Epstein Secrets

t must be filed within 21 days. Fed. R. Civ. P. 12(a)(1)(A). False Statement by Richard Barnett, an Agent of Epstein 9. On October 29, 2010, Lilly Ann Sanchez, legal counsel for Epstein, filed a motion in this Court to Quash Service of Process. (DE 7). 4 EFTA00722414 Case 9:10-cv-81111-WPD Document 15

legal counsel filed a motion to "quash" service of process, alleging that process was not properly made. Attached to the Motion was an Affidavit of Richard Barnett, which swore that an "unmarked and unpostmarked envelope was discovered in the mailbox at Mr. Epstein's vacation home in New York at 9 East 7111 St

nothing short of an intentional fraud being committed on the court. The circumstances surrounding the making of this statement strongly suggest that Barnett swore to this false statement deliberately, for the purpose of obstructing proper proceedings in this case. Defendant Epstein's history of obstruct

not state who made the discovery. The affidavit does not state whether Bamett has personal knowledge of the facts contained in his affidavit. 13. Barnett subsequently filed a second affidavit, this time to merely announce that nobody named "Mark` was at the house on October 8, 2010. While this may be

ove, and that the Court grant such other and further relief as deemed necessary and proper. Respectfully submitted, s/Christopher E. Knight Lilly Ann Sanchez Fla. Bar No. 195677 Christopher E. Knight Fla. Bar No. 607363 Helaine S. Goodner Fla. Bar No. 462111 FOWLER WHITE BURNETT P.A. Espirito Santo

testify. The Court should also deny Plaintiff's motion for Rule 11 sanctions based upon the submission of an allegedly fraudulent affidavit by Mr. Barnett. Plaintiff has not offered any probative evidence of fraud, relying solely on caustic rhetoric. Moreover, Plaintiff has violated the mandatory saf

tant case solely to harass the Defendant and create a tempest in a teapot? Conduct involving two witnesses in prior litigation, neither of whom is Richard Bamett, is patently irrelevant to the narrow, threshold issue of whether substitute service was properly made in the instant case, and should 2Plaintiff's

. This case is CLOSED. Signed by Judge Kenneth A. Marra on 7/20/2010. (ir) (Entered: 07/20/2010) 09/02/2010 NOTICE of Attorney Appearance by Lilly Ann Sanchez on behalf of Jeffrey Epstein (Sanchez, Lilly Ann) (Entered: 09/02/2010) EFTA00226950 09/02/2010 213 Defendant's MOTION for Hearing Jeffrey Epst

ON for Entry of Default by Clerk Against Defendant Jane Doe No. 3 filed by Jeffrey Epstein. Replies due by 6/23/2008. (Attachments: # 1 Affidavit of Richard Barnett) (Goldberger, Jack) (Entered: 06/13/2008) Defendant's MOTION to Stay by Jeffrey Epstein. Responses due by 7/10/2008 (Goldberger, Jack) (Entered: 0

Jeffrey Epstein respectfully requests that service of process be quashed. Respectfully submitted, s/Lilly Arm Sanchez Christopher E Knight Lilly Ann Sanchez Helaine S. Goodner FOWLER WHITE BURNECt PA. Telephone: Facsimile: Counsel for Defendant Jeffrey Epstein 4 FiYinat WHITE BURItTr PA MEIMIIIMMII

action, a Civil Rico Case Statement, a deposition subpoena, notices of video depositions, interrogatories and requests for production. (Ex. A, Aff. Richard Barnett). 3. Service was never delivered to anyone at Mr. Epstein's vacation home in New York. (Id.). 4. On or about October 13, 2010, Plaintiff's couns

ly requests that service of process be quashed. Respectfully submitted, s/Christopher E. Knight Christopher E. Knight Fla. Bar No. 607363 Lilly Ann Sanchez Fla. Bar No. 195677 ner Fla. Bar No. 462111 FOWLER WHITE BURNETT P.A. Espirito Santo Plaza, 14th Floor 1395 Brickell Avenue Miami, Florida 331

bject action, a Civil Rico Case Statement, a deposition subpoena, notices of video depositions, interrogatories and requests for production. (A ff. Richard Barnett). 3. Service was never delivered to anyone at Mr. Epstein's vacation home in New York. (Id.). 4. There is no return of service in the court file

8. Lehrman PL 425 N Andrews Avenue Suite 2 Fort Lauderdale , FL 33301 USA 954-524-2820 Fax: 954-524-2822 Email: [email protected] Lilly Ann Sanchez [COR LD NTC] Fowler White Burnett 1395 Brickell Avenue 14TH Floor Miami , FL 33131-3302 USA 305-789-9200 Fax: 789-9201 Email: Lsanchez@fowle

of Jeffrey Epstein (Goldberger, Jack) (Entered: 06/13/2008) MOTION to Set Aside Clerk's Default by Jeffrey Epstein. (Attachments: # 1 Affidavit of Richard Barnett) (Goldberger, Jack) (Entered: 06/13/2008) RESPONSE in Opposition re 7 Plaintiff's MOTION for Judgment Upon Default and Order Setting Hearing on Da