EFTA00799781Set 9
2007-08-0722p5,853w
interviewed by the FBI unless she was granted use immunity. See
6/2/2017 Villafafia Decl. at 1II 6-12. The second sentence in paragraph 6 also is admitted in part.
During ... federal offense or came under the protection of the CVRA, 6/2/2017
Villafafia Decl. at 1 5, and because that fourth sentence presents an opinion and conclusion, not
an assertion ... plea discussions" because Epstein was never
charged with a federal offense. See 6/2/2017 Villafafia Decl. atilt 4, 17-18, 23, 29.
10. The Government admits the first sentence of paragraph
https://www.justice.gov/epstein/files/DataSet%209/EFTA00799781.pdf
EFTA00799803Set 9
2007-08-0722p5,839w
interviewed by the FBI unless she was granted use immunity. See
6/2/2017 Villafafia Decl. at 1II 6-12. The second sentence in paragraph 6 also is admitted in part.
During ... federal offense or came under the protection of the CVRA, 6/2/2017
Villafafia Decl. at 1 5, and because that fourth sentence presents an opinion and conclusion, not
an assertion ... plea discussions" because Epstein was never
charged with a federal offense. See 6/2/2017 Villafafia Decl. atilt 4, 17-18, 23, 29.
10. The Government admits the first sentence of paragraph
https://www.justice.gov/epstein/files/DataSet%209/EFTA00799803.pdf
EFTA00069312Set 9
2019-07-0227p8,046w
Declaration of Michael G. Seidel, dated June 2021 ("Seidel
Decl.") 1 6, Ex. A. By letter dated April 28, 2017, the FBI acknowledged receipt of Plaintiff's
FOIA request ... that could constitute an
invasion of personal privacy. Seidel Decl. 1 7, Ex. B. The FBI also informed Plaintiff's
counsel that it was closing Plaintiffs' request. Id.
3
EFTA00069314 ... June 2019, the FBI
made regular production of responsive records with appropriate redactions. Seidel Decl. ¶¶ 9-
29. During this time period, the FBI processed 11,525 pages. It produced
https://www.justice.gov/epstein/files/DataSet%209/EFTA00069312.pdf
EFTA00071554Set 9
2020-08-0530p8,407w
July 23, 2019, Epstein apparently attempted suicide in his
cell at the MCC. Capone DecL ¶ 6. On August 10, 2019, Epstein committed suicide in his cell ... duty at the MCC's Special Housing Unit, where Epstein was then
housed. Capone DecL ¶ 9. As alleged in the November 19, 2019, indictment against Noel and
Thomas, they repeatedly ... five counts of making or using a false
writing or document. See Capone DecL ¶ 9; Noel Indictment. The Noel prosecution is pending
before the Honorable Analisa Torres, U.S.D.J., with trial
https://www.justice.gov/epstein/files/DataSet%209/EFTA00071554.pdf
EFTA00088671Set 9
2020-08-0530p8,403w
July 23, 2019, Epstein apparently attempted suicide in his
cell at the MCC. Capone DecL ¶ 6. On August 10, 2019, Epstein committed suicide in his cell ... duty at the MCC's Special Housing Unit, where Epstein was then
housed. Capone DecL ¶ 9. As alleged in the November 19, 2019, indictment against Noel and
Thomas, they repeatedly ... five counts of making or using a false
writing or document. See Capone DecL ¶ 9; Noel Indictment. The Noel prosecution is pending
before the Honorable Analisa Torres, U.S.D.J., with trial
https://www.justice.gov/epstein/files/DataSet%209/EFTA00088671.pdf
EFTA00075437Set 9
2020-08-0530p8,449w
July 23, 2019, Epstein apparently attempted suicide in his
cell at the MCC. Capone DecL ¶ 6. On August 10, 2019, Epstein committed suicide in his cell ... duty at the MCC's Special Housing Unit, where Epstein was then
housed. Capone DecL ¶ 9. As alleged in the November 19, 2019, indictment against Noel and
Thomas, they repeatedly ... five counts of making or using a false
writing or document. See Capone DecL ¶ 9; Noel Indictment. The Noel prosecution is pending
before the Honorable Analisa Torres, U.S.D.J., with trial
https://www.justice.gov/epstein/files/DataSet%209/EFTA00075437.pdf
EFTA00799874Set 9
2017-08-1114p4,113w
example, Bradley J. Edwards represented Jane Doe 2 in July 2008. See Edwards Decl., DE
225-1 at 17; Edwards Affidavit ... Jane Doe 2 Decl., 361-27 at 1-2.
