RE: A question regarding a very old case

Hi - I saw that you were the AUSA who worked on a case several years ago against Jeffrey Epstein involving the lease of a former embassy. Do you remember anything about the case that you might be willing to share?

Attached is a copy of the complaint, summary judgment brief and court's decisions. Please let me know if you need any further info. Good luck!

Thank you so much. Were you able to determine if you ever deposed my subject?

I have a very vague memory of deposing him. Do you want me to put you in touch with someone in the USAO to see if they can order the file?

If it isn't too much trouble. Let me just review the protective order that you sent to me to make sure I don't get us into trouble by looking at those items for possible use in my case.

Discussion context: confusion between court file vs USAO file; court file lacks a copy of the Epstein deposition. Action offer: retrieve USAO file if needed; timing unclear.

Thank you so much!

Unfortunately my Clerk's office misunderstood my request and retrieved the court file and just spent several hours copying it, rather than retrieving the USAO file. So if there are any documents in the court file that you need, I probably have those. The court file does not have a copy of the Epstein deposition. If you want me to have our Clerk's office retrieve our USAO file, I can do so but I do not know how long it will take. Please let me know.

Hi - Can you ask your office to retrieve the file? It would be most appreciated. Thank you!

Yes I will. I assume you have worked out the issues related to the protective order.

My review of the order is that, if a deposition even exists, I can review it, but I can't use it in connection with any other litigation. Do you agree?

Right. The docket entry for the protective order states, "The Government may not use confidential information produced in discovery pursuant to the protective order for any purpose other than prosecuting this lawsuit, absent further order of the Court."

I'm sorry to report that we retrieved the closed files in this case and were not able to locate the Epstein deposition.

Thanks for looking.

Thank you both very much. Have a great weekend.

Assistant U.S. Attorney
500 S. Australian Ave, Suite 400
West Palm Beach. FL 33401
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