Epstein Secrets

ment 58 Entered on FLSD Docket 04/13/2009 Page 1 of 18 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80811-CIV-MARRA/JOHNSON C.M.A., Plaintiff, vs. JEFFREY EPSTEIN and SARAH KELLEN, Defendants. PLAINTIFF'S MEMORANDUM IN RESPONSE TO DEFENDANT, JEFFREY EPSTEIN'S, MOTIO

he Plaintiff, for the purpose of sexually assaulting the girls and/or coercing them to engage in prostitution in return for the payment of monies. (First Amended Complaint, ¶ 9). The scheme was motivated by the Defendant's sexual preference and obsession for minor girls. Id. Pursuant to the scheme, minor girls, includ

8 Case 9:08-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 2 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint 4. At all times material to this cause of action, the Defendant, JEFFREY EPSTEIN, had a residence located in Palm Beach C

8-cv-80811-KAM Document 40 Entered on FLSD Docket 02/09/2009 Page 35 of 91 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-C IV-MARRA/JOH NSON First Amended Complaint 84. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the same position as if he had been tried and convicted of the sexual offenses

osario "may be called upon to provide evidence is not sufficient to make [him a] necessary part[y]" under Rule 19(aX1)(A). Gibbs Wire & Steel Co. v Johnson, 255 F.R.D. 326, 330 (D. Conn. 2009); see Johnson v. Smithsonian Inst., 189 F.3d 180, 188-89 (2d Cir. 1999) ("Rule 19 does not list the need to obt

fs are contractually prohibited from suing or initiating, prosecuting, participating in or otherwise pursuing a suit against Molyneux. l A copy of First Amended Complaint filed in J.P. Molynex Studio, Ltd. and Juan Pablo Molyneux v. Jeffrey Epstein and L.S.J., LLC filed in the District Court of the Virgin Islands, Div

ment 113 Entered on FLSD Docket 06/05/2009 Page 1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80811-CIV-MARRA/JOHNSON Plaintiff, VS. Y EPSTEIN and Defendants. PLAINTIFF, M.'S, CONDITIONAL NOTICE OF INTENT TO EXCLUSIVELY RELY ON STATUTORY DAMAGES PROVIDED BY 18

ase 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 63 of 91 vs. Epstein, et al. Case No.: 08-CV-80811-C IV-MARRA/JOH NSON First Amended Complaint 147. For the second time in April of 2003, again returned to JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directe