Epstein Secrets

privacy. 5. This is strictly a "fishing expedition" unrelated to any aspect of this case. A similar Request to Produce was served in the casel v. Jeffrey E. Epstein and , Case No. 502008CA025129XXXXMB Al, in front of Judge Garrison. A copy of the objection to the Notice is attached as Exhibit "B" and Judge Garr

BOARD CERTIFIED CVO-TRIAL LAWYER Sent by Fax and U.S. Mail Isidro M. Garcia, Esq. A LIMITED LIABILITY PARTNERSHIP April 13, 2009 Re: Doe II v. Epstein, et al. Case No. 09-80469-Civ-MARRA/JOHNSON ADELQUI.LBENAVENTE rmukumALINVBSTIOMOR BARBARA M. NkKENNA ASHLIE STOKEN-BARING BETTY STOKES PARALE

kKENNA ASHLIE STOKEN-BARING BETTY STOKES PARALEGALS RITA H. BUDNYK OP COUNSEL Dear Sid: Please be informed thal subpoenaed deposition in thel.L. Epstein case on April 16th, 2009 is hereby cancelled. Cordially Robert D. Critton, Jr. RDC/clz cc: Jack A. Goldberger, Esq. L•A•W•Y•E •R•S TELEPHONE

py of the case law and Florida Statutes cited in Defendant Epstein' otion to Dismiss, For More Definite Statement, a

ar Request to Produce was served in the casel v. Jeffrey E. Epstein and , Case No. 502008CA025129XXXXMB Al,

ar Request to Produce was served in the casel v. Jeffrey E. Epstein and , Case No. 502008CA025129XXXXMB Al,

OW CAB Defendant, Jeffrey Epstein, (hereinafter "Mr. Epstein"), by and through his undersigned attorneys, pur

2005) 2. Miami Herald Pub. Co. v. Ferre, 636 F.Supp. 970 (S.D. Fla. 1985) 3. Mantooth v. Richards, 557 So.2d 646 (Fla. 4th DCA 1990) 4. Lay v. Kremer, 411 So.2d 1347 (Fla. 1st DCA 1982) 5. Wright v. Yurko, 446 So.2d 1162, 1165 (Fla. 5th DCA 1984).; 6. American Diversified Ins. Srvcs., Inc. v. U

o privacy. 5. This is strictly a "fishing expedition" unrelated to any aspect of this case. A similar Request to Produce was served in the caa v. Jeffrey E. Epstein and Case No. 502008CA025129XXXXMB Al, in front of Judge Garrison. A copy of the objection to the Notice is attached as Exhibit "B" and Judge Garris

RIAL LAWYER Sent by Fax and U.S. Mail Isidro M. Garcia, Esq. Garcia Law firm P.A. A LIMITED LIABILITY PARTNERSHIP April 13, 2009 Re: Doe II v. Epstein, et al. Case No. 09-80469-Civ-MARRA/JOHNSON ADELQUI.LBENAVENTE rmemeom. I INVBSTIOMOR BARBARA M. NkKENNA ASHLER STOKEN-BARING BETTY STOKES PAR

OW CAB Defendant, Jeffrey Epstein, (hereinafter "Mr. Epstein"), by and through his undersigned attorneys, pur

ilar Request to Produce was served in the caa v. Jeffrey E. Epstein and Case No. 502008CA025129XXXXMB Al, i

py of the case law and Florida Statutes cited in Defendant Epstein' otion to Dismiss, For More Definite Statement, a

CASE NO. 502008CA037319XXXXMB AB Plaintiff, v. JE an Defendants. DEFENDANT'S, JEFFREY EPSTEIN, O

ilar Request to Produce was served in the caa v. Jeffrey E. Epstein and Case No. 502008CA025129XXXXMB Al, in

2005) 2. Miami Herald Pub. Co. v. Ferre, 636 F.Supp. 970 (S.D. Fla. 1985) 3. Mantooth v. Richards, 557 So.2d 646 (Fla. 4th DCA 1990) 4. Lay v. Kremer, 411 So.2d 1347 (Fla. 1st DCA 1982) 5. Wright v. Yurko, 446 So.2d 1162, 1165 (Fla. 5th DCA 1984).; 6. American Diversified Ins. Srvcs., Inc. v. U

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

another by force, or exertion of force directed toward another under such circumstances as to create a reasonable fear of imminent peril. See Lay'. Kremer, 411 So.2d 1347 (Fla. 1st DCA 1982). It must be premised upon an affirmative act - a threat to use force, or the actual EFTA00175636 Case 9:08-cv

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

ge of the plaintiffs complaint and construe Count I as a claim for common-law assault, that claim would also fail. As the court explained in Lay v. Kremer, 411 So. 2d 1347, 1349 (Fla. 1st DCA 1982), an assault is "an intentional, unlawful offer of corporal injury to another by force, or force unlawful

11, Plaintiff "demands judgment against Defendant Jeffrey Epstein for all damages available under 28 U.S.C

0/06/2008 Page 1 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2 Plaintiff, V. JEFFREY EPSTEIN, Defendant. --------------'' DEFENDANT'S. EPSTEIN. MOTION TO DISMISS AND MOTION FOR MORE DEFINITE STATEMENT DIRECTED TO PLAINTIFF'S AMENDED COMPL

