Epstein Secrets

uthern District of Florida . However, the NPA does not provide Epstein with any protection from criminal investigation or prosecution other than in the Southern District of Florida. As the court has acknowledged in its orders (e.g., DE 462), complaints in these related matters allege that Epstein both resided in and

Doe v. Epstein 08-CV80119 Page No. 26 also Fed.R.Civ.P. 26(b)(1) and Fla. Stat. 768.72; Gallina v. Commerce And Industry, Ins., 2008 WL 3895918 (S.D. Ha. 2009)(unless liability for punitive damages is established at trial, the discovery sought is not relevant). In Gallina, the court held that in lig

n alleged that, "[u]pon information and believe, [Jeffrey Epstein] is engaged in plea negotiations with the Office of the United States Attorney for the Southern District of Florida concerning federal crimes which he is alleged to have committed against minor children, including [Jane Doe No. 1]." DE 1 at 1-2. Jane D

ding royalty, politicians, businessmen, and professional and personal acquaintances. Complaint, Jane Doe No. 102 v. Epstein, No. 9:09-CV-80656- KAM (S.D. Ha. May 1, 2009). 3. In 2006, at the request of the Palm Beach Police Department, the Federal Bureau of Investigation opened an investigation into all

the parallel federal criminal action against him described in that motion (In re Grand Jury, No. FGJ 07-103(WPB), United States District Court for the Southern District of Florida) (the "Federal Criminal Action"), remains pending. On September 24, 2007, the United States Attorney's Office for the Southern District

ldberger Fla. Bar No. 262013 Attorneys for Defendant Jeffrey Epstein CERTIFICATE OF SERVICE 1 HEREBY CERTIFY that this motion, in accordance with S.D. Ha. L.R. 5.4, has not been served on opposing counsel and was filed under seal on July 10, 2008. Michael R. Tein 4 EFTA00221171

ully states as follows: 1. This civil action is a private counterpart to two ongoing criminal actions, one in Palm Beach state court, the other in the Southern District of Florida. 2. These cases purport to arise from the same occurrence: the alleged sexual assault of a minor, Jane Doe No. 2. 3. On June 20, 2008

N, Defendant. DEFENDANT'S MOTION FOR ENLARGEMENT OF TIME TO ANSWER OR OTHERWISE RESPOND TO COMPLAINT Defendant Jeffrey Epstein moves, pursuant to S.D. Ha. L.R. 7.1(A), for an enlargement of time to answer or otherwise respond to the complaint until ten days after his motion for a mandatory stay, file

risdiction of this Court. This case is properly removable because it falls within the original jurisdiction of the United States District Court for the Southern District of Florida. See 28 U.S.C. § 1332(a)(1) (establishing that federal district courts have original I C.M.A. v. Epstein et aL, Case No. 50 2008 CA 005

See Jane Doe No. 2 v. Jeffrey Epstein, No. 08-CV-80119-1CAM (S.D. Fla. filed Feb. 6, 2008); Jane Doe No. 3 v. Jeffrey Epstein, No. 08-CV-80232-KAM (S.D. Ha. filed Mar. 5, 2008); Jane Doe No. 4 v. Jeffrey Epstein, No. 08-CV-80380-KAM (S.D. Fla. filed Apr. 14, 2008); Jane Doe No. 5 v. Jeffrey Epstein, No

risdiction of this Court. This case is properly removable because it falls within the original jurisdiction of the United States District Court for the Southern District of Florida. See 28 U.S.C. § 1332(a)(1) (establishing that federal district courts have original v. Epstein et at, Case No. 50 2008 CA 005240 XXXX M

rement of complete diversity. (a) Plaintiff= is a citizen of Florida. (Compl. ¶ 2.) 3 See Jane Doe No. 2 v. Jeffrey Epstein, No. 08-CV-80119-KAM (S.D. Ha. filed Feb. 6, 2008); Jane Doe No. 3 v. Jeffrey Epstein, No. 08-CV-80232-KAM (S.D. Ha. filed Mar. 5, 2008); Jane Doe No. 4 v. Jeffrey Epstein, No.

ent should shock the conscience of anyone familiar with its details. "These problems run far beyond those identified by the U.S. District Court for the Southern District of Florida, which ruled that federal prosecutors violated the Crime Victims' Rights Act by hiding the terms of the deal from the women and girls th

the briefing remains sealed, the decision of District Judge Kenneth E. Marra denying the motion, Doe v. United States, 950 F. Supp. 2d 1262, 1266 (S.D. Ha. 2013), reveals that the government argued the victims did not have standing because the relief they sought—the vacation or rescission of the non-pr

s Orders Unsealing the NPA.1° Nor did the trial court's rejection of Petitioner's comity argument depart from the essential requirements of law. In the Southern District of Florida, one of the minor victims of Epstein filed a Petition for Enforcement of Crime Victim's Rights Acts (A-1)." The victim also asked the fe

oe No. 71. Epstein, Case No. 08-80993 (S.D. Fla. 2008); Doe No. 6'. Epstein, Case No. 08-80994 (S.D. Fla. 2008); Doe II Epstein, Case No. 09-80469 (S.D. Ha. 2009); Doe No. 101 Epstein, Case No. 09-80591 (S.D. Fla. 2009); Doe No. 102'. Epstein, Case No. 09-80656 (S.D. Fla. 2009); Doe No. 81. Epstein, C

orida, and the Defendant will be served by the following procedure; THEREFORE, on the authority of R. Alexander Acosta, United States Attorney for the Southern District of Florida, prosecution in this District for these offenses shall be deferred in favor of prosecution by the State of Florida, provided that Epstein

pstein, 2009 WL 383332 (S.D. Fla. Feb. 12, 2009); Doe No. 31. Epstein 2009 WL 383330 (S.D. Fla. Feb. 12, 2009); Doe No. 41. Epstein, 2009 WL 383286 (S.D. Ha. Feb. 12, 2009); and Doe No. 5I. Epstein, 2009 WI, 383383 (S.D. Fla. Feb. 12, 2009); see also U.S. Scheidt, Slip Copy, 2010 WL 144837, fn. 1 (E.D.