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EXHIBIT 1
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 08-80736-CIV-MARRA
JANE DOE # I and JANE DOE #2,
Petitioners,
vs.
UNITED STATES OF AMERICA,
Respondent.
DECLARATION OF JANE DOE 3
1. The Court is familiar with me from my previous declaration in this case. I am currently
31 years old and want to become a part of the case to enforce my rights and possibly allow
criminal prosecution ofJeffrey Epstein and others who abused underage girls.
2. I have seen a Government fi ling saying that I waited too long before trying to become a
part of this case. I don't think that the Government's position tells the full story about me. In
fact, I believe the Government is hiding some of the things that it knows about me and about
other powerful people involved in this case. I am fi ling this declaration so that the Court will
have more facts to make the decision about whether to let me come into the case.
3. In its latest filing, the Government seems to be questioning why I was afraid and did not
come forward to speak more quickly. To understand my reasons, it is important that I share at
least some additional information about why I was so fearful after my abuse by Epstein and
others.
4. The Court can best understand my situation by looking at my previous declaration and
then understanding why I was afraid of Epstein, how I eventually escaped from him, and how I
was forced to hide from him and others.
5. I first net Epstein when I was 15 years old. I have told the Court about some of my
sexual and physical abuse in my earlier declaration.
6. As a result of that abuse and my considerable interactions with Epstein and his fiends, I
knew that Epstein was connected to some of the most powerful people in the world, including a
member of the British Royal family, a former President of the United States, and other very
powerful lawyers, politicians and businessmen. I was afraid of what would happen if I tried to
escape from Epstein or report him to law enforcement.
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13. Part of my fear comes from physical abuse that I suffered when Epstein forced me to
have sex with other people. Without going into the details of the sexual activities I was forced to
endure, there were times when I was physically abused to the point that I remember fearfully
thinking that I didn't know whether I was going to survive.
14. Jeffrey Epstein knew about this physical and sexual abuse because I would detail it for
him as part of my debriefing. Epstein didn't care. Epstein said things like, "You get that
sometimes." I told him how much I hated having to be with some people, but Epstein still sent
me back. I had no choice.
15. 1 give the Court this information so that it can better understand why I was so afraid of
Epstein and what he could do to me. I could provide more details to the Court, if the Court needs
more details on this issue. I also wanted to provide this information to the Court because I have
been accused of being a "serial prostitute." I don't think that is a fair way to describe my
situation, given that I was so young and so many powerful people were forcibly abusing me.
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17. After years of abuse and being lent out, I began to look for a way to escape. I had been
first forced into all this because I wanted to be a massage therapist. Epstein had taken me into
his clutches through promises and talk. But once he had me under his control, I felt trapped.
18. I kept asking Epstein for my promised training and education. Epstein finally got me a
plane ticket to Thailand to go to Chaing Mai to learn Thai massage. This sounded like my
chance to escape. In September 2002, I packed my bags for good. I knew this would be my only
opportunity to break away from Epstein.
19. On September 27, 2002, I flew from JFK in New York to Chaing Mai, Thailand. I
arrived around September 29 for my training. But Epstein was going to get something out of this
as well. I was supposed to interview a girl to bring back to the United States for Epstein.
20. Exhibit I is a list of room charges in Thailand, with the charges going to Epstein's
account. This exhibit shows Epstein's telephone numbers and is evidence that he paid for my
hotel in Thailand.
21. Exhibit 2 is a set of documents showing my itinerary and flight plans for me going to
Thailand, paid for by Epstein.
22. I did the massage training in Chiang Mai. I met a truly great and special guy and told him
honestly what I was being forced to do. He told at I should get out of it. I told him that the
people I was working for were very powerful and that I could not disobey them without risking
my life. He told me he would protect me, and I had confidence in him. I saw my opportunity to
escape and to be with someone who truly loved me and would protect me. To make a long story
short, I married him and flew to Australia.
23. I called Epstein and told him I was not coming back. Ile asked why? I said "I've fallen
in love." And Epstein basically just said "good luck and have a good life." I could tell he was
not happy. I was very afraid of what he was going to do to me. I thought Epstein or one of his
powerful friends might send someone to have me killed.
