EFTA00210110.pdf

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE #1 and JANE DOE #2, Petitioners, vs. UNITED STATES OF AMERICA, Respondent. RESPONDENT'S INITIAL DISCLOSURES Respondent United States of America, by and through its undersigned counsel, makes its Initial Disclosures, pursuant to Fed.R.Civ.P. 26(a)(1)(A), and state: Fed.R.Civ.P. 26(a)(1)(A)fil: 1. R. Alexander Acosta Dean, School of Law Florida International University Rafael Diaz-Balart Hall 11200 S.W. 8'h Street Miami, Florida 33199 (305) 348-1118 Dean Acosta was the United States Attorney, Southern District of Florida, during the time when the criminal investigation of Jeffrey Epstein was opened in the U.S. Attorney's Office, and the non-prosecution agreement was negotiated. 2. was the First Assistant U.S. Attorney in the U.S. Attorney's Office, during the time when the criminal investigation of Jeffrey Epstein was opened, and the non-prosecution agreement was negotiated. EFTA00210110 3. .vas the Chief of the Criminal Division in 2006-2007, when the criminal investigation of Jeffrey Epstein was opened, 4. was a Supervisory Assistant U.S. Attorney in the West Palm Beach office of the U.S. Attorney's Office, during the time the criminal investigation of Jeffrey Epstein was opened, and the non-prosecution agreement was negotiated. 5. was the federal prosecutor in the Southern District of Florida assigned primary responsibility for the federal criminal investigation of Epstein during the time when that criminal investigation was open in the U.S. Attorney's Office and while the non-prosecution agreement was negotiated. 6. s a Supervisory Assistant U.S. Attorney in the West Palm Beach office of the U.S. Attorney's Office, and supervised portions of the criminal investigation of Jeffrey Epstein. 7. 2 EFTA00210111  was a Supervisory Assistant U.S. Attorney in the West Palm Beach office of the U.S. Attorney's Office, and supervised portions of the criminal investigation of Jeffrey Epstein. 8. assisted AUSA Villafana during the criminal investigation of.leffrey Epstein. 9. In his revious capacity as Deputy Chief of the Criminal Division, U.S. Attorney's Office, eviewed various portions of the criminal investigation of Jeffrey Epstein. 10. In 2008, was the Chief of the Child Exploitation & Obscenity Section at the DOJ. At the request of Mr. Epstein's attorneys, he conducted a review of the U.S. Attorney's handling of the Epstein matter. 11. participated in the review of the non-prosecution agreement, and other actions taken by the U.S. Attorney's Office, in her capacity as a deputy chief in the Child Exploitation & Obscenity Section, U.S. Department of Justice. 12. 3 EFTA00210112  in her previous capacity as a Trial Attorney in the Child Exploitation & Obscenity Section, participated in the criminal investigation of Jeffrey Epstein. 13. In her previalpacity as Assistant Attorney General, Criminal Division, Assistant Attorney General vas the recipient of correspondence from Kenneth Starr and Jay Lefkowitz, seeking review of the non-prosecution agreement. 14. was a Senior Associate Deputy Attorney General in the DOJ in 2008, and conducted a review of the U.S. Attorney's handling of the Epstein matter, at the request of Mr. Epstein's attorneys, Jay Lefkowitz and Kenneth Starr. 15. Special Agent I was the co-case agent in the criminal investigation of Jeffrey Epstein. 16. Special Agenl was the co-case agent in the criminal investigation of Jeffrey Epstein. 17. 4 EFTA00210113  Special Agent was the co-case agent for the Epstein investigation, prior to his transfer to FBI Headquarters in Washington, D.C. He contacted Jane Doe No. 3 by telephone in January-February 2007, in an attempt to interview her. 18. Kenneth W. Starr President and Chancellor Ba for Universi Judge Starr represented Jeffrey Epstein concerning the criminal investigation conducted by the U.S. Attorney's Office and the resolution of that investigation. 19. Jay Lefkowitz Kirkland and Ellis, LLP Mr. Lefkowitz represented Jeffrey Epstein concerning the criminal investigation conducted by the U.S. Attorney's Office and the resolution of that investigation 20. Gerald B. Lefcourt P.C. Mr. Lefcourt represented Jeffrey Epstein concerning the criminal investigation conducted by the U.S. Attorney's Office and the resolution of that investigation 21. Roy Black Black, Srebnick, Komspan and Stumpf Mr. Black represented Jeffrey Epstein concerning the criminal investigation conducted by the U.S. Attorney's Office and the resolution of that investigation. 