Epstein Secrets

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

nt to a criminal statute that provides no civil remedy, her complaint is properly dismissed for failure to state a cause of action. See Mantooth v. Richards, 557 So. 2d 646, 646 (Fla. 4th DCA 1990) (per curiam) (affinning dismissal of plaintiffs claim for parental kidnapping where "the mentioned statute

age 11 of 50 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CIV-80811-MARRA/JOHNSON CAROLYN MARGARET ANDRIANO Plaintiff, V. JEFFREY EPSTEIN and SARAH KELLEN, Defendants, NOTICE OF TAKING DEPOSITION PLEASE TAKE NOTICE that the undersigned attorney will take the deposition duces tecum

or use at trial, or for such other purposes as are permitted under the applicable Statutes of Rules~ Robert D. Critton, Jr. Attorney for Defendant Epstein Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing document is being served this day on all counsel of record identified on

6 of 50 8. Presently pending before the Court is Defendant EPSTEIN's Motion to Compel Plaintiff C.M.A. to Respond t

8691 [email protected] Counsel tor Defendant Jeffrey Epstein Searcy Denney Scarola Barnhart & Sh

:08-cv-80811-KAM Document 47 Entered on FLSD Docket 03/12/2009 Page 16 of 21 C.M.A. v. Epstein, et al. Page 16 action for damages); Mantooth v. Richards, 557 So.2d 646 (Fla. 4th DCA 1990), per curiam, (Dismissal of plaintiff's civil complaint affirmed where parental kidnapping statutes concerned onl

From: (USAFLS)" alMIN> To: (FBI)" ca Bcc: (USAFLS)" alMIE> Subject: RE: Jeff Epstein Date: Thu, 19 Jun 2008 17:59:13 +0000 Importance: Normal I doubt that Roy will call again. He didn't really call me last time, he called and ask

y Do u think u will hear from him again? Original Message From: (USAFLS) To: • Richards, Jason R. Sent: Thu Jun 19 13:23:07 2008 Subject: FW: MEpstein Hi Guys — This is attorney. He seems like a very good guy — much better than the others, but I am concerned about allegations of misconduct. What

resting call with Roy Black. I would have luvd to have been a fly Do u think u will hear from him again? Original Message From: (USAFLS) To: • Richards, Jason R. Sent: Thu Jun 19 13:23:07 2008 Subject: FW: MEpstein Hi Guys — This is attorney. He seems like a very good guy — much better than the o

From: (FBI)" ca To: (USAFLS)" Subject: Re: Epstein Plea Date: Fri, 27 Jun 2008 20:16:07 +0000 Impo

Subject: Re: Epstein Plea Date: Fri, 27 Jun 2008 20:16:07 +0000 Importance: Normal Call me when u can. --- Original Message From: To: Cc: • Richards, Jason R. Sent: Fri Jun 27 15:47:54 2008 Subject: Epstein Plea (USAFLS) < ;,• Wow, am I good. Here it is already. I think our faxes crossed in cy

1 EFTA00013926 --- PAGE BREAK --- Case 9:08-cv-80736-KAM Document 19 Entered on FLSD Docket 08/01/2008 Page 2 of 16 Agreement with defendant Epstein that is at the center of this litigation and (2) the FBI's report of interview concerning a meeting with Jane Doe #1. These requests were also made

D Docket 08/01/2008 Page 2 of 16 Agreement with defendant Epstein that is at the center of this litigation and (2)

-- Case 9:08-cv-80736-KAM Document 19 Entered on FLSD Docket 08/01/2008 Page 4 of 16 Investigation opened an investigation into allegations that Jeffrey Epstein had used facilities of interstate commerce to induce young girls between the ages of thirteen and seventeen to engage in prostitution (among other

ion opened an investigation into allegations that Jeffrey Epstein had used facilities of interstate commer

rnment from conferring with the victims about the plea arrangement. On about October 26, 2007, FBI Special Agents E. Nesbitt Kuyrkendall and Jason Richards met in person with Jane Doe #1 at a restaurant. The Special Agents explained that there had been discussions with Epstein about a possible resolutio

ail from Andy Laurie to Matt Menchel and Jeff Sloman (cc: Marie Villafatia) re letter received from Gerald Lefcourt discussing a meeting to discuss Epstein investigation Work Product Deliberative Process P-013982 5/23/2007 email from Jason Richards to Marie Villafaila re extradition research Work P

ork Product Deliberative Process Attorney-Client Privilege P-014299 thru P-014307 11/14/2007-11/19/2007 emails between Marie Villafafia, Jason Richards, Jeff Sloman, Rolando Garcia, Alex Acosta, and Karen Atkinson regarding communications with State Attorney's Office and Sheriff's Office in an atte