EFTA00010507.pdf

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Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 1 of 33
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 08-80736-CIV-MARRA
JANE DOE 1 AND JANE DOE 2,
Petitioners,
vs.
UNITED STATES,
Respondent.
OPINION AND ORDER
This cause is before the Court upon Jane Doe 1 and Jane Doe 2's Motion for Partial
Summary Judgment (DE 361); the United States's Cross-Motion for Summary Judgment (DE
408); Jane Doe 1 and Jane Doe 2's Motion to Compel Answers (DE 348) and Jane Doe 1 and
Jane Doe 2's Motion for Finding Waiver of Work Product and Similar Protections by
Government and for Production of Documents (DE 414). The Motions are fully briefed and ripe
for review. The Court has carefully considered the Motions and is otherwise fully advised in the
premises.
I. Background
The facts, as culled from affidavits, exhibits, depositions, answers to interrogatories and
reasonably inferred, for the purpose of these motions, are as follows:
From between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor
girls, including Petitioners Jane Doe 1 and Jane Doe 2 (hereinafter, "Petitioners"), at his mansion
in Palm Beach, Florida, and elsewhere in the United States and overseas. (Government Resp. to
Petitioner's Statement of Undisputed Material Facts (hereinafter, "DE 407" at 1 1.) Because
EFTA00010507

Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 2 of 33
Epstein and his co-conspirators knowingly traveled in interstate and international commerce to
sexually abuse Jane Doe 1, Jane Doe 2 and others, they committed violations of not only Florida
law, but also federal law. (DE 407 at ¶ 2.) In addition to his own sexual abuse of the victims,
Epstein directed other persons to abuse the girls sexually. (DE 407 at ¶ 3.) Epstein used paid
employees to find and bring minor girls to him. Epstein worked in concert with others to obtain
minors not only for his own sexual gratification, bu…

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