Epstein Data Wiki

The government's answers to the victims' first requests for admission

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tagstopic, cvra, usao-sdfl, court-records, discovery, non-prosecution-agreement, document-release

48 min read

What was answeredTwenty-six numbered requests for admission served on the United States by the two women suing it under the Crime Victims’ Rights Act, several with lettered sub-parts12
Who askedBradley J. Edwards and Paul G. Cassell for Jane Doe #1 and Jane Doe #2, in Jane Doe #1 and Jane Doe #2 v. United States, No. 08-80736-Civ-Marra/Johnson (S.D. Fla.), served 1 December 201112
Who answeredThe United States as respondent, under U.S. Attorney Wifredo A. Ferrer; the signature block carries Assistant U.S. Attorneys Dexter A. Lee, A. Marie Villafaña and Eduardo I. Sánchez, and the conformed signature is Lee’s3
The filed answer”United States’ Response to Petitioners’ First Request for Admissions to the Government”, Document 213-1, entered on the FLSD docket 19 July 2013, twelve pages, with a covering notice at Document 213 dated the same day45
Also in the releaseTwo copies of an undated, unsigned five-page draft captioned “RESPONDENT’S ANSWERS TO PETITIONERS’ FIRST REQUESTS FOR ADMISSIONS”, carrying twelve working notes in square brackets, nine of them in a first-person voice67891011
What the bracketed notes areQueries by whoever was drafting. They are not the government’s filed position, and no bracketed note appears anywhere in the filed answer111213
Requests the draft leaves to a bracketed note alone16, 18, 19, 21, 22 and 24 — every one of them answered outright in the filed response111213
A sub-part the draft never reachesRequest 2(e). Both copies of the draft run from the answer to 2(d) straight on to “3. Deny.”; the filed response answers 2(e) in a paragraph of its own681415
Requests where draft and filed answer point opposite ways17 (draft “Deny”, filed “Admitted”) and 26 (draft “Admit”, filed a privilege objection)111213
The two draft copiesThe Department released them redacted differently from each other, and the difference falls on names. This page reports the inconsistency and not its location, and completes no name that either copy withholds16

Page limits. This page distinguishes, in every instance, between what the United States filed and what a bracketed note in a draft says; where a note is quoted it is identified as a note. The draft carries no signature, no date and no name, and this page does not attempt to identify who wrote it. Where a bracketed note runs on into a list of colleagues’ first names, this page removes the names from its quotation and marks the removal at the point it falls; that marker is this page’s own and not the draft’s. One note records a rumour the note itself says was never confirmed, and is reported as that and nothing more. Two copies of the filed response redact different things: this page reproduces none of the counsel contact details either of them carries, and no bar number, address, telephone number or email address from any document cited. Every page cited below was rendered locally and read at the image.

In December 2011 the two victims suing the U.S. Attorney’s Office for the Southern District of Florida asked it to admit or deny twenty-six propositions about how it had handled the Epstein case.12 Nineteen months later the United States responded to all twenty-six in a filing on the public docket: it answered twenty-five of them and objected on privilege to the twenty-sixth without answering it.413 The release also contains something the docket does not: two copies of a working draft of those answers, in which the answers stand beside the drafter’s own notes about which of them could not yet be given.1116

The two documents are read together here because the decision and the making of the decision are both in the release. They are not read as one document. A note in square brackets is a person thinking on paper; the filed response is what the United States told a federal court.

This page is about the answers. The court’s rulings in the case are set out at Doe v. United States (CVRA litigation), and what the same office withheld from the same victims, entry by entry, at The 2013 privilege logs in the CVRA litigation. Neither is retold here.

What the victims asked

The requests were served on 1 December 2011 over the signature “s/ Bradley J. Edwards”, with Paul G. Cassell pro hac vice beneath, and are captioned “JANE DOE #1 AND JANE DOE #2’S FIRST REQUEST FOR ADMISSIONS TO THE GOVERNMENT REGARDING QUESTIONS RELEVANT TO THEIR PENDING ACTION CONCERNING THE CRIME VICTIMS RIGHTS ACT”.12 A background paragraph records that the court had allowed the requests while the government’s motion to dismiss was pending, and that the victims had asked the government to stipulate to undisputed facts and been declined.17

The twenty-six run from the general to the very specific. They ask the government to admit that its investigation “developed a case for a federal prosecution against Epstein for many federal sex offenses”; that it negotiated with Epstein’s lawyers about what victims would be told; that “at least one experienced attorney within the U.S. Attorney’s Office” took the position that the Act required notification; and that the non-prosecution agreement “currently blocks” any federal prosecution of the offences against these two women.171819 Request No. 5 and the government’s answer to it are set out at Doe v. United States.

Six requests name individuals. Request 6 asks the government to admit that it holds material reflecting contacts made on Epstein’s behalf between May 2007 and September 2008 by seven named people: “(a) President Bill Clinton; (b) Andrew Albert Christian Edward (a/k/a Prince Andrew, Duke of York); (c) Harvard Law Professor Alan Dershowitz; (d) Ken Starr; (e) Lillian Sanchez; (f) Jay Lefkowitz; and (g) Roy Black.”18 Requests 15, 16 and 17 concern “Defense attorney Bruce E. Reinhart”, a former Assistant U.S. Attorney in the same office.20 Request 18 asks about “improper communication or influence made or attempted with the Government, on Jeffrey Epstein’s behalf by: (a) Guy Lewis (b) LilyAnn Sanchez”.20 Requests 19, 20 and 21 ask whether the government holds information about a personal or business relationship between Epstein and, respectively, U.S. Attorneys or Assistant U.S. Attorneys generally, Matthew Menchel, and Alex Acosta, the two names being printed in bold in the requests themselves.2019 Request 22 asks whether the Office of Professional Responsibility “and/or other Government entities” had collected information about Reinhart’s possible involvement, about “[o]ther government attorney’s possible improper behavior”, and about a conflict of interest in the office’s handling of the matter.19

The draft in the release

Two identifiers in Data Set 9 carry the same five-page document, captioned in the court’s format: “UNITED STATES DISTRICT COURT / SOUTHERN DISTRICT OF FLORIDA / Case No. 08-80736-Misc-Marra/Matthewman”, the parties, and the heading “RESPONDENT’S ANSWERS TO PETITIONERS’ FIRST REQUESTS FOR ADMISSIONS”.67 Neither copy carries a docket stamp, a date, a signature block or a certificate of service. Each is followed immediately in the Bates sequence by an eight-page copy of the victims’ request it answers, so each sits in the production as a two-document packet: the answers, and the questions.21

