Epstein Secrets

Case 9:08-cv-80119-KAM Document 38 Entered on FLSD Docket 08/12/2008 Page 1 of 13 JANE DOE NO. 2, vs JEFFREY EPSTEIN. I JANE DOE NO. 3, vs. JEFFREY EPSTEIN. I JANE DOE NO. 4, vs. JEFFREY EPSTEIN. I JANE DOE NO. 5, vs. JEFFREY EPSTEIN. I UNITED STATES D

OF MOTION TO STAY ' This motion is filed under seal because the deferred-prosecution agreement between the United States Attorney's Office and Mr. Epstein. discussed herein, contains a confidentiality clause. A motion to seal has been filed contemporaneously. Case 9:08-cv-80119-KAM Document 38

between the United States Attorney's Office and Mr. Epstein. discussed herein, contains a confidentiality cla

ion In 2006, a Florida state grand jury indicted Jeffrey Epstein on allegations similar to those in the i

ould not be entitled to compel pre-trial production of any of this information. See Fed. R. Cr. P. 16(b)(l)(A), (C), and 16(b)(2); United States v. Argomaniz, 925 F.2d 1349, 1355-56 (11th Cir. 1991) (explaining act-of-production privilege). Thus, absent a stay of this civil action, the USAO would receive

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, CASE NO: 08-CV-80119-MARRA/JOHNSON Plaintiff vs. JEFFREY EPSTEIN, Defendant _____________________________/ JANE DOE NO. 3, CASE NO: 08-CV-80232-MARRA/JOHNSON Plaintiff vs. JEFFREY EPSTE

Way, Palm Beach, Florida, that depict the room(s) where massages took place (including massage table). Request No. 10: Correspondence between Epstein and federal prosecutors; Request No. 12: Personal tax returns; Request No. 13: Photocopies of Epstein’s passport; Request No. 14: A statem

broad. Request No. 16: All medical records of Defendant Epstein from Dr. Stephan Alexander. Defendant is asser

es this Court for an order compelling defendant, Jeffrey Epstein, to answer her first request for producti

ment invocations are valid. It is for the court, not the claimant, to determine whether the hazard of incrimination is justified. United States v. Argomaniz, 925 F.2d 1349, 1355 (11th Cir. 1991). “A court must make a particularized inquiry, deciding, in connection with each specific area that the Case

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, CASE NO: 08-CV-80119-MARRA/JOHNSON Plaintiff vs. JEFFREY EPSTEIN, Defendant _____________________________/ JANE DOE NO. 3, CASE NO: 08-CV-80232-MARRA/JOHNSON Plaintiff vs. JEFFREY EPSTE

Way, Palm Beach, Florida, that depict the room(s) where massages took place (including massage table). Request No. 10: Correspondence between Epstein and federal prosecutors; Request No. 12: Personal tax returns; Request No. 13: Photocopies of Epstein’s passport; Request No. 14: A statem

broad. Request No. 16: All medical records of Defendant Epstein from Dr. Stephan Alexander. Defendant is asser

es this Court for an order compelling defendant, Jeffrey Epstein, to answer her first request for producti

ment invocations are valid. It is for the court, not the claimant, to determine whether the hazard of incrimination is justified. United States v. Argomaniz, 925 F.2d 1349, 1355 (11th Cir. 1991). “A court must make a particularized inquiry, deciding, in connection with each specific area that the Case

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ____________________________________/ Related Cases: 08-80232, 08-80380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-804

ffrey Epstein (“Defendant” or “Epstein”) seeks to make additional in camera submissions in support of his appeal of Orders of the Magistrate Judge. Epstein has already made in camera submissions in opposition to Plaintiffs’ Motion to Compel Net Worth Discovery, which were reviewed and considered by the

iffs can then reasonably formulate a response. Defendant Epstein cites to no authority that would authorize him t

ED ARGUMENTS TO THE COURT (DE 518) Defendant Jeffrey Epstein (“Defendant” or “Epstein”) seeks to make

ion, and he exercised that right. He was given every opportunity to substantiate his claims of privilege before the Magistrate Judge. See U.S. v. Argomaniz 1 Nothing in Defendant’s Motion indicates that he seeks to submit in camera evidence that

