MAR-17-2818 12:45 P.@1 FD-448 FEDERAL BUREAU OF INVESTIGATION 10127-2006 FACSIMILE COVER SHEET PRECEDENCE © Immediate @ Priority C Routine CLASSIFICATION C Top Secret C Secret © Confidential @ Sensitive C Unclassified To Name of Office: U.S. Attorney's Office - Miarni Name of Office: FBI Miami, Chief Division Counsel Originator’s Name: PLS Deyanira Aponte DETAILS Subject: Jane Doe 2-7 v. Jeffrey Epstein Special Handling Instructions: Brief Description of Communication Faxed: Attached is the most recent correspondence that we received today from Mermelistein & Horowitz. WARNING Information attached to the cover sheet |s U.S. Government Property. If you are not the intended recipient of this information disclosure, reproduction, distribution, or use of this information is prohibited (16,USC, § 641), Please notify the originator or |ocal FBI Office immediately to arrange for proper disposition. FN -448 (Reviced 11-37.20M4) Bane 1 oft FENG A! RIB FAI OF INVESTIGATION EFTA00213221

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MAR-17-2818 12:46 P.@2 MERMELSTEIN & HOROWITZ PA ATTORNEYS AT Law Adam 0, Horowitz Tel 305-931-2200 Fax 305-931-0877 anorowitz @ sexabuseatiomey.com 18205 Biscayne Boulevard Suite 2218 Miam|, Florida 33160 www mey.com FAX TRANSMITTAL Lisa Rivera, legal assistant to February 17, 2010 RE: Jane Doe 2-7 v. Jeffrey Epstein Please see attached Motion to Compel Production of Jane Does Nos. 2-7's Sworn Statements to FBI Investigators and Incorporated Memorandum of Law. THIS MESSAGE IS INTENDED ONLY POR THE USE OF THE INDIVIDUAL OR ENTITY TO WHICH IT IS ADDRESSED AND MAY CONTAIN_INFORMATION THAT IS PRIVILEGED, CONFIDENTIAL AND EXEMPT FROM DISCLOSURE UNDER APPLICABLE LAW. IF THE READER OF THIS MESSAGE IS NOT THE INTENDED RECIPTENT OR THE EMPLOYEE OR AGENT RESPONSIBLE FOR DELIVERING THE MESSAGE TO THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIPIED THAT ANY DISSGMINATION, DISTRIBUTION OR COPYING OF THIS COMMUNICATION |S STRICTLY PROHIBITED. If YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONE, AND RETURN THE ORIGINAL MESSAGE TOUS AT THE ABOVE ADDRESS Via THE U.S, POSTAL SERVICE. THANK YOU. EFTA00213222

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MAR-17-2818 12:46 Case 9:08-cv-80119-KAM Document 489 Entered on FLSD Docket 03/17/2010 Page 1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. Related Cases: 08-80232, 08-80380, 08-$0381, 08-80994, 08-80993, 08-8081 |, 08-80893, 05-80469, 09-8059], 09-80656, 05-8002, 09-81092, / PLAINTIFF JANE DOE NOS, 2-7’S MOTION TO COMPEL PRODUCTION OF JANE DOE NOS, 2-7'S SWORN STATEMENTS TO FBI INVESTIGATORS AND INCORPORATED MEMORANDUM OF LAW Plaintiffs, Jane Docs Nos. 2-7, by and through undersigned counsel, hereby file this Motion to Compe! Production of Jane Doe Nos. 2-7's Sworn Statements to FBI Investigators and Incorporated Memorandum of Law, and state as follows: 1. These lawsuits arise from the alleged childhood sexual battery of Jane Doe Nos. 2-7 by Jeffrey Epstein (“Epstein”). 2. Prior to the filing of the Plaintiffs’ lawsuits, Epstein wes investigated by the Federa| Bureau of Investigation (FBJ). During the course of the FBI's investigation, some or @!! of Jane Doe Nos. 2-7 were interviewed by FBI agents and asked to provide sworn statements about their sexua! abuse by Jeffrey Epstein, the same abuse underlying P.83 EFTA00213223