------------'' DEFENDANT'S. EPSTEIN. MOTION TO DISMISS AND MOTION FOR MORE DEFINITE STATEMENT DIRECTED TO PLAINTIFF'S AMENDED COMPLAINT Defendant, JEFFERY EPSTEIN, by and through his undersigned counsel, moves to dismiss and for more definite statement of Plaintiff JANE DOE NO. 2's Amended Complaint. Rules 12

ntiff "demands judgment against Defendant Jeffrey Epstein for all damages available under 28 U.S.C. §2255(

nother by force, or exertion of force directed toward another under such circumstances as to create a reasonable fear of imminent peril. See Lay v. Kremer, 411 So.2d 134 7 (Fla. 1st DCA 1982). It must be premised upon an affirmative act - a threat to use force, or the actual Case 9:08-cv-80119-KAM

lsd Page 1 of 15 LRJ U.S. District Court Southern District of Florida (West Palm Beach) CIVIL DOCKET FOR CASE #: 9:08-cv-80232-KAM Doe No. 3 v. Epstein Assigned to: Judge Kenneth A. Marra Lead case: 2:flasaAhd Member case: (View Member Case) Case: 9:09-cv-80802-KAM Cause: 28:1332 Diversity-Perso

file this document. (Is) (Entered: 05/20/2009) 05/20/2009 2.$ NOTICE by C.M.A. of Filing Withdrawal of Previously Raised Objections to Defendant, Jeffrey Epstein's Motion to Compel And/Or Identify C.M.A. in the Style of This Case and Motion to Identify C.M.A. in Third-Party Subpoenas for Purposes of Discovery,

3/11/2008) 05/22/2008 4 AFFIDAVIT of Service for Summons and Complaint served on Jeffrey Epstein on May 7, 2008, filed by Jane Doe No. 3. (Herman, Jeffrey) (Entered: 05/22/2008) 05/29/2008 5 Plaintiffs MOTION for Entry of Default by Clerk Against Defendant by Jane Doe No. 3. (Attachments: # 1 Exhibi

plicable statute of limitations. WHEREFORE Defendant requests that this Court deny the re ' f sought by Plaintiff. Robert D. C itton, Jr. Attorney f. Defendant Epstein Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of the Court using CM/ECF. I also

nother by force, or exertion of force directed toward another under such circumstances as to create a reasonable fear of imminent peril. See Lay 1. Kremer, 411 So.2d 1347 (Fla. 1st DCA 1982). It must be premised upon an affirmative act - a threat to use force, or the actual exertion of force. See 3A F

- flsd ( Page 1 of 14 U.S. District Court Southern District of Florida (West Palm Beach) CIVIL DOCKET FOR CASE #: 9:08-cv-80381-KAM Doe No. 5'. Epstein Assigned to: Judge Kenneth A. Marra Lead case: 9:08-cv-80119-KAM Member case: (View Member Case] Case: 9:09-cv-80802-KAM Cause: 28:1332 Diversit

eth A. Marra on 5/20/2009. (1c3) (Entered: 05/20/2009) 05/20/2009 9B NOTICE by of Filing Withdrawal of Previously RaisedObjections to Defendant, Jeffrey Epstein's Motion to ConaitAnd/Or Identify . in the Style of This Case and Motion to IdentlfrM. in Third-Party Subpoenas for Purposes of Discovery, Or, Alter

4/17/2008) 05/22/2008 4 AFFIDAVIT of Service for Summons and Complaint served on Jeffrey Epstein on May 7, 2008, filed by Jane Doe No. 5. (Herman, Jeffrey) (Entered: 05/22/2008) 05/29/2008 5 Plaintiffs MOTION for Entry of Default by Clerk Against Defendant by Jane Doe No. 5. (Attachments: # I Exhibi

5 1. JEFFREY EPSTEIN, Plaintiff, Defendant. DEFENDANT EPSTEIN'S ANSWER & AFFIRMATIVE DEFENSES TO PLAINTIFF'S S

another by force, or exertion of force directed toward another under such circumstances as to create a reasonable fear of imminent peril. See Lay'. Kremer, 411 So.2d 1347 (Fla. 1st DCA 1982). It must be premised upon an affirmative act - a threat to use force, or the actual exertion of force. See 3A F

O PLAINTIFF JANE DOE N0.6'S COMPLAINT Defendant, JEFFERY EPSTEIN, by and through his undersigned counsel, moves t

/515-3148 Fax ( Co-Counsel for Defendant Jeffrey Epstein)

!h day of October, 2008: Adam D. Horowitz, Esq. Jeffrey Marc Herman, Esq. Stuart S. Mermelstein, Esq. 1

a reasonable fear of imminent peril. See Lay v. Kremer, 411 So.2d 1347 (Fla. 1st DCA 1982). It must be

1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80119-CIV-MARRA Jane Doe No. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. _______________________________/ OPINION AND ORDER ON MOTION TO DISMISS AND MOTION FOR MORE DEFINITE STATEMENT THIS CAUSE is before the

ed as less likely to complain to authorities or have credibility if allegations of improper conduct were made. Id. This was an important element of Epstein’s plan. Id. Defendant’s plan and scheme reflected a particular pattern and method. Am. Compl. ¶ 11. Upon arrival at Defendant’s mansion, the underag

ENT THIS CAUSE is before the Court upon Defendant Jeffrey Epstein (“Defendant”)’s Motion to Dismiss and Mo

d another under such circumstances as to create a fear of imminent peril, coupled with the apparent present ability to effectuate the attempt. Lay v. Kremer, 411 So.2d 1347, 1349 (Fla. 1st DCA 1982). A battery consists of the infliction of a harmful or offensive contact upon another with the intent to ca

: 191694 The Suppression of Science: The Case of Jeffrey MacDonald A case in which science has not yet pr

n a convoy since the women were shot and not gassed (emphasis added). Faurisson, who said he had researched the trial, knew that his own source, Dr. Kremer, had testified that the gas chambers did exist. Yet he deliberately omitted that crucial item from his book, while including the fact that the women