Epstein Secrets

were circulating (to celebrities such as Dustin Hoffman, Alec Baldwin and filmmaker Michael Mailer) that

ally, in paragraph 8 of his affidavit, Mr. Cassell cites a May 2008 Vanity Fair article and states "rumors were circulating (to celebrities such as Dustin Hoffman, Alec Baldwin and filmmaker Michael Mailer) that Epstein was moving all of his considerable assets to Israel." Id. 18 (emphasis added). The articl

in Opposition to Jane Doe's Injunction Motion Page 22 of 24 V. CONCLUSION For the foregoing reasons, Epstein respectfully requests the Court deny Jane Doe's Injunction Motion. By: ROBERT D. CRITTON, JR., ESQ. Florida Bar No. 224162 MICHAEL J. PIKE, ESQ. Florida Bar #617296 DAVID A. YAREMA, ESQ. Flo

ane Doe's Request for Admissions attached as Exhibit C to Injunction Motion (DE #165). Based on this unsupported presumption of fraudulent transfer, Jane Doe asks the Court to impose significant and unjustified restraints on Epstein's assets. Simply put, Jane Doe is improperly seeking assurance she will b

rse inference would be wholly unreliable and is clearly impermissible under the instant circumstances. Additionally, granting the relief sought by Jane Doc based solely on an adverse inference would violate Epstein's Fifth Amendment rights. LaSalle Bank Lake View v. Seguban, 54 F.3d 387, 389 (7th Cir.

ally, in paragraph 8 of his affidavit, Mr. Cassell cites a May 2008 Vanity Fair article and states "rumors were circulating (to celebrities such as Dustin Hoffman, Alec Baldwin and filmmaker Michael Mailer) that Epstein was moving all of his considerable assets to Israel." Id. '1[8 (emphasis added). The arti

were circulating (to celebrities such as Dustin Hoffman, Alec Baldwin and filmmaker Michael Mailer) that

e's Injunction Motion Page 5 of24 relief requested by Jane Doe. For the following reasons, the Court must deny Jane Doe's Injunction Motion. II. JANE DOE'S STATEMENT OF MATERIAL FACTS IS BASED ON SPECULATION AND HEARSAY AND CONTAINS NO MATERIAL "FACTS" Jane Doe's "Statement of Material Facts" relies h

JANE DOE NO. 102, CASE NO.: 09-80656-CIV-MARRA/JOHNSON Plaintiff, JEFFREY EPSTEIN, Defendant. I EPSTEIN'S MEMORANDUM OF LAW IN OPPOSITION TO JANE DOE'S MOTION FOR INJUNCTION RESTRAINING FRAUDULENT TRANSFER OF ASSETS, APPOINTMENT OF A RECEIVER TO TAKE CHARGE OF PROPERTY OF EPSTEIN, AND TO POST A $1

c Baldwin, Ralph Fiennes, George Hamilton, Dustin Hoffman, Kevin Spacey, Liz Hurley, Lauren Hutton, Janice

ce George Mitchell, New York City Mayor Michael Bloomberg, New York Gov. Andrew Cuomo, Barbara Walters, Alec Baldwin, Ralph Fiennes, George Hamilton, Dustin Hoffman, Kevin Spacey, Liz Hurley, Lauren Hutton, Janice Dickinson, Naomi Campbell, Christy Turlington, Henry Kissinger, Joan Rivers, Courtney Love, Mick Jag

The British press has been having a field day digging up new details about Epstein’s friendship with Prince Andrew. Virginia Roberts — known only as Jane Doe 102 in court papers — has been dishing her story to London’s Daily Mail. Details include Roberts having been in the company of the prince three times

ument 165 Entered on FLSD Docket 06/19/2009 Page 25 of 41 ward-you.html. According to this note, rumors were circulating (to celebrities such as Dustin Hoffman, Alec Baldwin, and filmmaker Michael Mailer) that Epstein was moving all of his considerable assets to Israel. The note also indicated that, having

were circulating (to celebrities such as Dustin Hoffman, Alec Baldwin, and filmmaker Michael Mailer) that