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MAR-17-2018 12:46 P.@4 Case 9:08-cv-80119-KAM Document 489 Entered on FLSD Docket 03/17/2010 Page 2 of 4 the factual allegations in the lawsuits now in front of this Court. 3. Pursuant to FBI protocol and the Federal Privacy Act, 5 U.S.C. § 552a(b), Plaintiff's undersigned counsel has served a subpoena on the Records Custodian of the FBI’s Miami office requesting the sworn statements of Jane Doe Nos. 2-7 given to FBI agents during their criminal investigation of Jeffrey Epstein. See Exhibit “A.” 4. The FBI informed Plaintiffs’ counsel that it requires further authorization in order to release the Plaintiffs’ own sworn statements pursuant to the Federal Privacy Act. Counsel for the FBI has advised that an Order from this Court authorizing the FBI to release the requested statements would be sufficient. See 5 U.S.C. § $$2a (b)(11). A proposed Order authorizing the FBI to release the subpoenaed statements is attached es Exhibit “3.” 5. The requested statements are directly relevant and germane to the factual allegations underlying the Plaintiffs’ lawsuits and seemingly cannot be obtained by the Plaintiffs in any other way. Upon information and belief, the Defendant is already in possession of thesc documents. 6. Plaintiffs’ counsel has conferred with counsel for the Defendant who advised that Defendant opposes the relief requested. WHEREFORE, Plaintiffs, Jane Does Nos. 2-7, respectfully request an Order directing the Federal Bureau of Investigation to release any sworn statements of Jane Doe Nos. 2-7 given to the FBI during the criminal investigation of Jeffrey Epstein and any materials responsive to the subpoena served upon the FBI. EFTA00213224

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_MAR-17-2018 12:46 Case 9:08-cv-80119-KAM Document489 Entered on FLSD Docket 03/17/2010 Page 3 of 4 Certificate Pursuant to S.D,Fla.L.R. 7.1(A)(3) Undersigned counsel has conferred with Defendant’s counsel in a good faith effort to resolve the issues raised in this Motion, and has been unable to do so. Dated: March 17, 2010 Respectfully submitted, By:__s/ Adam D. Horowitz Stuart S. Mermelstein (FL Ber No. 947245) ssm@sexabuseattomey.com Adam D. Horowitz (FL Bar No. 376980) ahorowitz@sexabuseattorney.com Jessica D. Arbour (FL Bar No. 67885) Jarbour@sexabuseattorney.com MERMELSTEIN & HOROWITZ, P.A. Attorneys for Plaintiffs 18205 Biscayne Blvd., Suite 2218 Miami, Florida 33160 Tel: (305) 931-2200 Fax: (305) 931-0877 CERTIFICATE OF SERVICE I hereby certify that on March 17, 2010, 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 to all parties on the attached Service List in the manner specified, cither via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those parties who are not authorized to receive electronically Notices of Electronic Filing. EFTA00213225

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MAR-17-2818 12:46 P.86 Case 9:08-cv-80119-KAM Document 489 Entered on FLSD Docket 03/17/2010 Page 4 of 4 SERVICE LIST DOE ys. JEFFREY EPSTEIN United States District Court, Southern District of Florida Jack Alan Goldberger, Esq. inoldberger@agwoa.com Robert D. Critton, Esq. Bradley James Edwards bedwards(@rra-law.com Isidro Manuel Garcia isidrogarcia@bel{south.net Jack Patrick Hill iph@searevlaw.com Katherine Warthen Ezel! KEzell@podhurst.com Micheel James Pike Paul G. Cassell cassellp@law.utah.cdu Richard Horace Willits illits@ao! Robert C. Josefsberg tiosefsberg@podburst.com By facsimile and U.S. Mail to: Frank Navas, Esq, Chief Division Counsel Federal Bureau of Investigations 16320 N.W. 2nd Avenue North Miami Beach, FL 33169 EFTA00213226

