Epstein Secrets

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

Jack Alan Goldberger, Esq. [email protected] Robert D. Critton, Esq. [email protected] Isidro Manual Garcia isid [email protected] Jack Patrick Hill [email protected] Katherine Warthen Ezell [email protected] Michael James Pike [email protected] Paul G. Cassell [email protected] Richa

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

Lake Worth, FL 33461 561-582-7600 Fax: 561-588-8819 Counsel for Plaintiff in Related Case No. 08-80811 [email protected] Jack Scarola, Esq. Jack P. Hill, Esq. Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 561-686-6300 Fax: 561-383-9424

his untenable connection. Similarly, Mr. Cassell states that Epstein was questioned by the SEC in 1981 regarding an insider trading investigation at Bear Steams involving EFTA00221934 Case 9:08-cv-80119-KAM Document 198 Entered on FLSD Docket 07/13/2009 Page 7 of 24 Jane Doe v. EDSICia Case No. 08-CV-

tely twenty-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

ell, Esq. 08-80994 Richard Horace Willits, Esq. Richard H. Willits, P.A. Counsel for Plaintiff in Related Case No. 08-80811 Jack Scarola, Esq. Jack P. Hill, Esq. Searcy Denney Scarola Barnhart & Shipley, Counsel for Plaintiff C.M.A. Pro Hac Vice [email protected] Co-counsel for Plaintiff Jane Do

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

Jack Alan Goldberger, Esq. k)Idberger aewpa.com Robert D. Critton, Esq. rcritton(&.bciclaw.com Isidro Manual Garcia isidrociarcia bellsouth.net Jack Patrick Hill inhesearcvlaw.com Katherine Warthen Ezell KEzella,podhurst.com Michael James Pike MPikeebelclaw.com Paul G. Cassell casselloabciclaw.com Rich

009 Jacquie Johnson Spencer Kuvin FW:Epstein-De I os of & Joint W/P Priv. 02071 08/18/2009 Adam Horowitz Jacquie Johnson RE:Epstein Sub to Bear Sterns Joint W/P Priv. 02072-02078 09/04/2009 Jacquie Johnson Spencer Kuvin FW:Epstein-De • os of & Joint W/P Priv. 03466-03468 05/14/2009 Spencer

to the discovery of admissible evidence; protected by privacy rights 04246 06/15/2009 Wayne Black Bradley Edwards Epstein secret plea deal for Bear Stearns W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights

depos Joint-privilege 06706-06708 10/14/2009 Bradley J. Edwards Kikka M. Claudio Igor Zinoview depo Joint-privilege 06715-06719 10/09/2009 Jack P. Hill Bradley J. Edwards Igor Zinoview depo Joint-privilege 06729-06735 10/13/2009 Bradley J. Edwards Jack P. Hill Igor Zinoview depo Joint-privi

009 Jacquie Johnson Spencer Kuvin FW:E , stein-De os of & Joint W/P Priv. 02071 08/18/2009 Adam Horowitz Jacquie Johnson RE:Epstein Sub to Bear Sterns Joint W/P Priv. 02072-02078 09/04/2009 Jacquie Johnson Spencer Kuvin FW:E .stein-De. & of Joint W/P Priv. 03466-03468 05/14/2009 Spencer Kuv

to the discovery of admissible evidence; protected by privacy rights 04246 06/15/2009 Wayne Black Bradley Edwards Epstein secret plea deal for Bear Stearns W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights

depos Joint-privilege 06706-06708 10/14/2009 Bradley J. Edwards Kikka M. Claudio Igor Zinoview depo Joint-privilege 06715-06719 10/09/2009 Jack P. Hill Bradley J. Edwards Igor Zinoview depo Joint-privilege 06729-06735 10/13/2009 Bradley J. Edwards Jack P. Hill Igor Zinoview depo Joint-privi