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

ether there be sufficient cause to call upon the party to answer" the charge of criminal activity. Beavers" Henkel, 194 U.S. 73, 84 (1904) (quoting William Blackstone, 4 Commentaries *303). The grand jury's sole purpose is to inquire into whether there is probable cause to bring an individual before a tribunal to

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

hether t4re be sufficient cause to call upon the party to answer" the charge of criminal activity. Beavers" Henkel, 194 U.S. 73, 84 (1904) (quoting William Blackstone, 4 Commentaries *303). The grand jury's sole purpose is to inquire into whether there is probable cause to bring an individual before a tribunal to

RA rights to confer and fairness in cases involving white- collar and other wealthy defendants who commonly engage in pro-charge plea negotiations. Jeffrey Epstein's case illustrates my point. The U.S. Attorney's Office assigned specific attorneys, with AUSA Villafana being the lead prosecutor and primary attorn

rey Epstein. In her petition, Ms. Wild alleges that when federal prosecutors secretly negotiated and entered into a non- prosecution agreement with Epstein in 2007, they violated her rights under the CVRA—in particular, her rights to confer with the government's lawyers and to be treated fairly by the

ized by notorious sex trafficker and child abuser Jeffrey Epstein. In her petition, Ms. Wild alleges that

t resolves the federal investigation by allowing Mr. Epstein to plead to a state offense. The victims identif

rule, that where there is a legal right, there is also a legal remedy." Marbury v. Madison, 5 U.S. 1 Cranch 137, 163, 2 L.Ed. 60 (1803) (quoting 3 William Blackstone, Commentaries *23). For that reason, "[w]here legal rights have been invaded, and a federal statute provides for a general right to sue for such i

' Rights Act ("CVRA"), 18 U.S.C. § 3771, that affect all crime victims in this Circuit. After over a decade of litigation, the Majority holds that Jeffrey Epsteie's victims were not authorized to bring this petition because the CVRA does not permit stand- alone suits, and, therefore, it should have been dismisse

pstein. In her mandamus petition, Ms. Wild asserts that when federal prosecutors secretly negotiated and executed a non- prosecution agreement with Epstein in 2007, they violated her rights under the CVRA—in particular, her rights to confer with and to be treated fairly by the government's lawyers. We

ida to some extent). While he was in custody on these charges, Epstein was found dead. Statement of Attorney General William P. Barr on the Death of Jeffrey Epstein (Aug. 10, 2018), available at https://www.justice.gov/opa/pristatement-attorney-general-william-p- barr-death-jeffrey-epstein. In June 2020,

t resolves the federal investigation by allowing Mr. Epstein to plead to a state offense. The victims identifi

hat where there is a legal right, there is also a legal remedy." I I Marbuty v. Madison, 5 U.S. (I Cranch) 137, 163, 2 L.Ed. 60 (1803) (quoting 3 William Blackstone, Commentaries *23). I agree with the Majority, however, that the presence of rights- creating language alone does not establish that crime victims

1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA NO. 08-80119-CIV-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, v. JEFFREY EPSTEIN, Defendant. ___________________________/ ORDER DENYING MOTION TO STAY THIS CAUSE comes before the Court on Defendant Jeffrey Epstein’s Motion to Stay

nal action is pending until its final adjudication in the trial court. 18 U.S.C. § 3509 (k). In his motion, Defendant cites a state case, Florida v. Epstein, No. 2006 Case 9:08-cv-80119-KAM Document 33 Entered on FLSD Docket 08/05/2008 Page 1 of 5 As Defendant recognizes, the state court case was

AY THIS CAUSE comes before the Court on Defendant Jeffrey Epstein’s Motion to Stay (DE 12), filed June 20,

ther there be sufficient cause to call upon the party to answer” the charge of criminal activity. Beavers v. Henkel, 194 U.S. 73, 84 (1904) (quoting William Blackstone, 4 Commentaries *303). The grand jury’s sole purpose is to inquire into whether there is probable cause to bring an individual before a tribunal to

/JOHNSON JANE DOE NO. 2, Plaintiff, v. JEFFREY EPSTEIN, Defendant. ORDER DENYING MOTION TO STAY THIS CAUSE comes before the Court on Defendant Jeffrey Epstein's Motion to Stay (DE 12), filed June 20, 2008. The motion is now fully briefed and is ripe for review. The Court has carefully considered the motion

al action is pending until its final adjudication in the trial court. 18 U.S.C. § 3509 (k). In his motion, Defendant cites a state case, Florida v. Epstein, No. 2006 EFTA00215875 Case 9:08-cv-80119-KAM Document 33 Entered on FLSD Docket 08/05/2008 Page 2 of 5 CF 09454AXX (Fla. Cir. Ct. 2008)' and