24. I stayed in Australia from that point on, with my husband and away from the life I had
been forced to live as Epstein's sex slave. I was in Australia from late 2002 to October 2013. To
be clear, I was never in the United States during these years, not even for a short trip to visit my
mother. And my absence from the United States was not voluntary — I was hiding from Epstein
out of fear of what he would do to me if I returned to the United States.
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25. In around 2007, after not hearing from anyone for years, out of the blue I was contacted
by someone who identified himself with a plain sounding name and claimed lie was with the
FBI. It seemed very odd for someone doing an official criminal investigation to just call up on
the phone like that. I hadn't heard Epstein's name for years. I didn't know who this person was
and what it was really about. I wasn't sure what was going on.
26. This man said he was looking into Jeffrey Epstein. The man asked if I had been involved
with Epstein. My first instinct was to say nothing; because I wasn't sure he was really with the
FBI or any authorities. I did answer a few basic questions, telling him that I knew Jeffrey
Epstein and met him at a young age. The whole conversation didn't feel like it was right. This
rum never offered to come and meet with me in person. He instead asked me right off the bat
about Epstein's sexual practices. I thought it would be strange for a real law enforcement officer
to behave that way. 1became increasingly uncomfortable and suspicious about who was actually
calling me.
27. The way the conversation was going made me doubt whether I was really talking to an
FBI agent. It did not seem very official. I became very uncomfortable, so I told him nothing
more about Epstein. The conversation probably didn't even last three minutes. The conversation
immediately triggered all of the fears of Epstein and his powerful friends that had caused me to
escape the first time. If the call accomplished anything, it only put me back in fear and told me
that I could be found quite easily and had nobody official protecting me.
28. I suspected that the man who called me was working for Epstein or one of Epstein's
powerful friends. If the man who called me was really an FBI agent and was interested in what I
knew about Epstein, I thought he would have made some effort to see me personally. I believed
that if this was really an agent who was investigating Epstein, then he knew who 1 was and how I
fit into Epstein's sexual crimes in many different places. Such an agent would send someone to
meet me in person (who could provide potential protection from Epstein). He never did.
29. Getting a call from this supposed FBI Agent made me very scared. I had left that old life
behind at and started a new life in a new country in hopes that the powerful people whose
illegal activities I knew all about would never find me. And now 1 had been tracked down by
someone and was frightened.
30. Shortly after this purported FBI call, I was contacted by someone who was clearly
working for Epstein. This person discussed an investigation into Epstein, and said that some of
the girls were saying Epstein had sexual contact with them. After they made those allegations,
they were being discredited as drug addicts and prostitutes. But, on the other hand, if I were to
keep quiet, I would "be looked after." The fact that this call came in right after the FBI call
reinforced my concern that the man I had talked to earlier was not really working for the FBI, but
was really working for Epstein. I didn't think that the FBI and Epstein would both be working
together and would both get my phone number at almost exactly the same time. I played along
and told this person that I had gotten a call from the "FBI" but that I didn't tell them anything.
The person was pleased with that.
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31. A short time later, one of Epstein lawyers (not Alan Dershowitz) called me, and then got
Epstein on the line at the same time. Epstein and his lawyer basically asked again if I was going
to say anything. The clear implication was that I should not say anything. The way they were
approaching me, I was afraid of what would happen if I didn't keep quiet My thought was that if
I didn't say the right things, I might get hurt.
32. I promised Epstein and his lawyer that 1 would keep quiet. They seemed happy with that
and that seemed to me the way to most likely keep me and my family safe. And I did what
Epstein and his lawyer told me — I kept quiet.
33. I now understand that Epstein reached a non-prosecution agreement with the federal
government in 2007 and pled guilty to two state crimes in June 2008. No one told me anything
about those events until much later. In fact, nobody called or came to see me to explain what a
non-prosecution agreement was, what crimes Epstein could have been charged with, why he was
not being charged with the crimes he committed, or anything whatsoever about the case. I was
never offered a chance to meaningfully confer with the prosecutor for the Government, and I was
never notified of any hearing that could affect me or my rights as a crime victim to ever bring
charges.
