Epstein Secrets

interviewing agents. advised that Epstein was a NYAA board member in the 1980's into the early 1990's. Epstein was a social acquaintance with artist Andy Warhol. Epstein allowed the board to have meetings at his apartment as well as his office space located in the Villard House, corner of Madison Avenue and 5

pstein was a social acquaintance with artist Andy Warhol. Epstein allowed the board to have meetings at hi

on her daughter's behalf and asked that P ; wee te ee mL “| the litigation be halted until her daughter turns 18. - The mother com- plained that Jane Doe’s father’ did not consult with her or their daughter before sting Epstein ‘for $50mil- Epstein lion. The lawsuit al- Accused of leges sexual assault,

g agents. Wilkinson advised that Epstein was a NYAA board member in the 1980's into the early 1990's. Epstein was a social acquaintance with artist Andy Warhol. Epstein allowed the board to have meetings at his apartment as well as his office space located in the Villard House, corner of Madison Avenue an

pstein was a social acquaintance with artist Andy Warhol. Epstein allowed the board to have meetings at h

at the wealthy money manager had her brought to his mansion for a massage, then engaged in sexual activity with her. The girl, identified only as Jane Doe, was 14 at the time. She was the youngest of sev- eral alleged victims of Epstein. according to Palm Beach police, who spent 11 months investigati

, 325 F.2d 403, 407-08 (2d Cir.1963); Smith v. Annour Phannaceutical Co., 838 F.Supp. 1573, 1578 (S.D.Fla.1993); Schlazfer Nance & Co. v. Estate of Warhol, 742 F.Supp. 165, 166 (S.D.N.Y.1990)). Likewise, the Court has the "inherent authority to sanction a party who attempts to use in litigation materia

S. University St. Salt Lake City, UT 84112 (above for address purposes only) Attorney E-Mail: [email protected] Attorneys for L.M., E.W., and Jane Doe 12 EFTA00795938

.3d 333, 338 (2d Cir. 2011) (dismissing complaint where plaintiff could not have reasonably relied on defendant); Schlaifer Nance & Co. v. Estate of Warhol, 119 F.3d 91, 98 (2d Cir. 1997) ("circumstances may be so suspicious as to suggest to a reasonably prudent plaintiff that the defendant's represent

") (collectively "Defendants") submit this memorandum in support of their motion to dismiss the First Amended Complaint ("FAC") filed by plaintiff Jane Doe ("Plaintiff') pursuant to Fed.R.Civ.P. 12(b)(2) and (6). The FAC represents the Plaintiff's second unsuccessful bite at the apple. On January 26,

3d 333, 338 (2d Cir. 2011) (dismissing complaint where plaintiff could not have reasonably relied on defendant); Schlaifer Nance & Co. v. Estate of Warhol, 119 F.3d 91, 98 (2d Cir. 1997) ("circumstances may be so suspicious as to suggest to a reasonably prudent plaintiff that the defendant's representa

017 Brad Edwards, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Re: Jane Doe 43 v. Jeffery Epstein, et al. Civil Action No. 17-cv-616 Dear Brad: In accordance with the procedures directed by the Court at the initial case ma