Epstein Secrets

lie to the police, don't you? 20 A. No. 21 Q. Well, you lied to the police in your 22 tape-recorded statement that you gave to Detective 23 Michelle Pagan three years ago, didn't you? 24 A. To my knowledge, no, I did not. 25 Q. Well, you lied to the police when you Ph. 561.682.0905 - Fax. 5

Doe is a citizen of Florida. (Am. Compl. ¶ 1.) 6 Jane Doe may, in fact, be a citizen of Georgia. not Florida, as she pled in her Amended Complaint. See New York Post, Jul. 1, 2008 (reporting that "On his way into court [for his state-court guilty plea on June 30], Epstein was served with a copy of a lawsuit by D

TA00175544 Case 9:08-cv-80ou4-KAM Document "L . Entered L. FLED Docket 09/05/i...d Page 3 of 14 CASE NO.: 08-80804-CrV-MARRA/JOHNSON cite. See Mitchell'. Brown & Williamson Tobacco Corp., 294 F.3d 1309, 1314 (11th Cir. 2002) (noting as an undisputed point that someone retains their pre-incarceration

Defendants claim that who has described herself as Heidi Fleiss (the Hollywood madam),' has "nothing to do with the plaintiff's case against Mr. ' See New York Post Oct. 12007 (reporting "Some of the girls, legal documents indicate, were recruited by now 21, who described herself as `like Heidi Fleiss,' the no

lie to the police, don't you? 20 A. No. 21 Q. Well, you lied to the police in your 22 tape-recorded statement that you gave to Detective 23 Michelle Pagan three years ago, didn't you? 24 A. To my knowledge, no, I did not. 25 Q. Well, you lied to the police when you Ph. 561.682.0905 - Fax. 5

Doe is a citizen of Florida. (Am, Compl. ¶ 1.) 6 'Jane Doe may, in fact, be a citizen of Georgia, not Florida, as she pled in her Amended Complaint. See New York Post, Jul. 1, 2008 (reporting that "On his way into court [for his state-court guilty plea on June 30], Epstein was served with a copy of a lawsuit by D