Epstein Secrets

the privilege log to be insufficient on its face and not in compliance with the requirements of Fla. R. Civ. P. 1.280(v)(5) and Tigg Ins. Corp. v. Johnson, 799 So. 2d 339 (Fla. 4'h DCA 2001). Although that Order was vacated without prejudice on August 17, 2012, the trial court still required a proper

he emergency stay of proceedings, it was Epstein's counsel who worked with opposing counsel over the weekend and appeared at 8:30 a.m. before Judge Hafele in order to enter an Agreed Order nunc pro tunc so the clerk could seal the records temporarily. (App. E.) To be clear, Epstein wants a full in ca

assell S.J. Quinney College of Law at the University of Utah 383 S. University St. Salt Lake City, UT 84112 [email protected] The Honorable Donald W. Hafele Palm Beach County Courthouse 205 N. Dixie Highway, Room 10.1216 West Palm Beach, FL 33401 Co-Counsel for Intervenors E.W., L.M. and Jane Doe 12

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CV-80893-CIV-MARRA/JOHNSON JANE DOE, Plaintiff, vs. JEFFREY EPSTEIN, et al., Defendants. / Related Cases: 08-80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 0

to the form, and in 15 MR. YAREMA: Object to the form. 15 addition this is irrelevant and has already 16 A Fifth. 16 been addressed by Judge Hafele as an 17 Q Have you ever physically touched C.L.? 17 inappropriate question. That's my 18 MR. YAREMA: Object to the form. 18 objection. 19

al Support (561) 835-0220 EFTA00181799 Page 5 33: L,8 grounds10:25 guess 95:4 guest58:3 95:19 guilty41:18 guise21:24 H habit30:23 57:19 Hafele 80:16 Hafele's81:6 68:7,14,19 70:8 74:24 75:5 half 7:19 HAIND100:17 hands45:20 hanging 93:21 happened 28:9 34:4 39:25 happening 84:6 hara

.struck Epstein's duty to pay.Josefsbetg if he and.the victims· did not accept settlements -- capped.at $150,000 -- and 'instead pursued lawsuits. Johnson said it appears .the government was frying to. balance the lesser ·sentence for Epstein with recovering $150;000 for ~ach victi_m. 'Tve.11ever:, ev

hat they suffered psychological, ills after being paid to give him sexually-charged massages at his Palm Beach mansion when they were as young as 14. Hafele told Epstein's attorneys they c.ouldn't go on a fishing expedition. The medical records^ he said,, can't be sought until the women are asked whether

t they suffered psychological.ills after l?eing paid.to give him sexually-charged massages at his Palm Beach mahsionwheii they were as young as 14. Hafele t_old Epstein's attorneys they c.ouldn't go on a fish1ng expeditfon. The medical records, he said,. can!t be sought until the women are asked whethe

he Court finds the privilege log is insufficient on its face and does not comply with the requirements of F.R.C.P. 1.280(b)(5) and TIC Ins. Corp. v. Johnson, 799 So. 2d 339 (Fla. 4th DCA 2001). In all other respects the Motion is denied at this time." On May 8, 2012, Edwards provided Epstein with 163 pa

er. Ultimately, following a summary judgment motion by Edwards, Epstein dropped his lawsuit; currently pending before Judge Crow's successor, Judge Hafele, is a follow-on action, Edwards v. Epstein, for malicious prosecution by Epstein in filing his lawsuit in the first place. 6 EFTA00799319 Case 0

x and U.S. Mail Isidro M. Garcia, Esq. A LIMITED LIABILITY PARTNERSHIP April 13, 2009 Re: Doe II v. Epstein, et al. Case No. 09-80469-Civ-MARRA/JOHNSON ADELQUI.LBENAVENTE rmukumALINVBSTIOMOR BARBARA M. NkKENNA ASHLIE STOKEN-BARING BETTY STOKES PARALEGALS RITA H. BUDNYK OP COUNSEL Dear Sid:

0 minutes Hearing on Defendant Epstein's Motion to Dismiss, for More Definite Statement, and to Strike Directed to Plaintiffs Complaint Dear Judge Hafele: Enclosed please find a copy of the case law and Florida Statutes cited in Defendant Epstein' otion to Dismiss, For More Definite Statement, and to

ally provide a 'lead or clue' to evidence having a tendency to incriminate. 8. In Jane Doe No. 2 v. Epstein, Case No. 08-CIV-80119 MARRA/JOHNSON, the Court sustained Epstein's Fifth Amendment objections to several interrogatories asking Epstein to identify information potentially related to t

OBBIE M. MCKENNA ASHLIE STOKEN-BARING BETTY STOKES PARALEGALS RITA H. BUDNYK OP COUNSEL ED RICCI SPECIAL CONSUMER JUSTICE COUNSEL Dear Judge Hafele: Enclosed, please find Jeffrey Epstein's Response in Opposition to ll's Motion for Inspection and to Compel Discovery, which are set for hearing be

pstein, Palm Beach County Case #502008CA028058XXXXMB), Jane Doe (Jane Doe v. Jeffrey Epstein, United States District Court Case #08-civ-80893-Marra/Johnson), and any other person who is or was represented by Rothstein Rosenfeldt & Adler that has not 2 EFTA00724397 yet filed an action against Jeffrey

e time you were employed by RRA (or that is being claimed by the Trustee). 20. In the attached transcript dated July 31, 2009, you stated to Judge Hafele with regard to the E.W. and L.M. cases the following: 5 EFTA00724400 "What the evidence is really going to show is that Mr. Epstein — at least

ed on attorney-client work product privilege and no privilege log has been prepared. 14. Under the case of TIG Insurance Corporation of America v. Johnson, 799 So. 2d 339 (Fla. 4111 DCA 2001) and its progeny, states that the failure to timely provide a privilege log may be grounds to determine that a

e time you were employed by RRA (or that is being claimed by the Trustee). 20. In the attached transcript dated July 31, 2009, you stated to Judge Hafele with regard to the E.W. and L.M. cases the following: 5 EFTA00606616 "What the evidence is really going to show Is that Mr. Epstein — at least

o M. Garcia, Esq. Garcia Law firm P.A. A LIMITED LIABILITY PARTNERSHIP April 13, 2009 Re: Doe II v. Epstein, et al. Case No. 09-80469-Civ-MARRA/JOHNSON ADELQUI.LBENAVENTE rmemeom. I INVBSTIOMOR BARBARA M. NkKENNA ASHLER STOKEN-BARING BETTY STOKES PARALEGALS RUA H. BUDNYK OP COMPEL Dear Sid:

0 minutes Hearing on Defendant Epstein's Motion to Dismiss, for More Definite Statement, and to Strike Directed to Plaintiffs Complaint Dear Judge Hafele: Enclosed please find a copy of the case law and Florida Statutes cited in Defendant Epstein' otion to Dismiss, For More Definite Statement, and to

Document 13 Entered on FLSD Docket 07/15/2008 Page 1 of 8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON IN RE: JANE DOE, Petitioner. FILED by JUL 0 9 2008 STEVEN N. LAMMORE CLERK U.S MST. CS s.o. or nA.-wra. GOVERNMENT'S RESPONSE TO VICTIM'S EMER

specific tangible need arises in a civil case the relief should be sought in that case.' In other words, the Civil cases which are in front of Judge Hafele is one forum that Judge Marra said go to it. Judge Marra did not say that this Court does not have Jurisdiction to unseal its own sealed records or