Subject: RE: Jane Does 1 U.S. (re Jeffrey Epstein) - Litigation Hold - Additional

UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOES #1 and #2 I UNITED STATES JANE DOE #1 AND JANE DOE #2'S MOTION FOR FINDING OF VIOLATIONS OF THE CRIME VICTIMS' RIGHTS ACT, REQUEST FOR AN EVIDENTIARY HEARING IF FACTS ARE CONTESTED, AND REQUEST FOR HEARING ON APPROPRIATE REMEDIES COMES NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to move for a finding from this Court that their rights as crime victims under the Crime Victims Rights Act (CVRA) have been repeatedly violated by the U.S. Attorney's Office, to request an evidentiary hearing to establish those violations if the U.S. Attorney's Office contests the underlying facts, and to request a brief schedule and a hearing on the appropriate remedies for these violations. As recounted in more detail below, the victims have recently-obtained correspondence between the U.S. Attorney's Office and defendant Jeffrey

EFTA01689427

UNITED STATES DISTRICT COURT

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 MOTION FOR FINDING OF VIOLATIONS OF THE CRIME VICTIMS' RIGHTS ACT, REQUEST FOR AN EVIDENTIARY HEARING IF FACTS ARE CONTESTED, AND REQUEST FOR HEARING ON APPROPRIATE REMEDIES COMES NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to move for a finding from this Court that their rights as crime victims under the Crime Victims Rights Act (CVRA) have been repeatedly violated by the U.S. Attorney's Office, to request an evidentiary hearing to establish those violations if the U.S. Attorney's Office contests the underlying facts, and to request a brief schedule and a hearing on the appropriate remedies for these violations. As recounted in more detail below, the victims have recently-obtained correspondence between the U.S. Attorney's Office and defendant Jeffre

U.S. Department of Justice

U.S. Department of Justice United States Attorney Southern District of Florida 99 N.E. 4 Street Miami, FL 33132 305.961.9290 November 2, 2010 Via E-Mail Wifredo A. Ferrer, United States Attorney Office of the United States Attorney Southern District of Florida 99 NE slIt' Street Miami, Florida 33132 Privileged Commication Re: Litigation Hold re: Jane Does #1 and #21 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 t

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 EFTA01711760