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From: "Jay Lefkowitz"Subject: Conference Call with Roy Black
Case File
efta-efta00215840DOJ Data Set 9Other

LAW OFFICE

LAW OFFICE 1 ?II/ ( il l/Ye AND ASSOCIATES October 9, 2008 United States Attorney's Office 99 N.E. 4th Street Miami, Florida 33132 Re: Jane Doe # and Jane Doe #2 v. United States of America Case No.: 08-80736-CIV-MARRA/JOHNSON De I am writing to call to your attention two potentially false statements that the Government made, albeit inadvertently, in a sworn declaration submitted to the Court in connection with the above-captioned case. I request that your office file a corrected declaration and accompanying explanation. first statement is found at page 3 to 4 of the July 9th, 2008 declaration ofillEl There a provision in a plea agreement with Mr. Jeffrey Epstein is recounted. As we understand the Government's current position in this case, it is that this provision is not in fact part of the plea agreement in this case. If our understanding is correct, then Ms. has filed a false affidavit with the court, albeit inadvertently. We respectfully request that she file

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Unknown
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DOJ Data Set 9
Reference
EFTA 00215840
Pages
2
Persons
3
Integrity

Summary

LAW OFFICE 1 ?II/ ( il l/Ye AND ASSOCIATES October 9, 2008 United States Attorney's Office 99 N.E. 4th Street Miami, Florida 33132 Re: Jane Doe # and Jane Doe #2 v. United States of America Case No.: 08-80736-CIV-MARRA/JOHNSON De I am writing to call to your attention two potentially false statements that the Government made, albeit inadvertently, in a sworn declaration submitted to the Court in connection with the above-captioned case. I request that your office file a corrected declaration and accompanying explanation. first statement is found at page 3 to 4 of the July 9th, 2008 declaration ofillEl There a provision in a plea agreement with Mr. Jeffrey Epstein is recounted. As we understand the Government's current position in this case, it is that this provision is not in fact part of the plea agreement in this case. If our understanding is correct, then Ms. has filed a false affidavit with the court, albeit inadvertently. We respectfully request that she file

Persons Referenced (3)

Jane Doe #2

“...ttorney's Office 99 N.E. 4th Street Miami, Florida 33132 Re: Jane Doe # and Jane Doe #2 v. United States of America Case No.: 08-80736-CIV-MARRA/JOHNSON De I am writing to call to your attentio...”

Jeffrey Epstein

“...y 9th, 2008 declaration ofillEl There a provision in a plea agreement with Mr. Jeffrey Epstein is recounted. As we understand the Government's current position in this case, it is that this provisio...”

Bradley Edwards

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LAW OFFICE 1 ?II/ ( il l/Ye AND ASSOCIATES October 9, 2008 United States Attorney's Office 99 N.E. 4th Street Miami, Florida 33132 Re: Jane Doe # and Jane Doe #2 v. United States of America Case No.: 08-80736-CIV-MARRA/JOHNSON De I am writing to call to your attention two potentially false statements that the Government made, albeit inadvertently, in a sworn declaration submitted to the Court in connection with the above-captioned case. I request that your office file a corrected declaration and accompanying explanation. first statement is found at page 3 to 4 of the July 9th, 2008 declaration ofillEl There a provision in a plea agreement with Mr. Jeffrey Epstein is recounted. As we understand the Government's current position in this case, it is that this provision is not in fact part of the plea agreement in this case. If our understanding is correct, then Ms. has filed a false affidavit with the court, albeit inadvertently. We respectfully request that she file a new affidavit that corrects this false information, along with all other information relevant to understanding how the false information came to be provided to the court — and to the victims in this case. This correction should, in my view, include more details about how Epstein and his attorneys approved a submission of false information to the victims as you stated on Page 5, n.2 in your October 8, 2008 filing "Respondent's Opposition to Victims' Motion to Unseal Non- Prosecution Agreement" — presumably knowing that litigation surrounding the victims' rights issues was on-going and that such false information might be ultimately presented to the court. Such information is highly relevant to what remedy the victims might ultimately choose to seek for violations of their rights in this case. statement may or may not be false, but may need some clarification. At page 4 of M eclaration, she states that "[i]n October 2007. shortly after the agreement was signed, four victims [including C.W.] were contacted and these ns were discussed" (emphasis added). Similarly at page 5, the declaration states: "Ant lilt had been notified of the terms of the agreement ....." (emphasis added). I write to inquire whether, in view of the fact that the provision noted above is not in fact (according to the Government's current view) part of the plea agreement, whether this was the provision that the government (inaccurately) discussed with the victims. Put another way, I am wondering whether the Government will now stipulate that it, at most, discussed with the victims a provision in the plea agreement that never was actually part of the plea agreement 2028 HARRISON STRERT,SITITE 202, HOLLYWOOD, FLORIDA 33020 OFFICE: 954-414-8033/305-935-2011 FAX: 954-924-1530/305-935-4227 BEIFERADEDWARDSLAW.COM EFTA00215840 United States Attorney's Office October 9, 2008 Page Two I continue to be interested in working out a joint stipulation of proposed facts in this case with the Government. If you would like to proceed in that direction, please give me a call. If, however, the Government is not willing to work out a joint stipulation of facts, then I need to have the record be as clear as possible, and at a minimum would request that the Government correct the inaccurate information it has provided to the court and clarify precisely how such inaccurate information came to be made a part of the record and the extent to which Mr. Epstein, through his attorneys, was culpable. Sincerely, BE/sg Brad Edwards 2026 HARRISON STRILET.SUITE 202, HOLLYWOOD, FLORIDA 33020 OFFICE: 954 - 414 - 6033/305-935-2011 FAX: 954 - 926-1530/306-935-4227 BEOBRADEDWARDSLAW.COM EFTA00215841

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Domainbeiferadedwardslaw.com
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FaxFAX: 954-924-1530
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Phone306-935-4227
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Phone954-924-1530

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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

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EFTA02726140

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DOJ Data Set 9OtherUnknown

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 DECLARATION OF BRADLEY J. 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 pen

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DOJ Data Set 9OtherUnknown

UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-CI V-Marra/Matthewman JANE DOE # I and JANE DOE #2, Petitioners, I UNITED STATES OF AMERICA, Respondent. UNITED STATES' RESPONSE TO PETITIONERS' FIRST REOUEST FOR ADMISSIONS TO THE GOVERNMENT The United States (hereinafter the "government") hereby responds to Jane Doe #1 and Jane Doe #2's First Request for Admissions to the Government Regarding Questions Relevant to Their Pending Action Concerning the Crime Victims Rights Act (hereinafter the "Request for Admissions"), and states as follows:' I. The government admits that the FBI and the U.S. Attorney's Office for the Southern District of Florida ("USAO") conducted an investigation into Jeffrey Epstein ("Epstein") and developed evidence and information in contemplation of a potential federal prosecution against Epstein for many federal sex offenses. Except as otherwise admitted above, the government denies Request No. I. The government's res

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Court UnsealedJan 26, 2015

Dershowitz Supplement to Motion for Limited Intervention

Case 9:08-cv-80736-KAM Document 285 Entered on FLSD Docket 01/12/2015 Page 1 of 6 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 AND JANE DOES #2 Plaintiffs, vs. UNITED STATES OF AMERICA, Defendant. ________________________________/ ALAN DERSHOWITZ’S SUPPLEMENT TO HIS MOTION FOR LIMITED INTERVENTION (DE 282) Alan M. Dershowitz, a nonparty to this litigation, respectfully supplements his previously filed Motion for Limited Intervention (

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