34. On September 3, 2008, the FBI sent a victim notification letter to me. This was the first
written communication I had received from the FBL The letter was attached as Exhibit 1 to my
earlier statement This kind of written communication, on official FBI stationary, is the way that
I thought the FBI really communicated with people that they wanted to talk to. The fact that I got
this official letter from them made me wonder even more whether that the call I had received
earlier was really from the FBI. The letter that I got did not mention that anyone from the FBI
had ever called me before.
35. The letter started off with the sentence: "By virtue of this letter, the United States
Attorney's Office for the Southern District of Florida provides you with the following notice
because you are an identified victim of a federal offense." That sentence (among others) made it
seem like this was the first time the FBI was officially contacting me. That was the first time I
was told about my rights as a crime victim.
36. I did not know what was happening about any criminal prosecution of Epstein at this
time. I wanted him prosecuted. And given his constant illegal sexual behavior, I thought it was
obvious that he should be prosecuted. But after reading the letter, I was confused. The letter did
not explain what was actually happening or what role, if any, that I could play. In fact, the letter
thanked me for my assistance during the investigations, yet it wasn't clear what that was
referring to.
37. Also, the letter did not directly say that Epstein's crimes against me were not going to be
prosecuted. It just said that "the United States has agreed to defer federal prosecution in favor of
this state plea and sentence . . . ." I did not know what that meant. The letter did not inform me
how it applied to me. The letter also said that there was "litigation between the United States
and two other victims regarding the disclosure of the entire agreement between the United States
and Mr. Epstein." Understanding more about that case now, I realize that the letter did not
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explain that the real purpose of that litigation was not to get "disclosure of the entire agreement"
but instead to get criminal charges filed against Epstein and to uphold the rights of Epstein's
victims. I wish that the Government had told me that was what was really going on.
38. I saw on the letter that I could call a lawyer. The letter also mentioned Jack Goldberger,
who 1 knew to be Epstein's attorney, which scared me. I first got in touch with the attorneys at
the Podhurst Orseck firm. My lawyers filed a lawsuit against Epstein for me, which mentioned
that I was abused by Epstein and other powerful people. I was hoping that the information I
gave as part of my lawsuit might help to put Epstein away in prison -- where he belongs. But the
lawsuit ended up just being about money, which Epstein paid to settle.
40. At this point, since nothing else seemed to be working to get Epstein and his associates
held accountable, I wanted to try by myself to get a message out to the public about what terrible
things Epstein and his friends had done to me and other girls. I was very disturbed about how no
one was prosecuting Epstein for these crimes. I was also very scared. It seemed that law
enforcement was not doing anything with the information they knew about me, which left me
and my family more vulnerable and scared.
41. The journalist printed an article using some of the information I told her. Shortly after
the article was published, I talked on the phone to Marie Villafafta, a federal prosecutor from
Florida. 1 had seen her name on the official letter from the FBI, so she seemed legitimate.
Villafafta seemed very interested in my case and seemed like she really wanted to do something.
42. Within a few weeks of the newspaper article being published, two FBI agents also called
me in Australia and then came to meet me. In around March 2011, they met me at the U.S.
Consulate in Sidney. They seemed to be very professional and hard working. I thought to myself
that I had finally gotten the attention of the people that I wanted to and that these people would
do the right things against Epstein and the other criminals. I also thought that they could protect
me.
43. When I met with the agents, they mainly focused on Epstein. But while there, I provided
them some information about some of the others who were involved in illegal acts as well. I was
aware that a false statement to these law enforcement officers was a crime and I told the truth —
giving them the information that I could recall at the time about the individuals they inquired
about.
44. The agents were clearly prepared to meet me and already knew a lot about Epstein's
crimes. The agents appeared to be very good at investigating and seemed like they really knew
how to piece together the whole story. But at the same time, they seemed like they were being
blocked from doing what they wanted to do — which I thought was to arrest Epstein and his
powerful friends for all of their illegal sexual crimes.
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45. During my interview with the real FBI agents, I told them about my contact from the
purported FBI agent. They did not tell me that it had been a legitimate call from the FBI.
