Epstein Secrets

, sets forth the following statements: FIRST: The name of the limited liability company is NES, LLC (the "Company"). ,SECOND: The county within the State of New York in which the office of the Company is to be located is the County of New York_ THIRD: The Company is not to have a specific date of dissolution in

BE ISSUED FOR BUSINESS PURPOSES: NAME (PRINT) SOCIAL SECURITY SIGNATURE CASH ADVANCE ACCESS? CREDIT LIMIT Shannon Pascuzzi DYES 'ONO 10,000.00 Emm Ta ler DYES ()NO 10,000.00 Tonirha Mackenzie OYES ONO & 5_000 on DYES ONO TOTAL CORPORATE CREDIT LIMIT REQUESTED: $ BILLING OPTIONS gONE CONSOLI

ements on the application for three corporate credit cards totaling $25,000 for Jeffrey's company NES, LLC issued in the names of Shannon Pascuzzi, Emmy Tayler and Jonitha Mackenzie which are being guaranteed by Mr. Epstein. EFTA00186439 DEPARTMENT OF THE ,REASURY INTERNAL REVENUE SERVICE HOLTSVILLE N

ida, has MI intent to stay in Palm Beach County after his incarceration and is otherwise suijuris. 4. Defendant, Mil is a citizen and resident of the State of New York and otherwise sui juris. EFTA00723266 5. This is an action for damages in excess of Fifteen Thousand Dollars (815,000), exclusive of interest a

missible evidence." Id.; see also Hickman 12 EFTA00723247 Case 9:08-cv-80119-KAM Document 242 Entered on FLSD Docket 08/04/2009 Page 13 of 22 v. Taylor, 329 U.S. 495, 507-508 (1947); Farnsworth v. Proctor and Gamble Co., 758 F.2d 1545, 1547 (11th Cir. 1985)(the Federal Rules of Civil Procedure "stro

d the company that its use of the word "university" violated state law, its name was changed to Trump Entrepreneur Initiative in 20105151 In 2013, the State of New York filed a $40 million civil suit against Trump University, alleging that the company made false statements and defrauded consumers.(9111 In addition,

after arriving in Ukraine in June 2019, he found that Zelenskyy was being subjected to pressure directed by Trump and led by Giuliani. According to Taylor and others, the goal was to coerce Zelenskyy into making a public commitment investigating the company that employed Hunter Biden, as well htips://

rial to this cause of action, Defendant, Jeffrey Epstein, was an adult male born in 1953. 7. Defendant, Sarah Kellen, is a citizen and resident of the State of New York. 8. At all times material to this cause of action, Defendant, Sarah Kellen, was an adult female. 9. At all times material to this cause of actio

t"); id. at 410 ("Simply put, once a federal court determines that it is without subject matter jurisdiction, the court is powerless to continue."); Taylor v. Appleton, 30 F.3d 1365, 1366 (11th Cir. 1994) ("[A] court must first determine whether it has proper subject matter jurisdiction before addressi

rial to this cause of action, Defendant, Jeffrey Epstein, was an adult male born in 1953. 7. Defendant, Sarah Kellen, is a citizen and resident of the State of New York. 8. At all times material to this cause of action, Defendant, Sarah Kellen, was an adult female. 9. At all times material to this cause of actio

t"); id. at 410 ("Simply put, once a federal court determines that it is without subject matter jurisdiction, the court is powerless to continue."); Taylor v. Appleton, 30 F.3d 1365, 1366 (11th Cir. 1994) ("[A] court must first determine whether it has proper subject matter jurisdiction before addressi

rial to this cause of action, Defendant, Jeffrey Epstein, was an adult male born in 1953. 7. Defendant, Sarah Kellen, is a citizen and resident of the State of New York. 8. At all times material to this cause of action, Defendant, Sarah Kellen, was an adult female. 9. At all times material to this cause of actio

t"); id. at 410 ("Simply put, once a federal court determines that it is without subject matter jurisdiction, the court is powerless to continue."); Taylor v. Appleton, 30 F.3d 1365, 1366 (11th Cir. 1994) ("[A] court must first determine whether it has proper subject matter jurisdiction before addressi

use this Complaint makes sensitive allegations of sexual assault and abuse upon a minor. 3. Defendant Jeffrey Epstein is a citizen and resident of the State of New York. 4. This is an action for damages in excess of $50 million. 5. This Court has jurisdiction of this action and the claims set forth herein pursuan

to effectuate their purpose), citing., Hickman v. Taylor 329 U.S. 495, 501, 507 (1947). 15. Next, the r

in the corporation. Claire was represented in the preparation of these agreements by defendant Green- spoon. Greenspoon is a member of the bar of the State of New York. He had, before and after the preparation of these agree- ments, represented Claire in personal mat- ters. Additionally, Greenspoon had at times r

)? the better reasoned conclusion is that Rule 612 does apply at depositions. 1. The Work Product Doctrine In the now famous case of Hickman 11. Taylor, 329 U.S. 495, 67 S.Ct. 385, 1 L.Ed. 451 (1947), the Supreme Court re- cognized the work product doctrine. The doctrine creates a "protected zone"

ll times material to this cause of action, Defendant, Jeffrey Epstein, was an adult male born in 1953. 7. Defendant, is a citizen and resident of the State of New York. 8. At all times material to this cause of action, Defendant, , was an adult female. 9. At all times material to this cause of action, the Defe

t"); id. at 410 ("Simply put, once a federal court determines that it is without subject matter jurisdiction, the court is powerless to continue."); Taylor v. Appleton, 30 F.3d 1365, 1366 (I I th Cir. 1994) ("[A] court must first determine whether it has proper subject matter jurisdiction before addres