UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson¶
JANE DOES #1 and #2 Petitioners,¶
UNITED STATES Respondent.¶
GOVERNMENT’S RESPONSE TO PETITIONERS’ REQUEST FOR NON-PROSECUTION AGREEMENT AND REPORT OF INTERVIEW¶
Respondent United States, by and through its undersigned counsel, files its Response to Petitioners’ Request for Non-Prosecution Agreement and Report of Interview, and states:¶
In their Response to Government’s Notice to Court Regarding Absence of Need for Evidentiary Hearing and Motion for Production of Non-Prosecution Agreement and Report of Interview (D.E. 19), petitioners seek an order compelling the Government to produce the Non-Prosecution Agreement with Jeffrey Epstein (D.E. 19 at 11-13), and the Report of Interview with Jane Doe #1 (D.E. 19 at 13-14).¶
The Government is unable to voluntarily produce the Non-Prosecution Agreement because the Agreement contains a clause where the parties expressed their anticipation that the Agreement would not be made part of any public record. The Government believes this clause in the Agreement precludes it from voluntarily producing the Agreement, as requested by petitioners.¶
As to petitioners’ request for the Report of Interview with Jane Doe #1, counsel for the Government has spoken with FBI Special Agents Nesbitt Kurykendall and Jason Richardson, who have advised that no Report of Interview was prepared subsequent to their meeting with Jane Doe #1 in late September 2007, to discuss the Non-Prosecution Agreement entered into with Jeffrey Epstein.¶
Respectfully submitted,¶
R. ALEXANDER ACOSTA¶
UNITED STATES ATTORNEY¶
By: s/Dexter A. Lee¶
DEXTER A. LEE¶
Assistant U.S. Attorney¶
Fla. Bar No. 0936693¶
99 N.E. 4th Street¶
Miami, Florida 33132¶
| (305) 961-9320 |¶
Fax: (305) 530-7139¶
E-mail: dexter.lee@usdoj.gov¶
Attorney for Respondent¶
CERTIFICATE OF SERVICE¶
EFTA00204625¶
I HEREBY CERTIFY that on August ___, 2008, I electronically filed the foregoing document with the¶
Clerk of the Court using CM/ECF.¶
s/ Dexter A. Lee¶
DEXTER A. LEE¶
Assistant U.S. Attorney¶
SERVICE LIST¶
Jane Does 1 and 2 United States,¶
Case No. 08-80736-CIV-MARRA/JOHNSON¶
United States District Court, Southern District of Florida¶
Brad Edwards, Esq.,¶
The Law Offices of Brad Edwards & Associates, LLC¶
2028 Street, Suite 202¶
Hollywood, Florida 33020¶
(954) 414-8033¶
Fax: (954) 924-1530¶
EFTA00204626¶