Epstein Secrets

auderdale, FL 33301 Gary M. Farmer, Jr. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 N. Andrews Ave., Suite 2 Fort Lauderdal

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

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

rida. I am currently a partner in the law firm of Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. In 2008, I was a sole practitioner running a per

stein hee ‘also ‘Heei sanvedl: “with: nterrogatories ‘ad ‘requests. “for . 7 » production; all requests. have been met: with 5th amendment assertions Pane Epstein’ has not given Tan Ween oe By: ' Jane, Doe's: complaint: contains. a punitive ‘damages: clainn, and Mr Tistein: he “also. . a elected: to tiivoke th

ion that any of those people (other than. . Mr- Dershowitz) have spoken to Mr. Epstein about Jane Doe or.any of the other. specific victims of Mr. '- .Epstein’s molestation. Mr. Dershowitz ‘is acting as an ‘attorney for Mr. Epstein, and therefore it is. ; 4 presumably unlikely to question him about any admi

[email protected] Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Ave., Ste. 2 Ft. Lauder

6/17 Page 2 of 7 3. Attached as Exhibit B is a true and correct copy of an article by Sharon Churcher entitled “Teenage girl recruited by paedophile Jeffrey Epstein reveals how she twice met Bill Clinton,” DAILY MAIL, dated March 5, 2011. 4. Attached as Exhibit C is a true and correct copy of a statement on beha

E FBI to reopen case = Epstein’s Girl Friday http:/Awww.dailym ail.co.uk/news/article- 1363452/Bill-Clinton- 15-year-old-masseuse-|-met-twice-claims-Epsteins-girl.htm! 1/31 HOUSE_OVERSIGHT_014669 --- PAGE BREAK --- Case 1:15-cv-07433-RWS Document 539-2 Filed 01/06/17 Page 3of5 6/15/2016 against sex of

0 Fort Lauderdale, FL 33301 Gary M. Farmer, Jr. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 N. Andrews Ave., Suite 2 Fort Lauderdal

owing specific facts as the undisputed material facts in this case. Each of the following facts is numbered separately and individually to facilitate Epstein’s required compliance with Fla. R. Civ. P. 1.510(c) (“The adverse party shall identify . . . any summary judgment evidence on which the adverse party

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

tz (attached hereto as Exhibit “H”), she attached the proposed plea agreement describing Epstein’s witness tampering as follows: "UNITED STATES vs. JEFFREY EPSTEIN PLEA PROFFER” On August 21, 2007, FBI Special Agents E. Nesbitt Kuyrkendall and Jason Richards traveled to the home of Leslie Groff to serve her with a f

e Jane Does." Bradley J. Edwards, a partner with Farmer Jaffe Weissing Edwards Fistos & Lehrman in Fort Lauderdale, represents the Jane Does. He

Daily Business Review: Jeffrey Epstein's attorneys fight to keep plea discussions private Page 1 of 3 DAILY BUSINESS REVIEW.COM Select 'Print’ in your browser menu to print this document.

oe | and Jane Doe 2 say the agreement should be invalidated because they were not adequately informed of the plan not to file federal charges against Epstein. The defense attorneys’ motion to intervene states the sanctity of plea talks would be undermined if U.S. District Judge Kenneth Marra in West Palm

the invitation to fuel the media campaign against Mr. Epstein." Epstein has had plenty of trouble avoiding the

[email protected] Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Ave., Ste. 2 Ft. Lauder

ents, and world leaders are highly relevant and admissible (Motion in Limine 1) ..00...0.. eee eceeeeeeeeeeeeeeteeneene 6 2. Meeting Bill Clinton at Jeffrey Epstein’s private island twice (Motion in Limine 2)..... 8 FOIA responses and related materials are admissible (Motion in Limine 3).................. 8 io)

er intervening causes of emotional distress and related damages (Motion in Limine 14) 23 15. Plaintiff's lies about her age and the year she met Mr. Epstein must be exposed to the Jury (Motion in Limine 15)... cccccccccccssenseecseeessecssecsecsseesseeeseecssessecsesteesteeens 24 16. All of Plaintiff’s m

aintiff's lies about her age and the year she met Mr. Epstein must be exposed to the Jury (Motion in Limine 15

iminal Law, S.J. Quinney College of Law at the University of Utah. ** Associate, Snow, Christensen & Martineau (Salt Lake City, Utah). *** Partner, Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman (Fort Lauderdale, Fla.). The authors thank Douglas Beloof, Patricia Cassell, Meg Garvin, Jay Howell, James Marsh, and Stephen Twist for their assista

GING RIGHTS ATTACH UNDER THE CVRA ............... 90 A. A Test for Determining When Rights Attach.......0...000ccceeee 9] B. Applying the Test to the Epstein Case ..........ccccccceccccceceeeneees 93 C. Current Department Policy on Pre-charging Rights.................... 94 D. State Law Extension of Pre-ch

ll phases of the criminal justice process.° Congress drafted the CVRA, for example, broadly to make crime victims participants in criminal cases. The Jeffrey Epstein sex abuse case demonstrates the importance of victim participation even before charges are filed. A. A BRIEF HISTORY OF CRIME VICTIMS’ RIGHTS The c

riminal Law, S.J. Quinney College of Law at the University of Utah. ** Associate, Snow, Christensen & Martineau (Salt Lake City, Utah). *** Partner, Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman (Fort Lauderdale, Fla.). The authors thank Douglas Beloof, Patricia Cassell, Meg Garvin, Jay Howell, James Marsh, and Stephen Twist for their assista

for crime victims has arisen - specifically, the Jeffrey Epstein sex abuse case before a federal court in Florida. In that case, girls victimized by Epstein have argued that they should have been consulted about a federal nonprosecution agreement; Department attorneys have responded that because prosecuto

Congress sought to end that suffering by making victims meaningful participants in criminal cases. 3° C. AN ILLUSTRATION OF THE PRE-CHARGING ISSUE: THE JEFFREY EPSTEIN CASE Grven the potentially expansive scope of victims' rights under both state provisions and the CVRA, a critical question arises about how to appl