22. Lilly Ann Sanchez LS Law Firm 5 EFTA00210114  Ms. Sanchez represented Jeffrey Epstein concerning the criminal investigation conducted by the U.S. Attorney's Office and the resolution of that investigation. 23. Alan M. Dershowitz Professor Emeritus Harvard Law School Professor Dershowitz represented Jeffrey Epstein concerning the criminal investigation conducted by the U.S. Attorney's Office and the resolution of that investigation. 24. Jack Goldberger Atterbury Goldberger et al. Mr. Goldberger represented Jeffrey Epstein concerning the criminal investigation conducted by the U.S. Attorney's Office and the resolution of that investigation. 25. Martin G. Weinberg Mr. Weinberg represented Jeffrey Epstein concerning the criminal investigation conducted by the U.S. Attorney's Office and the resolution of that investigation. 26. Guy Lewis Lewis & Tein Mr. Lewis represented Jeffrey Epstein concerning the criminal investigation conducted by the U.S. Attorney's Office and the resolution of that investigation. 27. Ba E. Krischer 6 EFTA00210115  Mr. Krischer was the State Attorney for Palm Beach County, Florida, who charged Jeffrey Epstein with state offenses arising out of his sexual activities with underaged girls. His office was responsible for the prosecution of the state criminal charges lodged against Epstein. 28. Lanna L. Belohlavek Ms. Belohlavek was the Assistant State Attorney in the State Attorney's Office, County of Palm Beach, who was responsible for the prosecution of Jeffrey Epstein. 29. Jane Doe No. 1 30. Jane Doe No. 2 31. Jane Does A through Z These are the young women who were referred to Jeffrey Epstein by Jane Doe No. 1, Jane Doe No. 2, and Jane Doe No. 3. Fed.R.Civ.P. 26(a)(1)(A)fii): Attorney General Guidelines for Victim and Witness Assistance, U.S. Department of Justice, Office of Justice Programs, Office for Victims of Crime (May 2005) October 10, 2007 letter from Jay Lefkowitz, Kirkland & Ellis, LLP, to R. Alexander Acosta November 29, 2007 letter from Jay Lefkowitz to R. Alexander Acosta December 5, 2007 letter from Kenneth W. Starr and Jay Lefkowitz to R. Alexander Acosta December 6, 2007 letter from First Assistant U.S. Attorney, to Jay Lefkowitz December 11, 2007 letter from Jay Lefkowitz to R. Alexander Acosta December 19, 2007 letter from R. Alexander Acosta to Lilly Ann Sanchez December 21, 2007 letter from Jay Lefkowitz to R. Alexander Acosta December 26, 2007 letter from Jay Lefkowitz to R. Alexander Acosta 7 EFTA00210116  Non-Prosecution Agreement, executed on September 24, 2007 Addendum to The Non-Prosecution Agreement, executed on October 29, 2007 Transcript of Taped Statement of Jane Doe No. I, April 24, 2007 Video Recording of Statement of Jane Doe No. I, April 24, 2007 January — May 2008 correspondence from Jay Lefkowitz regarding DOJ review of non- prosecution agreement May 2008 letter from Chief, Child Exploitation & Obscenity Section, U.S. Department of Justice, to Jay Lefkowitz May — June 2008 correspondence from Jay Lefkowitz and/or Kenneth Starr, to Deputy Attorney General ; Assistant Attorney General and Senior Associate Deputy Attorney General June 2008 letter =M, Senior Associate Deputy Attorney General, to Jay Lefkowitz and Kenneth Starr. These documents have already been produced in discovery. Fed.R.Civ.P. 26(a)(1)(A)(iiii: The United States Government is not seeking money damages in this case. Fed.R.Civ.P. 26(a)(1)(A)(ivi: The United States is self-insured. DATED: July 20, 2015 Respectfully submitted, UNITED STATES ATTORNEY 8 EFTA00210117  By: s/ Dexter A. Lee DEXTER A. LEE Assistant U.S. Attorney Fla. Bar No. 0936693 99 N.E. 4th Street, Suite 300 Miami, Florida 33132 (305) 961-9320 Fax: (305) 530-7139 E-mail: [email protected] ATTORNEY FOR RESPONDENT CERTIFICATE OF SERVICE I HEREBY CERTIFY that on July 20, 2015, I sent via electronic mail the foregoing document to the individuals on the attached Service List. ,s/ Dexter A. Lee DEXTER A. LEE Assistant U.S. Attorney SERVICE LIST Jane Does 1 and 2 I. United States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Bradley J. Edwards, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Fax: (954) 524-2822 E-mail: brad®pathtojustice.com Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, Utah 84112 (801) 585-5202 Fax: (801) 585-6833 E-mail: [email protected] 9 EFTA00210118 Attorneys for Jane Doe # 1 and Jane Doe # 2 I0 EFTA00210119