Epstein Secrets

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

elivered to anyone at Mr. E[psJtein's house." Affidavit of Richard Barnett at ¶ 2-3 (emphasis rearranged) (DE_7-1). The affidavit also stated that Bamett had been duly sworn. Barnett signed the document before a New York Notary Public, although it should be noted that the Notary does not properly ind

rnett"), is an individual residing in Broward County, Florida and, at all times relevant hereto, was the Director of Corporate Development for RRA. Barnett participated in the scheme by, among other things, recruiting and soliciting investors into the Ponzi scheme, participating in investor inducement m

Kerstetter, Caretsky, Gibraltar Bank, Berenfeld, Weintraub, Berkowitz, Leitstein, Levin, Preve, Banyon entities, Szafranski, Onyx, Villegas, Boden, Barnett, Stay, Platinum, and Centurion) and promoters (TD Bank, Spinosa, Kerstetter, Caretsky, Gibraltar Bank, Levin, Preve, Banyon entities, Szafranski, O

Scott W. Rothstein, et at Complex Litigation Division - Case No.: 09-062943 (19) Third Amended Complaint 283. BFMC's explicit understanding from Bamett, Boden and Rothstein was that the putative defendant's settlement proceeds were pre-funded and being held in RRA's escrow trust account and could o

d Seigel into Rothstein's private office where the five of them participated in the meeting. 277. After brief introductions, Rothstein, Boden, and Bamett described to Florescue and Seigel an opportunity involving the lump-sum purchase of various pre-funded confidential settlements with structured pay

n under penalty of perjury that he does not reside at that address. (See Barnett Aff.) Plaintiff has not submitted any evidence to suggest that Mr. Barnett is not credible, so allowing discovery on this point would simply be a waste of resources. 2 EFTA00724751 Case 9:08-cv-80381-KAM Document 32 Ent

Defendant in accordance with New York law, including that copies were sent through the mail. 'The Court again declines to allow discovery on whether Richard Bamett resides at Defendant's New York home. Mr. Bamett submitted an affidavit sworn under penalty of perjury that he does not reside at that address. (Se

copies were sent through the mail. 'The Court again declines to allow discovery on whether Richard Bamett resides at Defendant's New York home. Mr. Bamett submitted an affidavit sworn under penalty of perjury that he does not reside at that address. (See Barnett Aff.) Plaintiff has not submitted any e

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

"caretaker." 6. Plaintiff asserts that "Epstein concedes the materials were left at his "vacation home." (Id.) This assertion is misleading. Mr. Bamett's affidavit states only that the suit papers were discovered in the mailbox at 9 East 71g Street, New York, New York. (D.E. 7) 7. Paragraphs 14-22

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