Epstein Secrets

rth is in the hundreds of millions of dollars - if not, indeed, a billion dollars. See, e.g., New York Time, July 1, 2008, at A2 ("Over the weekend Jeffrey E. Epstein, who after years of advising billionaires became a billionaire himself, left his estate on Little St. James Island, with its staff of 70 and its fl

ant PLAINTIFF, JANE DOE'S MOTION FOR INJUNCTION RESTRAINING FRAUDULENT TRANSFER OF ASSETS, APPOINTMENT OF A RECEIVER TO TAKE CHARGE OF PROPERTY OF EPSTEIN, AND TO POST A $15 MILLION BOND, TO SECURE POTENTIAL JUDGMENT COMES NOW Plaintiff Jane Doe, by and through undersigned counsel, and hereby files t

IS ASSETS. As noted in the material facts above, defendant Epstein is currently making fraudulent transfers of his

ork Time, July 1, 2008, at A2 ("Over the weekend Jeffrey E. Epstein, who after years of advising billionair

ork Time, July 1, 2008, at A2 ("Over the weekend Jeffrey E. Epstein, who after years of advising billionaire

#23. 14. Epstein has blocked all discovery, in this and other related cases, regarding his assets. Affidavit of Paul Cassell at ¶¶ 7, 8. ARGUMENT I. EPSTEIN IS FRAUDULENTLY TRANSFERRING HIS ASSETS. As noted in the material facts above, defendant Epstein is currently making fraudulent transfers of his as

a "perfect circumstantial evidence case that [Epstein] ha[s] means, motive, and opportunity" to fraudulently transfer assets. See United States v. Sparks, 265 F.3d 825, 830 (9th Cir. 2001) (finding probable cause for an arrest based solely on a showing of means, motive, and opportunity). The fact tha

BURMAN CRITTON LUTTIER UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CIV- 80893 - MARRA/JOHNSON JANE DOE, Plaintiff, V. JEFFREY EPSTEIN, Defendant. ____________ ___;/ DEFENDANT EPSTEIN'S RESPONSE TO PLAINTIFF JANE DOE'S FIRST REQUEST FOR ADMISSIONS (dated 03/23/09) 14] 023/031 D

unsel, and hereby files this Motion for Injunction, pursuant to Federal Rule of Civil Procedure 64, for appointment of a receiver to take charge of Epstein's property, and to post a $15 million bond to secure any potential judgment in this case, for the reasons explained in the accompanying supporting

ork Time, July 1, 2008, at A2 ("Over the weekend Jeffrey E. Epstein, who after years of advising billionair

ork Time, July 1, 2008, at A2 ("Over the weekend Jeffrey E. Epstein, who after years of advising billionaire

IS ASSETS. As noted in the material facts above, defendant Epstein is currently making fraudulent transfers of his

a "perfect circumstantial evidence case that [Epstein] ha[s] means, motive, and opportunity" to fraudulently transfer assets. See United States v. Sparks, 265 F.3d 825, 830 (9th Cir. 2001) (finding probable cause for an arrest based solely on a showing of means, motive, and opportunity). The fact tha

Case 9:08-cv-80119-KAM Document 198 Entered on FLSD Docket 07/13/2009 Page 1 of 24 JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN Defendant. UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-cv-80119-MARRA/JOHNSON ----------~/ JANE DOE NO. 3, Plaintif

HNSON CASE NO.: 08-CV-80381-MARRA/JOHNSON I Case 9:08-cv-80119-KAM Document 198 Entered on FLSD Docket 07/13/2009 Page 2 of 24 Jane Doe v. Epstein Case No. 08-CV-80893-Marra/Johnson Epstein's Memorandum of Law in Opposition to Jane Doe's Injunction Motion Page 2 of24 JANE DOE NO. 6, Plainti

majority of Mr. Cassell's assertions in his affidavit are based on a 2005 Vanity Fair article (the "2005 Vanity Fair Article"). See Vicky Ward, "The Talented Mr. Epstein," Vanity Fair <http://vickyward.com/wordpress/archives/30>, (January 24, 2005; accessed June 24, 2009). Mr. Cassell's affidavit is essentially a

Weinstein .... " See Vicky Ward, "You Will Have Jeffrey Epstein to Kick Around!" Vanity Fair <http://www

