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ket 06/05/2009 Page 1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80811-CIV-MARRA/JOHNSON Plaintiff, VS. Y EPSTEIN and Defendants. PLAINTIFF, M.'S, CONDITIONAL NOTICE OF INTENT TO EXCLUSIVELY RELY ON STATUTORY DAMAGES PROVIDED BY 18 U.S.C. 42255 Plaintiff, ,
Defendant, JEFFREY EPSTEIN, ("EPSTEIN"), by and through his undersigned counsel, files his reply to Plaintiffs Memorandum in Response to Defendant, JEFFREY EPSTEIN's, Motion to Dismiss First Amended Complaint For Failure to State A Cause of Action; And Motion for More Definite Statement; Motion to Strike, And Sup
tion either under statutory or common law against Defendant EPSTEIN. Count I fails to plead any requisite elements o
tion to recover money damages against Defendant, JEFFREY EPSTEIN, for acts of sexual abuse and prostitutio
eed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enum
rivilege and risk loosing this case by virtue of not being able to present evidence, or waive that right and risk a potential criminal prosecution. Eastwood v, U.S., 2008 WL 5412857, *1 (E.D. Tenn.))("When a party to a civil action is subject to criminal proceedings and/or investigations that relate to s
al discovery beyond the limits of Fed.R.Crim.Pro. 16(b). Epstein satisfies the requirements to stay this action as set forth in St. Paul Fire and in Eastwood, including the similarity of issues underlying the civil litigation and ongoing criminal investigation. As such, a stay should be entered in the in
reates big investment profits for billionaire clients without revealing how he does it or whose portfolios he ban, dies. But now, investment whiz Jeffrey Epstein's darkest personal secrets have allegedly been bared in an ex- plosive, seamy prostitution case in- volving underage girls Instead of marveling at hi
element as far as the age is concerned." Dekle said. After an 11-month investi- gation, Palm Beach police said there was probable cause to charge Epstein. 53. with unlawful sex acts with a minor Epstein: Two politicians have returned dona- tions since he was charged with soliciting minors. and
r jurors were then called into Brown's courtroom one by one and asked if they had heard VA 5.1.4.‘E sLir wrwrire °MIMS Moore was a juror in the Jeffrey limb murder trial until it was discovered she neglected to disclose her daughter's murder. Moore say anything about her life that had relevance t
house to give him massages, Goldberg- er said. "Mr. Epstein absolute- ly insisted anybody who came to his ho
. provide evidence that he knew the girls were teenagers. One girl couldn't show up when Mr. Epstein wanted because she had soccer Another time. Mr Ep- stein had to wait for his "massage session because the girl he wanted was still in class. Why didn't State Attorney Barry Krischer let a jury decide wh
lad of Ricky Bobby raced ahead of the competition to remain the box office champ for a second weekend with $23 mil- WATT SIYILSOThe Acsocerec n.. Eastwood honored BEVERLY HILLS - Actor Clint Eastwood ac- cepts the Founders Award from actor Mor- gan Freeman at the Golden Boot Awards. Established in 198
With Incorporated Memorandum Of Law Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN") by and through his unde
eal, substantial and not remote possibility that Epstein may face criminal prosecution by the United State
intiff, Defendant. ______________ / Defendant, Jeffrey Epstein's Reply to Plaintiff's Response In Opposi
right and risk a potential criminal prosecution. Eastwood v. U.S., 2008 WL 5412857, *1 (E.D. Tenn.))("When
this action as set forth in St. Paul Fire and in Eastwood, including the similarity of issues underlying t
2009 Page 1 of 7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA C.M. A., CASE NO.: 08-CIV-80811-MARRAIJOHNSON Plaintiff, r lEEEREIY EPSTEIN and■ Defendants, v. Defendant, Jeffrey Epstein's Reply to Plaintiff's Response In Opposition To Defendant's Motion To Stay And/Or Continue Action
COURT SOUTHERN DISTRICT OF FLORIDA C.M. A., CASE NO.: 08-CIV-80811-MARRAIJOHNSON Plaintiff, r lEEEREIY EPSTEIN and■ Defendants, v. Defendant, Jeffrey Epstein's Reply to Plaintiff's Response In Opposition To Defendant's Motion To Stay And/Or Continue Action For Time Certain With Incorporated Memorandum Of La
EEEREIY EPSTEIN and■ Defendants, v. Defendant, Jeffrey Epstein's Reply to Plaintiff's Response In Opposi
