EFTA00205513.pdf

From: ' To:' (USAFLS)" (USAFLS)" Subject: Re: Jane Doe litigation Date: Sun, 08 Jan 2012 18:54:55 +0000 Importance: Normal I will confirm for you. The other case I think is Brad has represented at least a half dozen women who sued JE. AUSA From: (USAFLS) Sent: Sunday, January 08 2012 12:17 PM To: (USAFLS) Subject: Re: Jane Doe litigation Is there some way we can make sure so we can get all of the Petitioners' complaints. It's an important part of the argument. You're sure only one of them sued in state court? Brad represented plaintiffs in both of the cases I forwarded to you. From: (USAFLS) Sent: Sunda Janua 08, 2012 11:16 AM To: (USAFLS); Lee, (USAFLS) Subject: Re: Jane Doe litigation Hi I am 90% sure that III is our Jane Doe #1. Jane Doe #2 did not sue in federal court. She sued in Palm Beach County state court. I am pretty sure I have her case number somewhere. I don't think I have ever seen her civil complaint. AUSA From: (USAFLS) Sent: Friday, January 06, 2012 06:32 PM To: I . (USAFLS); Lee, (USAFLS) Subject: Re: Jane Doe litigation Were either of you able to confirm that these plaintiffs are our petitioners? From: (USAFLS) Sent: Wednesday, January 04, 2012 08:26 PM To: I . (USAFLS); Lee, (USAFLS) Subject: Jane Doe litigation Can you confirm that the plaintiffs in the cases cited below are the petitioners in our CVRA matter? First Am. Compl. ¶¶ 32-33, Doe g Epstein, Case No. 08-80893-CIV-MARRA ("assen[ing] a cause of action against the Defendant, Jeffrey Epstein, pursuant to [18 U.S.C. § 2255] and the [Non-Prosecution] agreement between the Defendant, Jeffrey Epstein, and the United States Government"); Compl. n 19-20, L.M. g Epstein, Case No. 09- 81092-CIV-Cohn (asserting that plaintiff was "covered by" provisions of the Non-Prosecution Agreement between the government and Epstein and that Epstein was thus "estopped by his plea and agreement with the Federal EFTA00205513 Government from denying the acts alleged in [the] Complaint, and must effectively admit liability to the Plaintiff, L.M., including admitting liability for all counts enumerated in this Complaint") Thanks, EFTA00205514