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efta-efta00235314DOJ Data Set 9Other

UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOES #1 and #2, Petitioners, v. UNITED STATES, Respondent. STATUS REPORT Respondent, United States of America, by and through its undersigned counsel, files this Status Report, with concurrence of counsel for Petitioners, to inform the Court of the status of this matter. I. On October 28, 2010, the Court filed its Order reopening the matter and stated that it would "allow the parties to continue their attempt to resolve this matter. In the event that the parties cannot reach a resolution, the Court will schedule a status conference to determine how this case will proceed." (DE 44 at 1-2.) 2. The parties have continued to meet telephonically and in person in an attempt to resolve this matter but have not yet reached a resolution. 3. Based upon recent communications received from Petitioners' counsel, the U.S. Attorney's Office has determined that it must seek an opinion fr

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DOJ Data Set 9
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EFTA 00235314
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2
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2
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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOES #1 and #2, Petitioners, v. UNITED STATES, Respondent. STATUS REPORT Respondent, United States of America, by and through its undersigned counsel, files this Status Report, with concurrence of counsel for Petitioners, to inform the Court of the status of this matter. I. On October 28, 2010, the Court filed its Order reopening the matter and stated that it would "allow the parties to continue their attempt to resolve this matter. In the event that the parties cannot reach a resolution, the Court will schedule a status conference to determine how this case will proceed." (DE 44 at 1-2.) 2. The parties have continued to meet telephonically and in person in an attempt to resolve this matter but have not yet reached a resolution. 3. Based upon recent communications received from Petitioners' counsel, the U.S. Attorney's Office has determined that it must seek an opinion fr

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOES #1 and #2, Petitioners, v. UNITED STATES, Respondent. STATUS REPORT Respondent, United States of America, by and through its undersigned counsel, files this Status Report, with concurrence of counsel for Petitioners, to inform the Court of the status of this matter. I. On October 28, 2010, the Court filed its Order reopening the matter and stated that it would "allow the parties to continue their attempt to resolve this matter. In the event that the parties cannot reach a resolution, the Court will schedule a status conference to determine how this case will proceed." (DE 44 at 1-2.) 2. The parties have continued to meet telephonically and in person in an attempt to resolve this matter but have not yet reached a resolution. 3. Based upon recent communications received from Petitioners' counsel, the U.S. Attorney's Office has determined that it must seek an opinion from the Justice Department regarding whether it can continue to represent the United States in this matter, or whether outside counsel from another part of the Justice Department is required. 4. The undersigned and AUSA have communicated this decision to counsel for Petitioners, and have explained that this will necessarily suspend activity on the case until an opinion is obtained and, if necessary, new counsel is in place. 5. Petitioners have agreed with the filing of this Status Report to inform the Court of this development and to ask the Court to allow the parties additional time to determine whether resolution of the matter is possible. 6. Consistent with the Court's Order, (DE44,) once this interim question of representation is decided, the parties will continue their attempts to resolve this case. If the parties determine that resolution without court intervention is impossible, one or both parties will ask the Court to set the matter for a Status Conference. Respectfully submitted, WIFREDO A. FERRER UNITED STATES ATTORNEY By: s/ Assistant U.S. Attome West Palm Beach, FL 33401 EFTA00235314 E-mail: Attorney for Respondent CERTIFICATE OF SERVICE I HEREBY CERTIFY that on December 16, 2010, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. 51 Assistant U.S. Attorney SERVICE LIST Jane Does 1 and 2 v. United States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Brad Edwards, Esq., Farmer Jaffe Weissing Edwards Fistos Lehrman 425 N Andrews Ave Ste 2 Fort Lauderdale, FL 33301-3268 Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law S.J. uinne Colle e of Law at the University of Utah Salt Lake City, UT 84112-0730 Attorneys for Petitioners EFTA00235315

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From: (USAFLS)" </DI To: "Brad Edwards Subject: Confidential Settlement Negotiations Date: Sat, 25 Jun 2016 20:17:08 +0000 Importance: High Attachments: Proposed_Order_Approving_Stip_for_Dismissal.pdf; Proposed_Stipulation_for_Dismissal.pdf; USAO_Letter_to Jane_Doe_l_-_06-22- 2016_with_watermark.pdf; 20160625_Jane_Doe_Settlement_Agreement.pdf Ili Brad —I am sending you our complete packet, that is: (1) Proposed Settlement Agreement, including title of DOJ official for meeting (2) Proposed Stipulation of Dismissal and Order accepting it (this would be Appendix "B") (3) Proposed letter (this would be Appendix "C") Sealed Appendix A is the victim list from you with my one addition. I need from you: Appendix D (proposed amendments to the "Attorney General Guidelines for Victim and Witness Assistance" and to the procedures for filing complaints with the Justice Department's Crime Victims' Rights Ombudsman) Appendix E (proposed amendments to the U.S. Attorney's Manual) I am

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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

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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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From: Brad Edwards

From: Brad Edwards To: Cc: Paul Cassell Subject: Re: Rescheduling Settlement Conference - bad date Date: Sat, 25 Jun 2016 20:39:34 +0000 Importance: Normal Inline-Images: image001.png; image002.png I will forward everything to Paul. is calling me Tuesday. I will use that time to relay everything to her and see where we are then. Sent from my iPhone On Jun 25, 2016, at 4:23 PM, wrote: Hi Paul — Thank you for your email. July 5th is bad for us, too, but I saw Judge Brannon to sign some search warrants yesterday and, although we didn't talk about this case, he mentioned how full his schedule was. I don't know that he is going to be inclined to move it, especially in light of Jane Doe #1's status. I am wondering if you think it is possible for us to finalize things without going back to court? Brad now has our complete packet and I think if we can get things resolved over the next week, then we can take the settlement conference off the calendar and move on to asking Judg

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