Epstein Secrets

ou there? 25 A. I was in there for the eighth grade again, Page 197 1. Q. For what? What had you done that brought 2 about you getting sent to Milton? 3 MR. EDWARDS: Fenn. 4 THE WITNESS: I crashed my grandmother's car. 5 BY MR. CRITTON: 6 EsonY7 7 A. I crashed my grandmother's car. 8 Q.

of that. 13 A. 14 Q. 15 A. 16 Q. 17 A. 18 Q. 19 A. 20 Q. 21 A. 22 Q. 23 A. 24 Q. 25 A. Yes. Where Is Milton located? In Milton, Florida Which is where? Which is near Okaloosa County. sort)/ Near Okaloosa. Where is Okaloosa? In the Panhandle. And were you required to go

k with 18 them? 19 MR. EDWARDS: Object to the form. 20 THE WITNESS: Yes. Yes, l did. 21 BY MR. CRITTON: 22 Q. All right. And then it says: 'Jane Doe's 23 status as a victim of a Federal offense was confirmed 24 when she was interviewed by Federal agents on May 28th. 25 2008." Page 138 1. co

MCGOVERN,KEVIN M LANE,JEFFREY MILETO,FRANCESCO CERIALE,MELISSA S NEWQUIS

QUINN,OLIVER H LOCKER,NANCY OWEN,JANE D CUSHMAN & WAKEFIELD KELLER,MICHAEL

It is not enough for the opposing party merely to assert that an issue of fact does exist. Fisel v. Wynns, 667 So.2d 761, 764 (Fla.1996); Landers v. Milton, 370 So.2d 368, 370 (F1a.1979) (same). Moreover, it is well-recognized that the non-moving party faced with a summary judgment motion supported by

atement of Undisputed Facts. 12 EFTA00725980 In addition, if Epstein had thought that there was some improper coercion involved in, for example, Jane Doe's case, his remedy was to raise the matter before Federal District Court Judge Kenneth A. Marra who was presiding over the matter. Far from raising an

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on as a teen and sexually abused. Prominent Miami at- torney Robert Josefsberg filed the most recent federal lawsuit last week, on behalf of the Jane Doe 101 who allegedly visited Epstein a few times while 17 years old and was paid S200 at least once for her time there, according to the complaint.

114. Victim's employment records from IHOP 115. Police report of Juan Alessi theft at Jeffrey Epstein's home 116. Victim's Medical Records from Milton Girls Juvenile Facility 117. Victim's Medical Records from Dr. Randee Speciale 118. Victim's Medical Records from Wellington Regional Hospital 1

rant of Jeffrey Epstein's home 27. Yearbooks of Jane Doe 28. 2002 Royal Palm Beach High School Year Book

d her grandmother's car and her grandmother pressed charges. Rivera was ordered to a drug program at Milton Girls Juvenile Residential Facility in Milton, Florida. Rivera stated she was in the drug program for 5 months, one week and 3 days. EFTA00178032 FD-302a (Rev. 10-6-95) 31E-MM-108062 Contin

ney General or any office under his direction.'" Id. at *2 (quoting 18 U.S.C. § 3771(d)(6)). For these reasons, the Court should deny the motion of Jane Doe 1 and Jane Doe 2 to discover and use the plea negotiation letters as evidence. PART II MR. EPSTEIN'S PLEA NEGOTIATIONS ARE PRIVILEGED AND NOT DISCO

ards filed a civil sot against Jeffrey Epstein to recover damages for his sexual assault of L.M. See Complaint, LM. v. Epstein, (Exhibit “V”). 3 47. Jane Doe’s federal complaint indicated that she sought damages of more than $50,000,000. Listing the amount of damages sought in the complaint was in accord wit

1966), It is not enough for the —— party merely to assert that an issue of fact does exist. Fisel v. Wynns, 667 So.2d 761, 764 (Fla.1996); Landers v. Milton, 370 So.2d 368, 370 (Fla.1979) (same). | Moreover, it is well-recognized that the non-moving party faced with a summary judgment motion supported by