09/2009 Page 1 of 14 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No.: 08-CIV-80893 - MARRA/JOHNSON JANE DOE, 1. Plaintiff, JEFFREY EPSTEIN, Defendant. / PLAINTIFF'S RESPONSE IN OPPOSITION TO DEFENDANT'S MOTION TO STAY COMPLAINT Plaintiff, Jane Doe, hereby responds to the motion by d

S RESPONSE IN OPPOSITION TO DEFENDANT'S MOTION TO STAY COMPLAINT Plaintiff, Jane Doe, hereby responds to the motion by defendant Jeffrey Epstein ("Epstein") to stay this action until late 2010. The motion for a stay should be denied. Defendant has not carried his heavy burden of justifying a stay in th

80893 - MARRA/JOHNSON JANE DOE, 1. Plaintiff, JEFFREY EPSTEIN, Defendant. / PLAINTIFF'S RESPONSE IN

ed on FLSD Docket 04/09/2009 Page 2 of 14 against any stay -- particularly since it involves allegations of serious sexual abuse against a minor. I. EPSTEIN IS NOT FACING PENDING CRIMINAL CHARGES AGAINST HIM RELATED TO JANE DOE. Epstein's initial burden is to show some sort of risk of criminal prosecuti

It is for the Court, not the claimant, to determine whether the hazard of incrimination justifies invocation of the privilege. See United States'. Argomaniz, 925 F.2d 1349, 1355 (11th Cir. 1991). "A court must make a particularized inquiry, deciding, in connection with each specific area that the 9 EFT

CV-80119-MARRA/JOHNSON Plaintiff vs. JEFFREY EPSTEIN, Defendant _____________________________/

e Doe has propounded 23 requests for admission to Epstein, including such straightforward requests as: •

es this Court for an order compelling defendant, Jeffrey Epstein, to answer her first requests for admissi

of incrimination is justified. United States v. Argomaniz, 925 F.2d 1349, 1355 (11th Cir. 1991). “A court

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, CASE NO: 08-CV-80119-MARRA/JOHNSON Plaintiff vs. JEFFREY EPSTEIN, Defendant _____________________________/ JANE DOE NO. 3, CASE NO: 08-CV-80232-MARRA/JOHNSON Plaintiff vs. JEFFREY EPSTE

in the alternative, to prove that his invocation of his Fifth Amendment privilege is proper. Jane Doe has propounded 23 requests for admission to Epstein, including such straightforward requests as: • Your net worth is greater than $1 billion. Case 9:08-cv-80119-KAM Document 195 Entered on FLSD

es this Court for an order compelling defendant, Jeffrey Epstein, to answer her first requests for admissi

ment invocations are valid. It is for the court, not the claimant, to determine whether the hazard of incrimination is justified. United States v. Argomaniz, 925 F.2d 1349, 1355 (11th Cir. 1991). “A court must make a particularized inquiry, deciding, in connection with each specific area that the quest

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, CASE NO: 08-CV-80119-MARRA/JOHNSON Plaintiff vs. JEFFREY EPSTEIN, Defendant _____________________________/ JANE DOE NO. 3, CASE NO: 08-CV-80232-MARRA/JOHNSON Plaintiff vs. JEFFREY EPSTE

in the alternative, to prove that his invocation of his Fifth Amendment privilege is proper. Jane Doe has propounded 23 requests for admission to Epstein, including such straightforward requests as: • Your net worth is greater than $1 billion. Case 9:08-cv-80119-KAM Document 211 Entered on FLSD

es this Court for an order compelling defendant, Jeffrey Epstein, to answer her first requests for admissi

ment invocations are valid. It is for the court, not the claimant, to determine whether the hazard of incrimination is justified. United States v. Argomaniz, 925 F.2d 1349, 1355 (11th Cir. 1991). “A court must make a particularized inquiry, deciding, in connection with each specific area that the quest