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.

fore or shortly after a substantial debt was incurred. See In re Ramsurat, 361 B.R. at 254; In re Dealers Agency Services, Inc., 380 B.R. 608, 613 (M.D. Ha. 2007) (recognizing that the Eleventh Circuit adopted the "badges of fraud" to determine fraudulent intent); Fla. Stat. §726.105(2). Moreover, Ha.

im to survive the motion. See. egs, SJ Opp. at 12 ("far from supporting summary judgment for the defendant, the evidence overwhelmingly inclines in Jane Doe's favor") (see other examples Carroll Reply Dec1.1 6). Further bolstering Doe's claims in the underlying case is the fact that evidence of sexual abu

beyond the power of evidence to controvert them.") (citation omitted)• accord Chick-Fil-A, Inc. v. CFT Development. LLC, 652 F. Supp. 2d 1252. 1260 (M.D. Ha. 2009), aff'd, No. 09- 15066, 2010 WL 1006661 (11th Cir. Mar. 19,2010): Bellefonte Re Ins. Co. v. Argonaut Ins. Co. 757 F.2d 523, 528-29 (2d Cir. 19

-cv-80736-KAM Document 462 Entered on FLSD Docket 06/24/2019 Page 1 of 32 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA JANE DOE 1 AND JANE DOE 2, Civil Action No. PETITIONERS, v. UNITED STATES OF AMERICA, RESPONDENT. 08-80736-CIV-MARRA • Government's Response to Petition

nces where a contract is clearly divisible." Galaxy Cable, Inc. v. Cablevision of Marion Cty., LLC, No. 5:05-CV-303-OC-GRJ, 2006 WL 2265419, at *3 (M.D. Ha. Aug. 8, 2006). A contract is considered to be "indivisible" when "each and all of its parts appear to be interdependent and common to one another

by-the ttemeyls-Offieer Mr. Edwards first saw a reference to the NPA on or after July 9, 2008, when the Government filed its responsive pleading to Jane Doe's emergency petition. That-pleading-was-the-first-publie mention-ef-the-neit-preseeution-agreement-and-the-fifst-diselesere-to-MirE4wards-(ead-thus-te

terial even if there 'certainly is a public interest in knowing more' about its contents." Tillman'. C.R. Bard, Inc., Case No. 3:13-cv-222-J-34JBT (M.D. Ha. March 13, 2014), 2014 U.S. Dist. LEXIS 41406, at *6, quoting Seattle Times Co.'. Rhinehart, 467 U.S. 20, 31 (1984) Placing limitations on the diss

eorgia before a Georgia notary), DE 4-2, Jane Doe No. 1 v. Epstein, Case No. 08- 80069-Civ-Marra (1/29/08); Intervenor's Complaint, at ¶ 2 (filed by "Jane Doe's Mother" and stating that "Jane Doe's Mother is a citizen and resident of the State of Georgia."), I)E 5-2, Jane Doe No. I v. Epstein, Case No. 08-8

t defendant is served. See Hill Dermaceuticals, Inc. v. RX Solutions, United Health Group, Inc., No. 6:08-cv-330-Or1-31KRS, 2008 WL 1744794, at *3 (M.D. Ha. Apr. 11, 2008) (concluding that removal petition was timely where it was filed within 30 days after the last defendant was served). 2. Notice has

eorgia before a Georgia notary), DE 4-2, Jane Doe No. l v. Epstein, Case No. 08- 80069-Civ-Marra (1/29/08); Intervenor's Complaint, at ¶ 2 (filed by "Jane Doe's Mother" and stating that "Jane Doe's Mother is a citizen and resident of the State of Georgia."). DE 5-2, Jane Doe No. I v. Epstein, Case No. 08-80

t defendant is served. See Hill Dermaceuticals, Inc. v. RX Solutions, United Health Group, Inc., No. 6:08-cv-330-Or1-31KRS, 2008 WL 1744794, at *3 (M.D. Ha. Apr. 11, 2008) (concluding that removal petition was timely where it was filed within 30 days after the last defendant was served). 2. Notice has