V-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, v. JEFFREY EPSTEIN, Defendant. ORDER DENYING MOTION TO STA

her there be sufficient cause to call upon the party to answer" the charge of criminal activity. Beavers v. Henkel, 194 U.S. 73, 84 (1904) (quoting William Blackstone, 4 Commentaries *303). The grand jury's sole purpose is to inquire into whether there is probable cause to bring an individual before a tribunal to

V-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, 1. JEFFREY EPSTEIN, Defendant. ORDER DENYING MOTION TO STA

/JOHNSON JANE DOE NO. 2, Plaintiff, 1. JEFFREY EPSTEIN, Defendant. ORDER DENYING MOTION TO STAY THIS CAUSE comes before the Court on Defendant Jeffrey Epstein's Motion to Stay (DE 12), filed June 20, 2008. The motion is now fully briefed and is ripe for review. The Court has carefully considered the motion

nal action is pending until its final adjudication in the trial court. 18 U.S.C. § 3509 (k). In his motion, Defendant cites a state case, Florida.. Epstein, No. 2006 1 EFTA00221953 Case 9:08-cv-80119-KAM Document 33 Entered on FLSD Docket 08/05/2008 Page 2 of 5 CF 09454AXX (Fla. Cir. Ct. 2008)' a

ether there be sufficient cause to call upon the party to answer" the charge of criminal activity. Beavers" Henkel, 194 U.S. 73, 84 (1904) (quoting William Blackstone, 4 Commentaries *303). The grand jury's sole purpose is to inquire into whether there is probable cause to bring an individual before a tribunal to

/JOHNSON JANE DOE NO. 2, Plaintiff, 1. JEFFREY EPSTEIN, Defendant. ORDER DENYING MOTION TO STAY THIS CAUSE comes before the Court on Defendant Jeffrey Epstein's Motion to Stay (DE 12), filed June 20, 2008. The motion is now fully briefed and is ripe for review. The Court has carefully considered the motion

nal action is pending until its final adjudication in the trial court. 18 U.S.C. § 3509 (k). In his motion, Defendant cites a state case, Florida.. Epstein, No. 2006 1 EFTA00222382 Case 9:08-cv-80119-KAM Document 33 Entered on FLSD Docket 08/05/2008 Page 2 of 5 CF 09454AXX (Fla. Cir. Ct. 2008)' a

V-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, 1. JEFFREY EPSTEIN, Defendant. ORDER DENYING MOTION TO STA

ether there be sufficient cause to call upon the party to answer" the charge of criminal activity. Beavers" Henkel, 194 U.S. 73, 84 (1904) (quoting William Blackstone, 4 Commentaries *303). The grand jury's sole purpose is to inquire into whether there is probable cause to bring an individual before a tribunal to

/JOHNSON JANE DOE NO. 2, Plaintiff, v. JEFFREY EPSTEIN, Defendant. ORDER DENYING MOTION TO STAY THIS CAUSE comes before the Court on Defendant Jeffrey Epstein's Motion to Stay (DE 12), filed June 20, 2008. The motion is now fully briefed and is ripe for review. The Court has carefully considered the motion

al action is pending until its final adjudication in the trial court. 18 U.S.C. § 3509 (k). In his motion, Defendant cites a state case, Florida v. Epstein, No. 2006 EFTA01660018 Case 9:08-cv-80119-KAM Document 33 Entered on FLSD Docket 08/05/2008 Page 2 of 5 CF 09454AXX (Fla. Cir. Ct. 2008)' and

V-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, v. JEFFREY EPSTEIN, Defendant. ORDER DENYING MOTION TO STA

her there be sufficient cause to call upon the party to answer" the charge of criminal activity. Beavers v. Henkel, 194 U.S. 73, 84 (1904) (quoting William Blackstone, 4 Commentaries *303). The grand jury's sole purpose is to inquire into whether there is probable cause to bring an individual before a tribunal to

ket 08:05:2008 Page 1 of 5 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA NO. 08-80119-CIV-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, v. JEFFREY EPSTEIN, Defendant. ORDER DENYING MOTION TO STAY THIS CAUSE comes before the Court on Defendant Jeffrey Epstein's Motion to Stay (DE 12), filed June 20,

al action is pending until its final adjudication in the trial court. 18 U.S.C. § 3509 (k). In his motion, Defendant cites a state case, Florida v. Epstein, No. 2006 1 EFTA00014187 --- PAGE BREAK --- Case 9:08-cv-80119-KAM Document 33 Entered on FLSD Docket 08/05/2008 Page 2 of 5 CF 09454AXX (Fl

Y THIS CAUSE comes before the Court on Defendant Jeffrey Epstein's Motion to Stay (DE 12), filed June 20,

her there be sufficient cause to call upon the party to answer" the charge of criminal activity. Beavers v. Henkel, 194 U.S. 73, 84 (1904) (quoting William Blackstone, 4 Commentaries *303). The grand jury's sole purpose is to inquire into whether there is probable cause to bring an individual before a tribunal to