The body runs straight from “1. Admit.” to “26. Admit.” with no preamble and no reservation of rights. Alongside the answers stand twelve passages in square brackets, at requests 6(a), 9(e), 11, 13(b), 16, 17, 18, 19, 20, 21, 22 and 24.891011 They are addressed to somebody else on the same side: “[These all need to be confirmed.]”, “[Need to explain.]”, “[OPR needs to answer these.]”, “[I can’t certify to the date.]”, “[Can we add: …]”, “[You need to check with DC about this. Does DC have my emails by any chance?]” Nine of the twelve are in the first person, singular or plural. The three that are not are the notes at requests 6(a), 9(e) and 22, which are the first three quoted here.891011

None of this is the government’s position. Every one of the twelve bracketed passages is absent from the filed response, and where the draft offers no answer at all the filed response gives one.221213

What the drafter had not settled

One sub-part the draft does not reach at all. Request 2 has five lettered sub-parts, (a) to (e), and the requests instruct that “[w]here the request for admission has separate, lettered sub-parts, please admit or deny each separate sub-part”.17 The draft answers 2(a) and 2(b) on its first page and 2(c) and 2(d) on its second, and then runs straight on to “3. Deny.” There is no 2(e), and the two copies are identical in this.6814 The filed response answers 2(e) in a paragraph of its own, admitting that neither Jane Doe #1 nor Jane Doe #2 was told that the office had entered into the non-prosecution agreement until after it was signed, and denying that Jane Doe #2 was not informed as a result of the negotiations or of the objections lodged by Epstein’s lawyers.15 The extraction of the draft does not show the gap: read as text, the answer to 2(d) and the answer to 3 simply follow one another.

Six of the twenty-six requests are answered in the draft by a bracketed note and nothing else: no admission, no denial, no objection. They are requests 16, 18, 19, 21, 22 and 24.11 Request 25 is answered “Deny?”, with the question mark.11 Request 17 carries a note and then “Deny.”; request 20 carries “Admit.” and then a note.11

The notes say why. Against request 16, which asks whether the government holds telephone logs or emails reflecting contacts between Reinhart and people affiliated with Epstein: “[I haven’t completed the review yet. So far there may be some personal emails with Jack Goldberger only. We don’t have any telephone logs or other documents.]”1120 Against request 17, which asks about contacts between Reinhart and people working at the Department or the office: “[You need to check with DC about this. Does DC have my emails by any chance?]”1120 Against request 18, on improper communication or influence: “[I don’t know how to answer this. ‘improper communication or influence’ is so vague and potentially broad that a denial is problematic. I also have never seen all of the emails between Guy and Lilly Ann and Alex, [given names, not reproduced by this page] (and any others in DC).]”11 Against request 19, on relationships between Epstein and U.S. Attorneys or Assistant U.S. Attorneys: “[Again, I don’t know how to answer this. The RFA does not use the word ‘former,’ so it would seem to only cover personal or business relationships between Epstein himself and persons who were then-employees of the USAO. I am unaware of any such relationships with Epstein directly. We will need to review emails and possibly interview Alex/[given names, not reproduced by this page].]”11 Both markers inside those two quotations are this page’s own substitutions and not the draft’s words: where the note runs on into a list of colleagues’ first names, this page takes the names out and says here that it did. Against request 21, on Acosta: “[I don’t know.]”11 Against request 22, on what OPR had collected: “[OPR needs to answer these.]”11

Two further notes bear on named people. Against request 20, on Menchel, the draft answers “Admit.” and adds: “[I know that Menchel now has a business relationship with Epstein. I don’t have any documentary evidence, but I have been told this by Jeff Sloman.]”11 By the note’s own words that assertion rests on no document and on what the drafter had been told by a colleague; the filed answer to request 20 is “Admitted.” and carries no such attribution.12 The Office of Professional Responsibility’s later findings on Menchel, and his own recorded response to it, are set out below. Against request 24, on whether Epstein had provided or offered valuable consideration to the federal government, the draft gives no answer and notes: “[I don’t know what ‘valuable consideration’ means. I had heard a rumor that Epstein was a cooperator in the Bear Stearns investigation but this was never confirmed.]”11 That note is a note recording an unconfirmed rumour, and it is reported here as that. The filed answer to request 24 says nothing about it.13

The bracket at request 6(a) sits against the denial of the first of the seven names: “6. (a) Deny. [These all need to be confirmed.]”8 The other six sub-parts follow without a note: (b) Deny; (c) Admit; (d) Admit; (e) “Admit to the extent this is meant to refer to Lilly Ann Sanchez”; (f) Admit; (g) Admit.8

The bracket at request 13(b) is not a query but a proposal. After “Admit.” it reads: “[Can we add: Members of the Executive Division at the USAO determined that attorneys for the USAO and the FBI agents would not confer with Jane Doe #1 prior to the USAO’s decision to enter into the non-prosecution agreement. Jane Doe #2 had already informed the attorney for the government and the FBI agents that she did not believe that Epstein should be prosecuted.]”10 It was not added. The filed answer to 13(b) contains no sentence about the Executive Division and no sentence resembling it.2324

What the United States filed

On 19 July 2013 the office filed the response on the public docket, under a covering notice reading in its entirety: “Respondent United States files its Response to Petitioners’ First Request for Admissions to the Government.”5 The response itself opens by fixing its own scope: it “is confined to Request No. 1 through Request No. 26 in the ‘Discovery Requested’ section” and does not respond to the Background section, while denying the assertion in that section that the government had declined to stipulate to undisputed facts.4 Its signature block stands under “WIFREDO A. FERRER / UNITED STATES ATTORNEY”, carries a conformed “/s Dexter A. Lee” and names three Assistant U.S. Attorneys (Lee, A. Marie Villafaña and Eduardo I. Sánchez) over the line “Attorneys for United States”; a certificate of service records service by CM/ECF the same day.3

The filed answers are written in the form the draft is not: each begins “The government admits that…” and closes “Except as otherwise admitted above, the government denies Request No. …”, so that a partial admission and the denial of everything else appear in the same paragraph.252226

On request 6 the filed answer is (a) Denied; (b) Denied; (c) Admitted; (d) Admitted; (e) “Admitted to the extent that the reference to ‘Lillian Sanchez’ was meant to refer to Lilly Ann Sanchez”; (f) Admitted; (g) Admitted.22 The government therefore denied that it holds material reflecting contacts on Epstein’s behalf by Bill Clinton or by Prince Andrew, and admitted that it holds such material as to Alan Dershowitz, Ken Starr, Lilly Ann Sanchez, Jay Lefkowitz and Roy Black.2218 On request 19 it objected that a request reaching “the 93 U.S. Attorneys and over 5,400 Assistant U.S. Attorneys serving across this country” was overly broad and burdensome, and then denied “possessing or having any knowledge or information about a personal or business relationship between Jeffrey Epstein and either the U.S. Attorney or any Assistant U.S. Attorney serving in the Southern District of Florida.”12 On request 24 it answered: “Admitted; Jeffrey Epstein provided valuable consideration to the federal government through the non-prosecution agreement he entered with the USAO.”13 On request 26, which asks whether the government holds evidence that other districts shared jurisdiction and venue, it objected on the ground of “the law enforcement investigative privilege” and gave no answer.1319

Where the draft and the filing part company

Nineteen of the twenty-six requests are answered differently in the two documents, counting a request as differing where any sub-part does.27 The draft’s answer is given first in each row.

