + 452.1035461425781 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 70 + ], + [ + "Line", + 35 + ], + [ + "Text", + 23 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 51 + ], + [ + "Line", + 26 + ], + [ + "Text", + 18 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207104" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207106/EFTA00207106.md b/marker2/ds9/EFTA00207106/EFTA00207106.md new file mode 100644 index 0000000000000000000000000000000000000000..3cc3a81806512b2e41423d9b076000d46b93dafe --- /dev/null +++ b/marker2/ds9/EFTA00207106/EFTA00207106.md @@ -0,0 +1,9 @@ +To: "cmecfautosender@flsd.uscourts.gov" + +Subject: Out of Office AutoReply: Activity in Case 9:08-cv-80119-KAM Doe v. Epstein Set Motion and R&R Deadlines/Hearings + +Date: Thu, 25 Mar 2010 19:12:39 +0000 + +Importance: Normal + +I will be out of the office in meetings on March 25th and will have only limited access to email. 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Epstein Motion for Leave to File Excess Pages + +Date: Fri, 26 Mar 2010 18:32:01 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +### Notice of Electronic Filing + +The following transaction was entered by Pike, Michael on 3/26/2010 at 2:32 PM EDT and filed on 3/26/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80119-KAM + +Filer: Jeffrey Epstein + +Document Number: 501 + +# Docket Text: + +Defendant's MOTION for Leave to File Excess Pages in Reply to Plaintiff's Response in Opposition to Defendant's Motion for Rule 4 Review and Appeal by Jeffrey Epstein. (Attachments: # (1) Exhibit Order)(Pike, Michael) + +9:08-cv-80119-KAM Notice has been electronically mailed to: + +Adam D. Horowitz ahorowitz@sexabuseattorney.com + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Isidro Manuel Garcia isidrogarcia®bellsouth.net + +Jack Alan Goldberger jagesq@bellsouth.net, nalanis®agwpa.com + +Jack Patrick Hill jph@searcylaw.com, clw®searcylaw.com, lcmc@searcylaw.com, s.slater@searcylaw.com, sas®searcylaw.com, vat@searcylaw.com + +Paul G. Cassell cassellp@law.utah.edu + +Richard Horace Willits lawyenvillits@aol.com, reelrhw@hotmail.com + +Robert C. Josefsberg rjosefsberg@podhurst.com, amann@podhurst.com, bertpatton®podhurst.com, mestrada@podhurst.com + +Robert Deweese Critton , Jr rcrit@bciclaw.com, bobbie@bciclaw.com + +Stuart S. Mermelstein ssm@sexabuseattomey.com, jarbour®sexabuseattomey.com, Irivera@sexabuseattomey.com + +9:08-cv-80119-1CAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +Martin G. 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Stat. §§ 948.05 and 948.10(4), assuming that Mr. Epstein has completed "the sanctions imposed in the community control plan." The Office takes no position regarding such an application; it is entirely within the discretion of the State Attorney's Office and the Palm Beach County Circuit Court Judge as to whether it is in "the best interests of justice and the welfare of society" to allow Mr. Epstein to terminate prematurely his community control. Mr. Epstein and his counsel may not make a representation to the State Attorney's Office, the Court, or any victim that the U.S. Attorney's Office agrees with, joins in, or does not oppose such a motion. In light of prior erroneous statements in court filings, we respectfully request that a copy of any court filing be provided to our office. + +If such a motion is made, in accordance with your proposal, the U.S. Attorney's Office will notify the federal victims that the application was filed and, if a hearing is scheduled, the date, time, and location of such hearing. The communication will consist merely of a notification and will neither encourage nor discourage attendance or submission of materials related to the application. + +D + +Please note: Florida has a very broad public records law. Most written communications to or from state officials regarding state business are public records available to the public and media upon request Your e-mail communications may therefore be subject to public disclosure. \ No newline at end of file diff --git a/marker2/ds9/EFTA00207109/EFTA00207109.metadata.json b/marker2/ds9/EFTA00207109/EFTA00207109.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b5a7360cfe4eb6aed30f45621b859a12ee4d9f44 --- /dev/null +++ b/marker2/ds9/EFTA00207109/EFTA00207109.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207109.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 2047, + "elapsed_seconds": 0.63, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 52 + ], + [ + "Line", + 26 + ], + [ + "Text", + 12 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207109" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207110/EFTA00207110.md b/marker2/ds9/EFTA00207110/EFTA00207110.md new file mode 100644 index 0000000000000000000000000000000000000000..b2f4e5017d91aa5d47f993e0af9492689f29bd2e --- /dev/null +++ b/marker2/ds9/EFTA00207110/EFTA00207110.md @@ -0,0 +1,75 @@ +To: "flsd\_cmecf notice@flsd.uscourts.gov" + +Subject: Activity in Case 9:08-cv-80119-ICAM Doe I. Epstein Motion for Extension of Time to Complete Discovery + +Date: Thu, 18 Mar 2010 19:09:48 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +# Notice of Electronic Filing + +The following transaction was entered by Pike, Michael on 3/18/2010 at 3:09 PM EDT and filed on 3/18/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80119-KAM + +Filer: Jeffrey Epstein + +Document Number:492 + +### Docket Text: + +Joint MOTION for Extension of Time to Complete Discovery Deadlines and Shorten Expert Disclosures by Jeffrey Epstein. (Attachments: # (1) Text of Proposed Order Proposed Order) (Pike, Michael) + +9:08-cv-80119-KAM Notice has been electronically mailed to: + +Adam D. Horowitz ahorowitz@sexatmseattorney.com + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Isidro Manuel Garcia isidrogarcia®bellsouth.net + +Jack Alan Goldberger jagesq@bellsouth.net, nalanis®agwpa.com + +Jack Patrick Hill jph@searcylaw.com, clw@searcylaw.com, lcmc@searcylaw.com, s.slater@searcylaw.com, sas®searcylaw.com, vat@searcylaw.com + +Paul G. Cassell cassellp@law.utah.edu + +Richard Horace Willits lawyenvillits@aol.com, reelrhw@hotmail.com + +Robert C. Josefsberg tjosefsberg@podhurst.com, amann@podhurst.com, bertpatton®podhurst.com, mestrada@podhurst.com + +Robert Deweese Critton , Jr rcrit@bciclaw.com, bobbie@bciclaw.com + +Stuart S. Merrnelstein ssm@sexabuseattorney.com, jarbour®sexabuseattomey.com, Irivera@sexabuseattomey.com + +9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be pt (n ided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +Martin G. Weinberg 20 Park Plaza Boston, MA 02116 + +The following document(s) are associated with this transaction: + +### Document description:Main Document + +Original filename:n/a + +#### Electronic document Stamp: + +[STAMP dcecfStamp\_IT 1105629215 [Date=3/18/2010] [FileNumber=7374673-0 ] [Ifl 81f2b2aa0aeb72253da3cd43d28796cdd951bee64e6e676bf6557f472174aee5 5f4691284c0555a87f82elleld42745a2eb06091c12498617dd7367631546]] + +### Document description:Text of Proposed Order Proposed Order + +Original filename:II/a + +## Electronic document Stamp: + +[STAMP dcecfStamp\_11: 1105629215 [Date=3/18/2010] [FileNumber=7374673-1 ] [3e1948b32efb323234f2725b7d8d4a6c74939c9db4ba4f9fd54fa67e33f8ace8fd9 6f0c50eeac7bdbfc2bb90d3b3b88895be217df0c2b0d65d8029365c5c6954]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00207110/EFTA00207110.metadata.json b/marker2/ds9/EFTA00207110/EFTA00207110.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e3464cdf583d703f6153ce111e0adbfaa38b2421 --- /dev/null +++ b/marker2/ds9/EFTA00207110/EFTA00207110.metadata.json @@ -0,0 +1,231 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207110.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 3196, + "elapsed_seconds": 1.19, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 321.57000000000005 + ], + [ + 184.37722778320312, + 321.57000000000005 + ], + [ + 184.37722778320312, + 338.1035461425781 + ], + [ + 30.6, + 338.1035461425781 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 436.59000000000003 + ], + [ + 101.52233123779297, + 436.59000000000003 + ], + [ + 101.52233123779297, + 452.1035461425781 + ], + [ + 30.6, + 452.1035461425781 + ] + ] + }, + { + "title": "Document description:Main Document", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 30.6, + 346.68 + ], + [ + 231.73399353027344, + 346.68 + ], + [ + 231.73399353027344, + 362.2330322265625 + ], + [ + 30.6, + 362.2330322265625 + ] + ] + }, + { + "title": "Electronic document Stamp:", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 30.6, + 374.22 + ], + [ + 183.70465087890625, + 374.22 + ], + [ + 183.70465087890625, + 389.2330322265625 + ], + [ + 30.6, + 389.2330322265625 + ] + ] + }, + { + "title": "Document description:Text of Proposed Order Proposed Order", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 30.6, + 427.68 + ], + [ + 345.4103088378906, + 427.68 + ], + [ + 345.4103088378906, + 443.2330322265625 + ], + [ + 30.6, + 443.2330322265625 + ] + ] + }, + { + "title": "Electronic document Stamp:", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 30.6, + 454.4100000000001 + ], + [ + 183.70465087890625, + 454.4100000000001 + ], + [ + 183.70465087890625, + 470.2330322265625 + ], + [ + 30.6, + 470.2330322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 78 + ], + [ + "Line", + 35 + ], + [ + "Text", + 23 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 54 + ], + [ + "Line", + 27 + ], + [ + "Text", + 13 + ], + [ + "SectionHeader", + 4 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207110" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207112/EFTA00207112.md b/marker2/ds9/EFTA00207112/EFTA00207112.md new file mode 100644 index 0000000000000000000000000000000000000000..dee21dfd93c388870ff081aaa9445bd3f4696014 --- /dev/null +++ b/marker2/ds9/EFTA00207112/EFTA00207112.md @@ -0,0 +1,31 @@ +**To:** [REDACTED] + +**Subject:** Excel spreadsheet/ phone co. info + +**Date:** Fri, 12 Mar 2010 18:49:20 +0000 + +**Importance:** Normal + +**Attachments:** excel\_[REDACTED].info.xls + +--- + +Hi [REDACTED] + +Sorry this has taken so long. Attached is a list of phone numbers and the corresponding phone company info for the massage lists in California, New Mexico, and the Virgin Islands. I also have Epstein's numbers from the island on this excel sheet . + +I'm still working on Epstein, Maxwell, and [REDACTED] numbers from [REDACTED] etc. and will attach those in a separate spreadsheet. There's around [REDACTED] additional of those numbers. + +I also have copies of 2 of 4 of the CD's of Alfredo's depos. There's a problem with a couple of the disks. Do you want me to drop off what I have copied to you? + +As far as Alfredo's case, is there anything that you'd like me to work on? + +Again, sorry it's been several weeks since I checked in with you. + +Have a good weekend, +[REDACTED] + +Special Agent [REDACTED] +FBI Miami Division + +[REDACTED] \ No newline at end of file diff --git a/marker2/ds9/EFTA00207112/EFTA00207112.metadata.json b/marker2/ds9/EFTA00207112/EFTA00207112.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..22f99455d6568adb3708c6f2a0c64512a11b4afc --- /dev/null +++ b/marker2/ds9/EFTA00207112/EFTA00207112.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207112.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1034, + "elapsed_seconds": 4.47, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 39 + ], + [ + "Text", + 30 + ], + [ + "Line", + 20 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207112" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207113/EFTA00207113.md b/marker2/ds9/EFTA00207113/EFTA00207113.md new file mode 100644 index 0000000000000000000000000000000000000000..8cc8fad3e9c4c2f4b423c02a93f688557ac7794c --- /dev/null +++ b/marker2/ds9/EFTA00207113/EFTA00207113.md @@ -0,0 +1,75 @@ +To: "flsd\_cmecf notice@flsd.uscourts.gov" + +Subject: Activity in Case 9:08-cv-80893-KAM Doe 1 Epstein Motion for Summary Judgment + +Date: Thu, 11 Mar 2010 23:12:23 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered by Pike, Michael on 3/11/2010 at 6:12 PM EST and filed on 3/11/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-ov-80893-KAM + +Filer: Jeffrey Epstein + +Document Number: 130 + +# Docket Text: + +Defendant's MOTION for Summary Judgment with incorporated Memorandum of Law by Jeffrey Epstein. Responses due by 4/5/2010 (Attachments: # (1) Exhibit A, # (2) Exhibit B)(Pike, Michael) + +9:08-cv-80893-KAM Notice has been electronically mailed to: + +Ann Marie C. Villafana ann.marie.c.villafana@usdoj.gov + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Jack Alan Goldberger jagesq@bellsouth.net, nalanis®agwpa.com + +Michael James Pike MPike@bciclaw.com, bobbie@bciclaw.com, jcadwell@bciclaw.com + +Paul G. Cassell cassellp@law.utah.edu + +Robert Deweese Critton , Jr rcrit@bciclaw.com, bobbie®bc1claw.com + +9:08-cv-80893-ICAM Notice has not been delivered electronically to those listed below and will be provided by other means. 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Epstein Motion to Compel + +Date: Wed, 10 Mar 2010 22:41:42 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the C1VUECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +# U.S. District Court + +#### Southern District of Florida + +#### Notice of Electronic Filing + +The following transaction was entered by Edwards, Bradley on 3/10/2010 at 5:41 PM EST and filed on 3/10/2010 + +Case Name: Doe v. Epstein + +Case Number: 9:08-cv-80119-KAM + +Filer: Jane Doe + +Document Number:486 + +## Docket Text: + +Plaintiff's MOTION to Compel Production of FBI Records by Jane Doe. Responses due by 3/29/2010 (Attachments: # (1) Text of Proposed Order)(Edwards, Bradley) + +9:08-cv-80119-KAM Notice has been electronically mailed to: + +Adam D. Horowitz + +Bradley James Edwards + +Isidro Manuel Garcia + +Jack Alan Goldberger + +Jack Patrick Hill + +Jeffrey Marc Herman + +Paul G. Cassell + +Richard Horace Willits + +Robert C. Josefsbe + +Robert Deweese Critton , Jr + +Stuart S. Merrnelstein + +9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1 + +Martin G. 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+Subject: Activity in Case 9:08-cv-80119-ICAM Doe l Epstein Response in Opposition to Motion + +Date: Wed, 10 Mar 2010 20:38:20 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +## U.S. District Court + +## Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered by Edwards, Bradley on 3/10/2010 at 3:38 PM EST and filed on 3/10/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80119-KAM + +Filer: Jane Doe + +Document Number:485 + +## Docket Text: + +RESPONSE in Opposition re [477] Defendant's MOTION for Reconsideration re [462] Order, Terminate Motions and/or Request for Rule 4 Review and Appeal of Portions of the Magistrate's Order Dated February 4, 2010 (DE 462) with Incorporated Objections and MemorDefendant's MOTION for Reconsideration re (462] Order, Terminate Motions and/or Request for Rule 4 Review and Appeal of Portions of the Magistrate's Order Dated February 4, 2010 (DE 462) with Incorporated Objections and Memor filed by Jane Doe. (Edwards, Bradley) + +9:08-cv-80119-KAM Notice has been electronically mailed to: + +Adam D. Horowitz + +• + +Bradley James Edwards + +Isidro Manuel Garcia + +Jack Alan Goldberger + +Katherine Warthen Ezell + +Michael James Pike + +Paul G. Cassell + +Richard Horace Willits + +Robert t Jose sbe + +Robert Deweese Critton , Jr + +Stuart S. Mermelstein + +9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1 + +Martin G. Weinberg 20 Park Plaza Boston, MA 02116 + +The following document(s) are associated with this transaction: + +Document description:Main Document + +Original filename:nth + +Electronic document Stamp: + +[STAMP dcecpamp\_ID=1105629215 [Date=3/10/2010] IFileNumber=7344569-0 J [1b50cc30e8684da928b72019cb5a415d449bfJbc10c97934c018c25bbb53b933e6e 9e20277e9da1275b17ad51a9a62gb182bfafc6de60d34c4f276c2cb77ee6]1 \ No newline at end of file diff --git a/marker2/ds9/EFTA00207117/EFTA00207117.metadata.json b/marker2/ds9/EFTA00207117/EFTA00207117.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..81758b48ad57693e21bfff5486a174ec19c755d0 --- /dev/null +++ b/marker2/ds9/EFTA00207117/EFTA00207117.metadata.json @@ -0,0 +1,181 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207117.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2555, + "elapsed_seconds": 1.16, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "U.S. District Court", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 253.98, + 257.58 + ], + [ + 357.3714294433594, + 257.58 + ], + [ + 357.3714294433594, + 273.603515625 + ], + [ + 253.98, + 273.603515625 + ] + ] + }, + { + "title": "Southern District of Florida", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 231.33599999999998, + 283.5 + ], + [ + 380.1379089355469, + 283.5 + ], + [ + 380.1379089355469, + 299.1035461425781 + ], + [ + 231.33599999999998, + 299.1035461425781 + ] + ] + }, + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 308.61 + ], + [ + 184.3336639404297, + 308.61 + ], + [ + 184.3336639404297, + 324.23358154296875 + ], + [ + 30.6, + 324.23358154296875 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 436.59000000000003 + ], + [ + 101.65031433105469, + 436.59000000000003 + ], + [ + 101.65031433105469, + 452.1035461425781 + ], + [ + 30.6, + 452.1035461425781 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 75 + ], + [ + "Line", + 36 + ], + [ + "Text", + 20 + ], + [ + "SectionHeader", + 4 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 44 + ], + [ + "Line", + 21 + ], + [ + "Text", + 15 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207117" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207119/EFTA00207119.md b/marker2/ds9/EFTA00207119/EFTA00207119.md new file mode 100644 index 0000000000000000000000000000000000000000..9a13c4d5ab1ea24317f8e5f0412b13528899f4b2 --- /dev/null +++ b/marker2/ds9/EFTA00207119/EFTA00207119.md @@ -0,0 +1,89 @@ +From: + +[REDACTED] + +To: + +[REDACTED] + +Subject: Activity in Case 9:08-cv-80119-KAM Doe [REDACTED] Epstein Motion for Order to Show Cause + +Date: Wed, 10 Mar 2010 19:53:02 +0000 + +Importance: Normal + +--- + +**This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended.** + +**\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\*** Judicial Conference of the United States policy permits attorneys of record and parties in a case (including prose litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +### Notice of Electronic Filing + +The following transaction was entered by Edwards, Bradley on 3/10/2010 at 2:52 PM EST and filed on 3/10/2010 + +Case Name: Doe [REDACTED] Epstein + +Case Number: [9:08-cv-80119-KAM](#) + +Filer: Jane Doe + +Document Number: [483](#) + +### Docket Text: + +**Plaintiff's MOTION for Order to Show Cause by Jane Doe. (Edwards, Bradley)** + +**9:08-cv-80119-KAM Notice has been electronically mailed to:** + +Adam D. Horowitz + +[REDACTED] + +[REDACTED] + +Bradley James Edwards + +[REDACTED] + +Isidro Manuel Garcia + +[REDACTED] + +Jack Alan Goldberger + +[REDACTED] + +Jack Patrick Hill + +[REDACTED] + +[REDACTED] + +Jeffrey Marc Herman + +[REDACTED] + +Richard Horace Willits + +Robert C. Josefsbe + +Robert Deweese Critton , Jr + +Stuart S. Mermelstein + +9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +The following document(s) are associated with this transaction: + +Document description:Main Document + +Original filename:n/a + +Electronic document Stamp: + +[STAMP dcecfStamp\_11: 1105629215 [Date=3/10/2010] [FileNumber=7344174-0 ] [7296791efa553735bed153e28754e045b7c43c1fabf2928ae766512192e22f8e122 500eff6488cb2da177ba3728d3 f6f2b8d1ce917ef51234ec5 ea753 ce6babd]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00207119/EFTA00207119.metadata.json b/marker2/ds9/EFTA00207119/EFTA00207119.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..2d1b08aae4e060634936bdcd4237666c727359d1 --- /dev/null +++ b/marker2/ds9/EFTA00207119/EFTA00207119.metadata.json @@ -0,0 +1,135 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207119.