Epstein Secrets

Y EPSTEIN RALD LEFCO r RT ESQ. COUNSEL TO JEFFR Y EPSTEIN LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR JEFFREY EP

in the woe position as they would have been had Mr. Epstein been convicted al trial. No more; no less. From

hearing shall be limited to the issue of whether Defendant Epstein's defense of the civil actions filed against him

of Breach USAO No. 2006R0 181 June 9, 2009 To Jeffrey H. Sloman Acting United States Attorney Robert

TATES ATTORNEY Dated: By: Dated: Dated: Dated: A. MARIE VILLAFARA ASSISTANT U.S. ATTORNEY JEFFREY EPSTEIN RALD LEFCO r RT ESQ. COUNSEL TO JEFFR Y EPSTEIN LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR JEFFREY EPSTEIN Case No. 08-80736-CV-MARRA P-011815 EFTA00192861 By signing this Addendum, Epstein assert

is 935 F.2d 385, 389-90 (1st Cir. 1991); see also United States'. Hoschouer, 224 Fed. Appx. 923, 926-27 (11th Cir. 2007) (unpublished opinion); cf. Gustafson'. Alloyd Co.. Inc., 513 U.S. 561, 570 (1995) ("[W]e adhere[] to the normal rule ... that "identical words used in different parts of -27- Case No.

DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE No. 101, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED COMPLAINT OR, IN THE ALTERNATIVE, FOR A MORE DEFINITE STATEMENT Defendant JEFFREY EPSTEIN, by and through his u

ed on FLSD Docket 05/26/2009 Page 27 of 36 Defendant's mansion in or about the spring of 2003," FAC ¶ 18, and that she later was "lured ... to the Epstein mansion on at least one and perhaps two other occasions in the spring and/or summer of 2003." Id. ¶ 19. Since these vague allegations leave open the

01, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S

, 935 F.2d 385, 389-90 (1st Cir. 1991); see also United States v. Hoschouer, 224 Fed. Appx. 923, 926-27 (11th Cir. 2007) (unpublished opinion); cf. Gustafson v. Allovd Co.. Inc., 513 U.S. 561, 570 (1995) ("[W]e adhere[' to the normal rule ... that "identical words used in different parts of -27- EFTA0018

DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE No. 101, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED COMPLAINT OR, IN THE ALTERNATIVE, FOR A MORE DEFINITE STATEMENT Defendant JEFFREY EPSTEIN, by and through his u

ed on FLSD Docket 05/26/2009 Page 27 of 36 Defendant's mansion in or about the spring of 2003," FAC ¶ 18, and that she later was "lured ... to the Epstein mansion on at least one and perhaps two other occasions in the spring and/or summer of 2003." Id. ¶ 19. Since these vague allegations leave open the

01, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S

, 935 F.2d 385, 389-90 (1st Cir. 1991); see also United States v. Hoschouer, 224 Fed. Appx. 923, 926-27 (11th Cir. 2007) (unpublished opinion); cf. Gustafson v. Allovd Co.. Inc., 513 U.S. 561, 570 (1995) ("[W]e adhere[' to the normal rule ... that "identical words used in different parts of -27- EFTA0021

DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE No. 101, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED COMPLAINT OR, IN THE ALTERNATIVE, FOR A MORE DEFINITE STATEMENT Defendant JEFFREY EPSTEIN, by and through his u

ed on FLSD Docket 05/26/2009 Page 27 of 36 Defendant's mansion in or about the spring of 2003," FAC ¶ 18, and that she later was "lured ... to the Epstein mansion on at least one and perhaps two other occasions in the spring and/or summer of 2003." Id. ¶ 19. Since these vague allegations leave open the

01, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S

, 935 F.2d 385, 389-90 (1st Cir. 1991); see also United States v. Hoschouer, 224 Fed. Appx. 923, 926-27 (11th Cir. 2007) (unpublished opinion); cf. Gustafson v. Allovd Co.. Inc., 513 U.S. 561, 570 (1995) ("[W]e adhere[' to the normal rule ... that "identical words used in different parts of -27- EFTA0021

DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE No. 101, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED COMPLAINT OR, IN THE ALTERNATIVE, FOR A MORE DEFINITE STATEMENT Defendant JEFFREY EPSTEIN, by and through his u

ed on FLSD Docket 05/26/2009 Page 27 of 36 Defendant's mansion in or about the spring of 2003," FAC ¶ 18, and that she later was "lured ... to the Epstein mansion on at least one and perhaps two other occasions in the spring and/or summer of 2003." Id. ¶ 19. Since these vague allegations leave open the

01, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S

, 935 F.2d 385, 389-90 (1st Cir. 1991); see also United States v. Hoschouer, 224 Fed. Appx. 923, 926-27 (11th Cir. 2007) (unpublished opinion); cf. Gustafson v. Allovd Co.. Inc., 513 U.S. 561, 570 (1995) ("[W]e adhere[' to the normal rule ... that "identical words used in different parts of -27- EFTA0022

DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE No. 101, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED COMPLAINT OR, IN THE ALTERNATIVE, FOR A MORE DEFINITE STATEMENT Defendant JEFFREY EPSTEIN, by and through his u

ed on FLSD Docket 05/26/2009 Page 27 of 36 Defendant's mansion in or about the spring of 2003," FAC ¶ 18, and that she later was "lured ... to the Epstein mansion on at least one and perhaps two other occasions in the spring and/or summer of 2003." Id. ¶ 19. Since these vague allegations leave open the

01, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S

, 935 F.2d 385, 389-90 (1st Cir. 1991); see also United States v. Hoschouer, 224 Fed. Appx. 923, 926-27 (11th Cir. 2007) (unpublished opinion); cf. Gustafson v. Allovd Co.. Inc., 513 U.S. 561, 570 (1995) ("[W]e adhere[' to the normal rule ... that "identical words used in different parts of -27- EFTA0022

torage drives, and other devices. Reuters (07/17, Lange) reported that 69% of Americans believe the Trump administration is concealing details about Jeffrey Epstein's clients, according to a Reuters/Ipsos poll. Only 17% of Americans approve of President Donald Trump's handling of the Epstein case, with 35% of Repu

ting, calling it "false, malicious, and defamatory". The letter, which was reportedly collected by Ghlslaine Maxwell as part of a birthday album for Epstein, includes text framed by the outline of a hand-drawn naked woman and ends with the phrase "Happy Birthday — and may every day be another wonderful s

ersy surrounding the handling of records from the Jeffrey Epstein investigation has intensified after The

thamist (07/17, Hurewltz•Ravitch), New York Daily News (07/17, Annese), amNewYork (07/17, Moses), SlLive (07/17, Axelrod), and P IX (CW. 11) (07/17, Gustafson). Judge Tosses Lawsuit Seeking to Shield Names of FBI Agents on Capitol Riot Probe Reuters (07/17, Goudsward) reported that a U.S. Judge, Jia Cobb,

torage drives, and other devices. Reuters (07/17, Lange) reported that 69% of Americans believe the Trump administration is concealing details about Jeffrey Epstein's clients, according to a Reuters/Ipsos poll. Only 17% of Americans approve of President Donald Trump's handling of the Epstein case, with 35% of Repu

ting, calling it "false, malicious, and defamatory". The letter, which was reportedly collected by Ghlslaine Maxwell as part of a birthday album for Epstein, includes text framed by the outline of a hand-drawn naked woman and ends with the phrase "Happy Birthday — and may every day be another wonderful s

ersy surrounding the handling of records from the Jeffrey Epstein investigation has intensified after The

thamist (07/17, Hurewltz•Ravitch), New York Daily News (07/17, Annese), amNewYork (07/17, Moses), SlLive (07/17, Axelrod), and P IX (CW. 11) (07/17, Gustafson). Judge Tosses Lawsuit Seeking to Shield Names of FBI Agents on Capitol Riot Probe Reuters (07/17, Goudsward) reported that a U.S. Judge, Jia Cobb,

TIEFEL,WILLIAM SMITH,HAROLD B COLE,JEFFREY A BRAUER,CAMILLA T LUBOTTA,JACK

OBERT A THE BREAKERS PALM BEACH INC EPSTEIN,JEFFREY TIEFEL,WILLIAM R MCCLOSKEY,

DELLAQUILA,STEPHEN EVANS,MITCHELL R GUSTAVSON,TROY E GUARI,NICOLE M COHON,GEORGE

proposed indictment contains 60 counts and seeks the forfeiture of Epstein's Palm Beach home and two airplanes.' The FBI has information regarding Epstein's whereabouts on May 16th and May 19th and they would like to arrest him on one of those dates. Epstein is considered an extremely high flight risk

k." Up to three appointments each day would be made. The girls would travel to Epstein's barsip Palm Beach where they would meet Epstein's chef and Epsteiti's assistant—usually an the kitchen. The assistant normally would escort the girls upstairs to the master bedroom/bathroom area and set up the mass

minute later, again called JD#2. and th say that = A security guard at Epstein's home asked why they were there, and said they were there to see Jeffrey. The guard let them in and they entered the house t ough a side door into the kitchen. igh School at the time. cousin, was Epstein and an assist