RequestIn the annotated draftIn the filed response
1”Admit.”6An admission that the FBI and the office “developed evidence and information in contemplation of a potential federal prosecution against Epstein for many federal sex offenses”, closing “Except as otherwise admitted above, the government denies Request No. 1.”4
2(a) and (c) “Cannot admit or deny”, each with an explanation; (b) “Admit.”; (d) “Deny. Notifications prior to signing the agreement were not contemplated.”; no answer to (e)68(b) “Admitted.”; (a), (c), (d) and (e) each an admission in part closing with a denial of the remainder, (d) admitting that the office “altered the language that was ultimately contained in the July 9, 2008 notification letter to Jane Doe #1”2515
5”Admit.”8An admission in part, then an objection to the balance “as violative of the deliberative process privilege”15
7”Admit; however…”; the answer ends “thus, the case was, in fact, ‘currently under investigation.’”8The admission and the explanation are kept and the conclusion is dropped22
9(a), (e)(a) “Admit.”; (e) “Deny. [Need to explain.]”89(a) an admission that the office agreed to a provision “at Epstein’s insistence”, the provision then quoted in place of the request’s word “secret”, and a denial of the remainder; (e) a partial admission: no notification to Jane Doe #2 in the stated period, and no USAO employee personally notified Jane Doe #12228
11”[I can’t certify to the date.] Admit in part and deny in part”, then an answer that Epstein’s counsel asked to have the case reviewed in Washington and the office “did not, at that time, send the proposed victim notification letter”9An admission naming the Assistant U.S. Attorney who sent a draft victim notification letter to Epstein’s counsel on or about 28 November 2007, quoting that letter, and stating that the office “never sent victims the draft notification letter”26
12”Admit.”10Admission that a binding agreement was already in place, plus a denial that Edwards worked on his letter on the stated date2623
13(a), (b)(a) “Deny as to Jane Doe #1; admit as to Jane Doe #2. Please see response to Request #10.”; (b) “Admit.” and a bracketed proposal to add a sentence about the Executive Division10(a) an admission that Jane Doe #2 had not been informed of the agreement by the time of the guilty plea and a further admission that, although the office had notified Jane Doe #1 through FBI agents, “no employee of the USAO had personally notified Jane Doe #1 at that time”, closing with a denial of the remainder — so the draft denies as to Jane Doe #1 where the filing admits in part; (b) a denial of the request as framed and two narrower admissions, the proposed sentence not appearing2324
14”Admit in part. The parties sought to keep the document confidential, not its existence, which was disclosed to the state court judge during the change of plea.”10The same admission and the same denial, without the sentence about the state court judge, the denial limited to what the parties sought “at that time”, and a denial of the remainder24
16Bracketed note only, no answer11”Admitted.”12
17Bracketed note, then “Deny."11"Admitted.”12
18Bracketed note only, no answer11”(a) Denied. (b) Denied.”12
19Bracketed note only, no answer11Objection as overly broad and burdensome, then a denial12
21”[I don’t know.]"11"Denied.”12
22”[OPR needs to answer these.]"11"(a) Admitted. (b) Admitted. (c) Admitted.”13
23”Admit.”11Admission qualified by a proviso in three alternative limbs, then a denial of the remainder13
24Bracketed note only, no answer11”Admitted; Jeffrey Epstein provided valuable consideration to the federal government through the non-prosecution agreement he entered with the USAO.”13
25”Deny?"11"Denied.”13
26”Admit.”11Objection: the request “seeks information protected from disclosure by the law enforcement investigative privilege”13

Two of those are reversals rather than refinements. At request 17 the draft denies that the government holds telephone logs or emails reflecting contacts between Reinhart and people working at the Department or the office, under a note asking whether Washington had the drafter’s own emails; the filed answer admits it.111220 At request 26 the draft admits and the filed response declines to answer on privilege.1113

Through requests 1 to 15 the draft answers every item except 2(e), which it does not reach at all, and the filed response answers all of them. The differences in that range are not only of degree and framing: at 1, 5, 9(a) and 11 the draft gives a flat answer and the filing gives a narrower one closing with a denial of the request as framed or with an objection, and at 9(e) and 13(b) the draft’s flat answer became a qualified one pointing the other way. From request 16 the draft’s coverage breaks down: of the last eleven items six carry only a note, one carries a query mark, and the filed response answers ten of the eleven. The exception is request 26, which it declines to answer on privilege.111213

Request 7 shows how the rewriting worked where the substance did survive. The draft answers “Admit; however, on or about January 10, 2008, Epstein was challenging the legitimacy of the non-prosecution agreement and the FBI and the USAO were preparing for the possibility that the non-prosecution agreement might be set aside and a federal prosecution might proceed; thus, the case was, in fact, ‘currently under investigation.’”8 The filed answer keeps the admission and the explanation and drops the conclusion. It admits that when the two women were sent letters saying “this case is currently under investigation” the office “had already signed a non-prosecution agreement with Jeffrey Epstein”, and adds only that the agreement “nonetheless remained in a state of some flux and was subject to being set aside as Epstein was challenging the propriety of the non-prosecution agreement and seeking further review from the Department of Justice.”22 The draft’s own finding that the case “was, in fact, ‘currently under investigation’” is not in the filing.22

The three officials named in the requests

Bruce E. Reinhart. Request 15 asks the government to admit that he “learned confidential, non-public information about the Epstein matter”, “discussed the Epstein matter with an attorney working on the case for the U.S. Attorney’s Office”, and “was involved in decision-making with regard to the Epstein matter”.20 Both the draft and the filed response admit the first two in part and deny the third. The filed version reads: “The government admits that, while Bruce E. Reinhart was an Assistant U.S. Attorney, he learned confidential, non-public information about the Epstein matter”; and “The government admits that, while Bruce E. Reinhart was an Assistant U.S. Attorney, he discussed the Epstein matter with another Assistant U.S. Attorney working on the Epstein matter”; then “(c) Denied.”1210

