Epstein Secrets

due by 5/29/2009), MOTION to identify jane doe #102 in the third-party subpoenas for purposes of discovery, with incorporated memorandum of law by Jeffrey Epstein.(see docket entry 5 for image) (tas) (Entered: 05/12/2009) https://eef.flsd.uscourts.gov/egi-bin/DktRpt.p17825839498761356-L_801 0-1 6/10/2009 EFTA001

09-80656-CIV-Ryskamp JANE DOE No. 102, Plaintiff, v. JEFFREY EPSTEIN, Defendant, RESPONSE IN OPPOSITION TO MOTION TO PROCEED ANONYMOUSLY AND EPSTEIN'S MOTION TO COMPEL AND/OR IDENTIFY JANE DOE #102 IN THE STYLE OF THIS CASE AND MOTION TO IDENTIFY JANE DOE #102 IN THIRD-PARTY SUBPOENAS FOR PURPOS

erve so Epstein can defend this case. In support, Mr. Epstein states as follows: EFTA00175214 • Case 9:09-c

10/03/2008 4 r 82.8 KB ACKNOWLEDGMENT OF SERVICE Executed as to 2 Summons Issued, 1 Complaint Acknowledgement filed by Jane Doe No. 7. (Herman, Jeffrey) (Entered: 10/03/2008) 10/03/2008 5 fi 26.1 Ica NOTICE of Striking 4 Acknowledgment of Service filed by Jane Doe No. 7 by Jane Doe No. 7 (Her

175301 CM/Eg - Live Database - flsd Page 4 of 7 05/20/2009 18 n NOTICE by of Filing Withdrawal of Previously Raised Objections to Defendant, Jeey Epstein's Motion to Compel And/Or Identify in the Style of This Case and Motion to Identify . in Third-Party Subpoenas for Purposes of Discovery, Or, Altern

7 Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S FIRST AMENDED ANSWER & AFFIRMATIVE DEFENSES TO

statutory enactments is simply not present here, and the record is devoid of any factual material that would support such a conclusion.10 As Justice Blackmun said in dissent in Landsgraf, there is no vested right to break the law." Bottom line is, a motion to dismiss a claim is not the correct procedural

lease. 16 MR. INDYKE: Objection. To the extent the 17 knowledge of the facts of this case derive from 18 Mr. Dershowitz's representation of Mr. Epstein, 19 I don't think he can answer that question 20 without violating the privilege. 21 SPECIAL MASTER POZZUOLI: Hang on one 22 second. Did we h

ould have told you. 4 What I would have told you was that I have 5 documentation that could prove categorically that I 6 could not have been on Jeffrey Epstein's island 7 during the three-year period that is relevant. 8 I can prove categorically that I could not 9 have had sex or any contact with her at

omen. 25 MR. SCOTT: We covered this all in the www.phi sre orting.com EFTA00615762 642 1 last depo. 2 A. I never saw an underage person in Jeffrey 3 Epstein's house. I saw , who is a young 4 woman. I saw Giselle [sic] Maxwell, who is a young 5 woman. I saw women in their late 20s and 30s.

rive from 18 Mr. Dershowitz's representation of Mr. Epstein, 19 I don't think he can answer that question

police report, 4 have you been able to learn that fact? 5 A. I think it's false. I think it's a false 6 fact. When I was offered a massage at Jeffrey 7 Epstein's house, I received a legitimate massage by 8 a professional masseuse who hurt me. And I called 9 my wife and told her about it. I didn't

talk about my client being presumed 14 innocent, my client being innocent. That's part of 15 the role of a criminal defense lawyer. Justice 16 Blackmun has said that the criminal defense lawyer's 17 role does not end in a courtroom, it continues to 18 the courthouse steps. 19 And so when my cli

cument 36 Entered on FLSD Docket 06/12/2009 Page 1 of 19 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE II Plaintiff, VS. JEFFREY EPSTEIN, and Defendants. ) CASE NO.: 09-80469-CIV-MARRA ) ) ) ) ) ) ) ) ) PLAINTIFF'S AMENDED' MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANT EP

IN, and Defendants. ) CASE NO.: 09-80469-CIV-MARRA ) ) ) ) ) ) ) ) ) PLAINTIFF'S AMENDED' MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANT EPSTEIN'S MOTION TO DISMISS Plaintiff, JANE DOE II, through counsel, opposes Defendant's RICHARD EPSTEIN's Motion to Dismiss. Defendant's argument for a di

