Subject: Revised Notification to Victims regarding right to see Epstein agreement.
From: To: Cc: Subject: Revised Notification to Victims regarding right to see Epstein agreement. Date: Tue, 02 Sep 2008 16:18:36 +0000 Importance: Normal HAM- In light of the complaint of Mr. Epstein's counsel regarding my earlier notification language, I have revised it as follows: "In addition, there has been litigation between the United States and two other victims regarding the disclosure of the entire agreement between the United States and Mr. Epstein. Mr. Josefsberg can provide further guidance on this issue or, if Ms. has selected another attorney to represent her in the context of civil litigation, that attorney can review the Court's order in the matter of In re Jane Does 1 and 2, S.D. Fl. Court File No. 08-80736- CIV-MARRA, and advise her accordingly." What do you think? This was my original language: "In addition, a judge has ordered that the United States make available to any designated victim (and/or her attorney) a copy of the actual agreement between M
Summary
From: To: Cc: Subject: Revised Notification to Victims regarding right to see Epstein agreement. Date: Tue, 02 Sep 2008 16:18:36 +0000 Importance: Normal HAM- In light of the complaint of Mr. Epstein's counsel regarding my earlier notification language, I have revised it as follows: "In addition, there has been litigation between the United States and two other victims regarding the disclosure of the entire agreement between the United States and Mr. Epstein. Mr. Josefsberg can provide further guidance on this issue or, if Ms. has selected another attorney to represent her in the context of civil litigation, that attorney can review the Court's order in the matter of In re Jane Does 1 and 2, S.D. Fl. Court File No. 08-80736- CIV-MARRA, and advise her accordingly." What do you think? This was my original language: "In addition, a judge has ordered that the United States make available to any designated victim (and/or her attorney) a copy of the actual agreement between M
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Case 9:08-cv-80119-KAM
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 013-80736-Civ-Marra/Nlatthewman JANE DOE 1 AND JANE DOE 2, Petitioners, vs. UNITED STATES, Respondent. DECLARATION OF IN SUPPORT OF GOVERNMENT'S RESPONSE AND OPPOSITION TO PETITIONERS' MOTION FOR PARTIAL SUMMARY JUDGMENT AND CROSS-MOTION FOR SUMMARY JUDGMENT do hereby declare that I am a member in good standing of the Bar of the State of Florida. I also am admitted to practice in all courts of the states of Minnesota and Florida, the Eighth, Eleventh, and Federal Circuit Courts of Appeals, and the U.S. District Courts for the Southern District of Florida, the District of Minnesota, and the Northern District of California. My bar admission status in California and Minnesota is currently inactive. I am currently employed as an Assistant United States Attorney in the Southern District of Florida and was so employed during all of the events described herein. 2. I am the Assistant United States Attorne
Case 9:08-cv-80119-KAM
Case 9:08-cv-80736-KAM Document 50
Case 9:08-cv-80736-KAM Document 50 Entered on FLSD Docket 0372172011 Page 1 of 15 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 1. UNITED STATES JANE DOE #1 AND JANE DOE #2'S MOTION FOR ORDER DIRECTING THE U.S. ATTORNEY'S OFFICE NOT TO WITHHOLD RELEVANT EVIDENCE COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to move for an order from this Court directing the U.S. Attorney's Office not to suppress material evidence relevant to this case. The Court should enter an order, as it would in other criminal or civil cases, requiring the Government to make appropriate production of such evidence to the victims. BACKGROUND In discussions with the U.S. Attorney's Office about this case, counsel for Jane Doe #1 and Jane Doe #2 inquired about whether the Office would voluntarily provide to the victims information in its possession that was mater
Case 9:08-cv-80736-KAM Document 50
Case 9:08-cv-80736-KAM Document 50 Entered on FLSD Docket 0372112011 Page 1 of 15 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 MOTION FOR ORDER DIRECTING THE U.S. ATTORNEY'S OFFICE NOT TO WITHHOLD RELEVANT EVIDENCE COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to move for an order from this Court directing the U.S. Attorney's Office not to suppress material evidence relevant to this case. The Court should enter an order, as it would in other criminal or civil cases, requiring the Government to make appropriate production of such evidence to the victims. BACKGROUND In discussions with the U.S. Attorney's Office about this case, counsel for Jane Doe #1 and Jane Doe #2 inquired about whether the Office would voluntarily provide to the victims information in its possession that was mater
Case 9:08-cv-80119-KAM Du..ument 511 Entered on FLSD Docku, J3/29/2010 Page 1 of 11
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