rivilege and risk loosing this case by virtue of not being able to present evidence, or waive that right and risk a potential criminal prosecution. Eastwood v. U.S., 2008 WL 5412857, *1 (ED. Tenn.))("Vvien a party to a civil action is subject to criminal proceedings and/or investigations that relate to s
al discovery beyond the limits of Fed.R.Crim.Pro. 16(b). Epstein satisfies the requirements to stay this action as set forth in St. Paul Fire and in Eastwood, including the similarity of issues underlying the civil litigation and ongoing criminal investigation. As such, a stay should be entered in the ins
CT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE, Plaintiff, v. JEFFREY EPSTEIN, Defendant. CASE NO.: 08-CIV- 80893 — MARRA/JOHNSON Defendant, Jeffrey Epstein's Reply to Plaintiff's Response In Opposition To Defendant's Motion To Stay And/Or Continue Action For Time Certain With Incorporated Memorandum Of La
To Defendant's Motion To Stay And/Or Continue Action For Time Certain With Incorporated Memorandum Of Law Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN") by and through his undersigned attorneys, hereby files his Reply to Plaintiffs Response In Opposition to Defendant's Motion to Stay Complaint (SI
N DISTRICT OF FLORIDA JANE DOE, Plaintiff, v. JEFFREY EPSTEIN, Defendant. CASE NO.: 08-CIV- 80893 —
rivilege and risk loosing this case by virtue of not being able to present evidence, or waive that right and risk a potential criminal prosecution. Eastwood v. U.S. 2008 WL 5412857, *1 (E.D. Tenn.)X"When a party to a civil action is subject to criminal proceedings and/or investigations that relate to suc
al discovery beyond the limits of Fed.R.Crim.Pro. 16(b). Epstein satisfies the requirements to stay this action as set forth in St. Paul Fire and in Eastwood, including the similarity of issues underlying the civil litigation and ongoing criminal investigation. As such, a stay should be entered in the in
From: To: Jeffrey Epstein Subject: about apartments Date: Wed, 18 May 2011 05:54:27 +0000 Attachments• Hi! I hope you are fine!!!! I was looking for a place to move, as y
From: To: Jeffrey Epstein Subject: about apartments Date: Wed, 18 May 201
From: To: Jeffrey Epstein Subject: about apartments Date: Wed, 18
nd all consistent - right place (district), price, room size and the people with whom it would be nice to live. Cheap apartments only in Harlem and Eastwood. There's even scary in broad daylight. And I have an idea. What if I try to rent the whole apartment in normal (not dangarouse) area and then I can
From: To: Jeffrey Epstein <[email protected]> Subject: Re: about apartments Date: Wed, 18 May 2011 11:23:20 +0000 Thank you. But I'm dissappointment only when I find t
From: To: Jeffrey Epstein <[email protected]> Subject: Re: about apart
From: To: Jeffrey Epstein <[email protected]> Subject: Re: abo
ind all consistent - right place (district), price, room size and the people with whom it would be nice to live. Cheap apartments only in Harlem and Eastwood. There's even scary in broad daylight. And I have an idea. What if I try to rent the whole apartment in normal (not dangarouse) area and then I can
TIEFEL,WILLIAM SMITH,HAROLD B COLE,JEFFREY A BRAUER,CAMILLA T LUBOTTA,JACK
OBERT A THE BREAKERS PALM BEACH INC EPSTEIN,JEFFREY TIEFEL,WILLIAM R MCCLOSKEY,
VESENAZ HOLDING CORP ELSON,EDWARD HEATHWOOD,DESMOND J BEYER,LAWRENCE WYCKKOFF,S
Entities connected to both Jeffrey Epstein and Eastwood

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Prince Andrew
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Woody Allen
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John F. Kennedy
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Eric Trump
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George Mitchell
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Alan Dershowitz
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George W. Bush
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Donald Trump
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Bradley Edwards
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United States
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Harry Reid
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Stephen Hawking
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Prince Charles
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