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2222, + "elapsed_seconds": 7.6, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 308.61 + ], + [ + 182.37599999999998, + 308.61 + ], + [ + 182.37599999999998, + 323.19 + ], + [ + 30.6, + 323.19 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 436.59000000000003 + ], + [ + 99.144, + 436.59000000000003 + ], + [ + 99.144, + 449.55000000000007 + ], + [ + 30.6, + 449.55000000000007 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 68 + ], + [ + "Text", + 59 + ], + [ + "Line", + 34 + ], + [ + "SectionHeader", + 5 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 31 + ], + [ + "Line", + 15 + ], + [ + "Text", + 11 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207119" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207121/EFTA00207121.md b/marker2/ds9/EFTA00207121/EFTA00207121.md new file mode 100644 index 0000000000000000000000000000000000000000..3676753d14e0f7c171b6f882d56bab04d3b32c4c --- /dev/null +++ b/marker2/ds9/EFTA00207121/EFTA00207121.md @@ -0,0 +1,63 @@ +![](_page_0_Picture_126.jpeg) + +To: + +![](_page_0_Picture_128.jpeg) + +**Subject:** Activity in Case 9:08-cv-80893-KAM Doe v. Epstein Answer to Amended Complaint + +**Date:** Fri, 12 Mar 2010 20:39:49 +0000 + +**Importance:** Normal + +--- + +**This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended.** + +**\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\*** Judicial Conference of the United States policy permits attorneys of record and parties in a case (including prose litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +**Notice of Electronic Filing** + +The following transaction was entered by Pike, Michael on 3/12/2010 at 3:39 PM EST and filed on 3/12/2010 + +**Case Name:** Doe v. Epstein + +**Case Number:** [9:08-cv-80893-KAM](#) + +**Filer:** Jeffrey Epstein + +**Document Number:** [131](#) + +**Docket Text:** + +***Defendant, Epstein's, ANSWER and Affirmative Defenses to Amended Complaint by Jeffrey Epstein.(Pike, Michael)*** + +**9:08-cv-80893-KAM Notice has been electronically mailed to:** + +![](_page_0_Picture_145.jpeg) + +Bradley James Edwards + +![](_page_0_Picture_147.jpeg) + +Jack Alan Goldberger + +Michael James Pike + +Paul G. Cassell + +Robert Deweese Critton , Jr + +**9:08-cv-80893-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. 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I said we'd take no position; however, we'd support the concept that Epstein is obligated to pay Josefsberg a reasonable fee. + +From: PETER PRIETO + +To: Sloman, Jeff (USAFLS) + +Sent: Tue Mar 23 15:20:49 2010 + +Subject: Epstein + +Jeff, I understand that you're out of town. Do you have a few minutes to talk about either after 5 p.m. today or tomorrow, Wednesday. Just tes of your time. You can reach me until about 6 p.m. at number below, or after 6 p.m. on my cell phone: . Many thanks. Safe travels. Peter. + +Peter Prieto + +Podhurst Orseck P.A. + +25 West Flagler Street, Suite 800 Miami, FL 33130 + +Office + +Email: ppdetoepodhurst.com \ No newline at end of file diff --git a/marker2/ds9/EFTA00207123/EFTA00207123.metadata.json b/marker2/ds9/EFTA00207123/EFTA00207123.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..8be765863ee1368a976aa3b5da9b21b528e1e7ff --- /dev/null +++ b/marker2/ds9/EFTA00207123/EFTA00207123.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207123.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 774, + "elapsed_seconds": 0.74, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 41 + ], + [ + "Line", + 21 + ], + [ + "Text", + 16 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207123" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207124/EFTA00207124.md b/marker2/ds9/EFTA00207124/EFTA00207124.md new file mode 100644 index 0000000000000000000000000000000000000000..ed49c87a079f8ecc10f7066265402bb2755349de --- /dev/null +++ b/marker2/ds9/EFTA00207124/EFTA00207124.md @@ -0,0 +1,63 @@ +To: "flsd\_cmecf notice®flsd.uscourts.gov" + +Subject: Activity in Case 9:08-cv-80119-ICAM Doe I. Epstein Clerks Notice of Docket Correction and Instruction to Filer - Attorney + +Date: Mon, 22 Mar 2010 19:20:16 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic cop) of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered on 3/22/2010 at 3:20 PM EDT and filed on 3/22/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80119-KAM + +Filer: + +Document Number: 498(No document attached) + +## Docket Text: + +Clerks Notice to Filer re [495] Amended MOTION for Extension of Time to File Response/Reply as to [485] Response in Opposition to Motion" UnopposedAmended MOTION for Extension of Time to File Response/Reply as to [485] Response in Opposition to Motion" Unopposed. + +Incorrect Document Link; ERROR - The filed document was not correctly linked to the related docket entry. The correction was made by the Clerk. It is not necessary to refile this document but future filings must comply with the instructions in the CM/ECF Attorney User's Manual. (tp) + +9:08-cv-80119-KAM Notice has been electronically mailed to: + +Adam D. Horowitz + +Ann Marie C. Villafana + +Bradley James Edwards + +Isidro Manuel Garcia + +Jeffrey Marc Herman + +Katherine Warthen Ezell + +Michael James Pike + +Paul G. Cassell + +Richard Horace Willits + +Robert C. Josefsberg + +Robert Deweese Critton , Jr + +Stuart S. Merrnelstein + +9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +Martin G. Weinberg 20 Park Plaza Boston, MA 02116 \ No newline at end of file diff --git a/marker2/ds9/EFTA00207124/EFTA00207124.metadata.json b/marker2/ds9/EFTA00207124/EFTA00207124.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..92629e234b9b58686375edd25daac587587d5bf1 --- /dev/null +++ b/marker2/ds9/EFTA00207124/EFTA00207124.metadata.json @@ -0,0 +1,135 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207124.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2368, + "elapsed_seconds": 1.4, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 321.57000000000005 + ], + [ + 184.79776000976562, + 321.57000000000005 + ], + [ + 184.79776000976562, + 338.10357666015625 + ], + [ + 30.6, + 338.10357666015625 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 436.59000000000003 + ], + [ + 101.65031433105469, + 436.59000000000003 + ], + [ + 101.65031433105469, + 452.1035461425781 + ], + [ + 30.6, + 452.1035461425781 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 73 + ], + [ + "Line", + 37 + ], + [ + "Text", + 23 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 27 + ], + [ + "Line", + 14 + ], + [ + "Text", + 10 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207124" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207126/EFTA00207126.md b/marker2/ds9/EFTA00207126/EFTA00207126.md new file mode 100644 index 0000000000000000000000000000000000000000..fde9460947e8c3c3731a947cf73eb52c14f2271d --- /dev/null +++ b/marker2/ds9/EFTA00207126/EFTA00207126.md @@ -0,0 +1,77 @@ +To: "flsd\_cmecf notice@flsd.uscourts.gov" + +Subject: Activity in Case 9:08-cv-80119-ICAM Doe I. Epstein Extension of Time to File Response/Reply + +Date: Fri, 19 Mar 2010 14:47:50 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +# Notice of Electronic Filing + +The following transaction was entered by Pike, Michael on 3/19/2010 at 10:47 AM EDT and filed on 3/19/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80119-KAM + +Filer: Jeffrey Epstein + +Document Number: 495 + +## Docket Text: + +Amended MOTION for Extension of Time to File Response/Reply as to [485] Response in Opposition to Motion" Unopposed by Jeffrey Epstein. (Attachments: # (1) Text of Proposed Order Proposed Order)(Pike, Michael) + +9:08-cv-80119-KAM Notice has been electronically mailed to: + +Adam D. Horowitz ahorowitz@sexabuseattomey.com + +Ann Marie C. Villafana ann.marie.c.villafana@usdoj.gov + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Isidro Manuel Garcia isidrogarcia®bellsouth.net + +Jack Alan Goldberger jagesq@bellsouth.net, nalanis@agwpa.com + +Jack Patrick Hill jph@searcylaw.com, clw®searcylaw.corn, kmc@searcylaw.com, s.slater@searcylaw.com, sas@searcylaw.com, vat@searcylaw.com + +Paul G. Cassell cassellp@law.utah.edu + +Richard Horace Willits lawyenvillits@aol.com, reelrhw@hotmail.com + +Robert C. Josefsberg tjosefsberg@podhurst.com, amann@podhurst.com, bertpatton®podhurst.com, mestrada@podhurst.com + +Robert Deweese Critton , Jr rcrit@bciclaw.com, bobbie@bciclaw.com + +Stuart S. Merrnelstein ssm@sexabuseattorney.com, jarbour®sexabuseattomey.com, Irivera@sexabuseattomey.com + +9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be pt (n ided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +Martin G. Weinberg 20 Park Plaza Boston, MA 02116 + +The following document(s) are associated with this transaction: + +## Document description:Main Document + +Original filename:lila + +#### Electronic document Stamp: + +[STAMP dcecfStamp\_11: 1105629215 [Date=3/19/2010] [FileNumber=7377665-0 ] [880b I ce6eefl eaabeabf3e545ac553487ea9c02fa419caeaa3287e414b891cebb89 289130bb51d76f4636eelb00c0f47728a9f43alcbf50b5c717657a006d84d]] + +## Document description:Text of Proposed Order Proposed Order + +Original filenamem/a + +#### Electronic document Stamp: + +[STAMP dcecfStamp\_11: 1105629215 [Date=3/19/2010] [FileNumber=7377665-1 ] [9b2e077ffcccacefb76537693d3811ef4fe22e5dbced455073c2554bf461d73780e 5bIce4913519d719c2ec4a5cla898084aff5051a77da61403886bee2dde6e]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00207126/EFTA00207126.metadata.json b/marker2/ds9/EFTA00207126/EFTA00207126.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..14086b9f79cac43bc8786455737081e268a6f68b --- /dev/null +++ b/marker2/ds9/EFTA00207126/EFTA00207126.metadata.json @@ -0,0 +1,231 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207126.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 3261, + "elapsed_seconds": 1.25, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 321.57000000000005 + ], + [ + 184.37722778320312, + 321.57000000000005 + ], + [ + 184.37722778320312, + 338.10357666015625 + ], + [ + 30.6, + 338.10357666015625 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 436.59000000000003 + ], + [ + 101.65031433105469, + 436.59000000000003 + ], + [ + 101.65031433105469, + 452.1035461425781 + ], + [ + 30.6, + 452.1035461425781 + ] + ] + }, + { + "title": "Document description:Main Document", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 30.6, + 346.68 + ], + [ + 231.72769165039062, + 346.68 + ], + [ + 231.72769165039062, + 362.1035461425781 + ], + [ + 30.6, + 362.1035461425781 + ] + ] + }, + { + "title": "Electronic document Stamp:", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 30.6, + 374.22 + ], + [ + 183.71038818359375, + 374.22 + ], + [ + 183.71038818359375, + 389.1035461425781 + ], + [ + 30.6, + 389.1035461425781 + ] + ] + }, + { + "title": "Document description:Text of Proposed Order Proposed Order", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 30.6, + 427.68 + ], + [ + 345.4133605957031, + 427.68 + ], + [ + 345.4133605957031, + 443.1035461425781 + ], + [ + 30.6, + 443.1035461425781 + ] + ] + }, + { + "title": "Electronic document Stamp:", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 30.6, + 455.22 + ], + [ + 183.71038818359375, + 455.22 + ], + [ + 183.71038818359375, + 470.1035461425781 + ], + [ + 30.6, + 470.1035461425781 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 72 + ], + [ + "Line", + 36 + ], + [ + "Text", + 24 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 56 + ], + [ + "Line", + 27 + ], + [ + "Text", + 13 + ], + [ + "SectionHeader", + 4 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207126" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207128/EFTA00207128.md b/marker2/ds9/EFTA00207128/EFTA00207128.md new file mode 100644 index 0000000000000000000000000000000000000000..980ec8ce3939ee281674a70d647238f335a61160 --- /dev/null +++ b/marker2/ds9/EFTA00207128/EFTA00207128.md @@ -0,0 +1,78 @@ +To: [REDACTED] + +Subject: Activity in Case 9:08-cv-80119-KAM Doe [REDACTED]. Epstein Motion for Extension of Time to Complete Discovery + +Date: Fri, 19 Mar 2010 15:28:41 +0000 + +Importance: Normal + +**This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended.** + +**\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\*** Judicial Conference of the United States policy permits attorneys of record and parties in a case (including prose litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +**Notice of Electronic Filing** + +The following transaction was entered by Pike, Michael on 3/19/2010 at 11:28 AM EDT and filed on 3/19/2010 + +Case Name: Doe v. Epstein + +Case Number: [9:08-cv-80119-KAM](#) + +Filer: Jeffrey Epstein + +Document Number: [496](#) + +**Docket Text:** + +**Amended MOTION for Extension of Time to Complete Discovery and Shorten Expert Disclosures by Jeffrey Epstein. (Attachments: # (1) Text of Proposed Order Amended Order) (Pike, Michael)** + +**9:08-cv-80119-KAM Notice has been electronically mailed to:** + +Adam D. Horowitz [REDACTED] + +[REDACTED] + +Bradley James Edwards [REDACTED] + +Isidro Manuel Garcia [REDACTED] + +Jack Alan Goldberger [REDACTED] + +Jack Patrick Hill [REDACTED] +[REDACTED] + +Paul G. Cassell + +Richard Horace Willits + +Robert C. Josefsbe + +Robert Deweese Critton , Jr + +Stuart S. Merrnelstein + +9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be pt (n ided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +Martin G. Weinberg + +The following document(s) are associated with this transaction: + +# Document description:Main Document + +Original filename:It/a + +#### Electronic document Stamp: + +[STAMP dcecfStamp\_IE 1105629215 [Date=3/19/2010] [FileNumber=7377979-0 ] [9cb2f074002dd18483c55c610d1f7a1a23ad9d3662974a25f8bdfbc4deea07fff46 e I f6bbc922d17e3be454587b1b05e2561d502225d3b03839d59191763afcf]] + +# Document description:Text of Proposed Order Amended Order + +Original tilenamem/a + +#### Electronic document Stamp: + +[STAMP dcecfStamp\_11: 1105629215 [Date=3/19/2010] [FileNumber=7377979-1 ] [7189bf351562cefkkle8e1cf270eeb6aa 1477711 77 f79d32e3cebe63c5b3ed6d25c7 c9696a99d97217109c91057df756b232545f324edIffc6a2dd0ce8f339f75]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00207128/EFTA00207128.metadata.json b/marker2/ds9/EFTA00207128/EFTA00207128.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..a6906ff32b85f0d69465ec4423c3d675955a8822 --- /dev/null +++ b/marker2/ds9/EFTA00207128/EFTA00207128.metadata.json @@ -0,0 +1,231 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207128.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2662, + "elapsed_seconds": 7.25, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 322.38 + ], + [ + 182.37599999999998, + 322.38 + ], + [ + 182.37599999999998, + 336.15 + ], + [ + 30.6, + 336.15 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 437.40000000000003 + ], + [ + 99.144, + 437.40000000000003 + ], + [ + 99.144, + 449.55000000000007 + ], + [ + 30.6, + 449.55000000000007 + ] + ] + }, + { + "title": "Document description:Main Document", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 31.212, + 346.68 + ], + [ + 231.73399353027344, + 346.68 + ], + [ + 231.73399353027344, + 362.2330322265625 + ], + [ + 31.212, + 362.2330322265625 + ] + ] + }, + { + "title": "Electronic document Stamp:", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 31.212, + 374.22 + ], + [ + 183.70465087890625, + 374.22 + ], + [ + 183.70465087890625, + 389.2330322265625 + ], + [ + 31.212, + 389.2330322265625 + ] + ] + }, + { + "title": "Document description:Text of Proposed Order Amended Order", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 31.212, + 427.68 + ], + [ + 346.5302734375, + 427.68 + ], + [ + 346.5302734375, + 443.2330322265625 + ], + [ + 31.212, + 443.2330322265625 + ] + ] + }, + { + "title": "Electronic document Stamp:", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 31.212, + 455.22 + ], + [ + 183.70465087890625, + 455.22 + ], + [ + 183.70465087890625, + 470.2330322265625 + ], + [ + 31.212, + 470.2330322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 68 + ], + [ + "Text", + 49 + ], + [ + "Line", + 34 + ], + [ + "SectionHeader", + 4 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 46 + ], + [ + "Line", + 23 + ], + [ + "Text", + 13 + ], + [ + "SectionHeader", + 4 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207128" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207130/EFTA00207130.md b/marker2/ds9/EFTA00207130/EFTA00207130.md new file mode 100644 index 0000000000000000000000000000000000000000..75fb280e5ab163f7e3dabced7f52ef350ce0189b --- /dev/null +++ b/marker2/ds9/EFTA00207130/EFTA00207130.md @@ -0,0 +1,65 @@ +To:' + +Subject: Activity in Case 9:08-cv-80119-ICAM Doe I. Epstein Appeal of Magistrate Judge Decision to District Court + +Date: Thu, 18 Mar 2010 23:15:43 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered by Mermelstein, Stuart on 3/18/2010 at 7:15 PM EDT and filed on 3/18/2010 + +Case Name: Doe Epstein + +Case Number: 9:08-cv-80119-KAM + +Filer: Jane Doe + +Document Number:493 + +## Docket Text: + +APPEAL OF MAGISTRATE JUDGE DECISION to District Court by Jane Doe re 14801 Order on Motion to Compel (Mermelstein, Stuart) + +9:08-cv-80119-ICAM Notice has been electronically mailed to: + +Adam D. Horowitz + +Bradley James Edwards + +Isidro Manuel Garcia + +Jack Alan Goldberger + +Jack Patrick Hill + +Paul G. Cassell + +Richard Horace Willits + +Robert C. Josefsberg + +Robert Deweese Critton , Jr + +Stuart S. Merrnelstein + +9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be pt (n ided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +The following document(s) are associated with this transaction: + +## Document description:Main Document + +Original filename:n/a + +## Electronic document Stamp: + +[STAMP dcecfStamp\_1 1105629215 [Date=3/18/2010] [FileNumber=7376775-0 ] [2d42472d27f2b975865378dec54ddb647a009a1512f893858ea5162f42e0aa0f35a 9bbd22d09b6c283ab9ea096e15cfl 885813fe8d2720fb63d3aedfd9d90826]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00207130/EFTA00207130.metadata.json b/marker2/ds9/EFTA00207130/EFTA00207130.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f1d38e415223e15d913567e4eb7a5f8942d6438d --- /dev/null +++ b/marker2/ds9/EFTA00207130/EFTA00207130.metadata.json @@ -0,0 +1,185 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207130.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2123, + "elapsed_seconds": 1.23, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 31.212, + 322.38 + ], + [ + 184.79776000976562, + 322.38 + ], + [ + 184.79776000976562, + 338.10357666015625 + ], + [ + 31.212, + 338.10357666015625 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 31.212, + 451.1700000000001 + ], + [ + 101.65031433105469, + 451.1700000000001 + ], + [ + 101.65031433105469, + 465.6035461425781 + ], + [ + 31.212, + 465.6035461425781 + ] + ] + }, + { + "title": "Document description:Main Document", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 31.212, + 347.49 + ], + [ + 232.20684814453125, + 347.49 + ], + [ + 232.20684814453125, + 361.8170471191406 + ], + [ + 31.212, + 361.8170471191406 + ] + ] + }, + { + "title": "Electronic document Stamp:", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 31.212, + 374.22 + ], + [ + 183.31948852539062, + 374.22 + ], + [ + 183.31948852539062, + 388.8170471191406 + ], + [ + 31.212, + 388.8170471191406 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 67 + ], + [ + "Line", + 34 + ], + [ + "Text", + 24 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 34 + ], + [ + "Line", + 16 + ], + [ + "Text", + 11 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207130" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207132/EFTA00207132.md b/marker2/ds9/EFTA00207132/EFTA00207132.md new file mode 100644 index 0000000000000000000000000000000000000000..eab89b0aca58e20e0d121db9ed1f636c55284b3c --- /dev/null +++ b/marker2/ds9/EFTA00207132/EFTA00207132.md @@ -0,0 +1,73 @@ +To: [REDACTED] + +Subject: Activity in Case 9:08-cv-80119-KAM Doe v. Epstein Order on Motion for Extension of Time to Complete Discovery + +Date: Fri, 19 Mar 2010 12:55:22 +0000 + +Importance: Normal + +--- + +**This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended.