EFTA00592481.pdf

Case 9:08-cv-80736-KAM Document 335 Entered on FLSD Docket 07/24/2015 Page 1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO: 08-80736-CIV-MARRAMATTHEWMAN JANE DOE #1 AND JANE DOE #2, Petitioners, vs. UNITED STATES OF AMERICA, Respondent. RESPONSE TO COURT ORDER OF JULY 6, 2015 AND UNITED STATES' NOTICE OF PARTIAL COMPLIANCE Robert C. Josefsberg, Esq., of Podhurst Orseck, P.A., files this pleading on behalf of his former clients ("Settled Victims" )t in response to the Court's Order of July 6, 2015 [DE 330] and the Government's pleading of July 20, 2015 [DE 333]. The Settled Victims do not consent to their identities being revealed to the Petitioners. Pursuant to their Settlement Agreements, the CVRA, and their Federal and State rights to privacy, they insist that they maintain their anonymity. To the extent that the Government and/or Jeffrey Epstein and/or others are aware of their identity, they, the Settled Victims, request that their identities not be further disseminated. The addresses, email addresses, telephone numbers of some of the Settled Victims may be outdated. The Settled Victims have specifically and adamantly demanded that their counsel not update any One of counsel's former clients is currently a Jane Doe Plaintiff in these proceedings. Therefore, she is not included in this class of "Settled Victims". EFTA00592481 Case 9:08-cv-80736-KAM Document 335 Entered on FLSD Docket 07/24/2015 Page 2 of 4 CASE NO: 08-80736-CIV-MARRAMATTHEWMAN information regarding their whereabouts to the Government, any law enforcement agency, the Petitioners, Jeffrey Epstein, and/or anyone else. Respectfully submitted, PODHURST ORSECK, Attorneys for Settled Victims City National Bank Bldg. 25 W. Flagler Street, Suite 800 Miami, Florida 33130 Telephone Facsimile: By: /s/ Robert C. Josefsberg Robert C. Josefsberg Fla. Bar No.: 040856 2 EFTA00592482 Case 9:08-cv-80736-KAM Document 335 Entered on FLSD Docket 07/24/2015 Page 3 of 4 CASE NO: 08-80736-CIV-MARRA/MATTHEWMAN CERTIFICATE OF SERVICE I HEREBY CERTIFY that on July 24, 2015, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of record, either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those counsel or parties who are not authorized to receive electronically Notices of Electronic Filing. s/ Robert C. Josefsberg ROBERT C. JOSEFSBERG 3 EFTA00592483 Case 9:08-cv-80736-KAM Document 335 Entered on FLSD Docket 07/24/2015 Page 4 of 4 CASE NO: 08-80736-CIV-MARRAMATTHEWMAN SERVICE LIST Brad Edwards, Esc' Farmer Jaffe, Et Al. 425 N. Andrews Avenue Suite 2 Ft. Lauder - 268 Telephone: Facsimile: Attorneys for Jane Doe #1 and Jane Doe #2 Paul G. Cassell, Esq. S.J. Quinney College of Law University of Utah 332 S. 1400 E. Salt Lake City, UT 85112 Telephone: Facsimile: Attorneys for Jane Doe #1 and Jane Doe #2 A. Marie Villafafia, Esq. AUSA United States Attorney's Office 500 S. Australian Avenue Suite 400 West Palm Beach, FL 33401 Telephone: Facsimile: 4 EFTA00592484