His own answer is on the record in the same case and predates the filing by two years. In a declaration executed on 3 May 2011 and filed as Document 79-1, signed in manuscript above his typed name and made “under penalty of perjury”, he stated that he served as an Assistant U.S. Attorney in the West Palm Beach office from 1 May 1996 to 1 January 2008; that he and the prosecutor assigned to the Epstein case “were assigned to different sections within the Office” and “reported to different supervisors”; that “I did not participate in any way in the Office’s investigation of Epstein. I was not involved in any of the Office’s decisionmaking with regard to the Epstein matter”; and, in terms, that “I never learned any confidential, non-public information about the Epstein matter.”293031 He further stated that after leaving he was retained to represent Sarah Kellen and later other members of Epstein’s staff in civil depositions; that “After leaving the Office, I did not participate in any of the negotiations over Mr. Epstein’s non-prosecution agreement”; and that “Because I did not have any, I did not share non-public confidential information about the Epstein investigation with any of Epstein’s attorneys.”3031

So on request 15(a) the sworn declaration and the government’s filed admission say opposite things about the same proposition, and both are in this release. The declaration also records an “exit meeting” in late December 2007 with Dexter A. Lee, described in it as “the Office’s ethics officer”, who is the same Assistant U.S. Attorney whose conformed signature appears on the response filed in July 2013.303

Matthew Menchel. Request 20 asks whether the government has knowledge or information about a personal or business relationship between Epstein and Menchel; both draft and filed answer are “Admit” and “Admitted”, with no qualification of any kind in the filing.191112 The draft’s bracketed note beside that admission attributes the drafter’s belief to a colleague and says expressly that it rests on no document.11 The note is not the admission, and the admission carries no such attribution.

The Justice Department’s Office of Professional Responsibility later examined the office’s conduct and named Menchel as one of five subject attorneys. It concluded that “Menchel, Sloman, Lourie, and Villafaña did not commit professional misconduct with respect to any aspect of the NPA because they acted under Acosta’s direction and with his approval”, and, on a separate allegation that a defence lawyer had asked Menchel to intervene over the sentence, that “there is no evidence supporting the suggestion that the plea was instigated by Menchel as a favor to defense counsel.”3233 Menchel told OPR, “I have no recollection of any discussions or decisions regarding whether the USAO should notify victims of its intention to enter into a pre-charge disposition of the Epstein matter.”34 Those findings and responses are set out at A. Marie Villafaña.

Alex Acosta. Request 21, the same question about Acosta, is the one the draft answers “[I don’t know.]” and the filed response answers “Denied.”191112 OPR’s report criticised Acosta for “poor judgment” in resolving the investigation through the agreement and in leaving the notification of victims about the state plea hearing to the state, while concluding that “Acosta’s exercise of his discretionary authority did not breach any clear and unambiguous standard” and that “none of the subject attorneys violated a clear and unambiguous standard or engaged in professional misconduct in developing, negotiating, or entering into the NPA, including its addendum.”353632

Two copies, two sets of redactions

The two copies of the draft are the same document, and the Department released them redacted differently. The difference falls on names.16

This page does not say which names, how many of them there are, or where on the sheet they stand, and it completes none of them: not from the other copy, not from the filed response, and not from the words around them. That is a desk rule and not a judgement about these particular documents. A description exact enough to locate a bar is a description exact enough to lift it, and in a release that holds the same document twice the other copy is never far away. What the page reports is the inconsistency itself, which is a fact about the release rather than about anybody named in it.

The same inconsistency runs through the filed response, and there it runs in both directions. The release holds two complete copies of the identical twelve-page filing, and their signature pages are not redacted alike: each covers something the other prints, and what is covered on either is counsel’s professional contact detail or part of counsel’s own name, on a document counsel put on a public docket.337 This page reproduces none of it and does not say which copy covers what.

The extraction shows none of this. In the machine text a covered name is simply absent or replaced by stray characters, so a reader working from the text layer alone would see a shorter note rather than a redacted one, and could take the difference for a difference between drafts. It is not: read at the image, the two copies carry the same twelve bracketed notes at the same twelve requests, and what separates them is redaction.16 The general problem is set out at Document Redaction Integrity in the Epstein Evidence.

What the release holds, and in what form

The desk’s question was whether the release contains the government’s answers in any form but draft. It does.

A search of the released corpus for the exact caption on the draft, “RESPONDENT’S ANSWERS TO PETITIONERS”, returns two pages in two runs: EFTA00205324 and EFTA00205393, the two annotated copies. Searching instead for the caption the filed document carries, “PETITIONERS’ FIRST REQUEST FOR ADMISSIONS TO THE GOVERNMENT”, returns thirteen pages across ten runs, and searching for the docket stamp “Document 213-1 Entered on FLSD Docket” returns all twelve pages of each of two complete copies of the filing, EFTA01081186 and EFTA02754352.38 Three further runs carry the two-page covering notice, Document 213.38 So the filed answer is in the release twice over, complete and docket-stamped, and one of those copies is already cited on this wiki at Doe v. United States (CVRA litigation).

What the release adds, and the docket does not have, is the draft.

Footnotes

  1. “Jane Doe #1 and Jane Doe #2’s First Request for Admissions to the Government Regarding Questions Relevant to Their Pending Action Concerning the Crime Victims Rights Act,” Jane Doe #1 and Jane Doe #2 v. United States, No. 08-80736-Civ-Marra/Johnson (S.D. Fla.), its own p. 1 of 8, read at the image at 300 dpi: the caption, and “COME NOW Jane Doe #1 and Jane Doe #2 (‘the victims’), by and through undersigned counsel, and request the defendant United States (hereinafter ‘the Government’) to admit or deny the following facts”. The Background section on this page records the victims’ earlier Motion for Finding of Violations of the Crime Victims’ Rights Act (DE 48) and Motion to Have Their Facts Accepted (DE 49), and that on 26 September 2011 the court denied the second while ordering discovery (DE 99 at 11). https://epstein-data.com/EFTA01657803 p. 1. ↩ ↩2 ↩3 ↩4

  2. Same request, its own p. 8 of 8, read at the image at 300 dpi: “DATED: December 1, 2011”, a conformed “s/ Bradley J. Edwards” over the Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. block with Paul G. Cassell pro hac vice below, and a certificate of service reading “The foregoing document was served on December 1, 2011, on the following persons via US Mail and electronic mail to:”. Professional contact lines and part of a name are covered on this page; nothing under a bar is supplied here. https://epstein-data.com/EFTA01657803 p. 8. ↩ ↩2 ↩3 ↩4