FF'S AMENDED' MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANT EPSTEIN'S MOTION TO DISMISS Plaintiff, JANE DOE II, thro

ISTRICT OF FLORIDA JANE DOE II Plaintiff, VS. JEFFREY EPSTEIN, and Defendants. ) CASE NO.: 09-80469

when there is a parallel state action. In that case, a bare majority of one held upheld the District Court's decision to abstain, however, Justice Blackmun, in casting the deciding vote, did so because he was of the opinion that the remedy sought (mandamus) was premature, since the Appellate Court whic

cument 20 Entered on FLSD Docket 05/22/2009 Page 1 of 20 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE II Plaintiff, VS. JEFFREY EPSTEIN, and Defendants. ) CASE NO.: 09-80469-CIV-MARRA ) ) ) ) ) ) ) ) ) PLAINTIFF'S MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANT EPSTEIN'S M

REY EPSTEIN, and Defendants. ) CASE NO.: 09-80469-CIV-MARRA ) ) ) ) ) ) ) ) ) PLAINTIFF'S MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANT EPSTEIN'S MOTION TO DISMISS Plaintiff, JANE DOE II, through counsel, opposes Defendant's RICHARD EPSTEIN's Motion to Dismiss. Defendant's argument for a di

PLAINTIFF'S MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANT EPSTEIN'S MOTION TO DISMISS Plaintiff, JANE DOE II, thro

ISTRICT OF FLORIDA JANE DOE II Plaintiff, VS. JEFFREY EPSTEIN, and Defendants. ) CASE NO.: 09-80469

when there is a parallel state action. In that case, a bare majority of one held upheld the District Court's decision to abstain, however, Justice Blackmun, in casting the deciding vote, did so because he was of the opinion that the remedy sought (mandamus) was premature, since the Appellate Court whic

ecause 18 I'd like to then file a formal complaint with the 19 FBI about that, or with the Justice Department. 20 I recommend that you speak to Jeffrey 12:20:33 21 Sloman. 22 Q. You know that is not the 12:20:35 23 only person who has sworn under oath that you were 24 present at Jeffrey E

o Jeffrey 12:20:33 21 Sloman. 22 Q. You know that is not the 12:20:35 23 only person who has sworn under oath that you were 24 present at Jeffrey Epstein's Palm Beach home with 25 young girls, right? EFTA00601267 in 1 A. No. 12:20:54 2 Q. You don't know that? 12:20:55 3 A. No. I know that

t's not a 5 teenager. It's not a middle-aged woman. It's a 6 woman between the ages of 25 and 30. 7 Q. What was role in Jeffrey 12:48:32 8 Epstein's entourage? 9 A. She would, to my knowledge, arrange 12:48:37 10 transportation, she would arrange meetings when 11 meetings were occurring.

t as a result of your legal 7 representation of Mr. Epstein, I object to your 8 answering on that basis. If

ading hoping to get judicial immunity, yes, at 4 that point the appropriate response is in the court 5 of public opinion. 6 That's what Justice Blackmun said in a 15:46:00 7 concurring opinion in the Supreme Court, that the 8 duty of a lawyer does not stop at the courtroom door 9 but it continu

lose my abuse until I was in high school," he said. Juror No. 50 also had an excuse for why the alleged victims in this case kept going back to Mr. Epstein and Ms. Maxwell and accepting help from them even after they had been abused. The alleged victims' conduct, explained Juror No. 50, was irrelevant t

JN) GIIISLAINE MAXWE 'S MOTION FOR A NEW TRIAL Jeffrey S. Pagliuca Laura A. Menninger HADDON. M R AN &

alleged victims in this case kept going back to Mr. Epstein and Ms. Maxwell and accepting help from them even

to a finding that a defendant's constitutional right to a fair and impartial jury have been violated. McDonough, 464 U.S. at 553-56; id. at 556-57 (Blackmun, J., concurring); id. at 557-59 (Brennan, J., concurring in judgment). So long as a truthful answer would have subjected the juror to a challenge f

ry to prove the certainty of their innocence. The Jeffrey MacDonald case discussed previously, is a prime e

s a good deal of homogeneity over the generations of Harvard College classes, as well as homogeneity in a large part of any given class. Mr. Justice Blackmun doubted whether there was much difference between the Davis and Harvard programs, commenting that the “cynical” may say that “under a program such as