** + +**\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\*** Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +**Notice of Electronic Filing** + +The following transaction was entered on 3/19/2010 at 8:55 AM EDT and filed on 3/19/2010 + +Case Name: Doe v. Epstein + +Case Number: [9:08-cv-80119-KAM](#) + +Filer: + +Document Number: [494](#) + +Docket Text: + +**ORDER granting [492] Motion for Extension of Time to Complete Discovery. Signed by Judge Kenneth A. Marra on 3/18/2010. (ir)** + +**9:08-cv-80119-KAM Notice has been electronically mailed to:** + +Adam D. Horowitz [REDACTED] + +[REDACTED] + +Bradley James Edwards [REDACTED] + +Isidro Manuel Garcia [REDACTED] + +Jack Alan Goldberger [REDACTED] + +Jack Patrick Hill [REDACTED] + +[REDACTED] + +Paul G. Cassell + +Richard Horace Willits + +Robert C. Josefsberg + +Robert Deweese Critton , Jr + +Stuart S. Merrnelstein + +9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +Martin G. Weinberg 20 Park Plaza Boston, MA 02116 + +The following document(s) are associated with this transaction: + +## Document description:Main Document + +Original filename:n/a + +## Electronic document Stamp: + +[STAMP dcecfStamp \_11- 1105629215 [Date=3/19/2010] [FileNumber=7377126-0 ] [3e6e27e896dd5926eeb32881150a3d0bea950125340877a17c7392e9104b007d093 0f5d76a48346f5469c5287a9Ia30233795be38ca532188a80f4104978e424]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00207132/EFTA00207132.metadata.json b/marker2/ds9/EFTA00207132/EFTA00207132.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b14d21e56debd92ed2837205a08a33370f001b26 --- /dev/null +++ b/marker2/ds9/EFTA00207132/EFTA00207132.metadata.json @@ -0,0 +1,162 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207132.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2270, + "elapsed_seconds": 7.12, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 322.38 + ], + [ + 182.37599999999998, + 322.38 + ], + [ + 182.37599999999998, + 336.15 + ], + [ + 30.6, + 336.15 + ] + ] + }, + { + "title": "Document description:Main Document", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 31.212, + 332.90999999999997 + ], + [ + 231.73399353027344, + 332.90999999999997 + ], + [ + 231.73399353027344, + 348.7330322265625 + ], + [ + 31.212, + 348.7330322265625 + ] + ] + }, + { + "title": "Electronic document Stamp:", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 31.212, + 360.45000000000005 + ], + [ + 183.70465087890625, + 360.45000000000005 + ], + [ + 183.70465087890625, + 375.7330322265625 + ], + [ + 31.212, + 375.7330322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 68 + ], + [ + "Text", + 51 + ], + [ + "Line", + 33 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 39 + ], + [ + "Line", + 19 + ], + [ + "Text", + 11 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207132" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207134/EFTA00207134.md b/marker2/ds9/EFTA00207134/EFTA00207134.md new file mode 100644 index 0000000000000000000000000000000000000000..1bec61ebe0b2d302ffa33409a1e486f5e0e0451b --- /dev/null +++ b/marker2/ds9/EFTA00207134/EFTA00207134.md @@ -0,0 +1,69 @@ +To: "flsd cmecf notice®flsd.uscourts.gov" + +Subject: Activity in Case 9:08-cv-80119-ICAM Doe I. Epstein Order on Motion for Extension of Time to Complete Discovery + +Date: Fri, 19 Mar 2010 19:11:40 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered on 3/19/2010 at 3:11 PM EDT and filed on 3/19/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80119-KAM + +Filer: + +Document Number: 497 + +Docket Text: + +AMENDED ORDER granting [496] Motion for Extension of Time to Complete Discovery. Signed by Judge Kenneth A. Marra on 3/19/2010. (ir) + +9:08-cv-80119-KAM Notice has been electronically mailed to: + +Adam D. Horowitz ahorowitz@sexabuseattomey.com + +Ann Marie C. Villafana ann.marie.c.villafana@usdoj.gov + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Isidro Manuel Garcia isidrogarcia®bellsouth.net + +Jack Alan Goldberger jagesq@bellsouth.net, nalanis®agwpa.com + +Jack Patrick Hill jph@searcylaw.com, clw@searcylaw.com, lcmc@searcylaw.com, s.slater@searcylaw.com, sas®searcylaw.com, vat@searcylaw.com + +Paul G. Cassell cassellp@law.utah.edu + +Richard Horace Willits lawyenvillits@aol.com, reelrhw@hotmail.com + +Robert C. Josefsberg rjosefsberg@podhurst.com, amann@podhurst.com, bertpatton®podhurst.com, mestrada@podhurst.com + +Robert Deweese Critton , Jr rcrit@bciclaw.com, bobbie@bciclaw.com + +Stuart S. Mermelstein ssm@sexabuseattomey.com, jarbout®sexabuseattomey.com, Irivera@sexabuseattomey.com + +9:08-cv-80119-1CAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +Martin G. Weinberg 20 Park Plaza Boston, MA 02116 + +The following document(s) are associated with this transaction: + +Document description:Main Document + +Original filename:n/a + +Electronic document Stamp: + +[STAMP dcecfStamp\_11: 1105629215 [Date=3/19/2010] [FileNumber=7379703-0 ] [979cd7e5677062d08fcb241cab71e7fd8bladcc218ffc82176822a17b7c44bd55fb 8afa7164ab38aa331f7f0c30fa98928590588a16090911732bb0a3e7lfd19]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00207134/EFTA00207134.metadata.json b/marker2/ds9/EFTA00207134/EFTA00207134.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d455b54628bf220847a7f54ef790a0d6ee7e2222 --- /dev/null +++ b/marker2/ds9/EFTA00207134/EFTA00207134.metadata.json @@ -0,0 +1,112 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207134.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2824, + "elapsed_seconds": 1.23, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 321.57000000000005 + ], + [ + 185.88690185546875, + 321.57000000000005 + ], + [ + 185.88690185546875, + 337.8170471191406 + ], + [ + 30.6, + 337.8170471191406 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 70 + ], + [ + "Line", + 35 + ], + [ + "Text", + 25 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 41 + ], + [ + "Line", + 21 + ], + [ + "Text", + 13 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207134" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207136/EFTA00207136.md b/marker2/ds9/EFTA00207136/EFTA00207136.md new file mode 100644 index 0000000000000000000000000000000000000000..741ffcd0d5ffa8e4e7446b4fda80459dffadcaa1 --- /dev/null +++ b/marker2/ds9/EFTA00207136/EFTA00207136.md @@ -0,0 +1,31 @@ +From To + +Subject: FW: Excel spreadsheet/ phone co. info + +Date: Mon, 22 Mar 2010 13:05:17 +0000 + +Importance: Normal + +Attachments: excel\_subpoena\_info.xls + +Hi a I forgot to send this to you eons ago. Can you prepare grand jury subpoenas in the Operation Stolen Globe matter for these numbers? + +Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 + +From: Sen ' To: Sub : xce spreasee pone co. info + +Hi I= + +Sorry this has taken so long. Attached is a list of phone numbers and the corresponding phone company info for the massage lists in California, New Mexico, and the Virgin Islands. I also have Epstein's numbers from the island on this excel sheet. + +I'm still working on Epstein, Maxwell, and umbers from NY, NM, etc. and will attach those in a separate spreadsheet. There's around 150 additional of those numbers. + +I also have copies of 2 of 4 of the CD's of Alfredo's depos. There's a problem with a couple of the disks. Do you want me to drop off what I have copied to you? + +As far as Alfredo's case, is there anything that you'd like me to work on? + +Again, sorry it's been several weeks since I checked in with you. + +Have a good weekend, + +FBI Miami Division 505 Flagler Dr. Ste. 500 West Palm Beach, FL 33401 \ No newline at end of file diff --git a/marker2/ds9/EFTA00207136/EFTA00207136.metadata.json b/marker2/ds9/EFTA00207136/EFTA00207136.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..25f8db4d10b714f68998edcc72b868696be76e11 --- /dev/null +++ b/marker2/ds9/EFTA00207136/EFTA00207136.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207136.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1245, + "elapsed_seconds": 0.79, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 62 + ], + [ + "Line", + 30 + ], + [ + "Text", + 17 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207136" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207137/EFTA00207137.md b/marker2/ds9/EFTA00207137/EFTA00207137.md new file mode 100644 index 0000000000000000000000000000000000000000..8d71fd8c8476eb4d0a93582203a20720a442e756 --- /dev/null +++ b/marker2/ds9/EFTA00207137/EFTA00207137.md @@ -0,0 +1,57 @@ +To: "flsd\_cmecf notice@flsd.uscourts.gov" + +Subject: Activity in Case 9:08-cv-80119-ICAM Doe I. Epstein Response to Motion + +Date: Tue, 09 Feb 2010 20:01:31 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered by Edwards, Bradley on 2/9/2010 at 3:01 PM EST and filed on 2/9/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80119-KAM + +Filer: Jane Doe + +Document Number:465 + +## Docket Text: + +RESPONSE to Motion re [464] Defendant's MOTION for Extension of Time to File an Appeal Pursuant to Rule 4, in Connection with this Court's Order Dated February 4, 2010 (DE 462)Defendant's MOTION for Extension of Time to File an Appeal Pursuant to Rule 4, in Connection with this Court's Order Dated February 4, 2010 (DE 462) Plaintiff's Objection to Defendants Rule 4 filed by Jane Doe. Replies due by 2/19/2010. (Edwards, Bradley) + +9:08-cv-80119-ICAM Notice has been electronically mailed to: + +Adam D. Horowitz ahorowitz@sexabuseattomey.com + +Ann Marie C. Villafana ann.marie.c.villafana@usdoj.gov + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Isidro Manuel Garcia isidrogarcia®bellsouth.net + +Jack Alan Goldberger jagesq@bellsouth.net, nalanis®agwpa.com + +Jack Patrick Hill jph@searcylaw.com, clw@searcylaw.com, lcmc@searcylaw.com, s.slater@searcylaw.com, sas®searcylaw.com, vat@searcylaw.com + +Martin G. Weinberg 20 Park Plaza Boston, MA 02116 + +The following document(s) are associated with this transaction: + +Document description:Main Document + +Original filename:n/a + +Electronic document Stamp: + +[STAMP dceciStamp\_11 1105629215 [Date=2/9/2010] [FileNumber=7242398-0] [488c5f66f72eb53350250dad72fe079ee864d741be72929ale03ce0664f7288cc623 8033a1a550069e86038ad52a6da55986a7499ce59e1b7101791d0d958028]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00207137/EFTA00207137.metadata.json b/marker2/ds9/EFTA00207137/EFTA00207137.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..c7946eadfcac6069597bf8adc8de9fb84967ab71 --- /dev/null +++ b/marker2/ds9/EFTA00207137/EFTA00207137.metadata.json @@ -0,0 +1,135 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207137.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2520, + "elapsed_seconds": 1.16, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 308.61 + ], + [ + 184.3336639404297, + 308.61 + ], + [ + 184.3336639404297, + 324.23358154296875 + ], + [ + 30.6, + 324.23358154296875 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 422.82 + ], + [ + 101.52233123779297, + 422.82 + ], + [ + 101.52233123779297, + 438.3170471191406 + ], + [ + 30.6, + 438.3170471191406 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 73 + ], + [ + "Line", + 36 + ], + [ + "Text", + 23 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 23 + ], + [ + "Line", + 11 + ], + [ + "Text", + 6 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207137" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207139/EFTA00207139.md b/marker2/ds9/EFTA00207139/EFTA00207139.md new file mode 100644 index 0000000000000000000000000000000000000000..a7c57871b1ae614e8e2e1038396d5ddac9832d35 --- /dev/null +++ b/marker2/ds9/EFTA00207139/EFTA00207139.md @@ -0,0 +1,25 @@ +Subject: RE: Epstein + +Date: Wed, 10 Feb 2010 13:39:15 +0000 + +Importance: Normal + +Don't worry. We will not agree to any early termination on his community control. I have not even been advised of his intent to seek early term. He was never required/ordered to be evaluated. A decision made by my predecessor — not something I would have let slide. Will keep you posted if anything comes up. + +From: Sent: . To: Barbara Burns Subject: Epstein + +Hi Barbara — We were just asked about our position on early termination of community control and/or transfer of Mr. Epstein to regular probation. I obviously am not well versed in how your programs work. I was looking over Chapter 948 and I was wondering whether Mr. Epstein was ever evaluated for treatment under 948.31, since he was convicted of "exploitation of a child ... for prostitution." I know the statute was enacted after he pled guilty, but it doesn't seem like there should be an Ex Post Facto issue since it isn't a punitive measure. + +Do you know whether he has completed "the sanctions imposed in the community control plan"? I don't want to give a position one way or the other if he isn't even eligible for modification or termination. + +Thank you. + +Assistant U.S. Attorney + +500 E. Broward Blvd, 7th Floor + +Ft Lauderdale, FL 33394 + +954-660-5946 + +Please note: Florida has a very broad public records law. Most written communications to or from state officials regarding slate business are public records available to the public and media upon request. 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Epstein Response/Reply (Other) + +Date: Wed, 10 Feb 2010 21:56:02 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CNUECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +## U.S. District Court + +### Southern District of Florida + +### Notice of Electronic Filing + +The following transaction was entered by Pike, Michael on 2/10/2010 at 4:56 PM EST and filed on 2/10/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80119-KAM + +Filer: Jeffrey Epstein + +Document Number:466 + +### Docket Text: + +RESPONSE/REPLY to [465] Response to Motion, Reply to Plaintiff Jane Doe's Objection to Extension of Time to File Appeal and, in the Alternative, Request for Direction to Epstein to Begin Assembling Documents by Jeffrey Epstein. (Pike, Michael) + +9:08-cv-80119-KAM Notice has been electronically mailed to: + +Adam D. Horowitz + +Bradley James Edwards + +Isidro Manuel Garcia + +Jack Alan Goldberger + +Jack Patrick Hill + +Paul G. Cassell + +Richard Horace Willits + +Robert I. Josefsberg + +Robert Deweese Critton , Jr + +Stuart S. Merrnelstein + +9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at I + +Martin G. Weinberg 20 Park Plaza Boston, MA 02116 + +The following document(s) are associated with this transaction: + +# Document description:Main Document + +Original filename:n/a + +# Electronic document Stamp: + +[STAMP dcecfStamp\_11 1105629215 [Date=2110/2010] [FileNumber=7248326-0 ][1910acbbe954f64db869da6ad74ff5b101db1ab0cb3fd2ca2ef3a0525cc82baef4f 32819dca9fa15836dfbefcd244ee05e584acfb296b8f5edab6c0daa213019]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00207140/EFTA00207140.metadata.json b/marker2/ds9/EFTA00207140/EFTA00207140.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..25309e6f3e26c60fcf55a8459526b6f867a895fa --- /dev/null +++ b/marker2/ds9/EFTA00207140/EFTA00207140.metadata.json @@ -0,0 +1,231 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207140.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2265, + "elapsed_seconds": 1.23, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "U.S. District Court", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 253.98, + 257.58 + ], + [ + 356.95135498046875, + 257.58 + ], + [ + 356.95135498046875, + 273.603515625 + ], + [ + 253.98, + 273.603515625 + ] + ] + }, + { + "title": "Southern District of Florida", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 231.33599999999998, + 283.5 + ], + [ + 380.0978088378906, + 283.5 + ], + [ + 380.0978088378906, + 299.1035461425781 + ], + [ + 231.33599999999998, + 299.1035461425781 + ] + ] + }, + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 308.61 + ], + [ + 184.3336639404297, + 308.61 + ], + [ + 184.3336639404297, + 324.23358154296875 + ], + [ + 30.6, + 324.23358154296875 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 422.82 + ], + [ + 101.65031433105469, + 422.82 + ], + [ + 101.65031433105469, + 438.6035461425781 + ], + [ + 30.6, + 438.6035461425781 + ] + ] + }, + { + "title": "Document description:Main Document", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 30.6, + 332.09999999999997 + ], + [ + 232.56, + 332.09999999999997 + ], + [ + 232.56, + 348.3170471191406 + ], + [ + 30.6, + 348.3170471191406 + ] + ] + }, + { + "title": "Electronic document Stamp:", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 30.6, + 360.45000000000005 + ], + [ + 183.6, + 360.45000000000005 + ], + [ + 183.6, + 376.65000000000003 + ], + [ + 30.6, + 376.65000000000003 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 69 + ], + [ + "Line", + 33 + ], + [ + "Text", + 21 + ], + [ + "SectionHeader", + 4 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 41 + ], + [ + "Line", + 19 + ], + [ + "Text", + 11 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207140" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207142/EFTA00207142.md b/marker2/ds9/EFTA00207142/EFTA00207142.md new file mode 100644 index 0000000000000000000000000000000000000000..e77106d550a78c98892de45906d94b978dda74c8 --- /dev/null +++ b/marker2/ds9/EFTA00207142/EFTA00207142.md @@ -0,0 +1,101 @@ +To: "flsd\_cmecf notice@flsd.uscourts.gov" + +Subject: Activity in Case 9:08-cv-80119-ICAM Doe I. Epstein Response/Reply (Other) + +Date: Thu, 11 Feb 2010 16:51:23 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered by Pike, Michael on 2/11/2010 at 11:51 AM EST and filed on 2/11/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80119-KAM + +Filer: Jeffrey Epstein + +Document Number:467 + +## Docket Text: + +RESPONSE/REPLY to [456] Response to Motion Epstein's Reply to Jane Doe #3's Response to Epstein's Motion for Sanctions by Jeffrey Epstein. (Attachments: # (1) Exhibit A, # (2) Exhibit B, # (3) Exhibit C)(Pike, Michael) + +9:08-cv-80119-KAM Notice has been electronically mailed to: + +Adam D. Horowitz ahorowitz@sexabuseattorney.com + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Isidro Manuel Garcia isidrogarcia®bellsouth.net + +Jack Alan Goldberger jagesq@bellsouth.net, nalanis®agwpa.com + +Jack Patrick Hill jph@searcylaw.com, clw®searcylaw.com, kmc@searcylaw.com, s.slate searcylaw.com, sas@searcylaw.com, vat@searcylaw.com + +Paul G. Cassell cassellp@law.utah.edu + +Richard Horace Willits lawyerwillits@aol.com, reelrhw@hotmail.com + +Robert C. Josefsberg rjosefsberg@podhurst.com, amann@podhurst.com, bertpatton@podhurst.com, mestrada@podhurst.com + +Robert Deweese Critton , Jr rcrit@bclclaw.com, bobbie@bclclaw.com + +Stuart S. Mermelstein ssm@sexabuseattorney.com, jarbour@sexabuseattorney.com, lrivera@sexabuseattorney.com + +**9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.:** + +Martin G. Weinberg +20 Park Plaza +Boston, MA 02116 + +The following document(s) are associated with this transaction: + +**Document description:**Main Document + +**Original filename:**n/a + +**Electronic document Stamp:** + +[STAMP dcecfStamp\_ID=1105629215 [Date=2/11/2010] [FileNumber=7250130-0 +] [305c7d0b75b0cec4e8329cec07e429ed5d105f9ef3010ed98d19133433acd46c865 +8331e03c8e26d6483ce9c62f8739746ee4b692ed07c25bcc0c1eec9f686fa]] + +**Document description:**Exhibit A + +**Original filename:**n/a + +**Electronic document Stamp:** + +[STAMP dcecfStamp\_ID=1105629215 [Date=2/11/2010] [FileNumber=7250130-1 +] [042d871c1c076655d7c8d8ea60afa1c53b65370f08e63b0e0ac0b4f316ac3e624f3 +d4cefedd3f4288530fac7a4c9f17e4c2ebbda9ac377f0a8b9efc08550d0e8]] + +**Document description:**Exhibit B + +**Original filename:**n/a + +**Electronic document Stamp:** + +[STAMP dcecfStamp\_ID=1105629215 [Date=2/11/2010] [FileNumber=7250130-2 +] [797cfba1a6336c905fb9a2fa41e6a786fae2e52fa2c9e768a6d9de64458605dbadb +d55738362875d8a034eb31df496bbe7af57375ae0847c45ae0b246b7bcf7a]] + +**Document description:**Exhibit C + +**Original filename:**n/a + +**Electronic document Stamp:** + +[STAMP dcecfStamp\_ID=1105629215 [Date=2/11/2010] [FileNumber=7250130-3 +] [9446abd5983a27492736f433197159c6b5a8befbcafa9bacdd8c9e6d8524f483441 +f20f05eb1c4e726cb13e547bb4a5c40b32acd44095ad627391502744e7e65]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00207142/EFTA00207142.metadata.json b/marker2/ds9/EFTA00207142/EFTA00207142.