Epstein Secrets

ews reports contained in JP Morgan's due diligence reports-Epstein purchased at the age of 14. Like other women who received payments from Epstein, Jane Doe 1 listed Epstein's apartments on 66th Street in New York City as her address, which should have been a red flag to JP Morgan. 67. Epstein and/or his

29. Many of these women, particularly after Epstein's conviction in 2008, were trafficked from Eastern Europe. As the Government explained in its Second Amended Complaint, these women were recruited and, in several instances, required to many other Epstein victims in order to maintain their immigration status and the

uropean surnames who were publicly and internally identified as Epstein recruiters and/or victims. For example, Epstein paid more than $600,0000 to Jane Doe 1, a woman who—according to news reports contained in JP Morgan's due diligence reports-Epstein purchased at the age of 14. Like other women who recei

29. Many of these women, particularly after Epstein's conviction in 2008, were trafficked from Eastern Europe. As the Government explained in its Second Amended Complaint, these women were recruited and, in several instances, required to many other Epstein victims in order to maintain their immigration status and the

se No. 08-cv- 80736-MARRA/JOHNSON (S.D. Fla.) (the "Federal Action"). 6. According to the "Emergency Petition" filed in the Federal Action (DE #1), Jane Doe #1 is an adult who allegedly "was a victim of federal crimes committed by Jeffrey Epstein" ("Epstein") within the jurisdiction of the Southern Distr

Amended Counterclaim, which expands on the factual allegations of Edwards's and Cassell's tortious conduct in several ways: • First, the proposed Second Amended Complaint asserts an additional count for defamation based on the attorneys' actions in asserting the unsubstantiated and irresponsible allegation that Dersh

.D. Tenn. 2008). 5. Annexed hereto as Exhibit C is the Supplementary Affidavit of George Rush in this proceeding, sworn to on April 30, 2010. 6. Jane Doe's brief in opposition to Jeffrey Epstein's motion for summary judgment dismissing the federal claims in this action ("Si °pp.') may be found on PACER,

int in April 20O9, after EDWARDS joined RRA, the allegations against EPSTEIN in ■.'s complaint became even more salacious. In paragraph 12 of ■.'s Second Amended Complaint, ■. alleges among other things, that: "Jeffrey Epstein coerced, induced, or enticed . .the then minor Plaintiff to commit various acts of sexual

.D. Tenn. 2008). 5. Annexed hereto as Exhibit C is the Supplementary Affidavit of George Rush in this proceeding, sworn to on April 30, 2010. 6. Jane Doe's brief in opposition to Jeffrey Epstein's motion for summary judgment dismissing the federal claims in this action ("Si °pp.') may be found on PACER,

int in April 20O9, after EDWARDS joined RRA, the allegations against EPSTEIN in ■.'s complaint became even more salacious. In paragraph 12 of ■.'s Second Amended Complaint, alleges among other things, that: "Jeffrey Epstein coerced, induced, or enticed . .the then minor Plaintiff to commit various acts of sexual mi

ges that "Epstein committed willful acts of child sexual abuse" on her, which resulted in "mental or sexual injury," and "caused or likely to cause Jane Doe's mental or emotional health to be significantly impaired." 2d Am. Complaint, ¶25. The items sought are clearly relevant to the injuries and damages

s ability to earn a living and be self-supporting has not only a financial component, but also an emotional/psychological/mental component. In her Second Amended Complaint, Plaintiff attempts to allege claims in Count I for "Sexual Assault and Battery," Count II for "Intentional Infliction of Emotional Distress," and

eges that "Epstein committed willful acts of child sexual abuse" on her, which resulted in "mental or sexual injury," and "caused or likely to cause Jane Doe's mental or emotional health to be significantly impaired." 2d Am. Complaint, ¶25. The information sought is dearly relevant to the injuries and dama

nfidentiality of the information obtained through discovery. The evidence sought is relevant based on the facts and theories of this action. In her Second Amended Complaint, Plaintiff attempts to allege claims in Count I for "Sexual Assault and Battery," Count II for "Intentional Infliction of Emotional Distress," and

, ROTHSTEIN, EDWARDS (who either know or should have known) and, at times, L.M. in her Civil Action against EPSTEIN: a) ded claims for damages in Jane Doe's federal action in rces s of $50,000,000.00 rather than simply alleging the jurisdictional limits. b) Organized a Jane Doe TV media interview witho

aint in April 2009, after EDWARDS joined RRA, the allegations against EPSTEIN in <SL7 complaint became even more salacious. In paragraph 12 of .'s Second Amended Complaint, L.M. alleges among other things, that: "Jeffrey Epstein coerced, induced, or enticed . . .the then minor Plaintiff to commit various acts of sexu

ims under, as appropriate, state and federal law. These RICO claims alleged that it was no accident that young girls like his clients L. , E.W. and Jane Doe ended up in EPSTE1N's mansion where he sexually abused them. Inst d, the RICO claims contended that EPSTEIN ran an entire criminal organization that

and prosecute against El) ARDS and the pending, closely related counterclaims. FACTUAL BACKGROUND Plaintiff/Counterdefendant, EPSTEIN has filed a Second Amended Complaint against ED ARDS. The complaint challenges EDWARDS' professionalism as an attorney rep enting girls who had been sexually abused. In particular,

of 18 U.S.C. §§ 1591(a)(1) & (a)(2) by aiding, abetting, and inducing Epstein's and his conspirators sex-trafficking venture and sex trafficking of Jane Doe 1, as well as other Class Members. As a consequence, Jane Doe 1, as well as other members of the Class, are victims of JP Morgan's criminally aiding,

29. Many of these women, particularly after Epstein's conviction in 2008, were trafficked from Eastern Europe. As the Government explained in its Second Amended Complaint, these women were recruited and, in several instances, required to marry other Epstein victims in order to maintain their immigration status and th