  3. Same response, its own p. 11 of 12, read at the image at 400 dpi: “Respectfully submitted, WIFREDO A. FERRER / UNITED STATES ATTORNEY”, a conformed “/s Dexter A. Lee” over “Dexter A. Lee / Assistant United States Attorney”, then “A. Marie Villafaña / Assistant United States Attorney” and “Eduardo I. Sánchez / Assistant United States Attorney”, closing “Attorneys for United States”; and a certificate of service stating that the response “was served via CM/ECF on this 19th day of July, 2013, on the parties and counsel appearing on the attached service list”, over a second conformed “/s Dexter A. Lee”. The three names print in full on this copy; the professional contact details on it are covered and are not reproduced here. The text layer of this page garbles the conformed signature as “A Dexter A. Lee / Dexter A. Lee mr” and the surname as “Villafafia”. https://epstein-data.com/EFTA01081186 p. 11. ↩ ↩2 ↩3 ↩4

  4. “United States’ Response to Petitioners’ First Request for Admissions to the Government,” Document 213-1, entered on the FLSD docket 19 July 2013, its own p. 1 of 12, read at the image at 400 dpi: the caption “Case No. 08-80736-CIV-Marra/Matthewman”; answer 1 in full, “The government admits that the FBI and the U.S. Attorney’s Office for the Southern District of Florida (‘USAO’) conducted an investigation into Jeffrey Epstein (‘Epstein’) and developed evidence and information in contemplation of a potential federal prosecution against Epstein for many federal sex offenses. Except as otherwise admitted above, the government denies Request No. 1.”; and the scope paragraph, “The government’s response is confined to Request No. 1 through Request No. 26 in the ‘Discovery Requested’ section of the Request for Admissions and does not intend to respond to assertions in any other section of the Request for Admissions (including the ‘Background’ section), none of which appear to separately state any matter calling for an admission. Nonetheless, the government denies the assertion that the government has declined the request of Jane Doe #1 and Jane Doe #2 to stipulate to undisputed facts in this case.” The image prints the numeral “1” in “Request No. 1”; the extraction of this page renders it as a capital “I”, as it does the numeral in answer 1. https://epstein-data.com/EFTA01081186 p. 1. ↩ ↩2 ↩3 ↩4

  5. “Respondent’s Notice of Filing Response to Petitioners’ First Request for Admissions to the Government,” Document 213, entered on the FLSD docket 19 July 2013, its own p. 1 of 2, read at the image at 400 dpi: “Respondent United States files its Response to Petitioners’ First Request for Admissions to the Government.”; “DATED: July 19, 2013”; and a conformed “s/ Dexter A. Lee” beneath “WILFREDO A. FERRER / UNITED STATES ATTORNEY”. The U.S. Attorney’s forename is spelled “WILFREDO” on this notice and “WIFREDO” on the response it files. Counsel’s bar number, address, telephone, facsimile and email lines are on the page and are not reproduced. https://epstein-data.com/EFTA01134856 p. 1. ↩ ↩2

  6. “RESPONDENT’S ANSWERS TO PETITIONERS’ FIRST REQUESTS FOR ADMISSIONS,” undated and unsigned, its own p. 1 of 5, read at the image at 400 dpi. The caption reads “UNITED STATES DISTRICT COURT / SOUTHERN DISTRICT OF FLORIDA / Case No. 08-80736-Misc-Marra/Matthewman” — “Misc” where the victims’ request and the filed response both read “Civ”; the text layer renders it “08-80736-Mise-Marra/MatthrA mari”. The page carries answers 1 and 2(a)–(b) and a footnote, keyed by a superscript numeral after “Jane Doe #2”, reading “This attorney was being compensated by Epstein to represent Jane Doe #2.” The text layer fuses that marker into the preceding text as “Jane Doe #21”. Answer 1 reads, in full, “1. Admit.” The page ends at “(b) Admit.” https://epstein-data.com/EFTA00205324 p. 1. ↩ ↩2 ↩3 ↩4 ↩5 ↩6

  7. The second copy of the same draft, its own p. 1 of 5, read at the image at 400 dpi, and both first pages read again at 600 dpi. The caption, heading, footnote and answers 1 and 2(a)–(b) are identical to the first copy. Each of the two first pages carries a solid black block in the caption, standing where the “v.” sits between the two party blocks, with the full stop beside it still printed. Measured at 600 dpi the block is 50 pixels wide and 112 deep — about one character wide and about a text line deep — and it is identical on both copies, so it forms no part of the differential this page reports. https://epstein-data.com/EFTA00205393 p. 1. ↩ ↩2

  8. Same draft, its own p. 2 of 5, read at the image at 400 dpi: answers 2(c)–(d) and 3 to 9(c), including “6. (a) Deny. [These all need to be confirmed.]”, “(e) Admit to the extent this is meant to refer to Lilly Ann Sanchez.” and answer 7, “Admit; however, on or about January 10, 2008, Epstein was challenging the legitimacy of the non-prosecution agreement and the FBI and the USAO were preparing for the possibility that the non-prosecution agreement might be set aside and a federal prosecution might proceed; thus, the case was, in fact, ‘currently under investigation.’” The text layer renders sub-part (f) as “(0 Admit”; the image prints “(f) Admit.” The page opens at “(c) Cannot admit or deny.” and, after “(d) Deny. Notifications prior to signing the agreement were not contemplated.”, runs straight on to “3. Deny.”: there is no answer 2(e) on it, and none anywhere else in the document. It also carries “4. Deny.”, “5. Admit.” and “9. (a) Admit.” https://epstein-data.com/EFTA00205324 p. 2. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10 ↩11 ↩12

  9. Same draft, its own p. 3 of 5, read at the image at 400 dpi: answers 9(d)–(e), 10(a)–(g) and 11, including “(e) Deny. [Need to explain.]” and answer 11 in full: “11. [I can’t certify to the date.] Admit in part and deny in part. The Respondent admits that, following that correspondence, Epstein’s counsel asked to have the case reviewed by attorneys at the Justice Department in Washington, D.C., and, accordingly, the U.S. Attorney’s Office did not, at that time, send the proposed victim notification letter because it was unclear whether the Non-Prosecution Agreement would, in fact, go into effect.” The text layer renders the item number as “II.”; the image prints “11.” https://epstein-data.com/EFTA00205324 p. 3. ↩ ↩2 ↩3 ↩4 ↩5

  10. Same draft, its own p. 4 of 5, read at the image at 400 dpi: answers 12 to 15, including “13. (a) Deny as to Jane Doe #1; admit as to Jane Doe #2. Please see response to Request #10.” and the bracketed proposal at 13(b) quoted in the text; “14. Admit in part. The parties sought to keep the document confidential, not its existence, which was disclosed to the state court judge during the change of plea.”; and “15. (a) Admit in part. While he was an Assistant U.S. Attorney, Bruce E. Reinhart learned confidential, non-public information about the Epstein matter. (b) Admit in part. While he was an Assistant U.S. Attorney, Bruce E. Reinhart discussed the Epstein matter with another Assistant U.S. Attorney working on the Epstein matter. (c) Deny.” The name at both places is supplied from this page. https://epstein-data.com/EFTA00205324 p. 4. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8