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..3c8d4eed18dffbb72849966da2680a4c14587ab6 --- /dev/null +++ b/marker2/ds9/EFTA00207142/EFTA00207142.metadata.json @@ -0,0 +1,127 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207142.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 3799, + "elapsed_seconds": 8.09, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 308.61 + ], + [ + 185.88690185546875, + 308.61 + ], + [ + 185.88690185546875, + 324.3170471191406 + ], + [ + 30.6, + 324.3170471191406 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 422.82 + ], + [ + 101.52233123779297, + 422.82 + ], + [ + 101.52233123779297, + 438.3170471191406 + ], + [ + 30.6, + 438.3170471191406 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 72 + ], + [ + "Line", + 34 + ], + [ + "Text", + 23 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 52 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207142" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207144/EFTA00207144.md b/marker2/ds9/EFTA00207144/EFTA00207144.md new file mode 100644 index 0000000000000000000000000000000000000000..120c83c7e1a5da0c55fb80b69fd00667e976e1ab --- /dev/null +++ b/marker2/ds9/EFTA00207144/EFTA00207144.md @@ -0,0 +1,67 @@ +From: ' II < > To:' , + +Subject: Activity in Case 9:08-cv-80119-ICAM Doe v. Epstein Order on Motion for Extension of Time to File + +Date: Thu, 11 Feb 2010 19:13:22 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered on 2/11/2010 at 2:13 PM EST and filed on 2/11/2010 + +Case Name: Doe v. Epstein + +Case Number: 9:08-cv-80119-KAM + +Filer: + +Document Number:468 + +Docket Text: + +ORDER granting in part and denying in part [464] Motion for Extension of Time to File Appeal. Deadline extended to 2/26/10. Signed by Judge Kenneth A. Marra on 2/11/2010. (ir) + +9:08-cv-80119-KAM Notice has been electronically mailed to: + +Adam D. Horowitz + +Bradley James Edwards + +Isidro Manuel Garcia + +Jack Alan Goldberger i + +Jack Patrick Hill + +Paul G. Cassell + +Richard Horace Willits + +Robert C. Josefsbera + +Robert Deweese Critton , Jr + +Stuart S. Mermelstein + +9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1 + +Martin G. Weinberg 20 Park Plaza Boston, MA 02116 + +The following document(s) are associated with this transaction: + +## Document description:Main Document + +Original filename:n/a + +## Electronic document Stamp: + +[STAMP dceciStamp\_II» 1105629215 [Date=2/11/2010] [FileNumber=7251065-0 ] [541bc2e9137e68b0llba2cbd75fa753fe08fc8edafd9a13b3e0cc45042667d51b16 a4e394fc2552218a4b4b999fab7786ff250b40dclf06028ef896e6ebd729f]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00207144/EFTA00207144.metadata.json b/marker2/ds9/EFTA00207144/EFTA00207144.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..be0f5d3f55e10279a4f64937d78853cc4b3bf500 --- /dev/null +++ b/marker2/ds9/EFTA00207144/EFTA00207144.metadata.json @@ -0,0 +1,162 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207144.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2188, + "elapsed_seconds": 1.16, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 31.212, + 322.38 + ], + [ + 184.79776000976562, + 322.38 + ], + [ + 184.79776000976562, + 338.10357666015625 + ], + [ + 31.212, + 338.10357666015625 + ] + ] + }, + { + "title": "Document description:Main Document", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 31.212, + 333.71999999999997 + ], + [ + 232.56, + 333.71999999999997 + ], + [ + 232.56, + 348.3170471191406 + ], + [ + 31.212, + 348.3170471191406 + ] + ] + }, + { + "title": "Electronic document Stamp:", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 31.212, + 360.45000000000005 + ], + [ + 183.31948852539062, + 360.45000000000005 + ], + [ + 183.31948852539062, + 376.65000000000003 + ], + [ + 31.212, + 376.65000000000003 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 72 + ], + [ + "Line", + 35 + ], + [ + "Text", + 24 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 37 + ], + [ + "Line", + 19 + ], + [ + "Text", + 11 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207144" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207146/EFTA00207146.md b/marker2/ds9/EFTA00207146/EFTA00207146.md new file mode 100644 index 0000000000000000000000000000000000000000..47f16ecd66ed21bcf7fe4af949ec0f9fdbc9e88d --- /dev/null +++ b/marker2/ds9/EFTA00207146/EFTA00207146.md @@ -0,0 +1,93 @@ +To: "flsd\_cmecf notice@flsd.uscourts.gov" + +Subject: Activity in Case 9:08-cv-80119-ICAM Doe I. Epstein Motion to Compel + +Date: Wed, 17 Feb 2010 22:03:27 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CIVUECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +# Notice of Electronic Filing + +The following transaction was entered by Horowitz, Adam on 2/17/2010 at 5:03 PM EST and filed on 2/17/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80119-KAM + +Filer: Jane Doe + +Document Number:469 + +### Docket Text: + +MOTION to Compel Compliance with Subpoena, MOTION for Contempt against Alfredo Rodriguez, and Incorporated Memorandum of Law by Jane Doe. Responses due by 3/8/2010 (Attachments: # (1) Exhibit A, # (2) Exhibit B, # (3) Exhibit C)(Horowitz, Adam) + +9:08-cv-80119-KAM Notice has been electronically mailed to: + +Adam D. Horowitz ahorowitz@sexabuseattomey.com + +Ann Marie C. Villafana ann.marie.c.villafana@usdoj.gov + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Isidro Manuel Garcia isidrogarcia®bellsouth.net + +Jack Alan Goldberger jagesq@bellsouth.net, nalanis®agwpa.com + +Jack Patrick Hill jph@searcylaw.com, clw®searcylaw.com, kmc@searcylaw.com, s.slater@searcylaw.com, sas®searcylaw.com, vat@searcylaw.com + +Paul G. Cassell cassellp@law.utah.edu + +Richard Horace Willits lawyenvillits@aol.com, reelrhw@hotmail.com + +Robert C. Josefsberg rjosefsberg@podhurst.com, amann@podhurst.com, bertpatton®podhurst.com, mestrada@podhurst.com + +Robert Deweese Critton , Jr rcrit@bciclaw.com, bobbie@bciclaw.com + +Stuart S. Mermelstein ssm@sexabuseattomey.com, jarbout®sexabuseattomey.com, Irivera@sexabuseattomey.com + +9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +Martin G. 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index 0000000000000000000000000000000000000000..85e261aa80a5fab924a82052e496ce361e45b947 --- /dev/null +++ b/marker2/ds9/EFTA00207148/EFTA00207148.md @@ -0,0 +1,30 @@ +**Subject:** RE: Epstein--NPA + +**Date:** Thu, 18 Feb 2010 16:20:16 +0000 + +**Importance:** Normal + +--- + +Thank you, Marie. + +**Subject:** RE: Epstein--NPA + +Here is the signed addendum. I looked through my electronic files but couldn't find that original NPA with my signature on it. The original document is up in WPB and I won't be up there until Friday. Can you wait until then? + +As to question 2, I believe that [REDACTED] was in Florida (Miami), I was in Florida (WPB), and the others were in New York, but I don't know that for certain. I was the last to sign. + +You are welcome. Have a good night. + +[REDACTED] + +**Cc:** ROBERT C. JOSEFSBERG; Amy Ederi + +**Subject:** Epstein--NPA + +Hi [REDACTED] I know you are busy and hate to bother you, but I have a question and a request. + +1. 1) Request—Can you provide me with ( pdf) copies of the signature pages of the NPA that contain your signature or that of anyone else on behalf of the United States Attorney. We have "umpteen" copies of the NPA, but cannot find any that contain that signature to either the Non-Prosecution Agreement or the Addendum. +2. 2) Question—Where were the various signers of the NPA when they signed it, i.e., West Palm Beach, Miami, etc., and who and where was the last signer. (I am assuming that would have been you)? + +I hope all is well. Thank you as always, [REDACTED] \ No newline at end of file diff --git a/marker2/ds9/EFTA00207148/EFTA00207148.metadata.json b/marker2/ds9/EFTA00207148/EFTA00207148.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..fb845c5b7da5fe67c61781c93ff6904248e9fa5b --- /dev/null +++ b/marker2/ds9/EFTA00207148/EFTA00207148.metadata.json @@ -0,0 +1,58 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207148.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1344, + "elapsed_seconds": 5.55, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 44 + ], + [ + "Text", + 26 + ], + [ + "Line", + 20 + ], + [ + "ListGroup", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207148" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207149/EFTA00207149.md b/marker2/ds9/EFTA00207149/EFTA00207149.md new file mode 100644 index 0000000000000000000000000000000000000000..beba8f67352cae5a8a97f462a708a212ddf628ec --- /dev/null +++ b/marker2/ds9/EFTA00207149/EFTA00207149.md @@ -0,0 +1,75 @@ +To: "flsd\_cmecf notice@flsd.uscourts.gov" + +Subject: Activity in Case 9:08-cv-80119-ICAM Doe I. Epstein Motion for Extension of Time to Complete Discovery + +Date: Fri, 19 Feb 2010 17:00:06 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +# Notice of Electronic Filing + +The following transaction was entered by Pike, Michael on 2/19/2010 at 12:00 PM EST and filed on 2/19/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80119-KAM + +Filer: Jeffrey Epstein + +Document Number:470 + +#### Docket Text: + +Joint MOTION for Extension of Time to Complete Discovery as to Jane Doe, 08-80893 by Jeffrey Epstein. (Attachments: # (1) Text of Proposed Order Proposed Order)(Pike, Michael) + +9:08-cv-80119-KAM Notice has been electronically mailed to: + +Adam D. Horowitz ahorowitz@sexabuseattomey.com + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Isidro Manuel Garcia isidrogarcia®bellsouth.net + +Jack Alan Goldberger jagesq®bellsouth.net, nalanis®agwpa.com + +Jack Patrick Hill jph@searcylaw.com, clw@searcylaw.com, lcmc@searcylaw.com, s.slater@searcylaw.com, sas®searcylaw.com, vat@searcylaw.com + +Paul G. Cassell cassellp@law.utah.edu + +Richard Horace Willits lawyenvillits@aol.com, reelrhw@hotmail.com + +Robert C. Josefsberg rjosefsberg@podhurst.com, amann@podhurst.com, bertpatton®podhurst.com, mestrada@podhurst.com + +Robert Deweese Critton , Jr rcrit@bciclaw.com, bobbie@bciclaw.com + +Stuart S. Mermelstein ssm@sexabuseattomey.com, jarbour®sexabuseattomey.com, Irivera@sexabuseattomey.com + +9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +Martin G. Weinberg 20 Park Plaza Boston, MA 02116 + +The following document(s) are associated with this transaction: + +### Document description:Main Document + +Original filename:n/a + +#### Electronic document Stamp: + +[STAMP dcecfStamp\_ID=1105629215 [Date=2/19/2010] [FileNumber=7276597-0 ] [89cae5b769bdbfl346b5eb744H538449318a0c2028cd8a35e9492d90730347347a e5b3ad44ae20a194c8eb90f4d8b7db82dfSea9b5bcf6a665630c3e03b62cf]] + +## Document description:Text of Proposed Order Proposed Order + +Original filename:n/a + +#### Electronic document Stamp: + +[STAMP dcecfStamp\_11:: 1105629215 [Date=2/19/2010] [FileNumber=7276597-1 ] [28a4ad458068ae225afeb178835c12895e4a1175dc0e5b68c9588bd84af70a85a00 72371c4031ac9e229c2ac8d14e9651596206723e9505a98093ab9c210e7 fb]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00207149/EFTA00207149.metadata.json b/marker2/ds9/EFTA00207149/EFTA00207149.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f48f702760369d1818f3a917aaa94e0ae0c59c2d --- /dev/null +++ b/marker2/ds9/EFTA00207149/EFTA00207149.metadata.json @@ -0,0 +1,231 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207149.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 3176, + "elapsed_seconds": 1.18, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 321.57000000000005 + ], + [ + 184.79776000976562, + 321.57000000000005 + ], + [ + 184.79776000976562, + 338.10357666015625 + ], + [ + 30.6, + 338.10357666015625 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 436.59000000000003 + ], + [ + 101.65031433105469, + 436.59000000000003 + ], + [ + 101.65031433105469, + 452.1035461425781 + ], + [ + 30.6, + 452.1035461425781 + ] + ] + }, + { + "title": "Document description:Main Document", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 31.212, + 332.90999999999997 + ], + [ + 231.73399353027344, + 332.90999999999997 + ], + [ + 231.73399353027344, + 348.7330322265625 + ], + [ + 31.212, + 348.7330322265625 + ] + ] + }, + { + "title": "Electronic document Stamp:", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 31.212, + 360.45000000000005 + ], + [ + 183.70465087890625, + 360.45000000000005 + ], + [ + 183.70465087890625, + 375.7330322265625 + ], + [ + 31.212, + 375.7330322265625 + ] + ] + }, + { + "title": "Document description:Text of Proposed Order Proposed Order", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 31.212, + 413.90999999999997 + ], + [ + 345.4103088378906, + 413.90999999999997 + ], + [ + 345.4103088378906, + 430.10302734375 + ], + [ + 31.212, + 430.10302734375 + ] + ] + }, + { + "title": "Electronic document Stamp:", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 31.212, + 441.45000000000005 + ], + [ + 183.70465087890625, + 441.45000000000005 + ], + [ + 183.70465087890625, + 456.7330322265625 + ], + [ + 31.212, + 456.7330322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 69 + ], + [ + "Line", + 34 + ], + [ + "Text", + 23 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 53 + ], + [ + "Line", + 27 + ], + [ + "Text", + 13 + ], + [ + "SectionHeader", + 4 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207149" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207151/EFTA00207151.md b/marker2/ds9/EFTA00207151/EFTA00207151.md new file mode 100644 index 0000000000000000000000000000000000000000..2a45d0d78259340f0dba557254da8f181eb1864a --- /dev/null +++ b/marker2/ds9/EFTA00207151/EFTA00207151.md @@ -0,0 +1,79 @@ +From: "cmecfautosender®flsd.uscourts.gov" + +To: "flsd\_cmecf notice®flsd.uscourts.gov" + +Subject: Activity in Case 9:08-cv-80119-KAM Doe I. Epstein Motion for Miscellaneous Relief + +Date: Fri, 19 Feb 2010 17:04:53 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CIVUECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +# Notice of Electronic Filing + +The following transaction was entered by Pike, Michael on 2/19/2010 at 12:04 PM EST and filed on 2/19/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80119-KAM + +Filer: Jeffrey Epstein + +Document Number:471 + +# Docket Text: + +Defendant's MOTION Attend Mediation and Memorandum In Support Thereof as to Jane Doe, 08-80893 by Jeffrey Epstein. (Attachments: # (1) Text of Proposed Order Proposed Agreed Order)(Pike, Michael) + +9:08-cv-80119-KAM Notice has been electronically mailed to: + +Adam D. Horowitz ahorowitz@sexabuseattomey.com + +Ann Marie C. Villafana ann.marie.c.villafana@usdoj.gov + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Isidro Manuel Garcia isidrogarcia®bellsouth.net + +Jack Alan Goldberger jagesq®bellsouth.net, nalanis®agwpa.com + +Jack Patrick Hill jph@searcylaw.com, clw@searcylaw.com, lcmc@searcylaw.com, s.slater@searcylaw.com, sas®searcylaw.com, vat@searcylaw.com + +Paul G. Cassell cassellp@law.utah.edu + +Richard Horace Willits lawyenvillits@aol.com, reelrhw@hotmail.com + +Robert C. Josefsberg rjosefsberg@podhurst.com, amann@podhurst.com, bertpatton®podhurst.com, mestrada@podhurst.com + +Robert Deweese Critton , Jr rcrit@bciclaw.com, bobbie@bciclaw.com + +Stuart S. Mermelstein ssm@sexabuseattomey.com, jarbour®sexabuseattomey.com, Irivera@sexabuseattomey.com + +9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +Martin G. Weinberg 20 Park Plaza Boston, MA 02116 + +The following document(s) are associated with this transaction: + +## Document description:Main Document + +Original filename:n/a + +### Electronic document Stamp: + +[STAMP dcecfStamp\_11: 1105629215 [Date=2119/2010] [FileNumber=7276642-0 ] [3d0876ec6c7331515fd2caef76b4fe3d5f845834504215317392904a1645bbl5a0b 151eb11228c6bdd10989722d1f3e910370fc0a78480e9639bfc0165194a8]] + +Document description:Text of Proposed Order Proposed Agreed Order + +Original filenamem/a + +### Electronic document Stamp: + +[STAMP dcecfStamp\_11: 1105629215 [Date=2/19/2010] [FileNumber=7276642-1 ] [63003357fe3603f6ea4c1b795071ed0e75ba2d6dc8878282bb2d2c2ael9abc 12441 89cbd8 fl de041b4c289e0084c9ba94ffa7300569cOdc8b3f1 cff70b655264]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00207151/EFTA00207151.metadata.json b/marker2/ds9/EFTA00207151/EFTA00207151.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..a67db64f54a8a31c74c5f153e3bf66ee053a524c --- /dev/null +++ b/marker2/ds9/EFTA00207151/EFTA00207151.metadata.json @@ -0,0 +1,208 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207151.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 3312, + "elapsed_seconds": 1.27, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 29.988, + 307.79999999999995 + ], + [ + 184.3336639404297, + 307.79999999999995 + ], + [ + 184.3336639404297, + 324.23358154296875 + ], + [ + 29.988, + 324.23358154296875 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 29.988, + 422.01000000000005 + ], + [ + 101.65031433105469, + 422.01000000000005 + ], + [ + 101.65031433105469, + 438.6035461425781 + ], + [ + 29.988, + 438.6035461425781 + ] + ] + }, + { + "title": "Document description:Main Document", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 31.212, + 332.90999999999997 + ], + [ + 231.72769165039062, + 332.90999999999997 + ], + [ + 231.72769165039062, + 348.6035461425781 + ], + [ + 31.212, + 348.6035461425781 + ] + ] + }, + { + "title": "Electronic document Stamp:", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 31.212, + 360.45000000000005 + ], + [ + 183.71038818359375, + 360.45000000000005 + ], + [ + 183.71038818359375, + 375.6035461425781 + ], + [ + 31.212, + 375.6035461425781 + ] + ] + }, + { + "title": "Electronic document Stamp:", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 31.212, + 441.45000000000005 + ], + [ + 183.71038818359375, + 441.45000000000005 + ], + [ + 183.71038818359375, + 456.6035461425781 + ], + [ + 31.212, + 456.6035461425781 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 69 + ], + [ + "Line", + 35 + ], + [ + "Text", + 24 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 55 + ], + [ + "Line", + 27 + ], + [ + "Text", + 14 + ], + [ + "SectionHeader", + 3 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207151" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207153/EFTA00207153.md b/marker2/ds9/EFTA00207153/EFTA00207153.md new file mode 100644 index 0000000000000000000000000000000000000000..9068aa4008cc9330e858707bc981e0cfa63975c2 --- /dev/null +++ b/marker2/ds9/EFTA00207153/EFTA00207153.md @@ -0,0 +1,69 @@ +To: "flsd\_cmecf notice®flsd.uscourts.gov" + +Subject: Activity in Case 9:08-cv-80119-ICAM Doe I. Epstein Order on Motion for Extension of Time to Complete Discovery + +Date: Fri, 19 Feb 2010 21:40:39 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered on 2/19/2010 at 4:40 PM EST and filed on 2/19/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80119-ICAM + +Filer: + +Document Number: 473 + +Docket Text: + +ORDER granting [470] Motion for Extension of Time to Complete Discovery. Signed by Judge Kenneth A. Marra on 2/19/2010. (ir) + +9:08-cv-80119-KAM Notice has been electronically mailed to: + +Adam D. Horowitz ahorowitz@sexabuseattomey.com + +Ann Marie C. Villafana ann.marie.c.villafana@usdoj.gov + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Isidro Manuel Garcia isidrogarcia®bellsouth.net + +Jack Alan Goldberger jagesq®bellsouth.net, nalanis®agwpa.com + +Jack Patrick Hill jph@searcylaw.com, clw®searcylaw.com, kmc@searcylaw.com, s.slater@searcylaw.com, sas@searcylaw.com, vat@searcylaw.com + +Paul G. Cassell cassellp@law.utah.edu + +Richard Horace Willits lawyenvillits@aol.com, reelrhw@hotmail.com + +Robert C. Josefsberg rjosefsberg@podhurst.com, amann@podhurst.com, bertpatton®podhurst.com, mestrada@podhurst.com + +Robert Deweese Critton , Jr rcrit@bciclaw.com, bobbie@bciclaw.com + +Stuart S. Mermelstein ssm@sexabuseattomey.com, jarbout®sexabuseattomey.com, Irivera@sexabuseattomey.com + +9:08-cv-80119-1CAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +Martin G. Weinberg 20 Park Plaza Boston, MA 02116 + +The following document(s) are associated with this transaction: + +Document description:Main Document + +Original filename:n/a + +Electronic document Stamp: + +[STAMP dcecfStamp\_11 1105629215 [Date=2119/2010] [FileNumber=7279747-0 ] [9796adfl c5fa652754af671191fe92908692020bcef4852ca3eda52121604700a27 b20663472d8dd9671f19be6931c7f924c34fc198b6e5325070ac3ea882440]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00207153/EFTA00207153.metadata.json b/marker2/ds9/EFTA00207153/EFTA00207153.