EFTA00016012

UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE #1 and JANE DOE #2, Petitioners, vs. UNITED STATES OF AMERICA, Respondent. RESPONDENT'S INITIAL DISCLOSURES Respondent United States of America, by and through its undersigned counsel, makes its Initial Disclosures, pursuant to Fed.R.Civ.P. 26(a)(1)(A), and state: Fed.R.Civ.P. 26(a)(1)(A)fil: 1. R. Alexander Acosta Dean, School of Law Florida International University Rafael Diaz-Balart Hall 11200 S.W. 8'h Street Miami, Florida 33199 (305) 348-1118 Dean Acosta was the United States Attorney, Southern District of Florida, during the time when the criminal investigation of Jeffrey Epstein was opened in the U.S. Attorney's Office, and the non-prosecution agreement was negotiated. 2. was the First Assistant U.S. Attorney in the U.S. Attorney's Office, during the time when the criminal investigation of Jeffrey Epstein was opened, and the non-prosecution agreement was negot

EFTA Document EFTA01718407

UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-MarratIVIatthewman JANE DOE #1 AND JANE DOE #2, Petitioners, UNITED STATES OF AMERICA, Respondent. UNITED STATES' NOTICE OF FILING THIRD SUPPLEMENTAL PRIVILEGE LOG Pursuant to the Court's June 18, 2013 Omnibus Order (DE 190), the Respondent, United States of America, by and through the undersigned Assistant United States Attorney, hereby gives notice of its filing of its Third Supplemental Privilege Log. The index has been marked with Bates Numbers P-014924 thru P-015267. The documents referenced in the Third Supplemental Privilege Log will be delivered tomorrow to the Chambers of U.S. District Judge Kenneth A. Marra for ex parte in camera review, pursuant to the Court's Omnibus Order. Respectfully submitted, WIFREDO A. FERRER UNITED STATES ATTORNEY By: s/A. Marie Villafafia A. MARIE VILLAFAFIA Assistant United States Attorney Florida Bar No. 0018255 500 South Australian Ave, Suite 40

Case 9:08-cv-80736-KAM

Case 9:08-cv-80736-KAM Document 28 Entered on FLSD Docket 09/25/2008 Page 1 of 8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 AND JANE DOE #2, Petitioners, v. UNITED STATES OF AMERICA, Respondent. VICTIM'S MOTION TO UNSEAL NON-PROSECUTION AGREEMENT COMES NOW the Petitioners, Jane Doe #1 and Jane Doe #2, by and through their undersigned attorneys, pursuant to the Crime Victim's Rights Act, 18 U.S.C. Section 3771 ("CVRA"), and file this motion to unseal the non-prosecution agreement that has been provided to their attorneys under seal in this case. The agreement should be unsealed because no good cause exists for sealing it. Moreover, the Government has inaccurately described the agreement in its publicly-filed pleadings, creating a false impression that the agreement protects the victims. Finally, the agreement should be unsealed to facilitate consultation by victims' counsel with others involved who have

6/19122, 3:62 PM

6/19122, 3:62 PM teSTEIN4 M;i„ ei.A15,DNIER - C,CA,SZNi frietv7 AoS-‘ ,..ci 11,N CC)•:E4 rjetrIW - tELNEPS ‘ -NidPedia tMA\etraE Epstein a massage'. She claims she was taken to his mansion, • Perversion of Justice, Miami Herald, where he exposed himself and had sexual intercourse with November 30, 2018. her, and paid her Sao° immediately afterward.1120 A similar $50-million suit was filed in March 2008, by a different woman, who was represented by the same lawyer.11n1 These and several similar lawsuits were dismissed.r1391 All other lawsuits have been settled by Epstein out of court.D311 Epstein made many out-of-cogr settlements with alleged vigil-m[1301 Victims' rights: Jane Does v. United States (2014)*56C, ni3C6 E St P i‘JEt<ri PCS rrl • It-•S A December 3o, 2O14, federal civil suit was filed in Florida by Jane Doe 1. ([REDACTED - Survivor]) and Jane Doe 2 against the United States for violations of the Crime Victims' Rights Act by the U.S. Department of Justice's

Case 9:08-cv-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 1 of 57

Case 9:08-cv-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 1 of 57 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 9:08-ev-80736-ICAM JANE DOE 1 AND JANE DOE 2, Petitioners, UNITED STATES, Respondent. JANE DOE 1 AND JANE DOE 2'S CONSOLIDATED STATEMENT OF UNDISPUTED MATERIAL FACTS AND MOTION FOR PARTIAL SUMMARY JUDGMENT WITH INCORPORATED MEMORANDUM OF LAW Jane Doe 1 and Jane Doe 2 (also referred to as "the victims"), by and through undersigned counsel, pursuant to Fed. R. Civ. P. 56 and Local Rule 56.1, move for summary judgment on the issue of the United States Government's violation of their rights under the Crime Victims' Rights Act (CVRA), where no genuine issue of material fact exists.' In support, they state: INTRODUCTION In 2004, Congress enacted the CVRA because it found that in case after case "victims, and their families, were ignored, cast aside, and treated as non-participants in a critical event in their lives. They were