46. The interview I did with these FBI agents was very stressful for me. My meeting lasted
for several hours. It was not easy to talk about all these difficult things, but 1 went through it. I
was crying at points in the interview. The interview also placed stress on my marriage, because
my husband had to listen to all the terrible things that happened to me. It was difficult for me to
have to discuss being passed around as a sex object among powerful people. It was very hard for
both of us.
47. The agents had come from Florida to meet with me in Australia and took my information
which gave me reason to believe that Epstein could still be prosecuted for the crimes he
committed against me. I was not told even at that point that he could not be prosecuted for the
crimes he committed in Florida. I was not told about the CVRA case or that there was any other
option for me to enforce my rights. In fact, by the agents meeting with me I believed I was doing
exactly what I needed to do to enforce my rights and assist in the prosecution.
48. I have seen the Government's recent brief trying to keep rre from joining this case. In
that brief, the Government says about me "the Government is aware that petitioners' counsel
have been representing her [that is, me] since at least as early as March 2011." This is
completely untrue, and I think the Government knows it is untrue. I was not represented by legal
counsel in March 2011. The Government has to know that I didn't have an attorney then,
because I didn't have an attorney when I met the agents in Sydney. I don't understand why the
Government is giving false facts to the court.
50. In around April 2011, as a follow-up to my earlier call with Brad Edwards, I got a
telephone call from him and another attorney, Jack Scarola. They just wanted general
information about whether various people had information relevant to the lawsuit. They told at
that they were taping the conversation, and I had no problem with that. I cooperated with them
and gave them information about which people had information relevant about Epstein's crimes.
Because it was over the phone and we did not know each other very well, they were very polite
and did not ask me a lot of details about specifically who I had sex with and what sexual
activities I was forced to participate in. It was a general, background interview.
51. As the months following the FBI meeting in Sydney passed, I was trying to be patient but
I began wondering what was going on about prosecuting Epstein. I continued to be very
confused about what was happening. I was hoping that some kind of prosecution would come
out of it. But when nothing came of it, I got very upset. I wanted to do something to stop
Epstein and the other people he associates with from sexually abusing girls. Law enforcement
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had taken my detailed statements, but nothing seemed to be happening. I wasn't sure what to do.
While I wanted to do all that I could to get justice for what had happened to me, it was very hard
for me to figure out how to get something done in the Unitcd States while I was living in a
foreign country; especially after I had already gave information to the FBI that I believed they
were using to investigate and eventually arrest Epstein.
52. In October 2013, I returned to the United States for the first time since I had left for
Thailand.
53. In April 2014, I decided to get back in touch with the FBI. In Sydney, the FBI had
seemed like they wanted to be helpful to me, and I have great respect for the FBI agents who met
me. It appeared to me they wanted to do the right thing in this case. But my feeling was once
the agents collected information about crimes committed against me, someone else stepped in
and blocked them from getting charges filed. I also thought that Marie Villafafta really wanted
to do the right thing and hold Epstein accountable for the horrible crimes he committed. But, it
seemed like the hands of Villafafia and the FBI were always tied by someone else with more
authority.
54. I have never been able to figure out who was (and still is) stopping a prosecution. I also
haven't been able to figure out who is trying to stop me from being able to participate in a court
case to a have a judge determine whether my rights have been violated. It doesn't seem fair to
me that the Government can argue that 1 don't even get the opportunity for a judge review the
issue. To the, this is fiuther verification of Epstein's power, which continues to make me very
scared.
55. I have asked the FBI to show me the video surveillance and other pictures of me that I
believe they have in their possession. They said that I would have to go to the pmsecutors to get
them. But the prosecutors will not share anything with me. I believe that the prosecutors have
lots of information that will support what I have been saying about Epstein and his associates.
56. Based on my knowledge of Epstein and his organisation, as well as discussions with the
FBI, it is my belief that federal prosecutors likely possess videotapes and photographic images of
me as an underage girl having sex with Epstein and some of his powerful friends. I don't
understand why they aren't moving forward with what the FBI has given to them. I also don't
understand why these pictures haven't been given to me nor why law enforcement officers from
any other jurisdictions have never contacted me.