  11. Same draft, its own p. 5 of 5, read at the image at 400 dpi: answers 16 to 26. Eight of the eleven items on this page carry square brackets — 16, 17, 18, 19, 20, 21, 22 and 24 — and every bracketed passage quoted in the text is quoted from this page. The image prints “Bear Stearns”; the corpus text layer reads “Bear Steams”, so a search on the correct spelling returns nothing for this page. Requests 23 and 26 read “Admit.” and request 25 “Deny?”, the question mark being the draft’s own. https://epstein-data.com/EFTA00205324 p. 5. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10 ↩11 ↩12 ↩13 ↩14 ↩15 ↩16 ↩17 ↩18 ↩19 ↩20 ↩21 ↩22 ↩23 ↩24 ↩25 ↩26 ↩27 ↩28 ↩29 ↩30 ↩31 ↩32 ↩33 ↩34

  12. Same response, its own p. 9 of 12, read at the image at 400 dpi: answers 15(a)–(c), 16 (“Admitted.”), 17 (“Admitted.”), 18(a)–(b) (“Denied.” twice), 19 in full, 20 (“Admitted.”) and 21 (“Denied.”). The name in answers 15(a) and 15(b) is supplied from this page. https://epstein-data.com/EFTA01081186 p. 9. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10 ↩11 ↩12 ↩13 ↩14 ↩15 ↩16

  13. Same response, its own p. 10 of 12, read at the image at 400 dpi: answers 22(a)–(c) (“Admitted.” three times), 23, 24 (“Admitted; Jeffrey Epstein provided valuable consideration to the federal government through the non-prosecution agreement he entered with the USAO.”), 25 (“Denied.”) and 26 (“The government objects to Request No. 26 because it seeks information protected from disclosure by the law enforcement investigative privilege.”). https://epstein-data.com/EFTA01081186 p. 10. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10 ↩11 ↩12 ↩13 ↩14 ↩15

  14. Second copy, its own p. 2 of 5, read at the image at 400 dpi. Like p. 2 of the first copy it opens at “(c) Cannot admit or deny.”, gives “(d) Deny. Notifications prior to signing the agreement were not contemplated.” and then runs straight on to “3. Deny.”, with no answer 2(e). https://epstein-data.com/EFTA00205393 p. 2. ↩ ↩2

  15. Same response, its own p. 3 of 12, read at the image at 400 dpi: answer 2(e), then “3. Denied.”, “4. Denied.” and answer 5. Answer 2(e) admits that “at least in part as a result of objections lodged by Epstein’s lawyers to victim notifications, the USAO reevaluated its obligations to provide notifications to victims, and Jane Doe #1 was thus not told that the USAO had entered into a non-prosecution agreement with Epstein until after the agreement was signed”, and that “Jane Doe #2 was not told that the USAO had entered into a non-prosecution agreement with Epstein until after the agreement was signed, but denies that the USAO did not inform Jane Doe #2 as a result of any negotiations involving Epstein or any objections lodged by Epstein’s lawyers”, closing “Except as otherwise admitted above, the government denies Request No. 2(e).” Answer 5 admits that “during the negotiations with Jeffrey Epstein regarding the non-prosecution agreement, at least one experienced attorney within the USAO subscribed to the position that the CVRA required notifications to the victims in this case and that position was communicated to Epstein’s counsel”, and then objects, so far as the request reaches positions “not communicated to non-government personnel”, “to Request No. 5 as violative of the deliberative process privilege”. https://epstein-data.com/EFTA01081186 p. 3. ↩ ↩2 ↩3 ↩4

  16. Second copy, read at the image at 400 dpi, every sheet of it. Its text is the first copy’s text: the same twelve bracketed items stand at the same twelve requests. What differs is redaction, and the redaction falls on names. Nothing under a bar is reproduced here, and neither the number of the bars, nor their place on any sheet, nor the words they stand beside is given. One consequence is worth recording so that a later reader does not take it for a difference of text: the extraction of this copy shows fewer matched pairs of square brackets than the extraction of the other, and that is an artefact of the redaction. https://epstein-data.com/EFTA00205393 pp. 1–5. ↩ ↩2 ↩3 ↩4

  17. Same request, its own p. 2 of 8, read at the image at 300 dpi: the sentence carried over from the previous page, “The Court allowed the victims to propound requests for admission to the Government.”; the “DISCOVERY REQUESTED” heading and the instruction that “Where the request for admission has separate, lettered sub-parts, please admit or deny each separate sub-part”; and requests 1 to 4, including “The FBI and the U.S. Attorney’s Office for the Southern District of Florida’s investigation into Jeffrey Epstein developed a case for a federal prosecution against Epstein for many federal sex offenses.” https://epstein-data.com/EFTA01657803 p. 2. ↩ ↩2 ↩3

  18. Same request, its own p. 3 of 8, read at the image at 400 dpi: request 5, quoted at Doe v. United States; request 6 and its seven lettered sub-parts, quoted in the text; and requests 7 to 9. The text layer renders sub-part (f) as “(0 Jay Leflcowitz”; the image prints “(f) Jay Lefkowitz”. https://epstein-data.com/EFTA01657803 p. 3. ↩ ↩2 ↩3

  19. Same request, its own p. 6 of 8, read at the image at 400 dpi: requests 20 (Matthew Menchel) and 21 (Alex Acosta), both names in bold on the page; request 22 and its three sub-parts; and requests 23 to 26, including “The Government possesses evidence, not covered by grand jury secrecy rules, that reveals that districts outside the Southern District of Florida share jurisdiction and venue with the Southern District of Florida over potential federal criminal charges”. https://epstein-data.com/EFTA01657803 p. 6. ↩ ↩2 ↩3 ↩4 ↩5 ↩6

  20. Same request, its own p. 5 of 8, read at the image at 400 dpi: requests 13(b)–(d), 14, and request 15, “Defense attorney Bruce E. Reinhart:”, with three sub-parts set out below it on the page: “learned confidential, non-public information about the Epstein matter;”, “discussed the Epstein matter with an attorney working on the case for the U.S. Attorney’s Office; and”, “was involved in decision-making with regard to the Epstein matter.” The lettering sits in a left-hand column on the image, and the extraction of this page runs the three letters together before the three clauses, so the request reads as a continuous string only at the image; request 16, naming “Jeffrey Epstein, the Florida Science Foundation, Jack Goldberger, Harvard Law Professor Alan Dershowitz, Roy Black, Ken Starr, Lily Ann Sanchez”; request 17; request 18 and its two sub-parts “(a) Guy Lewis (b) LilyAnn Sanchez”; and request 19. https://epstein-data.com/EFTA01657803 p. 5. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7