14. Admitted to the extent that the events described occurred on specific dates, and
otherwise denied. For example, Jane ... through counsel, provided information supporting
Epstein's prosecution in July 2008. See Edwards Decl., DE 225-1 at 17; Edwards Affidavit
https://www.justice.gov/epstein/files/DataSet%209/EFTA00799874.pdf
EFTA00038652Set 8
2017-04-2020p6,039w
withheld in full
based on certain exemptions to disclosure under FOIA. (Second Seidel Decl. (Dkt. No. 58)1 3)
In July 2019, Jeffrey Epstein was arrested and charged with ... United
States Attorney's Office for the Southern District of New York. (Third Comey Decl. (Dkt. No.
59)1 1), and a revised declaration from Michael G. Seidel, the Section ... Record/Information Dissemination Section ("RIDS") of the FBI's Information Management
Division ("IMD"). (Second Seidel Decl. (Dkt. No. 58) 1 1)
The page numbers referenced in this opinion correspond
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EFTA00100685Set 9
2019-10-1616p10,633w
Dismiss
claimed that she conspired with her lawyers at the law Complaint ("Proctus Decl."), dated June 25, 2019 [dkt.
firm of Boies Schiller Flexner LLP "the Firm ... Proctus Decl. Ex. F; Proctus Decl. Ex. H;
to extort Dershowitz and others redicates this Proctus Decl. -2, 8.9, 53-55, 61.63). These
action on the grounds a Dershowitz ... Dershowitz's motions to dismiss the "serial liar," and a "seria prostitute." (Proctus Decl. Ex.
action for failure to state a claim and to disqualify BSF as E; Proctus Decl
https://www.justice.gov/epstein/files/DataSet%209/EFTA00100685.pdf
EFTA00078646Set 9
2021-11-1916p4,502w
effective dispute resolution alternatives, and, with Ms. Biros, they have designed and
' Ex. A (Decl. of in Supp. of Mot. to Quash Rule 17(c) Subpoena a
Decl ... Victims' Compensation Program," dated June 25, 2020 ("6/25/20 Press
Release")); see Ex. A ¶ 3 Decl.).
EFTA00078647
November 19, 2021
Page Three
administered other large-scale, complex compensation programs, including ... Press Release); Ex. C at 1 (6/25/20 Press Release).
'Ex.AI3 Decl.).
6
Ex. B at 1 (11/14/19 Press Release).
7 Ex. C at 1 (6/25/20 Press Release
https://www.justice.gov/epstein/files/DataSet%209/EFTA00078646.pdf
EFTA00088605Set 9
2020-08-0525p7,830w
full and 339 pages released in part. Supplemental
Declaration of Kara Christenson ("Supp. Christenson Decl.") 9¶ 5, 7. The bases for withholdings
Unless otherwise noted, the abbreviations used in this ... review emails in its final round of review and
production. See Supp. Christenson Decl. 1 8.
3
EFTA00088611
Case 1:20-cv-00833-PAE Document 41 Filed 01/15/21 Page ... documents prepared by potential trial witnesses. See Supplemental Declaration
of Russell Capone ("Supp. Capone Decl.") ¶¶ 6-14. In addition, information contained in two of
the withheld Returned Records relates
https://www.justice.gov/epstein/files/DataSet%209/EFTA00088605.pdf
EFTA00099598Set 9
2020-08-0525p7,788w
pages released in full and 339 pages released in part. Supplemental
Declaration o ("Supp. Decl.") q¶ 5, 7. The bases for withholdings
' Unless otherwise noted, the abbreviations used in this ... review emails in its final round of review and
production. See Supp. Decl. 1 8.
3
EFTA00099604
Case 1:20-cv-00833-PAE Document 41 Filed 01/15/21 Page ... information and documents prepared by potential trial witnesses. See Supplemental Declaration
of ("Supp. Decl.") ¶¶ 6-14. In addition, information contained in two of
the withheld Returned Records relates
https://www.justice.gov/epstein/files/DataSet%209/EFTA00099598.pdf
EFTA00071584Set 9
2020-08-0525p7,810w
full and 339 pages released in part. Supplemental
Declaration of Kara Christenson ("Supp. Christenson Decl.") 9¶ 5, 7. The bases for withholdings
Unless otherwise noted, the abbreviations used in this ... review emails in its final round of review and
production. See Supp. Christenson Decl. 1 8.
