Epstein Secrets

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.

nction Restraining Fraudulent Transfer of Assets, Appointment of a Receive to Take Charge of Property of Epstein, and to Post a $15 Million Bond to Secure Potential Judgment (DE #165) ("Injunction Motion"), and states: EFTA00221931 Case 9:08-cv-80119-KAM Document 198 Entered on FLSD Docket 07/13/2009 Page 4 of 24 J

Entered: 07/06/2009) 189 ORDER granting 186 Motion for Extension of Time to Reply. Defendant has until July 14, 2009 to file a Reply to Plaintiffs Jane Doe's 2-7 Response to Defendant's Motion to Compel Identity.. Signed by Judge Kenneth A. Marra on 7/6/2009. (mkz) (Entered: 07/06/2009) Set/Reset Deadlin

Declarations of Jane Doe No. 4 and Y.B. in Further Support of Plaintiffs' Jane Does 2-7 Motion for Protective Order (Attachments: # 1 Declaration of Jane Doe 4, # 2 Declaration of Y.B.)(Mermelstein. Stuart) (Entered: 08/14/2009) 268 Sealed Document (rb) (Entered: 08/14/2009) 269 Unopposed MOTION for Exte

for Extension of Time to File Response/Reply to Defendant's Motions for Summary Judgment (Jane Doe 2, DE 539; Jane Doe 3 DE 141; Jane Doe 4, DE 157; Jane Doe 5, DE 139; Jane Doe 6, DE 91; Jane Doe 7, DE 107) by Jane Doe. (Attachments: # 1 Text of Proposed Order)(Horowitz, Adam) (Entered: 06/01/2010) 554 O

nction Restraining Fraudulent Transfer of ASsets, Appointment of a Receiver To Take Charge of Property of Epstein and to Post a $15 Million Bond to Secure Potential Judgment by Jane Doe. (Attachments: # 1 Text of Proposed Order) (Edwards, Bradley) Modified on 6/22/2009 (Is). (Entered: 06/19/2009) 166 Plaintiff's MOTION

$15 million Bond to Secure Potential Judgment, in Jane Doe v. Epstein, Case No. 08-CV-80893-Marra/Johnson.

ction Restraining Fraudulent Transfer of Assets, Appointment of a Receiver to Take Charge of Property of Epstein, and to Post a $15 million Bond to Secure Potential Judgment, in Jane Doe v. Epstein, Case No. 08-CV-80893-Marra/Johnson. The motion was reported in the press. Defendant, EDWARDS, admits that the motion was d

,08-80811, 09-80591, 09-80656, 08-80381, 08-80994, 08-80893, 09-80469, 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

ction Restraining Fraudulent Transfer of Assets, Appointment of a Receiver to Take Charge of Property of Epstein, and to Post a $15 Million Bond to Secure Potential Judgment (DE 165). Defendant Jeffrey Epstein filed a response in opposition to the motion (DE 198), and Plaintiff filed a reply (DE 217). The motion is now

MOTION to Compel Response to 1st RTP and 1st Interrogs filed by C.M.A.. (Hill. Jack) (Entered: 04/20/2009) 04/22/2009 63 MOTION for Leave to File Jane Doe's No. 101's Motion For Leave to File Brief as Amicus Curiae in Support of Plaintiff's Response in Opposition to Defendant Jeffrey Epstein's Motion to

unction Restraining Fraudulent Transfer of ASsets, Appointment of a Receiver To Take Charge of Property of Epstein and to Post a $15 Million Bond to Secure Potential Judgment by Jeffrey Epstein. (Attachments: # 1 Text of Proposed Order Order)(Pike. Michael) (Entered: 07/06/2009) 07/06/2009 189 ORDER granting 186 Motion