Epstein Secrets

y scheduled for November I 0, 2009. 4. The parties have reached an agreement related to Jane Doe's Independent Medical Examination subject to the State Court Order attached hereto as Exhibit A. 5. Therefore, Plaintiff, Jane Doe's, Motion for Order Permitting Legal Counsel to Attend Independent Medical E

80119, 08-80232, 08-80380, 08-80381, 08-80993, 08-80994 Richard Horace Willits, Esq. Richard H. Willits, P.A. 2290 10th Avenue North Suite 404 Lake Worth, FL 33461 561-582-7600 Fax: 561-588-8819 Counsel for Plaintiff in Related Case No. 08-80811 [email protected] Jack Scarola, Esq. Jack P. Hil

has not heard back from either of the attorneys. Additionally, the undersigned discussed the foregoing with counsel for Jane Doe this morning at a State Court hearing in Palm Beach County, Florida. Rule 7.1 Certification I hereby certify that counsel for the respective parties communicated by letters (e

manner specified by CM/ECF on this ~ay of ..Mfil:.., 2009 Richard Horace Willits, Esq. Richard H. Willits, P.A. 2290 10th Avenue North Suite 404 Lake Worth, FL 33461 561-582-7600 Fax: 561-588-8819 Counsel for Plaintiff C.M.A. [email protected] Jack Scarola, Esq. Jack P. Hill, Esq. Searcy Denney

CCONV? Goon, FLOOOM 33133 4 cot 40 EFTA00234071 • • Case 9:08-cv-80811-WJZ Document 1 Entered on FLSD Docket 07/21/2008 Page 5 of 40 5. The State Court docket has been filed. All papers filed in the State Court are attached to this Removal Petition. Conclusion Because this is a civil action betwee

Entered on FLSD Docket 07)21/2008 Page 7 of 40 Service List Richard H. Willits, Esq. Richard H. Willits, P.A. 2290 10th Avenue North, Suite 404 Lake Worth, Florida 33461 Fax: 561-588-8819 Counsel for Plaintiff C.M.A. 7 Lewis 3059 Gra* AMU, Sun 340, CoCCauT GA0vE, RONDA33133 7 cot 40 EFTA00234074

papers have been filed. In accordance with 28 U.S.C. § 1446(d), defendants have served this Notice of Removal on July 18, 2008. All papers filed in State Court are attached to this Removal Petition. 3. There is unanimity among the defendants. In accordance with 28 U.S.C. § 1446(b) the undersigned are auth

ii which was also previously seen on the property when there was physical surveillance being done at the property. The vehicle is registered to of Lake Worth, Florida. Researchin Mr. and the ve icle revealed that his daughter, had een driving the vehicle and was cited for unlaw u speed in Lake Clark Sh

ein was taking a consistent position with the State Attorney's Office, Judge McSorley, and the USAO, so I asked for a copy of what was filed in the State Court. This led to multiple letters with counsel for Epstein before I could finalize the victim notification letters (Exhibits B-57 through B-65). On July

1 (561)820-8711 Facsimile: (561) 820-8777 July 10, 2008 VIA FACSIMILE AND U.S. MAIL Richard H. Willits, P.A. 2290 10th Avenue North, Suite 404 Lake Worth, FL 33461 Re: Jeffrey Epstein/Carolyn NOTIFICATION OF IDENTIFIED VICTIM Dear Mr. Willits: By virtue of this letter, the United States Attorney'