, Defendant I ------------- CASE NO: 08-CV-80119-MARRA/JOHNSON CASE NO: 09-CV-80591-MARRA/JOHNSON CASE NO: 09-CV-80656-MARRA/JOHNSON PLAINTIFF, JANE DOE'S MOTION FOR INJUNCTION RESTRAINING FRAUDULENT TRANSFER OF ASSETS, APPOINTMENT OF A RECEIVER TO TAKE CHARGE OF PROPERTY OF EPSTEIN, AND TO POST A $15

ters including Tony Blair, Naomi Campbell, Dustin Hoffman. Michael Bloomberg and Richard Branson. In a 20

tn. Last year. The Guardian reported that Epstein's little black book" contained contact numbers for Misters including Tony Blair, Naomi Campbell, Dustin Hoffman. Michael Bloomberg and Richard Branson. In a 2006 court filing. Palm Beach peke noted that a search of Epstein's home uncovered two hidden cameras

Beach peke noted that a search of Epstein's home uncovered two hidden cameras. The Mirror reported that in 2015, a 6-yeanold civil lawsuit filed by 'Jane Doe No. 3," believed to be the now-merited S alleged that Epstein wired his mansion with hidden cameras. Secretly recording orgies involving his promi

cument 165 Entered on FLSD Docket 06/19/2009 Page 25 of 41 ward-you.html. According to this note, rumors were circulating (to celebrities such as Dustin Hoffman, Alec Baldwin, and filmmaker Michael Mailer) that Epstein was moving all of his considerable assets to Israel. The note also indicated that, having

were circulating (to celebrities such as Dustin Hoffman, Alec Baldwin, and filmmaker Michael Mailer) that

iff vs. JEFFREY EPSTEIN, Defendant JANE DOE NO. 102, CASE NO: 09-CV-80656-MARRA/JOHNSON Plaintiff vs. JEFFREY EPSTEIN, Defendant PLAINTIFF, JANE DOE'S MOTION FOR INJUNCTION RESTRAINING FRAUDULENT TRANSFER OF ASSETS, APPOINTMENT OF A RECEIVER TO TAKE CHARGE OF PROPERTY OF EPSTEIN, AND TO POST A $15

former mayor; the actors Alec Baldwin and Dustin Hoffman; the singer and songwriter Jimmy Buffett (whose n

entries for three Trumps (Donald, his ex-wife Ivana and their daughter Ivanka); Michael R. Bloomberg, the former mayor; the actors Alec Baldwin and Dustin Hoffman; the singer and songwriter Jimmy Buffett (whose name was misspelled); and the Nobel Peace Prize winner Elie Wiesel, among many others. He turned up

.' Questions about Epstein's deal started to surface after a series of lawsuits were filed by two of his alleged victims. The women, identified as Jane Doe 1 and Jane Doe 2, claim in court papers that they were unaware of the secret deal being made between the defense team and prosecutors back in 2007 tha

entries for three Trumps (Donald, his ex-wife Ivana and their daughter Ivanka); Michael R. Bloomberg, the former mayor; the actors Alec Baldwin and Dustin Hoffman; the singer and songwriter Jimmy Buffett (whose name was misspelled); and the Nobel Peace Prize winner Elie Wiesel, among many others. He turned up

former mayor; the actors Alec Baldwin and Dustin Hoffman; the singer and songwriter Jimmy Buffett (whose n

.' Questions about Epstein's deal started to surface after a series of lawsuits were filed by two of his alleged victims. The women, identified as Jane Doe 1 and Jane Doe 2, claim in court papers that they were unaware of the secret deal being made between the defense team and prosecutors back in 2007 tha

her back atis y- fabulous world that he Brooklyn boy knew not taught Epstein the differ But despite—or was il Epstein, she, too, gradi According to Jane Doe : | filed in 2009 by a womart Ly of the services Maxwell ment of underage wom papers, Maxwell has ve Virginia, with any othe with, or with any crim

Mexico, New York, and Michigan. The papers also included the names, addresses, and phone numbers of famous individuals—Henry Kissinger, Mick Jagger, Dustin Hoff- man, Ralph Fiennes, David Koch, Ted Kennedy, Donald Trump, Bill Richardson, Bill Clinton, and former Israeli prime minister Ehud Barak among them. This