57. It was not until 2014 that I first understood about the way in which Jane Doe No. I and
Jane Doe No. 2 were trying to invalidate the non-prosecution agreement to allow prosecution of
Epstein for crimes he committed against them, and me. I had never really heard anything
significant about this case while I was in Australia, and it was hard to get information about what
was happening in Florida while I was overseas. Once I heard about the case, I quickly wanted to
become a part of it.
58. In light of the way everything has played out, I believe that my rights as a crime victim
have been violated. It was never my choice to become the victim of crimes by Epstein and the
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people he forced me to have sex with. Epstein dragged me into his web when I was very young
and, after that, it was hard for me to escape. After I ran away to Australia, it appears that Epstein
reached an agreement in 2007 with the federal prosecutors in Florida blocking him from being
prosecuted for the crimes he committed against me.
59. When Epstein pled guilty to two low level crimes in 2008 as part of his agreement, no
one told me what was happening or that this plea had anything to do with preventing prosecution
of crimes against me or the hundreds of other girls he abused. Nobody told me that I could speak
to the Judge or that a hearing was even taking place.
60. Based on all the facts I have described here, I believe some kind of major cover-up is
going on to protect Epstein. As I look back on what Epstein and his friends have done, I see a lot
of powerful people who knew what they were doing to me and other girls was wrong. But they
also seemed to think that they were above the law and they had nothing to worry about From
what I can see, that turned out to be true. There are less powerful people -- like the FBI agents
and Marie Villafafta — that seem like they are trying to get the right thing done. But nothing
happens.
61. Because nothing is being done, it makes me think that Epstein was right when he told me
he had so many people in his pocket. Maybe those people are still helping him escape being
prosecuted for what he did against me. The justice system doesn't seem to respond to the
victims in this case. It seems to favor those who have the most money and power and influence.
62. I am also worried that this is a very dangerous circuit. By standing up for what is right,
I'm worried that Epstein, or others named here, will come after me. I wonder where this is going
to go if the United States government is not on my side. I am intent on seeing this through so
that Epstein isn't allowed to hurt other young girls. I can't stop abuse everywhere in the world.
But if I help one victim then I have made a positive difference.
63. In April 2014, I asked two good attorneys — Brad Edwards and Paul Cassell — to see if
they could help me bring Epstein and his friends to justice. They agreed to add me to the
existing case. They explained to me that the lawsuit was not asking to get money from Epstein
or others. I understand and have always understood that the goal of the case is to simply enforce
my rights as a crime victim— rights that were wrongly taken from me.
64. I want Epstein and the others who committed crimes against me to be punished fairly —
the way other less powerful would be. I also want to be added to the suit filed by the two girls,
Jane Doe Number I and Jane Doe Number 2, and I want to have rights the way a victim of a less
wealthy and powerful criminal would have.
65. Epstein and his friends sexually and physically abused many other girls. They did this in
many places around the world. I personally observed this. There are also many people who
could confirm what I am saying. I hope that these people will coat forward and tell the truth. I
hope that they will call my attorney in Fort Lauderdale, Florida — Brad Edwards — so that all
ofthe information can be presented to the court about what has happened to me and others.
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66. Because of how often Epstein and others were having sex with young girls, and how
much it was a centerpiece of their lives, I doubt they have just stopped. It also seems to me that,
when I knew them, they believed that they were above the law — too powerful to be prosecuted.
That feeling has no doubt been reinforced by the fact Epstein has escaped real punishment with
his plea bargain, and the others with whom he traveled have completely escaped. I hope that 1
can join this case and try to bring them to justice.
