3
Shared Docs
3
Same-Page
3 / 5
Mentions
patently illogical — and all the more so in light of Epstein's admission in his lawsuit against M. and others that he that he was "one of M's many `Johns.— See Complaint Epstein v. Rothstein, Edwards & M s, No. 50 2009 CA0 40800 (Cir. Ct., 15th Jud. Cir., Palm Beach Co.. Dec. 7, 2009) at 146(a), pert
ed on April 13.2010 ("Si Opp.").8 she repeatedly argues that in fact she has more than enough evidence against him to survive the motion. See. egs, SJ Opp. at 12 ("far from supporting summary judgment for the defendant, the evidence overwhelmingly inclines in favor") (see other examples Carroll Reply
tled his case; finding that "the probative value of this testimony is ex- tremely high because of its similarity with the allegations in this case"); SJ Opp. at 10-11 (- Statement of Material Fact (-SOMF") 1 19), citing F.R.E. 415 and passages of Epstein's and her own depositions in support of statement
patently illogical — and all the more so in light of Epstein's admission in his lawsuit against M. and others that he that he was "one of M's many 'Johns.'" See Complaint Epstein v. Rothstein, Edwards & M s, No. 50 2009 CA0 40800 (Cir. Ct., 15th Jut Cir., Palm Beach Co., Dec. 7, 2009) at 146(a), pert
d on April 13, 2010 ("Si Opp.").8 she repeatedly argues that in fact she has more than enough evidence against him to survive the motion. See. egs, SJ Opp. at 12 ("far from supporting summary judgment for the defendant, the evidence overwhelmingly inclines in Jane Doe's favor") (see other examples Carr
tled his case; finding that "the probative value of this testimony is ex- tremely high because of its similarity with the allegations in this case"); SJ Opp. at 10-11 (Doe's Statement of Material Fact (-SOMF") 1 19), citing F.R.E. 415 and passages of Epstein's and her own depositions in support of state
'Psalms" that she obtained from a religious store (DT 152:1-14). Under the circumstances, her claim for damages against EPSTEIN, one of ■.'s many "Johns" during that same period, would be so incredible and certainly not likely to produce the extraordinary settlements promised to "RRA'S investors."
for Admission as "[y]ou have committed sexual assault against Plaintiff, a minor," and "[y]ou digitally penetrated Plaintiff when she was a minor," SJ Opp. at 4, and his refusal to answer numerous questions at a Mar. 8, 2010, deposition, id. at 10 & Ex. D. 8. Annexed hereto as Exhibit E is a copy of
Entities connected to both Johns and SJ Opp

Jeffrey Epstein
PERSON
George W. Bush
PERSONJane Doe
PERSON
Bradley Edwards
PERSONthe Southern District
LOCATION
Julie K. Brown
PERSON
Alberto Gonzales
PERSON
Department of Justice
ORGANIZATION
Marc Rich
PERSONScott Rothstein
PERSON
Bill Richardson
PERSON
Palm Beach County
LOCATION
Michael Fisten
PERSONBerger
PERSON
Southern District of New York
ORGANIZATIONAdler, P.A.
ORGANIZATION
Kenneth Marra
PERSON
Burke
PERSONthe Civil Actions'
ORGANIZATION
Medina
PERSON