<[email protected] Cc: "Sanchez, Eduardo (USAFLS)" <[email protected]>, "Maria Kelljchian" <[email protected]> Subject: RE: two questions Date: Mon, 29 Jul 2013 20:46:10 +0000 Importance: Normal We are writing in connection with the Government's recent production of various materials pursuant to the Court's order granting Jane Doe No. 1 and Jane Doe No. 2's motion to compel. We have two questions: 1. We notice, on first review of the materials provided, that it does not appear that any materials from the Middle District of Florida are included. Given that, as we understand it, the U.S. Attorney's Office for the Southern District of Florida recused on various aspects of this case some time ago, we find it surprising that there are no such responsive documents. For example, if the Middle District of Florida had correspondence on the victims issues or conducted any kind of investigation into the allegations related to this case or to Epstein, that would have been included in our requests. We can follow up with the Middle District of Florida or in other ways. But before we did so, we wanted to give you an opportunity to confirm whether your production includes the Middle District of Florida. As you know, our discovery requests specifically included that district, so we were expecting to see such materials. We note production is now due not only for the initial requests sent back in 2011, but also our single, supplemental request sent on June 24, 2013. Under this supplemental request, for example, all investigations or grand juries that convened in the Middle District of Florida would be specifically covered. 2. We are preparing to contest many of the Government's assertions of privilege with regard to the materials submitted to Judge Marra. Under the court's order (doc. #190), we have thirty days to do and are limited, currently, to seven pages followed by a response of seven pages from you. We are preparing a motion asking f