Epstein Secrets

ned Defendant, Epstein's Motion to Dismi s. Respectful ours, Robert a. Critton, Jr., Esq. RDC/clz Enclosures cc: Theodore J. Leopold, Esq. and Spencer T. Kuvin, Esq. Jack Goldberger, Esq. L•A•W•Y•E •E•S TELEPHONE FAX EFTA00722694 • Plaintiff, v. JEF and Defendants. IN THE COURT OF THE FIFTEENTH

rger & Weiss. P.A. EFTA00722689 g e sz LEOPOLD—KUVIN, CONSUMER JUSTICE ATTORNEYS April 10, 2009 Fax

STAEMENT, AND TO STRIKE DIRECTED TO PLAINTIFF'S COMPLAINT 1. Am. Home Assurance Co. v. Plaza Materials Corp., 908 So.2d 360, 374 (Fla. 2005) 2. Miami Herald Pub. Co. v. Ferre, 636 F.Supp. 970 (S.D. Fla. 1985) 3. Mantooth v. Richards, 557 So.2d 646 (Fla. 4th DCA 1990) 4. Lay v. Kremer, 411 So.2d 1347 (Fla.

Authority in Support of the above-mentioned Defendant, Epstein's Motion to Dismiss. Robed RDC/clz Enclosures cc: Theodore J. Leopold, Esq. and Spencer T. Kuvin, Esq. Jack Goldberger, Esq. Critton, Jr., Esq. •A•W•Y•E •N•S EFTA00614424 IN THE COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEA

E I HEREBY CERTIFY that a true copy of the foregoing was sent by fax and U.S. Mail to the Theodore J. Leopold, Esq. Spencer T. Kuvin, Esq.,Leopold- Kuvin, P.A., Counsel for Plaintiff; Jack Alan Goldberger, Esq., Atterbury Goldberger & Weiss, Co-Counstaerfor Defendant Jeffrey Epstein, on this / Sia

STAEMENT, AND TO STRIKE DIRECTED TO PLAINTIFF'S COMPLAINT 1. Am. Home Assurance Co. v. Plaza Materials Corp., 908 So.2d 360, 374 (Fla. 2005) 2. Miami Herald Pub. Co. v. Ferre, 636 F.Supp. 970 (S.D. Fla. 1985) 3. Mantooth v. Richards, 557 So.2d 646 (Fla. 4th DCA 1990) 4. Lay v. Kremer, 411 So.2d 1347 (Fla.

kesman for the Manhattan U.S. Attorney's Office declined to comment on where the probe stands, only saying that the "investigation is continuing." Spencer Kuvin, a Palm Beach attorney who represents two women who were abused by Epstein, said the U.S. Attorney's Office for the Southern District of New York o

ntatives also worked to debunk conspiracy theories, which the victims have encountered online, related to Epstein's jailhouse suicide. According to Kuvin, prosecutors continue to battle wild speculation on how the 66-year-old money- manager died, along with rumors that he isn't dead at all. "The U.S.

-emerged in the press. Prosecutors say Epstein wired payments to two unnamed women—one received $250,000 while the other got $100,000—shortly after the Miami Herald's exposé on Epstein's 2007 sweetheart deal. Those individuals were listed as possible co- EFTA00083646 conspirators in Epstein's non-prosecution agr

rd day of November, 2009, 6 pursuant to Notice in said cause for theitaking ofsaid 7 deposilion.on behalfof the Plaintiff. 8' 9 OF PLAINTIFF B.B.r 10 SPENCER T. KUVIN. ESQ. LEOPOLiKKUVIN,P.A. 11 2925.*PGA Boulevard, Suite 200 Palm Beach Gardens, Florida ,33410 12 13 .APPEARING ONBEHAEEOF PLAINTIFFS'JANE DOES 2-8: 1

ifthat doesn't work there's an attack on the investigators. I don't know, I don't know. Shouldn't,say that. MR. CRITTON: Form, move to strike. BY MR. KU VIN: Q You were working as a police officer for twenty-eight years and then as a chief — well ■- A And two years prior to that actually. Q Right. During

two prostitution charges,” immunized from prosecution Epstein’s co-conspirators, and concealed from Epstein’s victims the terms of the NPA. Following the Miami Herald’s report, and after receiving a Congressional request to investigate, OPR. initiated an investigation into the allegations that prosecutors in the USAO