Epstein Secrets

nt in this case. In this Court's Opinion and Order on Motion to Dismiss and Motion for More Definite Statement in the case styled Jane Doe No. 6 v. Jeffrey Epstein Case No. 08-80994-CIV-Marra ("Jane Doe No. 6) this Court rejected any contention by the Defendant that the Supreme Court's decision in Bell Atlantic Corp

civious, and sexual acts, including, EFTA00201211 Case 9:08-cv-80811-KAM Document 58 Entered on FLSD Docket 04/13/2009 Page 2 of 18 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-C1V-MARRA/JOHNSON Plaintiffs Memorandum in Response to Defendant Jeffrey Epstein's Motion to Dismiss First Amended Co

12, 2009, this Court entered the Opinion and Order on Motion to Dismiss and Motion for More Definite Statement in the case styled Jane Doe No. 6 v. Jeji-ey Epstein, Case No. 08-80994-UV-Marra.' In that Order, the Court granted the Defendant's Motion for More Definite Statement with respect to allegations conce

The interpretation of Section 2255 urged by the Defendant Epstein implicates the same concerns EFTA00201218 Case

0811-CIV-MARRA/JOHNSON C.M.A., Plaintiff, vs. JEFFREY EPSTEIN and SARAH KELLEN, Defendants. PLAINTIFF

atement in the case styled Jane Doe No. 6 v. Jeji-ey Epstein, Case No. 08-80994-UV-Marra.' In that Order, the

is being served this day on all counsel of record identified above via transmission of Notices of Electronic Filing generated by CM/ECF. /.r/.lack P Hill JACK SCAROLA Florida Bar No. 169440 JACK P. HILL Florida Bar No.: 0547808 Searcy Denney Scarola Barnhart & Shipley, P.A. 3409 Attorneys for a

ercial sex act. Page 2 of 9 EFTA00182943 CT DATE(S) DEFENDANT(S) VICTIM(S) STATUTES/CHARGE 9 November 2004 - March 2005 --a N EPSTEIN ..NEPSTEIN Jane Doe #14 18 U.S.C. §§ 1591(aX1) and 2 Knowingly, in or affecting interstate or foreign commerce, recruiting, enticing, providing, and obtaini

ravel to 358 El Brillo Way so that JEFFREY EPSTEIN could, in exchange for money, engage in lewd conduct with those minor females in order to satisfy JEFFREY EPSTEIN's prurient interests. Manner and Means 27. The manner and means by which the Defendants and other participants sought to accomplish the purpose and

ments to be made to, minor females in exchange for engaging in lewd conduct. EPSTEIN, (c) It was further a part of the conspiracy that Defendants JEFFREY a/k/a ," and other participants would ask females to recruit other minor females to engage in lewd conduct with Defendant JEFFREY EPSTEIN. (d)

the public association of their identities with Defendant Epstein and these assaults. 3. Dr. Gilbert Kliman,2 a w

ober 28, 2006 132. Lawrence LE, Viron M, Johnson JE, Hudkins A, Samples G, Kliman G: A school-based m

SISTANT UNITED STATES ATTORNEY 52 EFTA00182941 INDICTMENT SUMMARY CT DATE(S) kEFENDANT(S) VICTIM(S) STATUTES/CHARGE 1 2001 - October 2005 NEPSTEIN Jane Does 1-19 18 U.S.C. §§ 371 and 2 Conspiracy to use a facility or means of interstate commerce to persuade, induce, or entice minors to enga

k of the Court by using CM/ECF system, which will send a notice of electronic filing to all counsel of record on the attached service list. istlank P Hill Jack Scarola Florida Bar No.: Jack P. Hill Florida Bar No.: Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard Wes

ket 06/05/2009 Page 1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80811-CIV-MARRA/JOHNSON Plaintiff, VS. Y EPSTEIN and Defendants. PLAINTIFF, M.'S, CONDITIONAL NOTICE OF INTENT TO EXCLUSIVELY RELY ON STATUTORY DAMAGES PROVIDED BY 18 U.S.C. 42255 Plaintiff, ,

Defendant, JEFFREY EPSTEIN, ("EPSTEIN"), by and through his undersigned counsel, files his reply to Plaintiffs Memorandum in Response to Defendant, JEFFREY EPSTEIN's, Motion to Dismiss First Amended Complaint For Failure to State A Cause of Action; And Motion for More Definite Statement; Motion to Strike, And Sup

tion either under statutory or common law against Defendant EPSTEIN. Count I fails to plead any requisite elements o

tion to recover money damages against Defendant, JEFFREY EPSTEIN, for acts of sexual abuse and prostitutio

eed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enum

day on all counsel of record identified on the attached counsel list via transmission of Notices of Electronic Filing generated by CM/ECF. tqllnck P Hill JACK SCAROLA Florida Bar No. 169440 JACK P. HILL Florida Bar No.: 0547808 Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes

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

et 08/05/2009 Page 38 of 50 Case 9:08-cv-80811-KAM Document 113 Entered on FLSD Docket 06/05/2009 Page 3 of 4 Respectfully submitted, [st.lack P Hill JACK SCAROLA Florida Bar No. 169440 JACKP. HILL Florida Bar No.: 0547808 Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes B

OF TIME IN WHICH TO FILE A RESPONSE TO DEFENDANT JEFFREY EPSTEIN'S MOTION TO IDENTIFY C.M.A. IN THIRD-PARTY SUBPOEN

f, C.M.A., by and through her undersigned attorneys, respectfully moves this Court for an extension of time in which file to a response to Defendant Jeffrey Epstein's Motion to Identify C.M.A. in Third Party Subpoenas For Purposes of Discovery, or Alternatively, Motion to Dismiss Sua Sponte, With Incorp

, by and through her undersigned attorneys, respectfully moves this Court for an extension of time in which file to a response to Defendant Jeffrey Epstein's Motion to Identify C.M.A. in Third Party Subpoenas For Purposes of Discovery, or Alternatively, Motion to Dismiss Sua Sponte, With Incorporated 3

k of the Court by using CM/ECF system, which will send a notice of electronic filing to all counsel of record on the attached service list. /sllack P Hill Jack Scarola Florida Bar No.: 169440 Jack P. Hill Florida Bar No.: 0547808 Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes