Epstein Secrets

tion cannot be used to enforce money damages or prevent a party of disposing of assets prior to the conclusion of an action at law." Id, .5_e_e also Briceno v. Bryden Investment, Ltd., 973 So. 2d 614, 616 (Fla. 3d DCA 2008) (noting that in Florida, an injunction cannot be entered to prevent a party of d

in Opposition to Jane Doe's Injunction Motion Page 22 of 24 V. CONCLUSION For the foregoing reasons, Epstein respectfully requests the Court deny Jane Doe's Injunction Motion. By: ROBERT D. CRITTON, JR., ESQ. Florida Bar No. 224162 MICHAEL J. PIKE, ESQ. Florida Bar #617296 DAVID A. YAREMA, ESQ. Flo

ane Doe's Request for Admissions attached as Exhibit C to Injunction Motion (DE #165). Based on this unsupported presumption of fraudulent transfer, Jane Doe asks the Court to impose significant and unjustified restraints on Epstein's assets. Simply put, Jane Doe is improperly seeking assurance she will b

rse inference would be wholly unreliable and is clearly impermissible under the instant circumstances. Additionally, granting the relief sought by Jane Doc based solely on an adverse inference would violate Epstein's Fifth Amendment rights. LaSalle Bank Lake View v. Seguban, 54 F.3d 387, 389 (7th Cir.

unction cannot be used to enforce money damages or prevent a party of disposing of assets prior to the conclusion of an action at law." Id. See also Briceno v. Bryden Investment, Ltd., 973 So. 2d 614, 616 (Fla. 3d DCA 2008) (noting that in Florida, an injunction cannot be entered to prevent a party of d

e's Injunction Motion Page 5 of24 relief requested by Jane Doe. For the following reasons, the Court must deny Jane Doe's Injunction Motion. II. JANE DOE'S STATEMENT OF MATERIAL FACTS IS BASED ON SPECULATION AND HEARSAY AND CONTAINS NO MATERIAL "FACTS" Jane Doe's "Statement of Material Facts" relies h

JANE DOE NO. 102, CASE NO.: 09-80656-CIV-MARRA/JOHNSON Plaintiff, JEFFREY EPSTEIN, Defendant. I EPSTEIN'S MEMORANDUM OF LAW IN OPPOSITION TO JANE DOE'S MOTION FOR INJUNCTION RESTRAINING FRAUDULENT TRANSFER OF ASSETS, APPOINTMENT OF A RECEIVER TO TAKE CHARGE OF PROPERTY OF EPSTEIN, AND TO POST A $1

7). In Florida, an injunction cannot be entered to prevent a party from using or disposing of his assets prior to the conclusion of a legal action. Briceno v. Bryden Investments, Ltd., 973 So.2d 614, 616 (Fla. 3d DCA 2008). See also SME Racks, Inc. v. Sistemas Mecanicos Para, Electronica, S.A. , 243 Fed

8-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 ____________________________________/ ORDER This cause is before the Court upon Plaintiff Jane Doe’s Motion for Injunction Restraining Fraudulent Transfer of Assets, Appointment of a Receiver to Take Charge of Property of Epstein, and to Post a $15