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MAR-17-2818 12:46 P.6? Case 9:08-cv-80119-KAM Document 489-1 Entered on FLSD Docket 03/17/2010 Page 1 of 4 AC $4B (Rev, 06/09) Svbpaena to Preduce Documents, Lafermation, or Objects or to Permit Inspestion of Prewizes im a Chil Action UNITED STATES DISTRICT COURT for the Southern District of Flonda _ sa ly Platrrgy ) | | ) Civil Actin No, 08-CV-80119- Marra ) ) (f the action it pending wn another district, mate where: ‘Defendiont ) ) SUBPOENA TO PRODUCE DOCUMENTS, INFORMATION, OR OBJECTS OR TO PERMIT INSPECTION OF PREMISES IN A CIVIL ACTION Te: Seeseete ested, Pete Beseegs of paatigaten, TERS Nineveh Decree Arenen, Mats Pies ate, Florida, 33169 & Production: YOU ARE COMMANDED to produce at the time, date, and place set forth below the following documents, electronically stored information, or objects, and permit their inspection, copying, testing, or sampling of the " See Schedule A as attached. Place: Mermatstein & Horowitz, PA. Date and Tune. 18205 Biscayne Bivd., Suite 2218 . H tend. FL ane 04/02/2010 10:00 am © Inspection of Premites: YOU ARE COMMANDED to perrait entry onte the designated premises, land, or other property possessed or controlled by you at the time, date, and location set forth below, so that the requesting party my inspect, measure, survey, photograph, test, or sample the property or any designated object or operation on it. The provisions of Fed. R. Civ. P. 45(c), releting to your protection as « person subject to a subpoena, und Rule 45 (d) and (e), relating to your duty to respond to this subpoena and the potential consequences of not doing so, are Pm CLERK OF COURT Signature of Clerk or Depwry Clark The name, address, e-mail, and telephone number of the attomey representing (name ofpory) _ PLAINTIFF , Who issues or requests this subpoena, are: Stuart Merme!stein, Adam Horowitz, Jessica Arbour, Mermeistein & Horowitz, P.A., 18205 Biscayne Bivd,, Suite 2218, Miami, FL 33160, (305) 831-2200, jarbour@sexabuseatlomey.com. — EFTA00213227

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MAR-17-2018 12:47 Case 9:08-cv-80119-KAM Document 489-1 Entered on FLSD Docket 03/17/2010 Page 2 of 4 AQ BAB (Rev, O6/0¥) Subpoena fo Prastute Documents, Infarrestios, of Ob, ects or io Permut Inapesvon of Promina: in 4 Civ Aaden (Page 2) Civil Action No, 08-CV-80119- Marra PROOF OF SERVICE (This section should not be filed with the court unless required by Fed. R. Civ. P. 45.) ue hy ES Tubpocan for taame of tndtldval and ile, any) was received by me oc (ore) OC I served the subpoena by delivering a copy to the named person as follows: On (ate) ;or O I retumed the subpoena unexecuted because: Unless the subpoena was issued on behalf of the United States, ar one of its officers or agents, I have also tendered to the witness fees for one day's attendance, and the mileage allowed by law, in the amount of $ My fees are $ for wavel and $ for services, for e total of S 0,00 I declare under penalty of perjury that this information is true Server's rigneture Prewed name and title Server's address Additional information regarding attempted service, etc: EFTA00213228