  21. Read at the image at 300 dpi. The draft’s five pages run from the page stamp EFTA00205324 to the page stamp EFTA00205328 on the first copy, and from the page stamp EFTA00205393 to the page stamp EFTA00205397 on the second. The identifier immediately following each is an eight-page copy of “JANE DOE #1 AND JANE DOE #2’S FIRST REQUEST FOR ADMISSIONS TO THE GOVERNMENT…”, captioned “Case No. 08-80736-Civ-Marra/Johnson”: p. 1 of each is the request’s caption page. https://epstein-data.com/EFTA00205329 p. 1; https://epstein-data.com/EFTA00205398 p. 1. ↩

  22. Same response, its own p. 4 of 12, read at the image at 400 dpi: answers 6(a)–(g), 7, 8 and 9(a), including “(e) Admitted to the extent that the reference to ‘Lillian Sanchez’ was meant to refer to Lilly Ann Sanchez.”, answer 7 in full, and answer 9(a), which admits that “at Epstein’s insistence, the USAO agreed to a provision in the non-prosecution agreement that provided as follows: ‘The parties anticipate that this agreement will not be made part of any public record. If the United States receives a Freedom of Information Act request or any compulsory process commanding the disclosure of the agreement, it will provide notice to Epstein before making that disclosure.’”, closing “Except as otherwise admitted above, the government denies Request No. 9(a).” The request as served asks the government to admit a provision “that made the agreement secret”; the filed answer does not use that word. https://epstein-data.com/EFTA01081186 p. 4. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8

  23. Same response, its own p. 7 of 12, read at the image at 400 dpi: the conclusion of answer 12, including the denial “that Edwards worked on that letter on July 3, 2008”; answer 13(a), which admits that “when Epstein pled guilty to state charges on June 30, 2008, Jane Doe #2 had not been informed by the USAO of the existence of the non-prosecution agreement” and further admits that, although the USAO had notified Jane Doe #1 through FBI agents before that plea, “no employee of the USAO had personally notified Jane Doe #1 at that time of the existence of the non-prosecution agreement”, closing “Except as otherwise admitted above, the government denies Request No. 13(a).”; and the opening of answer 13(b), “The government denies that, by the time of Epstein’s June 30, 2008 guilty plea, an attorney for the government working at the USAO had not already conferred with Jane Doe #1 and Jane Doe #2 about their opinions regarding how the federal investigation and potential prosecution of Epstein should proceed.” No sentence about the Executive Division appears on this page. https://epstein-data.com/EFTA01081186 p. 7. ↩ ↩2 ↩3

  24. Same response, its own p. 8 of 12, read at the image at 300 dpi: the conclusion of answer 13(b) — “Except as otherwise admitted above, the government denies Request No. 13(b).” — and answers 13(c), 13(d) and 14. Answer 14 admits that “when Epstein was pleading guilty to the state charges discussed in the non-prosecution agreement, the USAO and Epstein’s defense attorneys sought to keep the document memorializing the non-prosecution agreement confidential, but denies that they sought at that time to keep the existence of the non-prosecution agreement confidential”, closing “Except as otherwise admitted above, the government denies Request No. 14.”; it carries no sentence about the state court judge or the change of plea. No sentence about the Executive Division appears on this page either, so the draft’s bracketed proposal is absent from both pages on which answer 13(b) falls. https://epstein-data.com/EFTA01081186 pp. 7–8. ↩ ↩2 ↩3

  25. Same response, its own p. 2 of 12, read at the image at 300 dpi: answers 2(a)–(d). Three of the four are built on the same frame, opening “The government admits that” and closing “Except as otherwise admitted above, the government denies Request No. 2(a)”, “2(c)” or “2(d)” respectively; 2(b) is the single word “Admitted.” The frame as described here is a composite of those closings and is not a continuous quotation from any one of them. Answer 2(d) admits that “after the USAO received objections to victim notifications from Epstein’s counsel and reevaluated its victim notification obligations, the USAO altered the language that was ultimately contained in the July 9, 2008 notification letter to Jane Doe #1 in care of Bradley Edwards.” The page ends there; answer 2(e) begins the next page. https://epstein-data.com/EFTA01081186 p. 2. ↩ ↩2

  26. Same response, its own p. 6 of 12, read at the image at 300 dpi: answers 10(c)–(g), 11 and the opening of 12. Answer 11 admits that “on or about November 28, 2007, A. Marie Villafaña of the USAO sent a draft of a crime victim notification letter to Jay Lefkowitz, counsel for Jeffrey Epstein”, and that the office “never sent victims the draft notification letter”. The image prints the surname with its tilde; the extraction of this page renders it “Villafafia”. https://epstein-data.com/EFTA01081186 p. 6. ↩ ↩2 ↩3

  27. How this figure was derived. All twenty-six requests were compared answer by answer at the image, the draft on https://epstein-data.com/EFTA00205324 pp. 1–5 with https://epstein-data.com/EFTA00205393 pp. 1–5 read beside it, against the filed response on https://epstein-data.com/EFTA01081186 pp. 1–10, every page rendered at 400 dpi. A request is counted as differing where the two documents give different answers to it: one admits and the other denies or objects; one answers and the other does not; or one adds, drops or alters a qualification, an exception or a factual assertion inside the answer. A request is counted once, however many of its sub-parts differ. Two things are not counted. A change of verb form alone is not: the draft writes “Admit.” and “Deny.” where the filing writes “Admitted.” and “Denied.” throughout. Neither is the same admission and the same denial restated in other words. On that rule nineteen requests differ — 1, 2, 5, 7, 9, 11, 12, 13, 14, 16, 17, 18, 19, 21, 22, 23, 24, 25 and 26 — and seven do not. Of the seven: 3, 4, 8 and 20 are a bare denial or a bare admission in both documents; at 15 the two answers admit and deny the same three propositions in the same terms; at 10 the answers to every sub-part are the same, the filing adding to 10(a) a sentence that construes the request as directed solely to the communications between FBI agents and Jane Doe #1 at their meeting of 26 October 2007 and states that its responses to 10(b) through 10(g) “address only that meeting” — a frame on the request, not a different answer to any sub-part; and at 6 the only variation is one of wording, the draft’s “(e) Admit to the extent this is meant to refer to Lilly Ann Sanchez.” against the filing’s “(e) Admitted to the extent that the reference to ‘Lillian Sanchez’ was meant to refer to Lilly Ann Sanchez.” ↩