3
EFTA00071590
Case 1:20-cv-00833-PAE Document 41 Filed 01/15/21 Page ... documents prepared by potential trial witnesses. See Supplemental Declaration
of Russell Capone ("Supp. Capone Decl.") ¶¶ 6-14. In addition, information contained in two of
the withheld Returned Records relates
https://www.justice.gov/epstein/files/DataSet%209/EFTA00071584.pdf
EFTA00623075Set 9
2016-06-0140p11,688w
victims of sex offenses committed by
Jeffrey Epstein. See Declaration of Sigrid McCawley ("McCawley Decl.") at Exhibit 1,
Complaint filed in 1 v. United States ... because they had
suffered the same violations of their rights under the CVRA. McCawley Decl., Exhibit 2, Jane
Does' 3 and 4 Joinder Motion.2 To establish that they were "victims ... Court (Marra, J.) denied 3 and
.4's motion for joinder. McCawley Decl., Exhibit. 4, Order denying 3's motion to
join. With regard to the eight separate issues
https://www.justice.gov/epstein/files/DataSet%209/EFTA00623075.pdf
EFTA00617951Set 9
2016-05-2512p2,865w
assure
actual notice is provided to these persons. See Declaration of Sigrid McCawley ("McCawley
Decl.") at Composite Exhibit 1, Subpoenas for Jeffrey Epstein,
) and . This Court has repeatedly held that ... agreement that he would accept service
of the subpoena in this matter. See McCawley Decl. at Composite Exhibit 3, Electronic
Correspondence to Attorney Marty Weinberg. Ms. was unable to obtain ... Group Investigators commenced
efforts to personally serve Epstein on April 26, 2016. See McCawley Decl. at Exhibit 4
Affidavit of Douglas G. Mercer, Chief Investigator Alpha Group. Those efforts have
https://www.justice.gov/epstein/files/DataSet%209/EFTA00617951.pdf
EFTA00027666Set 8
2019-02-2133p11,282w
where Jane Doe 2 had obtained counsel paid for by Epstein.
(Jane Doe 2 Decl. ¶¶ 5-7.)
Assistant United States Attorney ("AUSA") ("line prosecutor"
S") testified that both Jane ... agent's
name and phone number, neither contacted either of them. (1 Decl. ¶ 5, DE 403-19.)
3
EFTA00027668
Case 9:08-cv-80736-KAM Document 435 Entered on FLSD ... about a NPA or told the
victims that such an agreement was under consideration. ( Decl. ¶ 7, DE 361-64; DE
407 at ¶ 43.) Many, if not all, other similarly-situated
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EFTA00040739Set 9
2019-02-2133p11,275w
agent's
name and phone number, neither contacted either of them. (Decl. ¶ 5, DE 403-19.)
3
EFTA00040741
Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket ... about a NPA or told the
victims that such an agreement was under consideration. (= Decl. ¶ 7, DE 361-64; DE
407 at ¶ 43.) Many, if not all, other similarly-situated ... Agents did not explain
that the NPA had already been signed. (Jane Doe 1 Decl. ¶ 5, DE 361-26.) Jane Doe 1's
understanding was that the federal investigation would
https://www.justice.gov/epstein/files/DataSet%209/EFTA00040739.pdf
EFTA00081333Set 9
2019-02-2133p11,299w
where Jane Doe 2 had obtained counsel paid for by Epstein.
(Jane Doe 2 Decl. ¶¶ 5-7.)
Assistant United States Attorney ("AUSA") ("line prosecutor"
) testified that both Jane ... agent's
name and phone number, neither contacted either of them. S Decl. ¶ 5, DE 403-19.)
3
EFTA00081335
Case 9:08-cv-80736-KAM Document 435 Entered on FLSD ... Agents did not explain
that the NPA had already been signed. (Jane Doe 1 Decl. ¶ 5, DE 361-26.) Jane Doe 1's
understanding was that the federal investigation would
https://www.justice.gov/epstein/files/DataSet%209/EFTA00081333.pdf
EFTA00794122Set 9
2019-02-2133p11,320w
where Jane Doe 2 had obtained counsel paid for by Epstein.
(Jane Doe 2 Decl. ¶¶ 5-7.)
Assistant United States Attorney ("AUSA") A. Marie Villafafia ("line prosecutor"
"Villafaiia") testified that ... agent's
name and phone number, neither contacted either of them. (Villafaila Decl. ¶ 5, DE 403-19.)
3
EFTA00794124
Case 9:08-cv-80736-KAM Document 435 Entered on FLSD ... told the
victims that such an agreement was under consideration. (Marie Villafaila Decl. ¶ 7, DE 361-64; DE
407 at ¶ 43.) Many, if not all, other similarly-situated victims received
https://www.justice.gov/epstein/files/DataSet%209/EFTA00794122.pdf