Epstein Secrets

Case 9:08-cv-80119-KAM Document 16-2 Entered on FLSD Docket 07/01/2008 Page 2 of 4 : tiP • ' CASE PIO ±-122OO.1.:IFO-51/4 541sXXX CF V. JEFFREY E. EPSTEIN Z41 'FP ^i ria4 Y tr..mr.y..PRzia"rtnivz•zrt : . • . 7 'Crt. Rep. lun,L__ Date : • -17 vcri J „Asir )----=-- • / PD e--P:9fot Pres, D

events or omissions giving rise to the claim occurred in this District. Factual Allegations 7. At all relevant times, Defendant Jeffrey Epstein ("Epstein") was an adult male, 52 years old. Epstein is a financier and money manager with a secret clientele limited exclusively to billionaires. He is hims

, represented by Assistant United States , and Mr. Epstein, entered into a deferred- prosecution agreement (

' CASE PIO ±-122OO.1.:IFO-51/4 541sXXX CF V. JEFFREY E. EPSTEIN Z41 'FP ^i ria4 Y tr..mr.y..PRzia"r

ach, Florida 33401 Tel. 561 659 8300 Fax. 561 835 8691 By: Jack A. Goldberger Fla. Bar No. 262013 jgoldberger®agwpa.com Attorneys for Defendant Jay Epstein CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 711.A.3 While defense counsel admittedly did not confer with plaintiffs' counsel prior to filing the moti

l distress based on the same factual allegations. Defendant Epstein has moved to dismiss only Count I of the Complai

' CASE PIO ±-122OO.1.:IFO-51/4 541sXXX CF V. JEFFREY E. EPSTEIN Z41 'FP ^i ria4 Y tr..mr.y..PRzia"rt

imminent peril. See Gatto v. Pubblx Supermarket, Inc., 387 So. 2d 377, 379 (Fla. 3d DCA 1980) (holding that where there was no evidence to show that Gatto was placed in fear of imminent peril, there was no assault). In fact, the plaintiff does not even allege that Mr. Epstein touched her. Thus, there

21 LRJ, MEDREQ, REF_DISCOV U.S. District Court Southern District of Florida (West Palm Beach) CIVIL DOCKET FOR CASE #: 9:08-cv-80119-1CAM Doe v. Epstein Assigned to: Judge Kenneth A. Marra Referred to: Magistrate Judge Linnea R. Johnson Member case: (View Member Case) Case: 9:09-cv-80802-KAM Caus

ON Plaintiffs Jane Doe No. 101 and Jane Doe 102's Motion for No- Contact Order Plaintiffs Jane Doe No. 101 and Jane Doe No. 102's Reply to Defendant Jeffrey Epstein's Response to Plaintiffi Jane Doe No. 101 and Jane Doe No. 102's Motion for a No-Contact Order filed by Jane Doe No. 101, Jane Doe No. 102. Associate

red: 02/08/2008) 05/22/2008 4 AFFIDAVIT of Service for Summons and Complaint served on Jeffrey Epstein on May 7, 2008, filed by Jane Doe. (Herman, Jeffrey) (Entered: 05/22/2008) 05/22/2008 5 SUMMONS Returned Executed by Jane Doe. Jeffrey Epstein served on 5/7/2008, Answer due 5/27/2008. (Ik) (Entere

FTA00175604 CM/ECF - Live Database - flsd Page 17 of 21 05/20/2009 Ma NOTICE be. of Filing Withdrawal of Previously Raise Lions to Defendant. Jetey Epstein's Motion to Ag And/Or IdentifyMf. in the Style of This Case and Motion to Identi . in Third-Party Subpoenas for Purposes of Discovery, Or, Alternati

. 2 I JEFFREY EPSTEIN, Plaintiff, Defendant. DEFENDANT EPSTEIN'S ANSWER & AFFIRMATIVE DEFENSES TO PLAINTIFF'S S

legations in her complaint, the plaintiff went to Mr. Epstein's house to give him "a massage for monetary comp

ions fall far short of an "offer of corporal injury by force." There are no allegations that Jane Doe was placed in any fear of imminent peril. See Gatto 's. Publix Supermarket, Inc., 387 So. 2d 377, 379 (Fla. 3d DCA 1980) (holding that where there was no evidence to show that Gatto was placed in fea

008 Page 1 of 8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-80119-CIV-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN Defendant. I ---------------- MOTION TO DISMISS Defendant Jeffrey Epstein, pursuant to Rule 12(b) of the Federal Rules of Civil Procedure and Ru

COMPLAINT This action arises out of the alleged assault of the plaintiff. According to the allegations in her complaint, the plaintiff went to Mr. Epstein's house to give him "a massage for monetary compensation" (Compl. ,r 12), where Mr. Epstein allegedly assaulted her "in violation of Chapter 800 of

legations in her complaint, the plaintiff went to Mr. Epstein's house to give him "a massage for monetary comp

