Epstein Secrets

owing Service List in the manner specified by CM/ECF on this 7th day of January, 2009: Richard Horace Willits, Esq. Richard H. Willits, P.A. th Lake Worth, FL 33461 Counsel for Plaintiff C.M.A. Jack Scarola, Esq. Jack P. Hill, Esq. Search Denney Scarola Shipley, P.A. Jack Alan Goldberger, Esq. A

joyment of life. (Plaintiff alleges in her Complaint, ¶2, that she is presently 21 years old. The suit was originally filed in Florida state court, Palm Beach County Circuit Court, on February 21, 2008.) Count I is lacking in sufficient factual allegations to allege the necessary elements to state a cause of action either un

r Drive, Suite 400 West Palm Beach FL 33414 Phone: Fax: Richard H. Willits, Esquire Richard H. Willits, P.A. 2290 10th Avenue North Suite 404 Lake Worth, FL 33461 Phone: Fax: EFTA00175318 Case 9:08-cv-80811-KAM Document 35 Entered on FLSD Docket 01/07/2009 Page 1 of 7 UNITED STATES DISTRICT C

joyment of life. (Plaintiff alleges in her Complaint, ¶2, that she is presently 21 years old. The suit was originally filed in Florida state court, Palm Beach County Circuit Court, on February 21, 2008.) Count I is lacking in sufficient factual allegations to allege the necessary elements to state a cause of action either un

)820-8711 Facsimile: (561) 820-8777 April 9, 2008 VIA FACSIMILE Richard H. Willets, Esq. Mr. Michael Danchuk 2290 10th Avenue North, Suite 404 Lake Worth, FL 33461 Re: Carolyn El Dear Messrs. Willits and Danchuk: Thank you for your letter of March 28, 2008, regarding Pursuant to the strict rules o

hip with Mr. Epstein. As we understand you are investigating this matter, we wanted you to be aware of our involvement. We have filed a lawsuit in Palm Beach County Circuit Court under Ms. initials, C.M.A. We are using the initials to try to keep publicity on this matter limited for Ms. Andriano's benefit. Possibly, you can

ii which was also previously seen on the property when there was physical surveillance being done at the property. The vehicle is registered to of Lake Worth, Florida. Researchin Mr. and the ve icle revealed that his daughter, had een driving the vehicle and was cited for unlaw u speed in Lake Clark Sh

TICE OF REMOVAL In accordance with 28 U.S.C. §§ 1441, 1446, and 1332(aX1), the defendants, Jeffrey Epstein, and hereby remove this action ) from Palm Beach County Circuit Court to the United States District Court for the Southern District of Florida, and respectfully state as follows: Introduction Six months ago, this pla

1 (561)820-8711 Facsimile: (561) 820-8777 July 10, 2008 VIA FACSIMILE AND U.S. MAIL Richard H. Willits, P.A. 2290 10th Avenue North, Suite 404 Lake Worth, FL 33461 Re: Jeffrey Epstein/Carolyn NOTIFICATION OF IDENTIFIED VICTIM Dear Mr. Willits: By virtue of this letter, the United States Attorney'

ed a letter from attorney Richard Willits, advising me that he represented Individual #3 and that he had filed suit on her behalf against Epstein in Palm Beach County Circuit Court (Exhibit B-41). I responded, acknowledging his representation (Exhibit B-42). On June 18, 2008, I liv received a call from attorney Brad ards, who