Epstein Secrets

ined the services of Thomas Marsigliano, a Private Investigator in New York, to make service on Epstein and one whom the law firm of Farmer, Jaffe, Weissing has been forced to pay $1,400.00, up to this point just to obtain service on Epstein. Declaration of Edwards - Exhibit 1 at 116-17. 3 EFTA00722413

legal counsel filed a motion to "quash" service of process, alleging that process was not properly made. Attached to the Motion was an Affidavit of Richard Barnett, which swore that an "unmarked and unpostmarked envelope was discovered in the mailbox at Mr. Epstein's vacation home in New York at 9 East 7111 St

nothing short of an intentional fraud being committed on the court. The circumstances surrounding the making of this statement strongly suggest that Barnett swore to this false statement deliberately, for the purpose of obstructing proper proceedings in this case. Defendant Epstein's history of obstruct

not state who made the discovery. The affidavit does not state whether Bamett has personal knowledge of the facts contained in his affidavit. 13. Barnett subsequently filed a second affidavit, this time to merely announce that nobody named "Mark` was at the house on October 8, 2010. While this may be

ICE LIST M.J. v. Epstein Case No. 9:10-cv-81111-WPD United States District Court, Southern District of Florida Bradley J. Edwards Farmer, Jaffe, Weissing, Edwards Fistos & Lehrman, PL Telephone: Facsimile: Attorneys for Plaintiff M.J. Served via CMIECF -14- EFTA00725489

testify. The Court should also deny Plaintiff's motion for Rule 11 sanctions based upon the submission of an allegedly fraudulent affidavit by Mr. Barnett. Plaintiff has not offered any probative evidence of fraud, relying solely on caustic rhetoric. Moreover, Plaintiff has violated the mandatory saf

tant case solely to harass the Defendant and create a tempest in a teapot? Conduct involving two witnesses in prior litigation, neither of whom is Richard Bamett, is patently irrelevant to the narrow, threshold issue of whether substitute service was properly made in the instant case, and should 2Plaintiff's

com University of Utah 383 University Street Salt Lake City, UT 84112 Tel: 801-585-5202 Fax: 801-585-2750 [email protected] Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman 425 North Andrews Avenue, Suite 2 Ft. Lauderdale, FL 33301 Tel: 954-524-2820 Fax: 954-524-2822 [email protected]

South Africa 4. Philip Barden (live) Devonshires Solicitors LLP 30 Finsbury Circus London, United Kingdom EC2M 7DT DX: 33856 Finsbury Square 5. Richard Barnett (live) 14 Oakland Ave Port Washington, NY 11050 6. Custodian of Records (live) The Mar-a-Lago Club, Inc. 725 Fifth Avenue New York, NY 10022 7

rd, Suite 1200 Ft. Lauderdale, FL 33301 Tel: Fax: University of Utah 383 University Street Salt Lake Cit , UT 84112 Tel: Fax: Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman 425 North Andrews Avenue, Suite 2 Ft. Lauderdale, FL 33301 Tel: Fax: 49 Twin Lakes Road South Salem, NY 10590 Tel:

iles (live) 4. Philip Barden (live) Devonshires Solicitors LLP 30 Finsbury Circus London, United Kingdom EC2M 7DT DX: 33856 Finsbury Square 5. Richard Barnett (live) 6. Custodian of Records (live) The Mar-a-Lago Club, Inc. 725 Fifth Avenue New York, NY 10022 7. 8. 9. Dershowitz (live) do Richard A.

chez Lill a Ann chez SERVICE LIST MJ. v. Epstein United States District Court, Southern District of Florida Bradley J. Edwards Fanner, Jaffe, Weissing, Edwards Fistos & Lehrman, PL Telephone: Facsimile: Attorneys for Plaintiff M.J. Served via CM/ECF 5 FIOVANN WW2 BURNETT PA. *MUM SANTO PLAZA.

action, a Civil Rico Case Statement, a deposition subpoena, notices of video depositions, interrogatories and requests for production. (Ex. A, Aff. Richard Barnett). 3. Service was never delivered to anyone at Mr. Epstein's vacation home in New York. (Id.). 4. On or about October 13, 2010, Plaintiff's couns

ight Christopher E. Knight SERVICE LIST v. Epstein United States District Court, Southern District of Florida Bradley J. Edwards Farmer, Jaffe, Weissing, Edwards Fistos & Lehrman, PL 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone: (954) 524-2820 Facsimile: (954) 524-28

bject action, a Civil Rico Case Statement, a deposition subpoena, notices of video depositions, interrogatories and requests for production. (A ff. Richard Barnett). 3. Service was never delivered to anyone at Mr. Epstein's vacation home in New York. (Id.). 4. There is no return of service in the court file