I ---------------- MOTION TO DISMISS Defendant Jeffrey Epstein, pursuant to Rule 12(b) of the Federal Ru

ions fall far short of an "offer of corporal injury by force." There are no allegations that Jane Doe was placed in any fear of imminent peril. See Gatto v. Publix Supermarket, Inc., 387 So. 2d 377, 379 (Fla. 3d DCA 1980) (holding that where there was no evidence to show that Gatto was placed in fear

v. Indyke, Case No. 19-cv-10475-LGS See, e.g., wants Ghislaine Maxwell to `rot in jail," NY Post (Dec. 4, 2019); Andrew Denney and Bruce Golding, "Jeffrey Epstein's no-bail ruling may encourage more accusers to come forward," NY Post (July 18, 2019) ("McCawley wouldn't identify her new clients but said she enco

ted pleadings involve Plaintiff's effort which were not and should not have been relevant to Plaintiffs false claim that she was sexually abused by Epstein as a minor. The Second Circuit in Brown itself redacted from the summary judgment pleadings and exhibits all of Ms. Maxwell's deposition answers in

o tnsealinu Sealed Materials Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN,

l the questions, lawsuit filed a lawsuit against Mr. Epstein to produce In fact, in connection with her cur

een admitted in a court of law; opening them up to the press presents an opportunity for abuse and misuse of the court's files. See United States v. Gatto, 17-CR-686 (LAK), 2019 WL 4194569, at *4 (S.D.N.Y. Sept. 3, 2019) ("documents merely shown to witnesses or otherwise discussed in Court but not off

008 Page 1 of 8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-80119-CIV-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN Defendant. MOTION TO DISMISS Defendant Jeffrey Epstein, pursuant to Rule 12(b) of the Federal Rules of Civil Procedure and Rule 7.1(A) of the Loc

COMPLAINT This action arises out of the alleged assault of the plaintiff. According to the allegations in her complaint, the plaintiff went to Mr. Epstein's house to give him "a massage for monetary compensation" (Compl. ¶ 12), where Mr. Epstein allegedly assaulted her "in violation of Chapter 800 of

-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN Defendant. MOTION TO DISMISS Defendant

legations in her complaint, the plaintiff went to Mr. Epstein's house to give him "a massage for monetary comp

imminent peril. See Gatto v. Pubblx Supermarket, Inc., 387 So. 2d 377, 379 (Fla. 3d DCA 1980) (holding that where there was no evidence to show that Gatto was placed in fear of imminent peril, there was no assault). In fact, the plaintiff does not even allege that Mr. Epstein touched her. Thus, there

008 Page 1 of 8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-80119-CIV-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN Defendant. MOTION TO DISMISS Defendant Jeffrey Epstein, pursuant to Rule 12(b) of the Federal Rules of Civil Procedure and Rule 7.1(A) of the Loc

COMPLAINT This action arises out of the alleged assault of the plaintiff. According to the allegations in her complaint, the plaintiff went to Mr. Epstein's house to give him "a massage for monetary compensation" (Compl. ¶ 12), where Mr. Epstein allegedly assaulted her "in violation of Chapter 800 of

-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN Defendant. MOTION TO DISMISS Defendant

legations in her complaint, the plaintiff went to Mr. Epstein's house to give him "a massage for monetary comp

imminent peril. See Gatto v. Pubblx Supermarket, Inc., 387 So. 2d 377, 379 (Fla. 3d DCA 1980) (holding that where there was no evidence to show that Gatto was placed in fear of imminent peril, there was no assault). In fact, the plaintiff does not even allege that Mr. Epstein touched her. Thus, there

e defendant's participation in conspiracies to transport and entice minor girls to travel with the intent that they engage in illegal sex acts with Jeffrey Epstein from 1994 through 1997, and the defendant's attempt to cover up that conduct during her civil deposition testimony in 2016. Specifically, the Indict

akes plain that the defendant is charged with engaging in a conspiracy to transport minor girls with intent that they engage in sexual activity with Epstein, engaging in a conspiracy to entice minor girls to travel with the intent that they engage in sexual activity with Epstein, aiding and abetting the

otion should accordingly be denied as moot. 65 In articular, fin page 12 of the notes from this 2006 intery line indicates tha s l , mor is that JE is gay," apparently referring to e Epstein's sexual orien ation. pt Out of an abundance of caution. today the Government has informed defense coun

intent that they engage in illegal sex acts with Jeffrey Epstein from 1994 through 1997, and the defendant

her recent trials in this District, and in those cases witnesses have typically been disclosed approximately three to four weeks before trial. E.g., Gatto, 17 Cr. 686 (LAK); Blaszczak, 17 Cr. 357 (LAK); Skelos, 15 Cr. 317 (KMW); Levin, 15 Cr. 101 (KBF); Silver, 15 Cr. 93 (VEC); Ulbricht, 14 Cr. 68 (KB

ugh his undersigned counsel, hereby submits this Response in Opposition to Plaintiff/Counter-Defendant Jeffrey Epstein’s Motion for Summary Judgment. Epstein seeks Summary Judgment on the claims of abuse of process and malicious prosecution set forth in Brad Edwards’ Fourth Amended Counterclaim. Each of th

he requisite elements is largely a question for a jury. See Patrick John McGinley, 21 Fla. Prac., Elements of an Action § 50:1 (2013-2014 ed.)(citing Gatto v. Publix Supermarket, Inc., 387 So. 2d 377 (Fla. 3d DCA 1980)). The usual case of abuse of process involves some form of extortion. Scozari v. Baro

Epstein. Sexual Abuse of Children By Epstein 1. Defendant Epstein has a nexual preference for young children. Depos