Epstein Secrets

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CV-80893-CIV-MARRA/JOHNSON JANE DOE, Plaintiff, vs. JEFFREY EPSTEIN, et al., Defendants. / Related Cases: 08-80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-80893, 0

12 13 14 15 16 17 18 19 20 21 22 23 24 25 in either 2001 or 2002? MR. YAREMA: Object to the form. A Fifth. Q Did you, in fact, call A.G. to come to Jeffrey Epstein's home and give him a massage in a sexual nature in 2001 or 2002? MR. YAREMA: Object to the form. A Fifth. Q Dld you

for a massage of a sexual nature? MR. YAREMA: Object to the Iona. A Fifth. Q Did Jeffrey Epstein tell you it was his intent during the course of A.G.'s visit to his home to persuade, induce or entice her to engage in sexual activity? MR. YAREMA: Object to the form. A Fifth. Q Didn't Jeffrey Ep

OF FLORIDA CASE NO. 08-80736-Civ-Marra/Johnson JANE DOE #1 AND JANE DOE #2, Plaintiffs, v. UNITED STAT

asonable opportunity for further investigation or discovery. Fed. R. Civ. P. 11(b). Rule 11 uses an objective standard. Kaplan v. DaimlerChrysler, A.G., 331 F.3d 1251, 1255 (11th Cir. 2003). The analysis is whether "a reasonable attorney in like circumstances could believe that his actions were fact

OF FLORIDA CASE NO. 08-80736-Civ-Marrailohnson JANE DOE #1 AND JANE DOE #2, Plaintiffs, v. UNITED STAT

asonable opportunity for further investigation or discovery. Fed. R. Civ. P. 11(b). Rule 11 uses an objective standard. Kaplan v. DaimlerChrysler, A.G., 331 F.3d 1251, 1255 (11th Cir. 2003). The analysis is whether "a reasonable attorney in like circumstances could believe that his actions were fact

ncorporate specific factual allegations from 2nd Amended Complaint 1.20 hr $360.00 03/25/2009 RHB Conference with paralegal regarding filing of Jane Doe's 2-5 Responses to 0.10 hr $30.00 Motions to Compel 03/25/2009 RHB Review Jane Doe's 2-7 2nd Amended Complaints for viable c/a, Count III 0.75 hr

yk regarding RICO 0.30 hr $90.00 03/03/2009 JMB Conference with Robert Critton a40 iv $200.00 03/03/2009 RDC Attend two hearings i M and A.G.); conference with Sid 1.60 hr $800.00 03/03/2009 RDC Memo to all 0.40 hr $200.00 03/0312009 RDC Conference with JMB and Rita re: new Compla

Balancing with the players stacked against you. Applied Cognitive Psychology, 16, 365-366 (Book Review). Loftus, E.F. & Guyer, M. (2002) Who Abused Jane Doe?: The Hazards of the Single Case History. Skeptical Inquirer. Part I. Vol 26, #3 (May/June), Pp. 24-32. Loftus, E. F. & Guyer, M. J. (2002) Who Abu

Roediger, D.L. Schacter & R.F. Thompson (Eds.) Encyclopedia of Learning and Memory. NY:: MacMillan, Vol I. Abelson, R.P., Loftus, E.F. & Greenwald, A.G. (1992) Attempts to improve the accuracy of self-reports of voting. In J.M. Tanur (Ed.) Questions about Questions: Inquiries into the Cognitive Bases

AM Document 48 Entered on FLSD Docket 03/21/2011 Page 4 of 42 Beach, Florida, and elsewhere. Among the girls he sexually abused were Jane Doe #1 and Jane Doe #2. Epstein performed repeated lewd, lascivious, and sexual acts on them, including (but not limited to) masturbation, touching of their sexual orga

sonable opportunity for further investigation or discovery. Fed. R. Civ. P. I1(b). Rule 1 1 uses an objective standard. Kaplan v. DaimlerChrysler, A.G., 331 F.3d I251, 1255 (11th ar. 2003). The analysis is whether "a reasonable attorney in like circumstances could believe that his actions were factu

KAM Document 79-1 Entered on FLSD Docket 05/03/2011 Page 2 of 31 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-Civ- JANE DOE #1 AND JANE DOE #2, Plaintiffs, v. UNITED STATES OF AMERICA, Defendant. BRUCE E. REINHART, Intervenor INTERVENOR'S MOTION FOR SANCTIONS Comes

easonable opportunity for further investigation or discovery. Fed. R. Civ. P. 11(b). Rule 11 uses an objective standard. Kaplan v. Dainderarysler, A.G., 331 F.3d 1251, .1255 (11th Cir. 2003). The analysis is whether "a reasonable • attorney in like circumstances could believe that his actions were

AM Document 48 Entered on FLSD Docket 03/21/2011 Page 4 of 42 Beach, Florida, and elsewhere. Among the girls he sexually abused were Jane Doe #1 and Jane Doe #2. Epstein performed repeated lewd, lascivious, and sexual acts on them, including (but not limited to) masturbation, touching of their sexual orga

reasonable opportunity for further investigation or discovery. Fed. R. Civ. P. 11(b). Rule 11 uses an objective standard. Kaplan'. Daimleravysler, A.G., 331 F.3d I251, 1255 (11th ar. 2003). The analysis is whether "a reasonable attorney in like circumstances could believe that his actions were factu

FLSD Docket 04/08/2011 Page 1 of 54 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 and JANE DOE #2, Petitioners, vs. UNITED STATES, Respondent. UNITED STATES' RESPONSE TO JANE DOE NI AND JANE DOE #2'S MOTION FOR FINDING OF VIOLATIONS OF TH

asonable opportunity for further investigation or discovery. Fed. R. Civ. P. 11(b). Rule 11 uses an objective standard. Kaplan ! DaintlerChrysler, A.G., 331 F.3d 1251, .1255 (11th Cir. 2003). The analysis is whether "a reasonable • attorney in like circumstances could believe that his actions were