Epstein Secrets

cv-81111-WPD Document 15 Entered on FLSD Docket 11/11/2010 Page 16 of 16 CASE NO: 08-CV-80119•MARRA/JOHNSON SERVICE LIST M.J. v. Jeffrey Epstein United States District Court, Southern District of Florida Lill Ann Sanchez Christo her E. Kni ht Helaine S. Goodner FOWLER WHITE BURNEMA Counsel for Defendant, Jeffrey Epst

legal counsel filed a motion to "quash" service of process, alleging that process was not properly made. Attached to the Motion was an Affidavit of Richard Barnett, which swore that an "unmarked and unpostmarked envelope was discovered in the mailbox at Mr. Epstein's vacation home in New York at 9 East 7111 St

nothing short of an intentional fraud being committed on the court. The circumstances surrounding the making of this statement strongly suggest that Barnett swore to this false statement deliberately, for the purpose of obstructing proper proceedings in this case. Defendant Epstein's history of obstruct

not state who made the discovery. The affidavit does not state whether Bamett has personal knowledge of the facts contained in his affidavit. 13. Barnett subsequently filed a second affidavit, this time to merely announce that nobody named "Mark` was at the house on October 8, 2010. While this may be

hristopher E. Knight Fla. Bar No. 607363 -13- EFTA00725488 Case No. 9:10-cv-81111-WPD SERVICE LIST M.J. v. Epstein Case No. 9:10-cv-81111-WPD United States District Court, Southern District of Florida Bradley J. Edwards Farmer, Jaffe, Weissing, Edwards Fistos & Lehrman, PL Telephone: Facsimile: Attorneys for Plai

testify. The Court should also deny Plaintiff's motion for Rule 11 sanctions based upon the submission of an allegedly fraudulent affidavit by Mr. Barnett. Plaintiff has not offered any probative evidence of fraud, relying solely on caustic rhetoric. Moreover, Plaintiff has violated the mandatory saf

tant case solely to harass the Defendant and create a tempest in a teapot? Conduct involving two witnesses in prior litigation, neither of whom is Richard Bamett, is patently irrelevant to the narrow, threshold issue of whether substitute service was properly made in the instant case, and should 2Plaintiff's

it card program was sentenced to 78 months in federal prison Tuesday. The article added that Judge Henry Lee Adams Jr. sentenced Amit Patel, 31, in the U.S. District Court in Jacksonville. Patel, wearing a charcoal suit and a burgundy tie, showed no emotion inside the packed courthouse as the punishment was handed down

1655810 Boeing, was found dead in a car outside a Holiday Inn from what appeared to be a self-inflicted gunshot wound. The articles explained that Barnett had been involved in several whistleblower cases regarding concerns over quality and safety at Boeing, including discarded metal shavings near wirin

ho are not authorized to receive electronically Notices of Electronic Filing. s/Lillv Ann Sanchez Lill a Ann chez SERVICE LIST MJ. v. Epstein United States District Court, Southern District of Florida Bradley J. Edwards Fanner, Jaffe, Weissing, Edwards Fistos & Lehrman, PL Telephone: Facsimile: Attorneys for Plai

action, a Civil Rico Case Statement, a deposition subpoena, notices of video depositions, interrogatories and requests for production. (Ex. A, Aff. Richard Barnett). 3. Service was never delivered to anyone at Mr. Epstein's vacation home in New York. (Id.). 4. On or about October 13, 2010, Plaintiff's couns

to receive electronically 4 EFTA00728928 Notices of Electronic Filing. s/Christopher E. Knight Christopher E. Knight SERVICE LIST v. Epstein United States District Court, Southern District of Florida Bradley J. Edwards Farmer, Jaffe, Weissing, Edwards Fistos & Lehrman, PL 425 North Andrews Avenue, Suite 2 Fort La

bject action, a Civil Rico Case Statement, a deposition subpoena, notices of video depositions, interrogatories and requests for production. (A ff. Richard Barnett). 3. Service was never delivered to anyone at Mr. Epstein's vacation home in New York. (Id.). 4. There is no return of service in the court file