Epstein Secrets

ert acts and charges 4 related to Jane Does number 1 and 2? 5 A Yes. 6 Q Today we are going to start with Jane Doe 7 number 3. Can you tell the Grand Jury who that is and 8 summarize briefly your previous testimony about her. 9 A Jane Doe number 3 is I and she first 10 started, we have first pho

ert acts and charges 4 related to Jane Does number 1 and 2? 5 A Yes. 6 Q Today we are going to start with Jane Doe 7 number 3. Can you tell the Grand Jury who that is and 8 summarize briefly your previous testimony about her. 9 A Jane Doe number 3 is I and she first 10 started, we have first pho

ert acts and charges 4 related to Jane Does number 1 and 2? 5 A Yes. 6 Q Today we are going to start with Jane Doe 7 number 3. Can you tell the Grand Jury who that is and 8 summarize briefly your previous testimony about her. 9 A Jane Doe number 3 is I and she first 10 started, we have first pho

the evidence supporting various overt acts and charges 4 related to Jane Does number 1 and 2? 5 A Yes. 6 Q Today we are going to start with Jane Doe 7 number 3. Can you tell the Grand Jury who that is and 8 summarize briefly your previous testimony about her. 9 A Jane Doe number 3 is I and

the evidence supporting various overt acts and charges 4 related to Jane Does number 1 and 2? 5 A Yes. 6 Q Today we are going to start with Jane Doe 7 number 3. Can you tell the Grand Jury who that is and 8 summarize briefly your previous testimony about her. 9 A Jane Doe number 3 is I and

the evidence supporting various overt acts and charges 4 related to Jane Does number 1 and 2? 5 A Yes. 6 Q Today we are going to start with Jane Doe 7 number 3. Can you tell the Grand Jury who that is and 8 summarize briefly your previous testimony about her. 9 A Jane Doe number 3 is I and

fortable just let him 3 know and he will stop, and the first massage that 4 did he repeatedly told , and I mentioned this to 5 you in the last Grand Jury session, she was very shy and 6 he would repeatedly tell her not to be so shy, that she 7 didn't have to be so shy. 8 Epstein asked her to remo

fortable just let him 3 know and he will stop, and the first massage that 4 did he repeatedly told , and I mentioned this to 5 you in the last Grand Jury session, she was very shy and 6 he would repeatedly tell her not to be so shy, that she 7 didn't have to be so shy. 8 Epstein asked her to remo

fortable just let him 3 know and he will stop, and the first massage that 4 did he repeatedly told , and I mentioned this to 5 you in the last Grand Jury session, she was very shy and 6 he would repeatedly tell her not to be so shy, that she 7 didn't have to be so shy. 8 Epstein asked her to remo

each County) (the "Florida Criminal Action"). As explained below, the parallel federal criminal action against him described in that motion (In re Grand Jury, No. FGJ 07-103(WPB), United States District Court for the Southern District of Florida) (the "Federal Criminal Action"), remains pending. On Septe

OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defend

use an act of production shield to turning over documents whose existence are known to the government or is a foregone conclusion. See, e.g. In re Grand Jury Subpoena Duces Tecum Dated Oct. 29, 1992, 1 F.3d 87, 93 (2d Cir. 1993) (rejecting act of production argument because compliance with subpoena requi

notice that more than 90 days had elapsed since the filing of her motion (dkt. #453). On February 4, 2010, the magistrate judge granted in part Jane Doe’s motion to compel, specifically ruling that Epstein had to produce the discovery provided to him by state and federal prosecutors, his recent tax re

nt or is a foregone conclusion. See, e.g. In re Grand Jury Subpoena Duces Tecum Dated Oct. 29, 1992, 1 F.3d

not require any mind to pick and choose. Indeed, Jane Doe’s request is significantly narrower that other req

ights to appeal to the Department of Justice with the full consent and knowledge of the USAO, he has not breached the Agreement. The re-commencing of the Grand Jury is in violation of the Agreement. But further, the new investigation, which features a wide-ranging, fishing-expedition type to search in New York d

contains the following agreed condition: Further, upon execution of this agreement and a plea agreement with the State Attomey’s Office, the federal Grand Jury investigation will be suspended, and all pending federal Grand Jury subpoenas will be held in abeyance unless and until the defendant violates any te

in the former firm of Herman, Sloman, & Mermelstein, filed five lawsuits, each asking for $50 million, against Mr. Epstein. Each lawsuit is entitled “Jane Doe # vs. Jeffrey Epstein,” despite the fact that each of the plaintiffs is an adult and not entitled to plead anonymously. See Tab 32, Examples of Feder

OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defend

each County) (the "Florida Criminal Action"). As explained below, the parallel federal criminal action against him described in that motion (In re Grand Jury, No. FGJ 07-103(WPB), United States District Court for the Southern District of Florida) (the "Federal Criminal Action"), remains pending. On Septe

TRICT OF FLORIDA NO. 08-80119-CIV-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, v. JEFFREY EPSTEIN, Defenda

--- Case 9:08-cv-80119-KAM Document 33 Entered on FLSD Docket 08/05/2008 Page 2 of 5 CF 09454AXX (Fla. Cir. Ct. 2008)' and a federal case, hr re Grand Jury, No. FGJ 07-103(WPB) (S.D. Fla.), that arise out of the same occurrences and are pending and thus require a stay of this civil case. The federal "c