From: Iris Zambrano
From: Iris Zambrano To:" Cc: , Maria Kelljchian Subject: SERVICE OF COURT DOCUMENT - 9:08-cv-80736-KAM - Doe v. United States of America Date: Fri, 16 May 2014 20:35:38 +0000 Importance: Normal Attachments: Victim-Response-Mtn-Protective-Order_FILED_UNDER_SEAL_5.16.14.pdf; M_Seal_- Victim-Response-Mtn-Protective-Order_5.16.14_-_Stamped.PDF Inline-Images: image001.png; image002.png Good afternoon Counsel: Pursuant to Federal Rules of Civil Procedure and Local Rules of the District Court Southern District of Florida, attached please find Petitioners' Motion for Seal and Proposed Order, in the subject matter. Additonally, please find attached Jane Doe 1 and lane Doe 2's Response in Opposition to Epstein's Motion for a Protective Confidentiality Order that was filed Under Seal today. Please contact us should you have any questions. Thank you. Iris Zambrano Farmer, Jaffe, Weissing, Edwards, Fistos Et Lehrman, P.L. Iris Zambrano Paralegal 443 North Andrews Avenue. Suite
Summary
From: Iris Zambrano To:" Cc: , Maria Kelljchian Subject: SERVICE OF COURT DOCUMENT - 9:08-cv-80736-KAM - Doe v. United States of America Date: Fri, 16 May 2014 20:35:38 +0000 Importance: Normal Attachments: Victim-Response-Mtn-Protective-Order_FILED_UNDER_SEAL_5.16.14.pdf; M_Seal_- Victim-Response-Mtn-Protective-Order_5.16.14_-_Stamped.PDF Inline-Images: image001.png; image002.png Good afternoon Counsel: Pursuant to Federal Rules of Civil Procedure and Local Rules of the District Court Southern District of Florida, attached please find Petitioners' Motion for Seal and Proposed Order, in the subject matter. Additonally, please find attached Jane Doe 1 and lane Doe 2's Response in Opposition to Epstein's Motion for a Protective Confidentiality Order that was filed Under Seal today. Please contact us should you have any questions. Thank you. Iris Zambrano Farmer, Jaffe, Weissing, Edwards, Fistos Et Lehrman, P.L. Iris Zambrano Paralegal 443 North Andrews Avenue. Suite
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9:08-CV-80736-KAMFacsimile: 954-524-2822800.400.1098954-524-2822Related Documents (6)
Case 9:08-cv-80893-KAM Document 217 Entered on FLSD Docket 09/13/2010 Page 1 of 7
Subjec
Fr • < > Subjec :Deliberative t Process ec aratton rom am Justice - equest or wo ee xtension Date: Fri, 20 Sep 2013 17:59:47 +0000 Importance: Normal We have no objection, provided we get the following accommodation, which you already anticipated. We would request that your motion for extension of time give us an extension on our reply document, such that our reply would be due 10 days after the main Justice Department declaration that will be coming in two weeks. If you would include such language as well in any proposed order, saving us (and the court) drafting time, that would be very much appreciated. Paul Cassell and Brad Edwards for Jane Doe #1 and Jane Doe #2 Paul G Cassell 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, you may not use, disseminate, distribute or copy this communication. If you have received this message
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
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
STATEMENT BY ALAN DERSHOWITZ
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