Epstein is fraudulently transferring assets because he purportedly has the means, the motive and the opportunity to do so, citing United States v. Sparks, 265 F.3d 825, 830 (9th Cir. 2001). See Injunction Motion (DE #165) at 11. Sparks is completely inapposite as it concerned whether probable cause fo

evidence with a new, recently-obtained Declaration – from Epstein himself. See Plaintiff Jane Doe’s Motion to Provide Recently-Obtained Affidavit of Jeffrey E. Epstein in Support of Material Facts Supporting Motion for Appointment of a Receiver to Take Charge of Property of Epstein [DE 213]. This Declaration was

iles this Reply Memorandum in Support of her Motion, pursuant to Federal Rule of Civil Procedure 64, for appointment of a receiver to take charge of Epstein’s property and to post a $15 million bond to secure any potential judgment in this case. As explained in Jane Doe’s motion, Epstein is a billion

Motion to Provide Recently-Obtained Affidavit of Jeffrey E. Epstein in Support of Material Facts Supporting

Motion to Provide Recently-Obtained Affidavit of Jeffrey E. Epstein in Support of Material Facts Supporti

ive, and opportunity to fraudulently transfer assets.” Jane Doe’s Motion to Restrain Fraudulent Transfer of Assets at 11 (quoting United States v. Sparks, 265 F.3d 825, 830 (9th Cir. 2001)).2 Epstein completely misses the point of Jane Doe’s means, motive, and opportunity argument, construing it as s

ey Epstein-Related Touhy Requests All, (USANYS) Please find attached an initial letter to Kaplan Hecker re: the request for information related to Epstein. Please let me know if you have any edits or concerns. Once I have sign-off, I'll send to Robbie Kaplan (by mail and at or let me know if I should

: Jeffrey Epstein-Related Touhy Requests I spoke to about continuing to use as the POC to outsiders for Touh.rests for rm info ation relating to Jeffrey Epstein. (Thank you !)= please give a call. , FWIW, following is a markup of a "please give us a Touhy statement" email that I have used in the past. a

From: ' To: "I Subject: RE: Jeffrey Epstein-Related Touhy Requests Date: Sun, 05 Jan

ereign immunity bars any proceeding in state court to enforce a subpoena or otherwise compel testimony or production of documents. See Louisiana v. Sparks, 978 F.2d 226, 234-36 (5th Cir. 1992); Boron Oil Co., 873 F.2d at 69-71; see also, e.g., People v. Rodriguez, 546 N.Y.S.2d 861, 862-63 (1st Dep't 19

ard Knock and Lamborghini Doors, continue pursuit of targets in the Dirt Bang Gang investigation, and reduce the workload for the case agents in the Jeffrey Epstein investigation. In addition, a surge in manpower will be needed to assist with anticipated trials in FY20 for the remaining indicted Hard Knock targ

e the workload for the case agents in the Jeffrey Epstein investigation. In addition, a surge in manpower

nd reduce the workload for the case agents in the Jeffrey Epstein investigation. In addition, a surge in m

ms. A C-20 analyst drafted a TIR highlighting a connection between a victim of the Hard Knock investigation and the subject Saeed Malik Norris, aka Sparks. Agents and TFOs from squad C-20 interviewed two of the juvenile victims from the Hard Knock child sex trafficking investigation and as a result, No

d to loop in everybody on the case on the criminal side, you'll be the point person for requests from civil plaintiffs / victims in connection with Epstein lawsuits, and we'll work with you on those requests given our knowledge of the relevant facts and materials. In terms of this first question from t

pstein-Related Touhy Requests (USANYS) I spoke to about continuing to use as the POC to outsiders for Touhy requests for information relating to Jeffrey Epstein. (Thank you !)= please give a call. FWIW, following is a markup of a "please give us a Touhy statement" email that I have used in the past. EFT

o: )c Cc: (USANYS) la; (USANYS) Subject: RE: Jeffrey Epstein-Related Touhy Requests (USANYS) All sou

ereign immunity bars any proceeding in state court to enforce a subpoena or otherwise compel testimony or production of documents. See Louisiana v. Sparks, 978 F.2d 226, 234-36 (5th Cir. 1992); Boron Oil Co., 873 F.2d at 69-71; see also, e.g., People v. Rodriguez, 546 N.Y.S.2d 861, 862-63 (1st Dep't 19

Jeffrey Epstein

SPARKS