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..4bc50e3f448898f4cba4adccabec898139e541a8 --- /dev/null +++ b/marker2/ds9/EFTA00207153/EFTA00207153.metadata.json @@ -0,0 +1,112 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207153.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2817, + "elapsed_seconds": 1.22, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 321.57000000000005 + ], + [ + 184.37722778320312, + 321.57000000000005 + ], + [ + 184.37722778320312, + 338.10357666015625 + ], + [ + 30.6, + 338.10357666015625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 71 + ], + [ + "Line", + 35 + ], + [ + "Text", + 25 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 43 + ], + [ + "Line", + 21 + ], + [ + "Text", + 13 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207153" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207155/EFTA00207155.md b/marker2/ds9/EFTA00207155/EFTA00207155.md new file mode 100644 index 0000000000000000000000000000000000000000..64b791308e30df547edc389741b4e8139b14b94c --- /dev/null +++ b/marker2/ds9/EFTA00207155/EFTA00207155.md @@ -0,0 +1,77 @@ +From: + +[REDACTED] + +To: + +[REDACTED] + +**Subject:** Activity in Case 9:08-cv-80119-KAM Doe █ Epstein Notification of Ninety Days Expiring + +**Date:** Tue, 23 Feb 2010 15:56:47 +0000 + +**Importance:** Normal + +--- + +**This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended.** + +**\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\*** Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +**Notice of Electronic Filing** + +The following transaction was entered by Mermelstein, Stuart on 2/23/2010 at 10:56 AM EST and filed on 2/23/2010 + +**Case Name:** Doe █ Epstein + +**Case Number:** [9:08-cv-80119-KAM](#) + +**Filer:** Jane Doe + +**Document Number:** [474](#) + +**Docket Text:** + +**Notification of Ninety Days Expiring by Jane Doe re [333] Plaintiff's MOTION to Compel Responses to Requests for Net Worth Discovery and Incorporated Memorandum of Law filed by Jane Doe (Mermelstein, Stuart)** + +**9:08-cv-80119-KAM Notice has been electronically mailed to:** + +Adam D. Horowitz [REDACTED] + +[REDACTED] + +Bradley James Edwards [REDACTED] + +Isidro Manuel Garcia [REDACTED] + +Jack Alan Goldberger [REDACTED] + +Jack Patrick Hill [REDACTED] + +[REDACTED] + +Paul G. Cassell + +Richard Horace Willits + +Robert C. Josefsberg + +Robert Deweese Critton , Jr + +Stuart S. Menne'stein + +9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be pt (n ided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +The following document(s) are associated with this transaction: + +## Document description:Main Document + +Original filename:n/a + +## Electronic document Stamp: + +[STAMP dceaStamp\_11: 1105629215 [Date=2/23/2010] [FileNumber=7286946-0 ] [2228c25fb7e0d377995631ccea339cf54bb0ea5dd3db2e04b994edac81c6c31f3d2 fa51b713e3a0dedc47399677e7446373746007bd9dfd892c0f2e9d64893c3]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00207155/EFTA00207155.metadata.json b/marker2/ds9/EFTA00207155/EFTA00207155.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..0a9f789b136e50a4b690e44e79fe2322c5f60773 --- /dev/null +++ b/marker2/ds9/EFTA00207155/EFTA00207155.metadata.json @@ -0,0 +1,185 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207155.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2361, + "elapsed_seconds": 7.44, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 308.61 + ], + [ + 182.37599999999998, + 308.61 + ], + [ + 182.37599999999998, + 322.38 + ], + [ + 30.6, + 322.38 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 436.59000000000003 + ], + [ + 99.144, + 436.59000000000003 + ], + [ + 99.144, + 449.55000000000007 + ], + [ + 30.6, + 449.55000000000007 + ] + ] + }, + { + "title": "Document description:Main Document", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 31.212, + 347.49 + ], + [ + 232.20684814453125, + 347.49 + ], + [ + 232.20684814453125, + 361.8170471191406 + ], + [ + 31.212, + 361.8170471191406 + ] + ] + }, + { + "title": "Electronic document Stamp:", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 31.212, + 374.22 + ], + [ + 183.31948852539062, + 374.22 + ], + [ + 183.31948852539062, + 388.8170471191406 + ], + [ + 31.212, + 388.8170471191406 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 71 + ], + [ + "Text", + 51 + ], + [ + "Line", + 35 + ], + [ + "SectionHeader", + 4 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 34 + ], + [ + "Line", + 16 + ], + [ + "Text", + 10 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207155" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207157/EFTA00207157.md b/marker2/ds9/EFTA00207157/EFTA00207157.md new file mode 100644 index 0000000000000000000000000000000000000000..54ac59e48c83ad92c47541839c17aa9e55fdc0e8 --- /dev/null +++ b/marker2/ds9/EFTA00207157/EFTA00207157.md @@ -0,0 +1,35 @@ +**From:** "[REDACTED] (USAFLS)" <[REDACTED]> +**To:** "[REDACTED]. (USAFLS)" <[REDACTED]> +**Subject:** RE: Jeffrey Epstein -- CORRECT ATTACHMENT +**Date:** Tue, 23 Feb 2010 15:57:48 +0000 +**Importance:** Normal + +--- + +Fine. + +--- + +**From:** [REDACTED]. (USAFLS) +**Sent:** Tuesday, February 23, 2010 10:07 AM +**To:** [REDACTED] (USAFLS); [REDACTED] (USAFLS) +**Subject:** RE: Jeffrey Epstein -- CORRECT ATTACHMENT + +Hi [REDACTED] and [REDACTED] – I propose simply sending Roy an email thanking him for his letter. Do you agree? + +[REDACTED] +**Assistant U.S. Attorney** +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +--- + +**From:** Roy BLACK [mailto:RBLACK@royblack.com] +**Sent:** Friday, February 19, 2010 8:05 PM +**To:** [REDACTED]. (USAFLS) +**Cc:** [REDACTED] (USAFLS); [REDACTED] (USAFLS) +**Subject:** Jeffrey Epstein -- CORRECT ATTACHMENT + +Attached please find the correct attachment of the pdf of a letter being mailed today. \ No newline at end of file diff --git a/marker2/ds9/EFTA00207157/EFTA00207157.metadata.json b/marker2/ds9/EFTA00207157/EFTA00207157.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..73f89c4229d77cf536de3401f8faf5c7686b2555 --- /dev/null +++ b/marker2/ds9/EFTA00207157/EFTA00207157.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207157.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 952, + "elapsed_seconds": 4.16, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 39 + ], + [ + "Text", + 26 + ], + [ + "Line", + 19 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207157" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207158/EFTA00207158.md b/marker2/ds9/EFTA00207158/EFTA00207158.md new file mode 100644 index 0000000000000000000000000000000000000000..7323b49099629e2a986af72ea5b8babb615bf9d7 --- /dev/null +++ b/marker2/ds9/EFTA00207158/EFTA00207158.md @@ -0,0 +1,33 @@ +From: + +To: + +Subject: . . -- 111111 + +Date: 11111 Tue, 23 Feb 2010 17:50:10 +0000 + +Importance: Normal + +Fine by me + +Fro + +To: + +Sent: ue + +Subject: RE: Jeffrey Epstein -- CORRECT ATTACHMENT + +Hi I propose simply sending Roy an email thanking him for his letter. Do you agree? + +From: Roy BLACK [mailto:RBLACK©royblack.corn] + +Sent: Friday, February 19, 2010 8:05 PM + +To: + +Cc: + +Subject: Jeffrey Epstein -- CORRECT ATTACHMENT + +Attached please find the correct attachment of the pdf of a letter being mailed today. \ No newline at end of file diff --git a/marker2/ds9/EFTA00207158/EFTA00207158.metadata.json b/marker2/ds9/EFTA00207158/EFTA00207158.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e1d51d584df6e3c24573658737ef353df3d84796 --- /dev/null +++ b/marker2/ds9/EFTA00207158/EFTA00207158.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207158.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 502, + "elapsed_seconds": 0.75, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 55 + ], + [ + "Line", + 27 + ], + [ + "Text", + 17 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207158" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207159/EFTA00207159.md b/marker2/ds9/EFTA00207159/EFTA00207159.md new file mode 100644 index 0000000000000000000000000000000000000000..6d7d5dc07d7a3b8a5edf378fa22359a1853c572d --- /dev/null +++ b/marker2/ds9/EFTA00207159/EFTA00207159.md @@ -0,0 +1,21 @@ +To: Roy BLACK + +Subject: RE: Jeffrey Epstein -- CORRECT ATTACHMENT + +Date: Tue, 23 Feb 2010 20:25:13 +0000 + +Importance: Normal + +Dear Roy: + +Thank you for your letter. + +Regards, + +From: Roy BLACK [mailto:RBLACK@royblack.corn] + +Sent: Friday, February 19, 2010 8:05 PM + +Subject: Jeffrey Epstein -- CORRECT ATTACHMENT + +Attached please find the correct attachment of the pdf of a letter being mailed today. \ No newline at end of file diff --git a/marker2/ds9/EFTA00207159/EFTA00207159.metadata.json b/marker2/ds9/EFTA00207159/EFTA00207159.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b1065cf4c258540f650212227fb4cc532c676c27 --- /dev/null +++ b/marker2/ds9/EFTA00207159/EFTA00207159.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207159.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 419, + "elapsed_seconds": 0.58, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 25 + ], + [ + "Line", + 12 + ], + [ + "Text", + 11 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207159" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207160/EFTA00207160.md b/marker2/ds9/EFTA00207160/EFTA00207160.md new file mode 100644 index 0000000000000000000000000000000000000000..c56198cbcc38e8450c55e612e3086175bca0ef20 --- /dev/null +++ b/marker2/ds9/EFTA00207160/EFTA00207160.md @@ -0,0 +1,27 @@ +To: + +Subject: . + +Date: Wed, 24 Feb 2010 16:47:19 +0000 + +Importance: Normal + +Hey, guess who is at it again. Now he is thinking of filing a motion to 1) early terminate his probation/community control, or 2) modify it to straight probation so he can move to New York. We are not agreeing to either but I also wanted your input/position. Thanks!!! + +From + +Sent: Tuesday, January 12, 2010 10:22 AM + +To: Barbara Burns + +Subject: Epstein + +Hi Barbara — This was just sent to me by someone in my office. In light of other instances where Mr. Epstein's counsel has falsely represented that something was agreed to, I just wanted to check with you to make certain that you were aware of, and joined in, the motion. Can you let me know? + +Thank you. (And Congratulations on your promotion!) + +«20100111143503.pdf» + +Assistant U.S. Attorney + +Please note: Florida has a very broad public records law. Most written communications to or from slate officials regarding state business are public records available to the public and media upon request. Your e-mail communications may therefore be subject to public disclosure. \ No newline at end of file diff --git a/marker2/ds9/EFTA00207160/EFTA00207160.metadata.json b/marker2/ds9/EFTA00207160/EFTA00207160.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..cb7ea87cddbacd0128cbfcf7b08954f547e4b697 --- /dev/null +++ b/marker2/ds9/EFTA00207160/EFTA00207160.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207160.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1103, + "elapsed_seconds": 0.69, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 45 + ], + [ + "Line", + 21 + ], + [ + "Text", + 15 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207160" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207161/EFTA00207161.md b/marker2/ds9/EFTA00207161/EFTA00207161.md new file mode 100644 index 0000000000000000000000000000000000000000..fede6f3150a71c0105e2243678c4410373e1c7db --- /dev/null +++ b/marker2/ds9/EFTA00207161/EFTA00207161.md @@ -0,0 +1,75 @@ +From: To: + +Subject: Activity in Case 9:08-cv-80119-ICAM Doe v. Epstein Motion for Protective Order + +Date: Fri, 26 Feb 2010 20:13:58 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered by Goldberger, Jack on 2/26/2010 at 3:13 PM EST and filed on 2/26/2010 + +Case Name: Doe I Epstein + +Case Number: 9:08-ev40 11 9-KAM + +Filer: + +Document Number: 475 + +Docket Text: + +Third Party OTION for Protective Order as to the Deposition of (Attachments: # (1) Exhibit A)(Goldberger, Jack) + +9:08-cv-80119-ICAM Notice has been electronically mailed to: + +Adam D. Horowitz ahorowitz@sezabuseattomey.com + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Isidro Manuel Garcia isidrogarcia®bellsouth.net + +Jack Alan Goldberger jagesq@bellsouth.net, nalanis®agwpa.com + +Jack Patrick Hill jph@searcylaw.com, clw@searcylaw.com, kmc@searcylaw.com, s.slater@searcylaw.com, sas@searcylaw.com, vat@searcylaw.com + +Jeffrey Marc Herman jherman@hermanlaw.com + +Richard Horace Willits lawyerwillits@aol.com, reelrhw@hotmail.com + +Robert C. Josefsberg rjosefsberg@podhurst.com, amann@podhurst.com, bertpatton®podhurst.com, mestrada@podhurst.com + +Robert Deweese Critton , Jr rcrit@bciclaw.com, bobbie@bciclaw.com + +Stuart S. Mennelstein ssm@sexabuseattorney.com, jarbour®sexabuseattomey.com, Irivera@sexabuseattomey.com + +9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +Martin G. Weinberg 20 Park Plaza Boston, MA 02116 + +The following document(s) are associated with this transaction: + +Document description:Main Document + +Original filename:n/a + +Electronic document Stamp: + +[STAMP dcecfStamp\_11 1105629215 [Date=2/26/2010] [FileNumber=7304957-0 ] [2738dbcbbd17d94230a8e7152b4eb008fad1320b09592fc4de033927 fl 7e4dd4def ff01731218ba359e8df4cc1140a2e84582607d167271f1 ef7cfee96e0a1 f4]] + +Document description:Exhibit A + +Original fileilainem/a + +Electronic document Stamp: + +[STAMP dcecfStamp\_ID=1105629215 [Date=2126/2010] [FileNumber=7304957-1 ] [0d8ed83df3ab0dcecb57db6361c04fb9c2e1a1841d8b24d39b6866c47d7a167c999 62c702ablec94295aaba0294bb218710e10a508df8b6a7b6d17a7c0bc366f]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00207161/EFTA00207161.metadata.json b/marker2/ds9/EFTA00207161/EFTA00207161.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..c88b694dc4ad066baeac0ed4bbe6a5873e592d03 --- /dev/null +++ b/marker2/ds9/EFTA00207161/EFTA00207161.metadata.json @@ -0,0 +1,112 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207161.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2963, + "elapsed_seconds": 1.25, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 31.212, + 309.42 + ], + [ + 184.3336639404297, + 309.42 + ], + [ + 184.3336639404297, + 324.23358154296875 + ], + [ + 31.212, + 324.23358154296875 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 70 + ], + [ + "Line", + 34 + ], + [ + "Text", + 24 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 53 + ], + [ + "Line", + 26 + ], + [ + "Text", + 16 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207161" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207163/EFTA00207163.md b/marker2/ds9/EFTA00207163/EFTA00207163.md new file mode 100644 index 0000000000000000000000000000000000000000..c2735c7190d7d3bcd0f9939a241408312e42c525 --- /dev/null +++ b/marker2/ds9/EFTA00207163/EFTA00207163.md @@ -0,0 +1,75 @@ +To:' + +Subject: Activity in Case 9:08-cv-80119-ICAM Doe I. Epstein Motion for Leave to File Excess Pages + +Date: Fri, 26 Feb 2010 21:39:02 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CIVUECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +# Notice of Electronic Filing + +The following transaction was entered by Pike, Michael on 2/26/2010 at 4:39 PM EST and filed on 2/26/2010 + +Case Name: Doe Epstein + +Case Number: 9:08-cv-80119-KAM + +Filer: Jeffrey Epstein + +Document Number:476 + +# Docket Text: + +Defendant's MOTION for Leave to File Excess Pages by Two (2) Pages in Defendant's Motion for Reconsideration and/or Request for Rule 4 Review and Appeal of Portions of the Magistrate's Order Dated February 4, 2010 (DE 462) with Incorporated Objections and Memorandum by Jeffrey Epstein. (Attachments: # (1) Text of Proposed Order Proposed Order) (Pike, Michael) + +9:08-cv-80119-KAM Notice has been electronically mailed to: + +Adam D. Horowitz + +Bradley James Edwards + +Isidro Manuel Garcia + +Jack Alan Goldberger + +Jack Patrick Hill + +Michael James Pike + +Paul G. Cassell + +Richard Horace Willits + +Robert C. Josefsberg + +Robert Deweese Critton , Jr + +Stuart S. Mermelstein + +9:08-cv-80119-ICAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +The following document(s) are associated with this transaction: + +## Document description:Main Document + +### Original filename:ft/a + +## Electronic document Stamp: + +[STAMP dcecfStamp\_11-2 1105629215 [Date=2/26/2010] [FileNumber=7305904-0 ] [578ee903ff4389faa5a3c I 3ae90b709bb7a42dcbf26e6 1 el98f3 fcf88 I 784f25cb3 d771f96208c66ccd9e5c5c2a926f35ef2fab06618b2ad659f4lc5aec2b55a]] + +### Document description:Text of Proposed Order Proposed Order + +### Original filename:it/a + +#### Electronic document Stamp: + +[STAMP dcecfStamp\_11> 1105629215 [Date=2/26/2010] [FileNumber=7305904-1 ] [4b05c8a16fcbffildb979f67517763894a4b9ab09ac7ec347bldeb00cf7dddb7f8e8 076ea44ea88e2d5eef775d3a651be048c17a8cf I 7c6139dc4064132639bfc]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00207163/EFTA00207163.metadata.json b/marker2/ds9/EFTA00207163/EFTA00207163.metadata.json new file mode 100644 index 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b/marker2/ds9/EFTA00207165/EFTA00207165.md @@ -0,0 +1,77 @@ +From: ' < + +To:' " < + +Subject: Activity in Case 9:08-cv-80119-ICAM Doe I. Epstein Motion for Reconsideration + +Date: Fri, 26 Feb 2010 21:42:39 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CIVUECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered by Pike, Michael on 2/26/2010 at 4:42 PM EST and filed on 2/26/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80119-KAM + +Filer: Jeffrey Epstein + +Document Number:477 + +# Docket Text: + +Defendant's MOTION for Reconsideration re [462] Order, Terminate Motions and/or Request for Rule 4 Review and Appeal of Portions of the Magistrate's Order Dated February 4, 2010 (DE 462) with Incorporated Objections and Memorandum of Law by Jeffrey Epstein. (Attachments: # (1) Exhibit A)(Pike, Michael) + +9:08-cv-80119-ICAM Notice has been electronically mailed to: + +Adam D. Horowitz + +Bradley James Edwards + +Isidro Manuel Garcia + +Jack Alan Goldberger + +Jack Patrick Hill + +Paul G. Cassell + +Richard Horace Willits + +Robert 1. Josefsberg + +Robert Deweese Critton , Jr + +Stuart S. Mermelstein + +9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and wilt 1w pi (n Wed by other means. For further assistance, please contact our Help Desk at 1 + +Martin G. Weinberg 20 Park Plaza Boston, MA 02116 + +The following document(s) are associated with this transaction: + +### Document description:Main Document + +Original filename:n/a + +#### Electronic document Stamp: + +[STAMP dcecfStamp\_11:» 1105629215 [Date=2/26/2010] [FileNumber=7305963-0 ] [3aldd33e3b765d5c7aafb59eab86a35be9a1756081683166ee5a652a842d1daea64 c4669da7c846cb609344t27977db0acf861e54856891ae590b2bflcdc652a]] + +### Document description:Exhibit A + +Original filename:Wa + +## Electronic document Stamp: + +[STAMP dceciStamp\_11:» 1105629215 [Date=2/26/2010] [FileNumber=7305963-1 ] [0357f663f37c96a7c757050a521b7d8016dafd56107b505fb038a1f2e7a5e564c5c 6df4cea623e512913b17eceb23abecl9b57952fcca8efbcf5lae8 fl 02fb89]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00207165/EFTA00207165.metadata.json b/marker2/ds9/EFTA00207165/EFTA00207165.