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MAR-17-2018 12:47 Case 9:08-cv-80119-KAM Document 489-1 Entered on FLSD Docket 03/17/2010 Page 3 of 4 AO BEB (Rev, 06/09) Subpecas to Produce Documents, Infarmatina, of Objects of to Permit Lnspection of Premises in » Civil Accion(Page 3) Federa) Rule of Civil Procedure 45 (¢), (d), and (e) (Effective 12/1/07) (c) Protecting a Perron Subject to « Subpoena. (1) Avoiding Undwe Burden or Expense; Sanctions. A patty of atocmey responsible for jesuing and serving a subpocna must tke reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena, The jssuing cowwt must onforce this pombe pele af hekey-weglsee- ey dersantgg earings and reasonable amorney's fees ~ on a party or attorncy who fails to comply. (2) Command to Produce Materials or Permit Inspection. Ce epeman Seated Apemenmnstapnie documents, electronically stored information, or tangible things, ar to permit the inspection of premises, nted not appear in person at the place of production oy inspection unless alse commanded to appear for « deposition, hearing, ot trial. (18) Objections. A person commanded to produce documents cr tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting che premises — of to producing electronically stored information in the form or forms requested. The objection must be verved before the carbier of the time specified for compliance of 14 days after the subpoans i: served If an objection is made, the following rules apply: () Al apy time, ap notice to the commanded person, the serving Party may move the issuing coun for an créer compelling preduction oa (UW) These acts my be required only as directed in the order, and the order must protect @ person who is neither s party nor s party's officer from sigraficant expense resulticg from compliance GB) Quashing or Modifying « Subpoena. OB) Fin Rotel Coteny mates, Gobming omrenn quash or medify « subpoena thet: (1) fails to allow « reasonable time to comply, (i) requires & persun who is neither a party nor a party's officer te travel more than 100 miles fram where that person resides, is cmployed, or regularly wansacts business in person — except thal, subject to Rule 43(c)(3)(BXiil), the person may be commanded to amend a tris) by waveling from sny such place within the state where the trial is held; (Ui) requires disclosure of privileged or other protected matter, if ho Exception or waiver applies; or (iv) subjects « person to undue burden, (8) When Permitted To protect » person subject to or affected by © subpoena, the icsuing court may, on motion, quash er modify the subpoena if it requires; (1) divelosing a wade secret or otber confidential research, Cevelopment, or commercial information; (ii) disclosing an unrewined expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by « party; or (ti) a person who is neither a party nor # party's officer two incur Substantial expense to travel more than 00 miles to attend qial. (C) Specifying Conditions as an Alvernative, Ip the circumstances described in Rule 45(¢)(3)(B), the court may, instead of quashing cr modifying « subpocns, order appearance or production under specified conditions if the serving party: (1) shows a substanria) need for the testimony or matsrial that cannot be otherwise met without undue hardship; and (11) ensures thar the subpoenaed person will be reasonably compensated. (4) Duties in Responding to a Subpoena. (1) Producing Documents or Electronically Stored Information. These procedures spply to producing documents or electronically Stored information: (A) Documents. A person responding to a subpoena to produce documents must produce them as they are kept ip the ordinary course of butiness or must organize and label them to correspond to the categories in the demand. (B) Form fer Producing Electronically Stared Informotion Not sccessible because of undue burden or cost. On motion © compel discovery or for » protective order, the persce respunding must show ‘that the information is not reasonebly acvessibie because of undue burden of cost. If that showing is made, the court may nopetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(6)(2)(C). The court may specify conditions for che discovery. ing subpoenaed information under a claim that it is privileged or subject to protection as trisl-preparation material most: (@ expressly make the claim; and (i) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim, (8) Information Produced. Lf information produced in response to & subpoena is subject to s claim of privilege or of protection as trial- preparation materiel, che person making the claim may notify any party that received the information of the claim and the bas|s far it. After being notified, « parry must promptly rerum, sequester, or destroy the specified information and any copies it has; must not use or disclose the informarion until the claim je resolved; must take reasonable steps tc retrieve the information if the party disclosed jt before being notified; and may promptly present the information wo the court under seal for a determination of the claim, The parson who produced the information must preserve tbe information uot!) the claim is resolved. (c) Contempt. The issuing court may hold in contempt 8 perton who, baying been served, fails without adequate excuse to obey the subpoena. A norparty's Gailure to obey must be excused if the subpoena purports to require the nonparty lo attend or produce ata place outside the limits of Rule 45(X3A){ii). P.@9 EFTA00213229

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MAR-17-2018 12:47 P.10 Case 9:08-cv-80119-KAM Document 489-1 Entered on FLSD Docket 03/17/2010 Page 4 of 4 chedule Sworn statements taken during the investigation of Jeffrey Edward Epstein (358 El Brillo Way, Palm Beach, FL, DOB: 01/20/1953) from the following: TOTAL P.18 EFTA00213230