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ct info and lead her up a flight of stairs lined with photos of nude women into a bedroom furnished with a massage table. Once the girl was inside, Kaplan would leave and Epstein would enter, wearing only a towel. He would proceed to "remove his towel, lay down naked on the massage table, and direct t
ein masturbated in front of her (she was 14 at the time) and used a vibrator on her at his home in February 2005. Another Epstein attorney, Lilly Ann Sanchez dismissed it: "Jeffrey Epstein did not have sex with this woman." For those girls who claim that he did, Mr. Epsteint.lawyers maintain that he d
dentiary support after a reasonable opportunity for further investigation or discovery. Fed. R. Civ. P. I1(b). Rule 1 1 uses an objective standard. Kaplan v. DaimlerChrysler, A.G., 331 F.3d I251, 1255 (11th ar. 2003). The analysis is whether "a reasonable attorney in like circumstances could believe t
STA UNITED STATES ATTORNEY Dated: Dated: 74/3 — Dated: Dated: By: ASSISTANT U.S. TEO GERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR JEFFREY EPSTEIN Page 7 of 7 EFTA00229978 Case 9:08-cv-80736-KAM Document 48-5 Entered on FLSO Docket 03/21/2011 Page 9 or 15
identiary support after a reasonable opportunity for further investigation or discovery. Fed. R. Civ. P. 11(b). Rule 11 uses an objective standard. Kaplan'. Daimleravysler, A.G., 331 F.3d I251, 1255 (11th ar. 2003). The analysis is whether "a reasonable attorney in like circumstances could believe tha
Dated: By: Dated: 74/9 — Dated: Dated: A. MARIE VILLAFARA ASSISTANT U.S. ATTORNEY GERALD LISPCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR JEFFREY EPSTEIN ••• Page 7 of 7 08-80736-CV-MARRA 000732 EFTA00230556 1 Case 9:08-cv-80736-KAM Document 48-5 Entered on F
Entities connected to both Kaplan and Ann Sanchez

Jeffrey Epstein
PERSON
Alexander Acosta
PERSONGerald Lefcourt
PERSON
United States
LOCATION
Department of Justice
ORGANIZATION
Bradley Edwards
PERSON
Lesley Groff
PERSONJack Goldberger
PERSONthe Southern District
LOCATIONLeon Black
PERSONFBI
ORGANIZATION
Lilly
ORGANIZATION
Alan Dershowitz
PERSON
George W. Bush
PERSON
Jay Lefkowitz
PERSONDarren Indyke
PERSON
Prince Andrew
PERSON
A. Marie Villafana
PERSON
Joe Biden
PERSONRoy Black
PERSON