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..0be214f358c86500da325e250fb7f020af27575c --- /dev/null +++ b/marker2/ds9/EFTA00207165/EFTA00207165.metadata.json @@ -0,0 +1,231 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207165.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2636, + "elapsed_seconds": 1.24, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 31.212, + 308.61 + ], + [ + 184.3336639404297, + 308.61 + ], + [ + 184.3336639404297, + 324.23358154296875 + ], + [ + 31.212, + 324.23358154296875 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 31.212, + 422.82 + ], + [ + 101.65031433105469, + 422.82 + ], + [ + 101.65031433105469, + 438.6035461425781 + ], + [ + 31.212, + 438.6035461425781 + ] + ] + }, + { + "title": "Document description:Main Document", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 30.6, + 347.49 + ], + [ + 231.72769165039062, + 347.49 + ], + [ + 231.72769165039062, + 362.1035461425781 + ], + [ + 30.6, + 362.1035461425781 + ] + ] + }, + { + "title": "Electronic document Stamp:", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 30.6, + 375.03000000000003 + ], + [ + 183.71038818359375, + 375.03000000000003 + ], + [ + 183.71038818359375, + 389.1035461425781 + ], + [ + 30.6, + 389.1035461425781 + ] + ] + }, + { + "title": "Document description:Exhibit A", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 30.6, + 428.49 + ], + [ + 200.19384765625, + 428.49 + ], + [ + 200.19384765625, + 443.1035461425781 + ], + [ + 30.6, + 443.1035461425781 + ] + ] + }, + { + "title": "Electronic document Stamp:", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 30.6, + 455.22 + ], + [ + 183.71038818359375, + 455.22 + ], + [ + 183.71038818359375, + 470.1035461425781 + ], + [ + 30.6, + 470.1035461425781 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 68 + ], + [ + "Line", + 34 + ], + [ + "Text", + 24 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 51 + ], + [ + "Line", + 25 + ], + [ + "Text", + 13 + ], + [ + "SectionHeader", + 4 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207165" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207167/EFTA00207167.md b/marker2/ds9/EFTA00207167/EFTA00207167.md new file mode 100644 index 0000000000000000000000000000000000000000..17a05b548af0f020f77d0319bea977adb5c372e4 --- /dev/null +++ b/marker2/ds9/EFTA00207167/EFTA00207167.md @@ -0,0 +1,13 @@ +Subject: A tip + +Date: Wed, 03 Mar 2010 18:44:59 -0000 + +Importance: Normal + +Hi Irene — Just got one of Judge M's orders on Epstein. Not that it is any of my business, but just wanted you to know that if he wants to avoid that really annoying line that sometimes appears at the beginning of paragraphs when you "publish" a document to PDF, there is a simple fix. + +Instead of "publishing" the document, "print" the document, and then select Adobe PDF as the printer. It will ask you to give it a file name, and then will create the pdf document. + +(Now you know why the US Attorney's Office can't ever fire me, I am the only one who actually knows all the computer geek stuff.) + +![](_page_0_Picture_6.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00207167/EFTA00207167.metadata.json b/marker2/ds9/EFTA00207167/EFTA00207167.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..4162c9efc01696a8594e3b6a0e05b86771b1fc1e --- /dev/null +++ b/marker2/ds9/EFTA00207167/EFTA00207167.metadata.json @@ -0,0 +1,60 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207167.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 702, + "elapsed_seconds": 0.46, + "image_assets": [ + "_page_0_Picture_6.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 21 + ], + [ + "Line", + 11 + ], + [ + "Text", + 6 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207167" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207167/_page_0_Picture_6.jpeg b/marker2/ds9/EFTA00207167/_page_0_Picture_6.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..030d61f65de5ded4e6ed2c9a66886a5a91530d61 --- /dev/null +++ b/marker2/ds9/EFTA00207167/_page_0_Picture_6.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:efc819a27216ac9807c54f6d6153acc0a5c6943310a59ad2751c1dc6185f8605 +size 10674 diff --git a/marker2/ds9/EFTA00207168/EFTA00207168.md b/marker2/ds9/EFTA00207168/EFTA00207168.md new file mode 100644 index 0000000000000000000000000000000000000000..774b6942d92dd6be0e91a07f484b7a302cf7d7ba --- /dev/null +++ b/marker2/ds9/EFTA00207168/EFTA00207168.md @@ -0,0 +1,31 @@ +From: 't=la + +To: (USAFLS)" + +Subject: Re: A tip + +Date: Wed, 03 Mar 2010 18:51:43 +0000 + +Importance: Normal + +I tried it and it works! Unfortunately the judge is the one who publishes the orders and I dont think he'll want to add an extra step. + +Courtroom Deputy Jud e Marra's Chambers + +'a SAFIS' + +03103,2010 01:45 PM + +To S. + +cc + +Subject A tip + +Hi Irene — Just got one of Judge M's orders on Epstein. Not that it is any of my business, but just wanted you to know that if he wants to avoid that really annoying line that sometimes appears at the beginning of paragraphs when you "publish" a document to PDF, there is a simple fix. + +Instead of "publishing" the document, "print" the document, and then select Adobe PDF as the printer. It will ask you to give it a file name, and then will create the pdf document. + +(Now you know why the US Attorney's Office can't ever fire me, I am the only one who actually knows all the computer geek stuff.) + +Assistant U.S. Attorney \ No newline at end of file diff --git a/marker2/ds9/EFTA00207168/EFTA00207168.metadata.json b/marker2/ds9/EFTA00207168/EFTA00207168.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..abd38baff69c98d72fe5ab202283a201232b80a1 --- /dev/null +++ b/marker2/ds9/EFTA00207168/EFTA00207168.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207168.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 965, + "elapsed_seconds": 0.95, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 48 + ], + [ + "Line", + 23 + ], + [ + "Text", + 19 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Text", + 2 + ], + [ + "PageFooter", + 1 + ], + [ + "Line", + 1 + ], + [ + "Span", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207168" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207170/EFTA00207170.md b/marker2/ds9/EFTA00207170/EFTA00207170.md new file mode 100644 index 0000000000000000000000000000000000000000..31be49d26d45cc6ab03f0c182330f24c03f7733a --- /dev/null +++ b/marker2/ds9/EFTA00207170/EFTA00207170.md @@ -0,0 +1,69 @@ +To: "flsd\_cmecf notice®flsd.uscourts.gov" + +Subject: Activity in Case 9:08-cv-80119-ICAM Doe I. Epstein Order on Motion for Protective Order + +Date: Wed, 03 Mar 2010 23:06:11 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered on 3/3/2010 at 6:06 PM EST and filed on 3/3/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80119-KAM + +Filer: + +Document Number: 479 + +Docket Text: + +ORDER Granting nunc pro tunc 14751 Motion for Protective Order. Signed by Magistrate Judge Linnea R. Johnson on 3/3/2010. (sa) + +9:08-cv-80119-ICAM Notice has been electronically mailed to: + +Adam D. Horowitz ahorowitz@sexabuseattomey.com + +Ann Marie C. Villafana ann.marie.c.villafana@usdoj.gov + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Isidro Manuel Garcia isidrogarcia®bellsouth.net + +Jack Alan Goldberger jagesq@bellsouth.net, nalanis@agwpa.com + +Jack Patrick Hill jph@searcylaw.com, clw@searcylaw.com, kmc@searcylaw.com, s.slater@searcylaw.com, sas@searcylaw.com, vat@searcylaw.com + +Jeffrey Marc Herman jherman@hermanlaw.com + +Richard Horace Willits lawyerwillits@aol.com, reelrhw@hotmail.com + +Robert C. Josefsberg rjosefsberg@podhurst.com, amann@podhurst.com, bertpatton®podhurst.com, mestrada@podhurst.com + +Robert Deweese Critton , Jr rcrit@bciclaw.com, bobbie@bciclaw.com + +Stuart S. Mennelstein ssm@sexabuseattorney.com, jarbour®sexabuseattomey.com, Irivera@sexabuseattomey.com + +9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +Martin G. Weinberg 20 Park Plaza Boston, MA 02116 + +The following document(s) are associated with this transaction: + +Document description:Main Document + +Original filenamem/a + +Electronic document Stamp: + +[STAMP dcecfStamp\_11: 1105629215 [Date=3/3/2010] [FileNumber=7321375-0] [62800771d861d07026ee5a7fcfad28d6393546ac94O30ab6b8e8b72286196a830a9 af9b6d72ba299cd2d7db31f06ee5a2d2164e0163010130625f15137b5c00]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00207170/EFTA00207170.metadata.json b/marker2/ds9/EFTA00207170/EFTA00207170.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..82de2f201005ffa40f65047ffd5442f2d0f74a97 --- /dev/null +++ b/marker2/ds9/EFTA00207170/EFTA00207170.metadata.json @@ -0,0 +1,112 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207170.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2794, + "elapsed_seconds": 1.29, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 308.61 + ], + [ + 184.3336639404297, + 308.61 + ], + [ + 184.3336639404297, + 324.23358154296875 + ], + [ + 30.6, + 324.23358154296875 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 69 + ], + [ + "Line", + 35 + ], + [ + "Text", + 26 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 39 + ], + [ + "Line", + 20 + ], + [ + "Text", + 12 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207170" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207172/EFTA00207172.md b/marker2/ds9/EFTA00207172/EFTA00207172.md new file mode 100644 index 0000000000000000000000000000000000000000..5d2c850334f9f8dca6114707aa3434bc4a17f239 --- /dev/null +++ b/marker2/ds9/EFTA00207172/EFTA00207172.md @@ -0,0 +1,67 @@ +To: "flsd\_cmecf notice@flsd.uscourts.gov" + +Subject: Activity in Case 9:08-cv-80119-ICAM Doe I. Epstein Order on Motion to Compel + +Date: Thu, 04 Mar 2010 22:39:32 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered on 3/4/2010 at 5:39 PM EST and filed on 3/4/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80119-KAM + +Filer: + +Document Number: 480 + +## Docket Text: + +ORDER Granting In Part and Denying In Part in Accordance with the terms of this Order [333] Motion to Compel. Signed by Magistrate Judge Linnea R. Johnson on 3/4/2010. (sa) + +9:08-cv-80119-ICAM Notice has been electronically mailed to: + +Adam D. Horowitz ahorowitz@sexabuseattomey.com + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Isidro Manuel Garcia isidrogarcia®bellsouth.net + +Jack Alan Goldberger jagesq@bellsouth.net, nalanis®agwpa.com + +Jack Patrick Hill jph@searcylaw.com, clw@searcylaw.com, kmc@searcylaw.com, s.slater@searcylaw.com, sas®searcylaw.com, vat@searcylaw.com + +Jeffrey Marc Herman jherman@hermanlaw.com + +Richard Horace Willits lawyerwillits@aol.com, reelrhw@hotmail.com + +Robert C. Josefsberg rjosefsberg@podhurst.com, amann@podhurst.com, bertpatton®podhurst.com, mestrada@podhurst.com + +Robert Deweese Critton , Jr rcrit@bciclaw.com, bobbie@bciclaw.com + +Stuart S. Mennelstein ssm@sexabuseattorney.com, jarbour®sexabuseattomey.com, Irivera@sexabuseattomey.com + +9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +Martin G. Weinberg 20 Park Plaza Boston, MA 02116 + +The following document(s) are associated with this transaction: + +Document description:Main Document + +Original filename:n/a + +Electronic document Stamp: + +[STAMP dcecfStamp\_11: 1105629215 [Date=3/4/2010] [FileNumber=7325909-0] [5ef7dfl a2790526d2a4c38efacae7132173016879b53a956873145556edle78fale2 02867da18a73ad9f30ac1386a6dt856ad46i0b6c5203c28e4Id2340cea3b]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00207172/EFTA00207172.metadata.json b/marker2/ds9/EFTA00207172/EFTA00207172.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..7fc44789d525db3caf305971b16c499841b17c50 --- /dev/null +++ b/marker2/ds9/EFTA00207172/EFTA00207172.metadata.json @@ -0,0 +1,135 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207172.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2779, + "elapsed_seconds": 1.53, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 308.61 + ], + [ + 184.3336639404297, + 308.61 + ], + [ + 184.3336639404297, + 324.23358154296875 + ], + [ + 30.6, + 324.23358154296875 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 422.82 + ], + [ + 101.65031433105469, + 422.82 + ], + [ + 101.65031433105469, + 438.6035461425781 + ], + [ + 30.6, + 438.6035461425781 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 67 + ], + [ + "Line", + 34 + ], + [ + "Text", + 24 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 39 + ], + [ + "Line", + 20 + ], + [ + "Text", + 12 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207172" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207174/EFTA00207174.md b/marker2/ds9/EFTA00207174/EFTA00207174.md new file mode 100644 index 0000000000000000000000000000000000000000..11f85fe76640ef5244589cc1214c3d7af06c156e --- /dev/null +++ b/marker2/ds9/EFTA00207174/EFTA00207174.md @@ -0,0 +1,57 @@ +To: "flsd\_cmecf notice®flsd.uscourts.gov" + +Subject: Activity in Case 9:08-cv-80119-ICAM Doe I. Epstein Sealed Document + +Date: Thu, 04 Mar 2010 22:44:37 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered on 3/4/2010 at 5:44 PM EST and filed on 3/4/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80119-KAM + +Filer: + +Document Number: 481(No document attached) + +Docket Text: + +Sealed Document (sa) + +9:08-cv-80119-KAM Notice has been electronically mailed to: + +Adam D. Horowitz ahorowitz@sexabuseattomey.com + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Isidro Manuel Garcia isidrogarcia®bellsouth.net + +Jack Alan Goldberger jagesq@bellsouth.net, nalanis®agwpa.com + +Jack Patrick Hill jph@searcylaw.com, clw@searcylaw.com, kmc@searcylaw.com, s.slater@searcylaw.com, sas@searcylaw.com, vat@searcylaw.com + +Jeffrey Marc Herman jherman@hermanlaw.com + +Richard Horace Willits lawyenvillits®aol.com, reelrhw@hotmail.com + +Robert C. Josefsberg rjosefsberg@podhurst.com, amann@podhurst.com, bertpatton®podhurst.com, mestrada@podhurst.com + +Robert Deweese Critton , Jr rcrit@bciclaw.com, bobbie@bciclaw.com + +Stuart S. Mermelstein ssm@sexabuseattomey.com, jarbour®sexabuseattomey.com, Irivera@sexabuseattomey.com + +9:08-cv-80119-1CAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +Martin G. 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Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +# Notice of Electronic Filing + +The following transaction was entered by Pike, Michael on 3/5/2010 at 11:09 AM EST and filed on 3/5/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80893-1CAM + +Filer: Jeffrey Epstein + +Document Number: 126 + +# Docket Text: + +Defendant's MOTION for Summary Judgment including Supporting Memorandum of Law by Jeffrey Epstein. Responses due by 3/29/2010 (Attachments: # (1) Exhibit A, # (2) Exhibit B) (Pike, Michael) + +9:08-cv-80893-KAM Notice has been electronically mailed to: + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Jack Alan Goldberger jagesq@bellsouth.net, nalanis®agwpa.com + +Michael James Pike MPike@bciclaw.com, bobbie@bciclaw.com, jcadwell@bciclaw.com + +Paul G. Cassell cassellp@law.utah.edu + +Robert Deweese Critton , Jr rcrit@bciclaw.com, bobbie@bciclaw.com + +9:08-cv-80893-ICAM Notice has not been delivered electronically to those listed below and will be provided by other means. 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Epstein Motion for Leave to File Excess Pages + +Date: Fri, 05 Mar 2010 20:09:20 +0000 + +Importance: Normal + +--- + +**This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended.** + +**\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\*** Judicial Conference of the United States policy permits attorneys of record and parties in a case (including prose litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +**Notice of Electronic Filing** + +The following transaction was entered by Pike, Michael on 3/5/2010 at 3:09 PM EST and filed on 3/5/2010 + +Case Name: Doe [REDACTED] Epstein + +Case Number: [9:08-cv-80893-KAM](#) + +Filer: Jeffrey Epstein + +Document Number: [127](#) + +**Docket Text:** + +**Defendant's MOTION for Leave to File Excess Pages in *Defendant's Motion for Summary Judgment Including Supporting Memorandum of Law* by Jeffrey Epstein. (Attachments: # (1) Text of Proposed Order Proposed Order)(Pike, Michael)** + +**9:08-cv-80893-KAM Notice has been electronically mailed to:** + +[REDACTED] + +Bradley James Edwards [REDACTED] + +Jack Alan Goldberger [REDACTED] + +Michael James Pike [REDACTED] + +Paul G. Cassell [REDACTED] + +Robert Deweese Critton, Jr [REDACTED] + +**9:08-cv-80893-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.:** + +**Original filename:**n/a + +**Electronic document Stamp:** + +[STAMP dcecfStamp\_ID=1105629215 [Date=3/5/2010] [FileNumber=7329351-0] +[6e6a32c88b4143018c8e1f31bf06e50b2e7d179fc290d5281a26e316de141038cab2 +12014746251570edcb777976975ae7ceb3d2c30f5990078ace57e6c1e1eb]] + +**Document description:**Text of Proposed Order Proposed Order + +**Original filename:**n/a + +**Electronic document Stamp:** + +[STAMP dcecfStamp\_ID=1105629215 [Date=3/5/2010] [FileNumber=7329351-1] +[3de62bfbc49e6832d155fe2d07238071c6695e0da1a566b0c4caaa53525d9252b5a3 +155a73073bdb87011b04024b9c792111b2889a3a373dc17d92ed6e50e5aa]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00207178/EFTA00207178.metadata.json b/marker2/ds9/EFTA00207178/EFTA00207178.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..a1e4453315d04cdd2b3da686b4bb60eb6ee10e30 --- /dev/null +++ b/marker2/ds9/EFTA00207178/EFTA00207178.metadata.json @@ -0,0 +1,131 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207178.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2487, + "elapsed_seconds": 8.46, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 308.61 + ], + [ + 181.76399999999998, + 308.61 + ], + [ + 181.76399999999998, + 322.38 + ], + [ + 30.6, + 322.38 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 422.82 + ], + [ + 99.144, + 422.82 + ], + [ + 99.144, + 435.7800000000001 + ], + [ + 30.6, + 435.7800000000001 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 67 + ], + [ + "Text", + 50 + ], + [ + "Line", + 34 + ], + [ + "SectionHeader", + 3 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 10 + ], + [ + "SectionHeader", + 6 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207178" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207180/EFTA00207180.md b/marker2/ds9/EFTA00207180/EFTA00207180.md new file mode 100644 index 0000000000000000000000000000000000000000..fe98c57633e3e19c46e44e368038f04bebfd31a6 --- /dev/null +++ b/marker2/ds9/EFTA00207180/EFTA00207180.md @@ -0,0 +1,53 @@ +To:' ' < + +Subject: Activity in Case 9:08-cv-80893-KAM Doe 1 Epstein Motion for Summary Judgment + +Date: Fri, 05 Mar 2010 20:11:21 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +# U.S. District Court + +#### Southern District of Florida + +# Notice of Electronic Filing + +The following transaction was entered by Pike, Michael on 3/5/2010 at 3:11 PM EST and filed on 3/5/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80893-KAM + +Filer: Jeffrey Epstein + +Document Number: 128 + +### Docket Text: + +Defendant's MOTION for Summary Judgment Including Supporting Memorandum of Law by Jeffrey Epstein. Responses due by 3/29/2010 (Pike, Michael) + +9:08-cv-80893-KAM Notice has been electronically mailed to: + +• I. + +Bradley James Edwards + +Jack Alan Goldberger + +Michael James Pike + +Paul G. Cassell + +Robert Deweese Critton , Jr + +9:08-cv-80893-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. 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I need to update my boss on what position you have on Epstein early terminating his probation. We, of course, are objecting. Please let me know. 