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ut Jeffrey Epstein, he is a billionaire and owner of a private island in the Virgin Island (Little St. James Island), and was a financial trader at Bear Steams. He then founded his own financial management firm, J. ..-- EXHIB\1 ~ Case 9:08-cv-80119-KAM Document 165 Entered on FLSD Docket 06/19/2009
s and Emery Air Freight. 6. According to the Vanity Fair article, before working with Wexner and Hoffenberg, defendant Jeffrey Epstein worked with Beam Stearns. He left the firm very suddenly in 1981 after being questioned by S.E.C. investigators in an insider trading scandal involving several Italian and
a "perfect circumstantial evidence case that [Epstein] ha[s] means, motive, and opportunity" to fraudulently transfer assets. See United States v. Sparks, 265 F.3d 825, 830 (9th Cir. 2001) (finding probable cause for an arrest based solely on a showing of means, motive, and opportunity). The fact tha
to Jane Doe's Injunction Motion Page 7 of24 Italian and Swiss investors. Id. '1[6. This statement is obviously intended to associate Epstein with Bear Sterns, a tarnished financial institution apparently involved in questionable international transactions in the 1980's, to somehow suggest Epstein is frau
wenty-eight years ago, in 1981, and that Epstein was merely questioned because the SEC believed "Epstein had information on insider trading at Bear Sterns." The foregoing assertions in Mr. Cassell's affidavit have absolutely no bearing on Jane Doe's Injunction Motion. Then, Mr. Cassell goes beyond the
Epstein is fraudulently transferring assets because he purportedly has the means, the motive and the opportunity to do so, citing United States v. Sparks, 265 F.3d 825, 830 (9th Cir. 2001). See Injunction Motion (DE #165) at 11. Sparks is completely inapposite as it concerned whether probable cause fo
the Virgin Islands (Little St. James Island), where he serves as a financial advisor to other billionaires. He was previously a financial trader at Bear Steams. It is therefore reasonable to infer that he has a great deal of financial sophistication. See Affidavit of Paul Cassell at ¶ 2 Attachment A to this
s and Emery Air Freight. 6. According to the Vanity Fair article, before working with Wexner and Hoffenberg, defendant Jeffrey Epstein worked with Beam Stearns. He left the firm very suddenly in 1981 after being questioned by S.E.C. investigators in an insider trading scandal involving several Italian and
a "perfect circumstantial evidence case that [Epstein] ha[s] means, motive, and opportunity" to fraudulently transfer assets. See United States v. Sparks, 265 F.3d 825, 830 (9th Cir. 2001) (finding probable cause for an arrest based solely on a showing of means, motive, and opportunity). The fact tha
Entities connected to both Bear Stearns and Sparks

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
Les Wexner
PERSON
George W. Bush
PERSON
Donald Trump
PERSONLeon Black
PERSON
Marc Rich
PERSON
U.S. Virgin Islands
LOCATION
Bill Clinton
PERSON
Michael Milken
PERSON
New York
LOCATION
Julie K. Brown
PERSON
United States
LOCATION
Kenneth Marra
PERSON
Vicky Ward
PERSON
Bradley Edwards
PERSONthe Southern District
LOCATION
Department of Justice
ORGANIZATION
Harvey Weinstein
PERSONJane Doe
PERSON