  28. Same response, its own p. 5 of 12, read at the image at 300 dpi: answers 9(b)–(e) and 10(a)–(b), including the partial admission at 9(e) that “during the period from September 24, 2007 through June 2008, the USAO did not notify Jane Doe #2 of the existence of the non-prosecution agreement” and that although FBI agents notified Jane Doe #1 on or about 27 October 2007 at the office’s request, “no employee of the USAO personally notified Jane Doe #1 of the existence of the non-prosecution agreement during the period from September 24, 2007 through June 2008.” https://epstein-data.com/EFTA01081186 p. 5. ↩

  29. “Declaration of Bruce E. Reinhart,” Exhibit 1 to Document 79-1, entered on the FLSD docket 3 May 2011, its own p. 1 of 4, read at the image at 400 dpi: “I, Bruce E. Reinhart, make the following declaration pursuant to 28 U.S.C. § 1746,” and paragraphs 1 to 5, giving his bar admissions and his service in the Criminal Division’s Public Integrity Section from 1988 to 1994. His office address is on the page and is not reproduced. https://epstein-data.com/EFTA01098305 p. 13. ↩

  30. Same declaration, its own p. 3 of 4, read at the image at 400 dpi, paragraphs 10 to 15: “The prosecutor assigned to the Epstein case, Ann Marie Villafana, and I were assigned to different sections within the Office. We reported to different supervisors.”; “I did not participate in any way in the Office’s investigation of Epstein. I was not involved in any of the Office’s decisionmaking with regard to the Epstein matter.”; “I never learned any confidential, non-public information about the Epstein matter.”; “In late December 2007, I had an ‘exit meeting’ with Dexter Lee, the Office’s ethics officer.”; “After opening my private practice on January 2, 2008, I was retained to represent Sarah Kellen for purposes of civil depositions in causes of action to which the United States was not a party. At a later time, I was retained to represent several other members of Mr. Epstein’s staff in their civil depositions.”; “After leaving the Office, I did not participate in any of the negotiations over Mr. Epstein’s non-prosecution agreement.” Paragraph 9, on the declaration’s own p. 2 of 4 and read at the image at 300 dpi, gives his service: “From May 1, 1996 to January 1, 2008, I served as an Assistant United States Attorney in the Southern District of Florida, assigned to the West Palm Beach office.” https://epstein-data.com/EFTA01098305 pp. 14–15. ↩ ↩2 ↩3

  31. Same declaration, its own p. 4 of 4, read at the image at 400 dpi, paragraphs 16 to 18 and the attestation: “Because I did not have any, I did not share non-public confidential information about the Epstein investigation with any of Epstein’s attorneys.”; “I declare under penalty of perjury that the foregoing is true and correct.”; “Executed on May 3, 2011.” A manuscript signature stands above the typed name “Bruce E. Reinhart”. https://epstein-data.com/EFTA01098305 p. 16. ↩ ↩2

  32. Same report, narrative pp. 134–135, both read at the image at 400 dpi. Page 134 carries “Menchel, Sloman, Lourie, and Villafaña did not commit professional misconduct with respect to any aspect of the NPA because they acted under Acosta’s direction and with his approval”, and, below the heading of section III, “Acosta’s exercise of his discretionary authority did not breach any clear and unambiguous standard.” The section conclusion is a single sentence broken across the two pages: p. 134 ends “As a result, OPR concludes that none of the subject attorneys violated a clear and” and p. 135 opens “unambiguous standard or engaged in professional misconduct in developing, negotiating, or entering into the NPA, including its addendum.” The heading of section III is worded differently — it reads “OPR FOUND THAT NONE OF THE SUBJECTS VIOLATED A CLEAR AND UNAMBIGUOUS STATUTE, PROFESSIONAL RESPONSIBILITY RULE OR STANDARD, OR DEPARTMENT REGULATION OR POLICY, IN NEGOTIATING, APPROVING, OR ENTERING INTO THE NPA”, of “the subjects” and not of “the subject attorneys” — and neither form is quoted above in the other’s words. Because the sentence spans a page break, a full-text search for it as one string returns nothing. https://epstein-data.com/EFTA02830776 pp. 160–161. ↩ ↩2

  33. Same report, narrative p. 154: “there is no evidence supporting the suggestion that the plea was instigated by Menchel as a favor to defense counsel.” https://epstein-data.com/EFTA02830776 p. 180. ↩

  34. Same report, narrative p. 204: Menchel’s written response to OPR, “I have no recollection of any discussions or decisions regarding whether the USAO should notify victims of its intention to enter into a pre-charge disposition of the Epstein matter.” https://epstein-data.com/EFTA02830776 p. 230. ↩

  35. Office of Professional Responsibility, Investigation into the U.S. Attorney’s Office for the Southern District of Florida’s Resolution of Its 2006–2008 Federal Criminal Investigation of Jeffrey Epstein, Executive Summary p. x. https://epstein-data.com/EFTA02830776 p. 12. ↩

  36. Same report, Executive Summary p. xi. https://epstein-data.com/EFTA02830776 p. 13. ↩

  37. A second complete copy of the same filing, its own p. 11 of 12, read at the image at 400 dpi. It carries the same docket stamp, “Document 213-1 Entered on FLSD Docket 07/19/2013 Page 11 of 12”, and the same three signature blocks, but it is not redacted as the first copy is: each of the two covers something the other carries, and what is covered on either is counsel’s professional contact detail or part of counsel’s own name. No value from either copy is reproduced on this page, and neither what is covered on which copy nor where it stands is given here. https://epstein-data.com/EFTA02754352 p. 11. ↩

  38. The searches behind this section were run against the full-text index of the released corpus, column-scoped to the page text. "RESPONDENT'S ANSWERS TO PETITIONERS" returns 2 pages in 2 runs, both p. 1 of the annotated draft; "ANSWERS TO PETITIONERS" returns the same 2. "PETITIONERS' FIRST REQUEST FOR ADMISSIONS TO THE GOVERNMENT" returns 13 pages across 10 runs. "Document 213-1 Entered on FLSD Docket" returns 24 pages: all 12 pages of https://epstein-data.com/EFTA01081186 and all 12 of https://epstein-data.com/EFTA02754352. Three runs carry the two-page Document 213 notice: https://epstein-data.com/EFTA01134856, https://epstein-data.com/EFTA02725951 and https://epstein-data.com/EFTA02754364. Probes for four distinctive strings unique to the draft — “These all need to be confirmed”, “OPR needs to answer these”, “Notifications prior to signing the agreement” and “Deny as to Jane Doe #1” — each return only the two draft copies, two pages each time. These are counts of what the extraction holds; a third copy whose text layer is damaged would not appear in them. ↩ ↩2

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