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I need to update my boss on what position you have on Epstein early terminating his probation. We, of course, are objecting. Please let me know. 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(USAFLS)" <[REDACTED]> + +**Subject:** RE: Congratulations on a Trial Victory! + +**Date:** Mon, 08 Mar 2010 20:04:46 +0000 + +**Importance:** Normal + +--- + +355-7277 Thanks!!! + +-----Original Message----- + +From: [REDACTED], [REDACTED], [REDACTED]. (USAFLS) [mailto:[REDACTED]] + +Sent: Monday, March 08, 2010 2:43 PM + +To: [REDACTED] + +Subject: RE: Congratulations on a Trial Victory! + +Hi [REDACTED] -- Where can I call you? + +[REDACTED] + +-----Original Message----- + +From: [REDACTED] [mailto:[REDACTED]] + +Sent: Monday, March 08, 2010 8:24 AM + +To: [REDACTED], [REDACTED], [REDACTED]. (USAFLS) + +Subject: RE: Congratulations on a Trial Victory! + +Hey, I never heard back from you on a Jeffrey Epstein email I sent a couple of weeks ago. I need to update my boss on what position you have on Epstein early terminating his probation. We, of course, are objecting. Please let me know. Thanks!!!! + +-----Original Message----- + +From: [REDACTED], [REDACTED], [REDACTED]. (USAFLS) [mailto:[REDACTED]] + +Sent: Saturday, March 06, 2010 10:45 AM + +[REDACTED] + +Subject: Congratulations on a Trial Victory! + +I also wanted to congratulate [REDACTED] on his victory in convicting [REDACTED] at trial. As many of you know [REDACTED] and his brothers have been trying to intimidate people inside and outside of the jail and to create the appearance that they have more power than the law enforcement community. Each victory along the way is a means to show that the gangs have not taken over the justice system, and that we are united in keeping our community safe, so that everyday people can enjoy a life free from fear. + +[REDACTED] + +![](_page_1_Picture_0.jpeg) + +----Original Message-- + +Fro Sent To: + +Hello All... + +Just wanted to let the group know that we arrested another co-conspirator today for bstruction of Justice and Making False Statements. was arrested this afternoon without incident. A BIG THANKS to and the two awesome marked unit patrol officers that came to help - they did great! + +Have a nice weekend! + +![](_page_1_Picture_6.jpeg) + +Please note: Florida has a very broad public records law. Most written communications to or from state officials regarding state business are public records available to the public and media upon request. Your e-mail communications may therefore be subject to public disclosure. \ No newline at end of file diff --git a/marker2/ds9/EFTA00207186/EFTA00207186.metadata.json b/marker2/ds9/EFTA00207186/EFTA00207186.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f943fe47a460249188a4e00b33a0a3d80087e252 --- /dev/null +++ b/marker2/ds9/EFTA00207186/EFTA00207186.metadata.json @@ -0,0 +1,91 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207186.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2333, + "elapsed_seconds": 7.23, + "image_assets": [ + "_page_1_Picture_0.jpeg", + "_page_1_Picture_6.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 63 + ], + [ + "Text", + 54 + ], + [ + "Line", + 30 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 25 + ], + [ + "Line", + 13 + ], + [ + "Text", + 6 + ], + [ + "Picture", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207186" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207186/_page_1_Picture_0.jpeg b/marker2/ds9/EFTA00207186/_page_1_Picture_0.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..3dfe5fb1c3db31d5badfd89f43c031e539847bde --- /dev/null +++ b/marker2/ds9/EFTA00207186/_page_1_Picture_0.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:8cc085c190d081e2a67c27ec32a3460c274c3f968fe945b51a67cb97ae58fa57 +size 5164 diff --git a/marker2/ds9/EFTA00207186/_page_1_Picture_6.jpeg b/marker2/ds9/EFTA00207186/_page_1_Picture_6.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..b9c3ec6fe0e46168b4a8c47e796dd442904115db --- /dev/null +++ b/marker2/ds9/EFTA00207186/_page_1_Picture_6.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:737397f9b8e0b2c14d2f1715a646830498bd99da758cd4e6a9ee6d1feb5dd72e +size 3846 diff --git a/marker2/ds9/EFTA00207188/EFTA00207188.md b/marker2/ds9/EFTA00207188/EFTA00207188.md new file mode 100644 index 0000000000000000000000000000000000000000..aad468b46dc8dcb3fdaed427a524da2d0aa8ea88 --- /dev/null +++ b/marker2/ds9/EFTA00207188/EFTA00207188.md @@ -0,0 +1,69 @@ +To: "flsd\_cmecf notice@flsd.uscourts.gov" + +Subject: Activity in Case 9:08-cv-80119-ICAM Doe I. Epstein Order + +Date: Tue, 09 Mar 2010 15:19:48 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered on 3/9/2010 at 10:19 AM EST and filed on 3/9/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80119-KAM + +Filer: + +Document Number:482 + +Docket Text: + +JOINT AGREED ORDER on [405] MOTION For Order for the preservation of evidence filed by Jeffrey Epstein. Signed by Magistrate Judge Linnea R. Johnson on 3/9/2010. (sa) + +9:08-cv-80119-ICAM Notice has been electronically mailed to: + +Adam D. Horowitz ahorowitz@sexabuseattomey.com + +y • + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Isidro Manuel Garcia isidrogarcia@bellsouth.net + +Jack Alan Goldberger jagesq@bellsouth.net, nalanis@agwpa.com + +Jack Patrick Hill jph@searcylaw.com, clw@searcylaw.com, kmc@searcylaw.com, s.slater@searcylaw.com, sas@searcylaw.com, vat@searcylaw.com + +Jeffrey Marc Herman jherman@hermanlaw.com + +Richard Horace Willits lawyerwillits@aol.com, reelrhw@hotmail.com + +Robert C. Josefsberg rjosefsberg@podhurst.com, amann@podhurst.com, bertpatton®podhurst.com, mestrada@podhurst.com + +Robert Deweese Critton , Jr rcrit@bciclaw.com, bobbie@bciclaw.com + +Stuart S. Mennelstein ssm@sexabuseattorney.com, jarbour®sexabuseattomey.com, Irivera@sexabuseattomey.com + +9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +Martin G. Weinberg 20 Park Plaza Boston, MA 02116 + +The following document(s) are associated with this transaction: + +Document description:Main Document + +Original filenamem/a + +Electronic document Stamp: + +[STAMP dcecfStamp\_11> 1105629215 [Date=3/9/2010] [FileNumber=7336772-0] [5847a42231d33f2c1eb797057121cd0f001bc3b49b9cca832bb5e1c01be9081455bc e3b711617a7bb8bea493ca5e56027bbd12c35af83f9e46c97a61a09d855c]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00207188/EFTA00207188.metadata.json b/marker2/ds9/EFTA00207188/EFTA00207188.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f0a82653f5d1ce370a34296017ad60bb32614abf --- /dev/null +++ b/marker2/ds9/EFTA00207188/EFTA00207188.metadata.json @@ -0,0 +1,112 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207188.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2753, + "elapsed_seconds": 1.26, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 308.61 + ], + [ + 184.3336639404297, + 308.61 + ], + [ + 184.3336639404297, + 324.23358154296875 + ], + [ + 30.6, + 324.23358154296875 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 69 + ], + [ + "Line", + 35 + ], + [ + "Text", + 26 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 39 + ], + [ + "Line", + 20 + ], + [ + "Text", + 12 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207188" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207190/EFTA00207190.md b/marker2/ds9/EFTA00207190/EFTA00207190.md new file mode 100644 index 0000000000000000000000000000000000000000..98e88d81cd1af35f0a3ce1d4f4a55c7b20875a66 --- /dev/null +++ b/marker2/ds9/EFTA00207190/EFTA00207190.md @@ -0,0 +1,67 @@ +To:" + +Subject: Activity in Case 9:08-cv-80119-ICAM Doe I. Epstein Response in Opposition to Motion + +Date: Wed, 31 Mar 2010 18:49:08 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered by Pike, Michael on 3/31/2010 at 2:49 PM EDT and filed on 3/31/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80119-KAM + +Filer: Jeffrey Epstein + +Document Number: 512 + +## Docket Text: + +RESPONSE in Opposition re [489] Plaintiffs MOTION to Compel Production of Jane Doe Nos. 2-7's Sworn Statements to FBI Investigators and Incorporated Memorandum of Law filed by Jeffrey Epstein. (Pike, Michael) + +9:08-cv-80119-KAM Notice has been electronically mailed to: + +Adam D. Horowitz + +Bradley James Edwards + +Isidro Manuel Garcia + +Jack Alan Goldberger + +Jack Patrick Hill + +Paul G. Cassell + +Richard Horace Willits + +Robert C. Josefsbe + +Robert Deweese Critton , Jr + +Stuart S. Merrnelstein + +9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. 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Epstein Extension of Time to File Response/Reply + +Date: Wed, 31 Mar 2010 21:16:27 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered by Edwards, Bradley on 3/31/2010 at 5:16 PM EDT and filed on 3/31/2010 + +Case Name: Doe v. Epstein + +Case Number: 9:08-cv-80893-KAM + +Filer: Jane Doe + +Document Number: 133 + +## Docket Text: + +Plaintiffs MOTION for Extension of Time to File Response/Reply as to [130] Defendants MOTION for Summary Judgment with Incorporated Memorandum of Law by Jane Doe. (Attachments: # (1) Text of Proposed Order)(Edwards, Bradley) + +9:08-cv-80893-KAM Notice has been electronically mailed to: + +Bradley James Edwards Jack Alan Goldberger Michael James Pike Paul G. Cassell Robert Deweese Critton , Jr + +9:08-cv-80893-KAM Notice as not een e were e ectromca y to t ose iste e ow an wi be provided by other means. 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Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered on 4/1/2010 at 10:59 AM EDT and filed on 4/1/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80893-KAM + +Filer: + +Document Number: 134(No document attached) + +## Docket Text: + +ENDORSED ORDER granting [133] Motion for Extension of Time to File Response/Reply re [130] Defendant's MOTION for Summary Judgment with Incorporated Memorandum of Law. Responses due by 4/12/2010. Signed by Judge Kenneth A. Marra on 4/1/2010. (ir) + +9:08-cv-80893-KAM Notice has been electronically mailed to: + +Ann Marie C. Villafana ann.marie.c.villafana@usdoj.gov + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Jack Alan Goldberger jagesq@bellsouth.net, nalanis®agwpa.com + +Michael James Pike MPike@bciclaw.com, bobbie@bciclaw.com, jcadwell@bciclaw.com + +Paul G. Cassell cassellp@law.utah.edu + +Robert Deweese Critton , Jr rcrit@bciclaw.com, bobbie@bciclaw.com + +9:08-cv-80893-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. 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Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +# U.S. District Court + +## Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered by Pike, Michael on 4/1/2010 at 11:13 AM EDT and filed on 4/1/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80893-ICAM + +Filer: Jeffrey Epstein + +Document Number: 135 + +## Docket Text: + +Defendant's MOTION for Attorney Fees and Costs Based on Dismissal With Prejudice of Plaintiff's RICO Claim by Jeffrey Epstein. Responses due by 4/19/2010 (Attachments: # (1) Exhibit Part I, # (2) Exhibit Part II, # (3) Exhibit B, # (4) Exhibit C)(Pike, Michael) + +9:08-cv-80893-KAM Notice has been electronically mailed to: + +Ann Marie C. Villafana ann.marie.c.villafana@usdoj.gov + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Jack Alan Goldberger jagesq@bellsouth.net, nalanis®agwpa.com + +Michael James Pike MPike@bciclaw.com, bobbie@bciclaw.com, jcadwell@bciclaw.com + +Paul G. Cassell cassellp@law.utah.edu + +Robert Deweese Critton , Jr rcrit@bciclaw.com, bobbie@bciclaw.com + +9:08-cv-80893-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. 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Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered on 4/1/2010 at 1:38 PM EDT and filed on 4/1/2010 + +Case Name: Doe Epstein + +Case Number: 9:08-cv-80119-KAM + +Filer: + +Document Number: 513 + +Docket Text: + +OMNIBUS ORDER Denying [477] Motion for Reconsideration ; Denying [488] Motion for Reconsideration. Signed by Magistrate Judge Linnea R. Johnson on 4/1/2010. (sa) + +9:08-cv-80119-KAM Notice has been electronically mailed to: + +Adam D. Horowitz + +Bradley James Edwards + +Isidro Manuel Garcia + +Jack Alan Goldberger f + +Jack Patrick Hill + +Jeffrey Marc Herman + +Richard Horace Willits + +Robert . Josefsbe + +Robert Deweese Critton , ir + +Stuart S. Mermelstein + +9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1 + +Martin G. 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Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered on 4/1/2010 at 2:44 PM EDT and filed on 4/1/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80893-ICAM + +Filer: + +Document Number: 136 + +## Docket Text: + +ORDER staying consideration of [135] Defendant's MOTION for Attorney Fees and Costs Based on Dismissal With Prejudice of Plaintiff's RICO Claim filed by Jeffrey Epstein. Signed by Judge Kenneth A. Marra on 4/1/2010. 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Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +# Notice of Electronic Filing + +The following transaction was entered by Pike, Michael on 4/1/2010 at 2:50 PM EDT and filed on 4/1/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80893-KAM + +Filer: Jeffrey Epstein + +Document Number: 137 + +# Docket Text: + +Notice of Supplemental Authority re [135] Defendant's MOTION for Attorney Fees and Costs Based on Dismissal With Prejudice of Plaintiff's RICO Claim by Jeffrey Epstein (Attachments: # (1) Exhibit A)(Pike, Michael) + +9:08-cv-80893-KAM Notice has been electronically mailed to: + +Ann Marie C. Villafana ann.marie.c.villafana@usdoj.gov + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Jack Alan Goldberger jagesq@bellsouth.net, nalanis®agwpa.com + +Michael James Pike MPike@bciclaw.com, bobbie@bciclaw.com, jcadwell@bciclaw.com + +Paul G. Cassell cassellp@law.utah.edu + +Robert Deweese Critton , Jr rcrit@bciclaw.com, bobbie@bciclaw.com + +9:08-cv-80893-ICAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +#### Original filename:n/a + +#### Electronic document Stamp: + +[STAMP dceciStamp\_11: 1105629215 [Date=4/1/2010] [FileNumber=7426983-0] [9866belc49d2fdf45046c7ca57d1138270a53364d65ac30e05876adaa4286abf7b52 8c 1 cbc3234103cdf5382378ebaec8cfc42d50619b2198cbca05b3d168efa]] + +### Document description:Exhibit A + +## Original filename:n/a + +### Electronic document Stamp: + +[STAMP dcecfStamp\_11: 1105629215 [Date=4/1/2010] [FileNumber=7426983-1] [39959523bdcfe6cd49261323806679cdbb26662effife7061b131252b187a9e0af5603 bc9alcaa9ebc265bd44c225a69ec2182851c2051ea43a5ab888a5c7c0686]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00207201/EFTA00207201.metadata.json b/marker2/ds9/EFTA00207201/EFTA00207201.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1f4e93a9ebb203b6bbc5c97b9742c5a4ad045a66 --- /dev/null +++ b/marker2/ds9/EFTA00207201/EFTA00207201.metadata.json @@ -0,0 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find our response to your letter of March 29, 2010. Thank you. + +«20100402 Ltr to BIack.pdt» + +![](_page_0_Picture_9.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00207203/EFTA00207203.metadata.json b/marker2/ds9/EFTA00207203/EFTA00207203.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..9a164e34dcdc546f95f509ea3af6f810fe6b01dd --- /dev/null +++ b/marker2/ds9/EFTA00207203/EFTA00207203.metadata.json @@ -0,0 +1,60 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207203.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 294, + "elapsed_seconds": 0.55, + "image_assets": [ + "_page_0_Picture_9.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 19 + ], + [ + "Line", + 10 + ], + [ + "Text", + 9 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207203" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207203/_page_0_Picture_9.jpeg b/marker2/ds9/EFTA00207203/_page_0_Picture_9.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..f566d20f0672d56bfac64530bfea4b2d57f00874 --- /dev/null +++ b/marker2/ds9/EFTA00207203/_page_0_Picture_9.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:07cdb2fe6654f525984bc698faeb63f75c5c179eea7adb70fa526fbdc9a4e847 +size 8315 diff --git a/marker2/ds9/EFTA00207204/EFTA00207204.md b/marker2/ds9/EFTA00207204/EFTA00207204.md new file mode 100644 index 0000000000000000000000000000000000000000..2b1baccb27afb36f94d776022bb5fca2340bf882 --- /dev/null +++ b/marker2/ds9/EFTA00207204/EFTA00207204.md @@ -0,0 +1,35 @@ +![](_page_0_Picture_0.jpeg) + +## U.S. Department of Justice + +United States Attorney Southern District of Florida + +500 S. Australian Ave, Ste 400 West Palm Beach FL 33401 (561)820-8711 Facsimile: (561) 820-8777 + +April 2, 2010 + +## DELIVERY BY ELECTRONIC MAIL + +Roy Black, Esq. Black Srebnick Komspan & Stumpf P.A. 201 S. Biscayne Blvd, Suite 1300 Miami, FL 33131 + +Re: Jeffrey Epstein + +Dear Mr. Black: + +The Office is in receipt of your letter of March 29, 2010. We have had a series of correspondence, telephone calls, and meetings regarding the issue of Mr. Epstein's obligation to his victims. We have repeatedly stated that Mr. Epstein is expected to abide by the letter and spirit of the Non-Prosecution Agreement. And we have repeatedly informed you that the U.S. Attorney's Office does not intend to provide advisory opinions to Mr. Epstein or his attorneys regarding the handling of the civil suits filed against him. Yet again, you have asked us to provide such an advisory opinion. The request relates to Mr. Epstein's Motion to Dismiss in toto the suit filed against him by Jane Doe 103, whom we understand is one of the victims identified through the 2006 through 2007 investigation that culminated in the signing of the Non-Prosecution Agreement. + +Jane Doe 103 is represented by Robert Josefsberg, the attorney-representative selected by the Special Master in accordance with the Non-Prosecution Agreement, and the Complaint raises claims exclusively under 18 U.S.C. § 2255. As such, Mr. Epstein has waived his right to contest liability. Despite this waiver, Mr. Epstein and his attorneys want the Court to dismiss the Complaint. In a word, yes, the Office believes that this is a breach of the Non-Prosecution Agreement. + +Sincerely, + +Jeffrey H. Sloman United States A m y + +• • + +By: + +ROY BLACK, ESQ. APRIL 2, 2010 PAGE 2 OF 2 + +cc: Jeffrey H. Sloman, U.S. Attorney + +a -' \ No newline at end of file diff --git a/marker2/ds9/EFTA00207204/EFTA00207204.metadata.json b/marker2/ds9/EFTA00207204/EFTA00207204.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..7f2b4ce5fd52f45abf5ee6a69a0004e466eb4fe3 --- /dev/null +++ b/marker2/ds9/EFTA00207204/EFTA00207204.metadata.json @@ -0,0 +1,141 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207204.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1877, + "elapsed_seconds": 0.88, + "image_assets": [ + "_page_0_Picture_0.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "U.S. Department of Justice", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 156.513, + 49.41 + ], + [ + 299.861572265625, + 49.41 + ], + [ + 299.861572265625, + 65.73748779296875 + ], + [ + 156.513, + 65.73748779296875 + ] + ] + }, + { + "title": "DELIVERY BY ELECTRONIC MAIL", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 62.727, + 231.66 + ], + [ + 258.6539306640625, + 231.66 + ], + [ + 258.6539306640625, + 249.85748291015625 + ], + [ + 62.727, + 249.85748291015625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 69 + ], + [ + "Line", + 35 + ], + [ + "Text", + 12 + ], + [ + "SectionHeader", + 2 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 13 + ], + [ + "Line", + 6 + ], + [ + "Text", + 3 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207204" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207204/_page_0_Picture_0.jpeg b/marker2/ds9/EFTA00207204/_page_0_Picture_0.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..b1d429cf01ce39370cdade47da654ee7ecb2d5c6 --- /dev/null +++ b/marker2/ds9/EFTA00207204/_page_0_Picture_0.