Epstein Secrets

rida, Case No. 09- 34791-BKC-RBR, The following are statements made by William Scherer, Razorback's counsel. • "[I]n November we filed a lawsuit in State Court and we alleged that as part of Mr. Rothstein and the firm, and the firm's employees, and maybe some of the firm's attorneys, conspired to use the

dwards' clients' Appellee Brief filed in that case, attached to this Notice as Exhibit B. In Jane Doe No. 1, the United States Court of Appeals for the Eleventh Circuit held that Epstein's former counsel had waived the work- product privilege with respect to documents sought by Edwards' clients, after having voluntar

osenfeld! Adler, P.A., in which the following were statements made by William Scherer, Razorback's counsel: • "[I]n November we filed a lawsuit in State Court and we alleged that as part of Mr. Rothstein and the firm, and the firm's employees, and maybe some of the firm's attorneys, conspired to use the E

ssary . . . to prevent a client from committing a crime."). Following earlier precedent in Parrott v. Wilson, 707 F.2d 1262, 1271 (11th Cir. 1983), the Eleventh Circuit affirmed the part of the district court's order determining that the crime-fraud exception may be applied because an attorney's illegal or fraudulen

t several of the young girls that were victimized and abused by Jeffrey Epstein. While we are aware of his recent guilty plea and conviction in his State Court case, the sentence imposed in that case is grossly inadequate for a sexual predator of this magnitude. The information and evidence that has come to

ng cases and concluding "the relevant case law unanimously agrees that the CVRA extends rights to crime victims before charges have been filed"). As the Eleventh Circuit has explained, "Congress is presumed to know the federal courts' interpretation of a statute that it intends to amend," and "[w]here there is no in

Mini • or Oardird) a WI 11.9-Thod Poly 26 USC 1600 I FILED by D.C.; VI. ORIGIN it 1. Original 0 2. Removed from 0 3. Remanded from Proceeding State Court Appellate Court (Specify) 0 4. Refilled 0 6. Multidistrict Litigation 0 7. Appeal to District Judge from 0 5. Transferred from another distric

njoin the stay. And we conclude that this provision does not violate separation of powers principles.") (emphasis added). One district court within the Eleventh Circuit, facing the identical issue with a pending state prosecution, recently construed "the plain language of § 3509(k)" as "requirfing] a stay in a case

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. § I446(b) the undersigned are auth

1 (Palm Beach Co. Family Ct.) (1/31/08). If this turns out to be the case, there is complete diversity, regardless of Robson's citizenship. Although the Eleventh Circuit has recently indicated that a district court may not conduct jurisdictional discovery under such circumstances, another division of this Court has

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(6) the undersigned are auth

1141 (Palm Beach Co. Family Ct.) (1/31/08). If this turns out to be the case, there is complete diversity, regardless ofillin citizenship. Although the Eleventh Circuit has recently indicated that a district court may not conduct jurisdictional discovery under such circumstances, another division of this Court has

NING MOTION TO STAY IDE 121 In connection with his motion to stay this action [DE 12], Defendant Jeffrey Epstein hereby notifies the Court that the State Court action, State of Florida' Jeffrey Epstein, Case No. 2006 CF 09454 AXX (Fifteenth Judicial Circuit, Palm Beach County), was resolved on June 30, 200

njoin the stay. And we conclude that this provision does not violate separation of powers principles.") (emphasis added). One district court within the Eleventh Circuit, facing the identical issue with a pending state prosecution, recently construed "the plain language of § 3509(k)" as "requirtingl a stay in a case

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

mother"), In re (Palm Beach Co. Family Ct.) . If this turns out to be the case, there is complete diversity, regardless of citizenship. Although the Eleventh Circuit has recently indicated that a district court may not conduct jurisdictional discovery under such circumstances, another division of this Court has

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

DR 001141 (Palm Beach Co. Family Ct.) (1/31/08). If this turns out to be the case, there is complete diversity, regardless of citizenship. Although the Eleventh Circuit has recently indicated that a district court may not conduct jurisdictional discovery under such circumstances, another division of this Court has

re• Nellie total.. COyerrY O S 0 $ O 6 3 6 I ORIGIN (Mess - X" is Or Oely) 47) I Original Cl 2 Removed from CI 3 Re-fitcd- Proceeding State Court (see VI below) Trans erred from O 4 Reinstated or ti 5 another district CJ 4 health:KUM Reopened (specify) Litigation Appall." District O 7

009 WL 2567831, fn. I (E.D. Cal. Aug. 18, 2009). U.S.' Zane, 2009 WL 2567832, fn.l (E.D. Cal. Aug. 18 2009). As to the meaning of "actual damages," the Eleventh Circuit in McMillian i t F.D.I.C., 81 F.3d 1041, 1055 (I I th Cir.1996)3, succinctly explained: 3 In McMillian the I 1th Circuit was faced with the task of