Epstein Secrets

Defendant and the U.S. Attorney or State Attorney 1-4 Telephone records 5-6 Videos, photographs of residence 7 Documents relating to Plaintiff Jane Doe 8 Air travel records 10 Documents relating to modeling agencies I 1 Correspondence with other witnesses 14, 15, 16, 17, 19 Social networking do

out 2004-2005." Interrogatory No. 6. Identify all persons who came to the St. Residence and who gave a massage or were asked to give a massage to Defen ant. Answer: Defendant is asserting specific legal objections to the interrogatories as well as his U.S. constitutional privileges. I intend to re

JECT OF THE MOTION ID.E. 140. dated 4/13/101 Defendant, JEFFREY EPSTEIN, ("EPSTEIN"), by and through his undersigned counsel, replies to Plaintiff JANE DOE's Corrected Response In Opposition To EPSTEIN's Motion For Summary Judgment And Incorporated Memorandum Of Law And In The Alternative, For Opportunit

23nd day of April, 2010: EFTA00611610 Jane Doe v. Epstein Case No. 0S-CV-80893-Marra-Johnson Page 10 Jack Alan Goldberger, Esq. Counsel for Defen ant Je rey Epstein Brad Edwards, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos Counsel for Plaintiff in Related Case No. 08-80893 Paul G. Cassel

. Defendants in civil actions. - EXHIBIT A_ EFTA00221878 Case 9:08-cv-80119-KAM Document 148-2 Entered on FLSD Docket 06/09/2009 Page 2 of 10 Jane Doe No. 2 v. Epstein Page 2 '... a civil defendant who raises an affirmative defense is not precluded from asserting the privilege [against self-incri

Bar No. 224162 MICHAEL J. PIKE, ESQ. Florida Bar #617296 BURMAN, CRITTON, LUTTIER & COLEMAN 515 N. Flagler Drive, Suite 400 01 (Co-Counsel for Defen ant effrey Epstein) EFTA00221887

s. To inform Jane Doe of dates that he had arranged, Evans called Jane Doe on a cellular telephone that she had acquired from him. Evans also gave Jane Doe's cellular telephone number to customers and told Jane Doe to arrange dates when customers called. During the dates, Ev- ans called Jane Doe on the

repeated references to what would be performed upon meeting the minor; (3) the transmission of a sexually suggestive photograph; and (4) travel by Defen t to meet the minor. See, e.g., United dr States Meek, 366 F.3d 705, 720 (9th Cir.2004); Root, 2 6 F.3d at 1229. The instant case contains all f