67. I declare under penalty of perjury that the foregoing is true and correct.
Executed this S"day of February, 2015. (Location of signature left undisclosed for
security reasons)
JANE DOE 3
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(033) la I -013 :no (053) 2:i-oo
ultra la Jadfutin sere (memo)
3.EPSTEIN euraiurnnaingluitur tflailma
Royal Princess, Chiang Mai, 18/10/02 12:51 III athitiam P.i1/00111 oleo satoo
188785 ' lm: (om) t$1-033 61011: (003) 211-0(4
11101Walltill014 00 33 0627
Room No. : 923 Page No. : 2 1001hiilikia01171701M 3 10 1 01110
Arr. Date : 29/09/02 Oept Oate 19/10/02
Guest : 1 Cashier i 11 CHFGAON103
Guest Name : DOE 3
USA
USA
DATE DESCRIPTION CHARGE CREDIT
12/10 Provincial Tax (Rm)
21.60
12/10 Long Distance #923 1 019980563 30.00
12/10 Overseas 0923 : 001171983648 913.00
12/10 Overseas 0923 : 001121276098
30.00
12/10 Overseas #923 : 001121276098
89.00
• 13/10
13/10
Room Charges
Service charge 10%
2700.00
270.00
13/10 Government Tax 207.90
• 13/10
13/10
Provincial Tax (Rm)
Room Service 8/F 11923 CHECL # 117
21.60
153.01
13/10 Long Distance 0923 : 069166556 45.00
13/10 Long Distance #923 : 069156556
30.00
13/10 Long Distance #923 :069166556 15.00
13/10 Overseas 1923 t 001156179290 30.00
13/10 Overseas #923 001156124844 30.00
13/10 Overseas #923 : 001156)79045 660.00
13/10 Overseas 8923 : 001156179835 30.00
• 13/10
13/10
Overseas 19.13 : 001121275098
Overseas #923 : 001166179290
30.00
59.00
13/10 Overseas #923 : 001156179855 384.00
13/10 Overseas 1923 : 001156179046 89.00
14/10 Room Charges 2700.00
14/10 Service charge 10%
270.00
14/10 Government Tax
a 207.90
14/10 Provincial Tax (Am) 21.60
14/10 Room Service B/F #923 : CHECK V 129
294.26
14/10 Ninibar #923 :
290.00
14/10 Overseas 11923 : 001121275098 59.00
14/10 Overseas 0923 : 001156130964 69.00
14/10 Overseas 0923 t 001121275098
59.00
14/10 Overseas #923 : 001166179290
30.00
S 15/10 Room Charges
2700.00
a 15/10
15/10
Service charge 10%
Government Tax
270.00
207.90
15/10 Provincial Tax (Rm)
21.60
• 15/10 Minibar 1923 :
120.00
Guest's signature
Dale
EFTA01081589
Case 9:08-cv-80736-KAM Document 341-3 Entered on FLSD Docket 11/23/2015 Page 15 of
28
Case 9:08-cv-80736-KAM Document 310.1 Entered on FLSD Docket 02/06/2015 Page 15 of
28
rd I
ROYAL PRINCESS
OVOAC MAI
0 III Clan Ma 1466 Laving lam AUm... laci ,61 50103. RAU
rel. (0531 .0p Fa. 013)) 211-044
1.111;11 glIsin (anoint)
J.EPSTEIN worAiiulusetiediutvo t00,4021
112 04610611/ 031,27x03 i.olon • ticilnd sown
Royal Princess, Chiang Mai, 18/10/02 12:51 lin: (023) 201.033 1014111 (0.13) 221-044
188785 nnatimaning 60 14 02627
umIssnifulihnniom 3 10 111110
Room No. : 923 Page No. : 3
O
Arr. Oats : 29/09/02 Dept Date : 19/10/02
Guest : 1 Cashier : 11 CHFGAGNTO3
0 Guest Name DOE 3
USA
USA
DATE DESCRIPTION CHARGE CREDIT
0 15/10 Overseas 8923 : 001156179290 796.00
15/10 Overseas 11923 : 001156165548 118.00
15/10 Overseas 8923 : 001121275098 354.00
0 16/10 Room Charges 2700.00
16/10 Service charge 101 270.00
16/10
• 16/10
Government Tax
Provincial Tax (Rm)
207.90
21.60
16/10 Poolside p.m. 8923 : CHECK 11 621 29.43
16/10 Room Service B/
ℹ️ Document Details
SHA-256
4f52c1398a5280b24a64e7fcf59dd21c13282ecd8c53a7738acbf6559ca4fa4d
Bates Number
EFTA01081576
Dataset
DataSet-9
Document Type
document
Pages
28
Comments 0