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:18a92fa3657ddb725d2ab12a59d56e3837bd2c135c5866816a104ad1be1b8ec3 +size 11749 diff --git a/marker2/ds9/EFTA00207206/EFTA00207206.md b/marker2/ds9/EFTA00207206/EFTA00207206.md new file mode 100644 index 0000000000000000000000000000000000000000..7e39235043617564a46595806df13afb73c13863 --- /dev/null +++ b/marker2/ds9/EFTA00207206/EFTA00207206.md @@ -0,0 +1,15 @@ +Subject: RE: Jeffrey Epstein + +Date: Fri, 02 Apr 2010 14:59:01 +0000 + +Importance: Normal + +GIRL POWER + +Subject: Jeffrey Epstein + +Attached please find our response to your letter of March 29, 2010. Thank you. + +« File: 20100402 Villafana Ltr to Black.pdf » + +I \ No newline at end of file diff --git a/marker2/ds9/EFTA00207206/EFTA00207206.metadata.json b/marker2/ds9/EFTA00207206/EFTA00207206.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..780abcf6cfa926edc605369d3763271b27c091d5 --- /dev/null +++ b/marker2/ds9/EFTA00207206/EFTA00207206.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207206.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 255, + "elapsed_seconds": 0.42, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 19 + ], + [ + "Line", + 9 + ], + [ + "Text", + 8 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207206" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207207/EFTA00207207.md b/marker2/ds9/EFTA00207207/EFTA00207207.md new file mode 100644 index 0000000000000000000000000000000000000000..130a70fc204bd88e4d44cafb1e9b217a2aed69e2 --- /dev/null +++ b/marker2/ds9/EFTA00207207/EFTA00207207.md @@ -0,0 +1,75 @@ +To: + +**Subject:** Activity in Case 9:08-cv-80119-KAM Doe █ Epstein Motion for Leave to File Excess Pages + +**Date:** Fri, 02 Apr 2010 19:29:06 +0000 + +**Importance:** Normal + +--- + +**This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended.** + +**\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\*** Judicial Conference of the United States policy permits attorneys of record and parties in a case (including prose litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +### Notice of Electronic Filing + +The following transaction was entered by Pike, Michael on 4/2/2010 at 3:29 PM EDT and filed on 4/2/2010 + +**Case Name:** Doe █ Epstein + +**Case Number:** [9:08-cv-80119-KAM](#) + +**Filer:** Jeffrey Epstein + +**Document Number:** [514](#) + +### Docket Text: + +**Defendant's MOTION for Leave to File Excess Pages in Rule 4 Appeal(s) Related to the Magistrate's Orders Entered at Docket Entries 462, 480, and 513 by Jeffrey Epstein. (Attachments: # (1) Text of Proposed Order Proposed Order)(Pike, Michael)** + +**9:08-cv-80119-KAM Notice has been electronically mailed to:** + +Adam D. Horowitz █ + +Bradley James Edwards █ + +Isidro Manuel Garcia █ + +Jack Alan Goldberger █ + +Jack Patrick Hill █ + +Paul G. Cassell + +Richard Horace Willits + +Robert C. Josefsberg + +Robert Deweese Critton , Jr + +Stuart S. Mermelstein + +9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +The following document(s) are associated with this transaction: + +Document description:Main Document + +Original filename:n/a + +Electronic document Stamp: + +[STAMP dcecfStamp\_11 1105629215 [Date=4/2/2010] [FileNumber=7431656-0] [52dcfca92aa524c843526553647e12611d165e2b418a2dd3de2ed6fc94abfbd77cea ae08822186d356aad3819a425a7fdb5b3b51226fbb9b6c453b3c07fbf34c]] + +Document description:Text of Proposed Order Proposed Order + +Original filename:lila + +Electronic document Stamp: + +[STAMP dcecfStamp\_1 1105629215 [Date=4/2/2010] [FileNumber=7431656-1] [7cObb72e650fb8a13b70b8bOae78d6c32elbald77faeeb58aa963912c7d7457221b9 975751ab28ed3946b67038b791183215c79elcd53e490ac9f6eld74a8fl c]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00207207/EFTA00207207.metadata.json b/marker2/ds9/EFTA00207207/EFTA00207207.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..0d311d12ceb83213627a6092426c7cf8f0bf78ac --- /dev/null +++ b/marker2/ds9/EFTA00207207/EFTA00207207.metadata.json @@ -0,0 +1,135 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207207.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2602, + "elapsed_seconds": 7.24, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 308.61 + ], + [ + 181.76399999999998, + 308.61 + ], + [ + 181.76399999999998, + 322.38 + ], + [ + 30.6, + 322.38 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 422.82 + ], + [ + 99.144, + 422.82 + ], + [ + 99.144, + 435.7800000000001 + ], + [ + 30.6, + 435.7800000000001 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 65 + ], + [ + "Text", + 47 + ], + [ + "Line", + 33 + ], + [ + "SectionHeader", + 3 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 47 + ], + [ + "Line", + 22 + ], + [ + "Text", + 16 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207207" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207209/EFTA00207209.md b/marker2/ds9/EFTA00207209/EFTA00207209.md new file mode 100644 index 0000000000000000000000000000000000000000..c5ffd40067606ce6ef9370d2020495007bc14769 --- /dev/null +++ b/marker2/ds9/EFTA00207209/EFTA00207209.md @@ -0,0 +1,67 @@ +To: "flsd\_cmecf notice@flsd.uscourts.gov" + +Subject: Activity in Case 9:08-cv-80119-ICAM Doe I. Epstein Order on Motion for Leave to File Excess Pages + +Date: Mon, 05 Apr 2010 18:16:09 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the C1VUECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered on 4/5/2010 at 2:16 PM EDT and filed on 4/5/2010 + +Case Name: Doe I Epstein + +Case Number: 9:08-cv-80119-KAM + +Filer: + +Document Number: 515 + +Docket Text: + +ORDER granting [514] Motion for Leave to File Excess Pages. Signed by Judge Kenneth A. Marra on 4/5/2010. (ir) + +9:08-cv-80119-KAM Notice has been electronically mailed to: + +Adam D. Horowitz ahorowitz@sexabuseattomey.com + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Isidro Manuel Garcia isidrogarcia®bellsouth.net + +Jack Alan Goldberger jagesq®bellsouth.net, nalanis®agwpa.com + +Jack Patrick Hill jph@searcylaw.com, clw@searcylaw.com, lcmc@searcylaw.com, s.slaterOtsearcylaw.com, sas@searcylaw.com, vat@searcylaw.com + +Paul G. Cassell cassellp@law.utah.edu + +Richard Horace Willits lawyenvillits@aol.com, reelrhw@hotmail.com + +Robert C. Josefsberg rjosefsberg@podhurst.com, amann@podhurst.com, bertpatton®podhurst.com, mestrada@podhurst.com + +Robert Deweese Critton , Jr rcrit@bciclaw.com, bobbie@bciclaw.com + +Stuart S. Mermelstein ssm@sexabuseattomey.com, jarbout®sexabuseattomey.com, Irivera@sexabuseattomey.com + +9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +Martin G. Weinberg 20 Park Plaza Boston, MA 02116 + +The following document(s) are associated with this transaction: + +Document description:Main Document + +Original filename:n/a + +Electronic document Stamp: + +[STAMP dcecfStamp\_11 1105629215 [Date=4/5/2010] [FileNumber=7434643-0] [94bad243ff59e38b2a3294e30274128e602cadea516d6f3d72102afc716a5c200b6c 341075e730ddcabddd5dae6815005b428eaa9686c9c049baa40c630792a2]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00207209/EFTA00207209.metadata.json b/marker2/ds9/EFTA00207209/EFTA00207209.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..0df3ccdfab7b4a5a6e97dac1a25530bad46c0746 --- /dev/null +++ b/marker2/ds9/EFTA00207209/EFTA00207209.metadata.json @@ -0,0 +1,112 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207209.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2729, + "elapsed_seconds": 1.16, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 321.57000000000005 + ], + [ + 184.79776000976562, + 321.57000000000005 + ], + [ + 184.79776000976562, + 338.10357666015625 + ], + [ + 30.6, + 338.10357666015625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 69 + ], + [ + "Line", + 34 + ], + [ + "Text", + 24 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 43 + ], + [ + "Line", + 21 + ], + [ + "Text", + 13 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207209" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207211/EFTA00207211.md b/marker2/ds9/EFTA00207211/EFTA00207211.md new file mode 100644 index 0000000000000000000000000000000000000000..aeb2e0fc35ea599a834027edeb4e97c1c1ee5940 --- /dev/null +++ b/marker2/ds9/EFTA00207211/EFTA00207211.md @@ -0,0 +1,69 @@ +From: ' II < > To:' , + +Subject: Activity in Case 9:08-cv-80119-ICAM Doe I Epstein Motion for Leave to File + +Date: Tue, 06 Apr 2010 13:49:57 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +## U.S. District Court + +#### Southern District of Florida + +### Notice of Electronic Filing + +The following transaction was entered by Pike, Michael on 4/6/2010 at 9:49 AM EDT and filed on 4/6/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80119-KAM + +Filer: Jeffrey Epstein + +Document Number: 518 + +### Docket Text: + +Defendant's MOTION for Leave to File to File Redacted Versions of Sensitive Fifth Amendment Arguments and Submit Un-Redacted Arguments to the Court by Jeffrey Epstein. (Pike, Michael) + +9:08-ev-80119-ICAM Notice has been electronically mailed to: + +Adam D. Horowitz + +M I. + +Bradley James Edwards + +Isidro Manuel Garcia + +Jack Alan Goldberger f + +Jack Patrick Hill + +Jeffrey Marc Herman + +Richard Horace Willits + +Robert . Josefsbe + +Robert Deweese Critton , ir + +Stuart S. Mermelstein + +9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1 + +Martin G. Weinberg 20 Park Plaza Boston, MA 02116 + +The following document(s) are associated with this transaction: + +## Document description:Main Document + +Original filenamem/a + +# Electronic document Stamp: + +[STAMP dcecfStamp\_11 1105629215 [Date=4/6/2010] [FileNumber=7437385-0] [70a1844e44b4071f5a737ad2c52998facd47dc1172d69d912f191fc55802dc9da94f b405c7a3d4cfbae5ebd48e8e16129cd7375e372ed59e5fd323a81daca2a4]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00207211/EFTA00207211.metadata.json b/marker2/ds9/EFTA00207211/EFTA00207211.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..ccb76408ffbccb9e53d4b42476833f27a18e5906 --- /dev/null +++ b/marker2/ds9/EFTA00207211/EFTA00207211.metadata.json @@ -0,0 +1,231 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207211.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2222, + "elapsed_seconds": 1.24, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "U.S. District Court", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 254.59199999999998, + 258.39 + ], + [ + 356.95135498046875, + 258.39 + ], + [ + 356.95135498046875, + 273.603515625 + ], + [ + 254.59199999999998, + 273.603515625 + ] + ] + }, + { + "title": "Southern District of Florida", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 231.948, + 284.31 + ], + [ + 380.1379089355469, + 284.31 + ], + [ + 380.1379089355469, + 299.1035461425781 + ], + [ + 231.948, + 299.1035461425781 + ] + ] + }, + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 31.212, + 309.42 + ], + [ + 185.88690185546875, + 309.42 + ], + [ + 185.88690185546875, + 324.3170471191406 + ], + [ + 31.212, + 324.3170471191406 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 31.212, + 423.63 + ], + [ + 101.65031433105469, + 423.63 + ], + [ + 101.65031433105469, + 438.6035461425781 + ], + [ + 31.212, + 438.6035461425781 + ] + ] + }, + { + "title": "Document description:Main Document", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 30.6, + 319.95000000000005 + ], + [ + 232.56, + 319.95000000000005 + ], + [ + 232.56, + 335.2330322265625 + ], + [ + 30.6, + 335.2330322265625 + ] + ] + }, + { + "title": "Electronic document Stamp:", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 30.6, + 347.92889404296875 + ], + [ + 183.6, + 347.92889404296875 + ], + [ + 183.6, + 364.5 + ], + [ + 30.6, + 364.5 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 72 + ], + [ + "Line", + 35 + ], + [ + "Text", + 22 + ], + [ + "SectionHeader", + 4 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 38 + ], + [ + "Line", + 18 + ], + [ + "Text", + 10 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207211" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207213/EFTA00207213.md b/marker2/ds9/EFTA00207213/EFTA00207213.md new file mode 100644 index 0000000000000000000000000000000000000000..009eba55ffe14930a611829d1ab965ed9c8baf27 --- /dev/null +++ b/marker2/ds9/EFTA00207213/EFTA00207213.md @@ -0,0 +1,81 @@ +From: + +[REDACTED] + +To: + +[REDACTED] + +**Subject:** Activity in Case 9:08-cv-80119-KAM Doe [REDACTED] Epstein Order on Motion for Leave to File Excess Pages + +**Date:** Tue, 06 Apr 2010 13:56:04 +0000 + +**Importance:** Normal + +--- + +**This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended.** + +**\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\*** Judicial Conference of the United States policy permits attorneys of record and parties in a case (including prose litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +**Notice of Electronic Filing** + +The following transaction was entered on 4/6/2010 at 9:56 AM EDT and filed on 4/6/2010 + +**Case Name:** Doe [REDACTED] Epstein + +**Case Number:** [9:08-cv-80119-KAM](#) + +**Filer:** + +**Document Number:** [519](#) + +**Docket Text:** + +**ORDER Granting [501] Unopposed Motion for Leave to File Excess Pages. Signed by Magistrate Judge Linnea R. Johnson on 4/6/2010. (sa)** + +**9:08-cv-80119-KAM Notice has been electronically mailed to:** + +Adam D. Horowitz [REDACTED] + +[REDACTED] + +Bradley James Edwards [REDACTED] + +Isidro Manuel Garcia [REDACTED] + +Jack Alan Goldberger [REDACTED] + +Jack Patrick Hill [REDACTED] + +[REDACTED] + +Paul G. Cassell ■ + +Richard Horace Willits + +Robert C. Josefsberg + +Robert Deweese Critton , Jr + +Stuart S. Mermelstein + +9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. 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Epstein Order + +Date: Wed, 07 Apr 2010 19:41:38 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered on 4/7/2010 at 3:41 PM EDT and filed on 4/7/2010 + +Case Name: Doe I. Epstein + +Case Number: 9:08-cv-80119-KAM + +Filer: + +Document Number: 520 + +## Docket Text: + +ORDER Resetting Deadlines as to [518] Defendant's MOTION for Leave to File Redacted Versions of Sensitive Fifth Amendment Arguments and Submit Un-Redacted Arguments to the Court. Responses due by 4/12/2010. Signed by Judge Kenneth A. Marra on 4/7/2010. (ir) + +9:08-cv-80119-KAM Notice has been electronically mailed to: + +Adam D. Horowitz ahorowitz@sexabuseattomey.com + +Bradley James Edwards brad@pathtojustice.com, beth@pathtojustice.com + +Isidro Manuel Garcia isidrogarcia®bellsouth.net + +Jack Alan Goldberger jagesq®bellsouth.net, nalanis®agwpa.com + +Jack Patrick Hill jph@searcylaw.com, clw@searcylaw.com, lcmc@searcylaw.com, s.slater@searcylaw.com, sas@searcylaw.com, vat@searcylaw.com + +Paul G. Cassell cassellp@law.utah.edu + +Richard Horace Willits lawyenvillits@aol.com, reelrhw@hotmail.com + +Robert C. Josefsberg rjosefsberg@podhurst.com, mestrada@podhurst.com, mvalledor@podhurst.com + +Robert Deweese Critton , Jr rcrit@bciclaw.com, bobbie@bciclaw.com + +Stuart S. Mermelstein ssm@sexabuseattorney.com, jarbour@sexabuseattomey.com, Irivera®sexabuseattomey.com + +9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at 1-888-318-2260.: + +Martin G. Weinberg 20 Park Plaza Boston, MA 02116 + +The following document(s) are associated with this transaction: + +Document description:Main Document + +Original filenamem/a + +Electronic document Stamp: + +[STAMP dcecfStamp\_1 1105629215 [Date=4/7/2010] [FileNumber=7444266-0) [4ac73c12399a835ca7999e5d0c83d4249dcb9a540b08e1a5c3e71c89ftbcff22ff24 d72a5aa8bc8ad0d8dde7ade07509bafa42401231af80b47a4e3e I 0859e5a]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00207215/EFTA00207215.metadata.json b/marker2/ds9/EFTA00207215/EFTA00207215.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..144172d40d24e86bad56ab6069f02f0a564f4c66 --- /dev/null +++ b/marker2/ds9/EFTA00207215/EFTA00207215.metadata.json @@ -0,0 +1,135 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00207215.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2817, + "elapsed_seconds": 1.19, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 308.61 + ], + [ + 184.3336639404297, + 308.61 + ], + [ + 184.3336639404297, + 324.23358154296875 + ], + [ + 30.6, + 324.23358154296875 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 422.82 + ], + [ + 101.52233123779297, + 422.82 + ], + [ + 101.52233123779297, + 438.3170471191406 + ], + [ + 30.6, + 438.3170471191406 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 68 + ], + [ + "Line", + 34 + ], + [ + "Text", + 23 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 41 + ], + [ + "Line", + 20 + ], + [ + "Text", + 13 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00207215" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00207217/EFTA00207217.md b/marker2/ds9/EFTA00207217/EFTA00207217.md new file mode 100644 index 0000000000000000000000000000000000000000..eb25e1b658401eedc55cef7dbd216e51820d9a6d --- /dev/null +++ b/marker2/ds9/EFTA00207217/EFTA00207217.md @@ -0,0 +1,83 @@ +From: ' < To: ' + +Subject: Activity in Case 9:08-cv-80119-ICAM Doe v. Epstein Notice of Supplemental Authority + +Date: Fri, 09 Apr 2010 15:47:45 +0000 + +Importance: Normal + +This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +U.S. District Court + +Southern District of Florida + +## Notice of Electronic Filing + +The following transaction was entered by Pike, Michael on 4/9/2010 at 11:47 AM EDT and filed on 4/9/2010 + +Case Name: Doe v. Epstein + +Case Number: 9:08-cv-80119-KAM + +Filer: Jeffrey Epstein + +Document Number: 521 + +# Docket Text: + +Notice of Supplemental Authority re [518] Defendant's MOTION for Leave to File to File Redacted Versions of Sensitive Fifth Amendment Arguments and Submit Un-Redacted Arguments to the Court by Jeffrey Epstein (Attachments: # (1) Exhibit A, # (2) Exhibit B)(Pike, Michael) + +9:08-cv-80119-KAM Notice has been electronically mailed to: + +Adam D. Horowitz + +Bradley James Edwards + +Isidro Manuel Garcia + +Jack Alan Goldberger + +Jack Patrick Hill + +Paul G. Cassell + +Richard Horace Willits + +Robert C. Josefsberg + +Robert Deweese Critton , Jr + +Stuart S. Merrnelstein + +9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at I + +Martin G. 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Epstein Response/Reply (Other) +**Date:** Fri, 09 Apr 2010 18:26:47 +0000 +**Importance:** Normal + +--- + +**This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended.** + +**\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\*** Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. + +**U.S. District Court** +**Southern District of Florida** + +**Notice of Electronic Filing** + +The following transaction was entered by Pike, Michael on 4/9/2010 at 2:26 PM EDT and filed on 4/9/2010 +**Case Name:** Doe v. Epstein +**Case Number:** [9:08-cv-80119-KAM](#) +**Filer:** Jeffrey Epstein +**Document Number:** [522](#) + +**Docket Text:** +**RESPONSE/REPLY to [493] Appeal of Magistrate Judge Decision to District Court *Defendant's Response in Opposition to Jane Does 2-8' Rule 4 Appeal with Incorporated Memorandum of Law by Jeffrey Epstein.* (Attachments: # (1) Exhibit A)(Pike, Michael)** + +**9:08-cv-80119-KAM Notice has been electronically mailed to:** + +Adam D. Horowitz [REDACTED] +[REDACTED] [REDACTED], [REDACTED] +Bradley James Edwards [REDACTED], [REDACTED] +Isidro Manuel Garcia [REDACTED] +Jack Alan Goldberger [REDACTED], [REDACTED] +Jack Patrick Hill [REDACTED], [REDACTED], [REDACTED], [REDACTED], [REDACTED], [REDACTED], [REDACTED], [REDACTED], [REDACTED], [REDACTED], [REDACTED], [REDACTED] +Jeffrey Marc Herman [REDACTED] +Katherine Warthen Ezell [REDACTED], [REDACTED], [REDACTED] + +Paul G. Cassell + +Richard Horace Willits + +Robert C. Josefsberg + +Robert Deweese Critton , Jr + +Stuart S. Mermelstein + +9:08-cv-80119-KAM Notice has not been delivered electronically to those listed below and will be provided by other means. For further assistance, please contact our Help Desk at + +Martin G. 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