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rtions in his affidavit are based on a 2005 Vanity Fair article (the "2005 Vanity Fair Article"). See Vicky Ward, "The Talented Mr. Epstein," Vanity Fair chttp://vickyward.com/wordpress/archives/30> (January 24, 2005; accessed June 24, 2009). Mr. Cassell's affidavit is essentially a recitation of irr
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.
n d actors Kevin Spaoey and Chris Tucker to Africa on his private jet. Sudd everyone wanted, to enlyEr know who tein was. New York magazine an Vattity Fair published - lengthy profiles. The New York Post listed him as one of the city's most eligible bachelors and began describing him in its gossip co
ster after she caught him in flagrante with a 19-year-old coed. But don't feel too bad for her. Women's Wear Daily reports Boardman has a new man - Vanity Fair's Graydon Carter. Truman must not be too pleased. When Boardman dumped him, he needed to recuperate at a Buddhist retreat upstate. Editorial meetings
Accused of sexuality assaulting then- 14-year-old gift the litigation be halted until her daughter turns 18. • The mother com- plained that Jane Doe's father did not consult with her or their daughter before suing Epstein for $50mil- lion. The lawsuit al- leges sexual assault, intentional
2001, contending that the assessment of his home exceeded its. fair market value. He dismissed his lawsuit in December 2002. A profile of Epstein in VanityFair magazine said he owns what are believed to be the largest private homes in Manhattan - 51,000 square feet -and in New Mexico - a 7,500-acre ranch. Th
.powerful, politically connected money manager and simply refused to testify against him. In other cases, they said, the women changed their stories. Jane Doe 2, who is trying to have the non-prpsecution agreement thrown out, initially described Epstein as "an awesome man" arid told prosecutors she hoped “not
2001, con~ending thatthe assessmentof.his home exceedeqi(s fair market v:ilµe. He dismissec:l his lawsuit in December2002. A profile of Epstein in VanityFait magazine.said he owns what are believed to betheJargest private homes in Manhattan - s·I:,000 square feet - and in.New Mexico - .a 7,500-a.cre ranc
Thank you very much. MR. EDWARDS: I believe that the next client is going to also be a Jane Doe; so I think for the purposes of the record it will be Jane Doe 2. THE COURT: Yes. JANE DOE NO. 2: Good morning, your Honor. THE COURT: Good morning. How are you? JANE DOE NO. 2: Doing okay. I hadn't prepared any wo
starting around 1992.E?J She has also been referred to as the "Lady of the House" by Epstein's staff and as his "aggressive assistant".M In a 2003 Vanitm Fair profile on Epstein, author Vicky Ward said Epstein referred to Maxwell as "my best friend".1541 Ward also observed that Maxwell seemed "to organize
ged victims.(130 Victims' rights: Jane Does v. United States (2014) A December 30, 2014, federal civil suit was filed in Florida by Jane Doe ) and Jane Doe 2 against the United States for violations of the Crime Victims' Rights Act by the US. Department of Justice's IsiZajgd • Usatja and his limited 200
ting around 1992.15?) She has also been referred to as the "Lady of the House" by Epstein's staff and as his "aggressive assistant".15-31 In a 2003 Vani Fair profile on Epstein, author Vicky Ward said Epstein referred to Maxwell as "my best friend". Ward also observed that Maxwell seemed "to organize muc
alleged victims. Victims' rights: Jane Does v. United States (2014) A December 3o, 2014, federal civil suit was filed in Florida by Jane Doe and Jane Doe 2 against the United States for violations of the Crime Victims' Rights Act by the U.S. Department of Justice's NPA with Epstein and his limited 2008
f, starting around1992.M She has also been referred to as the "Lady of the House" by Epstein's staff and as his "aggressive assistant"Ja In a 2003 Vani Fair profile on Epstein, author Vicky Ward said Epstein referred to Maxwell as "my best friend" Ward also observed that Maxwell seemed "to organize much
s v. United States (2014) 50' 43 e L ecsosE tRA1`19.... PROs-i NENS1 PCS a I ChX.3 A December 3o, 2014, federal civil suit was filed in Florida by Jane Doe 1 (Courtney Wild) and Jane Doe 2 against the United States for violations of the Crime Victims' Rights Act by the U.S. Department of Justice's NPA w
pla leach county, obviously. es pre can an in that pielpeptic. 23 O. Toil r•- let's go through sea one that 24 ids remerebar. Other than too Vanity Nair ['porter. 25 ~what other reporters have any smabør of your Ft. ULM.. " - --- oesspaInt Eleadvtakes Blvd,. site 500 -Werst.Pairn beach" 33101-
ROWITZ: Adam Horowitz, counsel for plaintiffs Jane 2 through Jane Doe 7. THE COURT: Good morning. MR. EDWARDS: Brad Edwards, counsel for plaintiff Jane Doe. THE COURT: Good morning. MR. : Good morning, Your Honor. Sid for Jane Doe II. THE COURT: Good morning. MR. WILLITS: Good morning, Your Honor
f the publicity following his trip with Clinton, he must be in a very difficult place." According to S.E.C. and other legal documents unearthed by Vanity Pair, Epstein may have good reason to keep his past cloaked in secrecy: his real mentor, it might seem, was not Leslie Wexner but Steven Jude Hoffenberg
sought to gain access to economically disadvantaged younger girls in his home for paid massages. The 16-year-old girl, identified in the lawsuit as "Jane Doe No. 2," has suffered traumatic injuries, according to the complaint. When the first lawsuit was filed Epstein's attorneys said Epstein never had se
Entities connected to both Vanity Fair and Jane Doe

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSON
Paul Cassell
PERSONJack Goldberger
PERSON
Scarlett Johansson
PERSON
United States
LOCATION
Alan Dershowitz
PERSONthe Southern District
LOCATIONMaria Farmer
PERSON
George W. Bush
PERSONRobert D. Critton
PERSON
Adam D. Horowitz
PERSON
Ghislaine Maxwell
PERSONLeon Black
PERSON
Alexander Acosta
PERSONScott Rothstein
PERSON
A. Marie Villafana
PERSONRobert C. Josefsberg
PERSON
Department of Justice
ORGANIZATION