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

lege without placing the witness in the 'cruel trilemma' of choosing among incrimination, perjury, or contempt." United States ex rel. DRC, Inc. v. Custer Battles, LLC, 415 F.Supp.2d 628, 633 (E.D. Va. 2006). The Eleventh Circuit has not hesitated to support district courts that draw an adverse inference from

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

dant’s] seemingly blanket invocation of the privilege against self-incrimination.” Custer Battles, 41 F.Supp.2d at 634-35 (emphasis added). Thus, Custer Battles cautioned against drawing inferences about other people’s state of mind via an adverse inference from defendant Morris’ invocation of his Fifth Amen

such an inference is somehow not proper under the test laid out by United States v. Custer Battles, LLC, 415 F.Supp.2d 628, 633 (E.D. Va. 2006). Custer Battles lays out a two-prong test for deciding whether a factfinder can appropriately draw an adverse inference. The first prong is whether there is “a vali

s. V. PLAINTIFF IS ENTITLED TO DEFENDANT'S HEALTH CARE INFORMATION IN DISCOVERY A. Interrogatory at Issue "Interrogatory No. 8. Identify all of Jeffrey Epstein's health care providers in the past (10) ten years, including without limitation, psychologists, psychiatrists, mental health counselors, physician,

to Plaintiff's discovery requests. - 1 - EFTA00728201 Case 9:08-cv-80119-KAM Document 57 Entered on FLSD Docket 03/02/2009 Page 2 of 16 II. EPSTEIN'S BLANKET ASSERTION OF PRIVILEGE AGAINST SELF-INCRIMINATION IN RESPONSES TO INTERROGATORIES IS INSUFFICIENT Defendant's response to each and every

cceptable). While Plaintiff does not dispute that Defendant Epstein's Fifth Amendment privilege may be asserted in a

-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. PLAINTIFF'S MOTION TO COMPE

ame in an Indictment as victims of an offense by Mr. Epstein enumerated in 18 U.S.C. §2255. Response: Defend

some relief to the civil litigant whose case is unfairly prejudicial by a witness' assertion of the Fifth Amendment privilege ..." United States v. Custer Battles, L.L.C., 415 F. Supp. 2d 628, 632 (E.D. Va. 2006); accord Basler v. Palmigiano, 425 U.S. 408, 318 (1976) ("the Fifth Amendment does not forbid adver

PLAINTIFF IS ENTITLED TO DEFENDANT’S HEALTH CARE INFORMATION IN DISCOVERY A. Interrogatory at Issue “Interrogatory No. 8. Identify all of Jeffrey Epstein’s health care providers in the past (10) ten years, including without limitation, psychologists, psychiatrists, mental health counselors, physician,

e, 822 F.2d 1035, 1037 (11th Cir. 1987) (rejecting a “blanket” refusal to testify as unacceptable). While Plaintiff does not dispute that Defendant Epstein’s Fifth Amendment privilege may be asserted in a civil case,3 the Fifth Amendment’s “protection must be confined to instances where the witness has

ceptable). While Plaintiff does not dispute that Defendant Epstein’s Fifth Amendment privilege may be asserted in a

t Issue “Interrogatory No. 8. Identify all of Jeffrey Epstein’s health care providers in the past (10)

e relief to the civil litigant whose case is unfairly prejudicial by a witness’ assertion of the Fifth Amendment privilege . . .” United States v. Custer Battles, L.L.C., 415 F. Supp. 2d 628, 632 (E.D. Va. 2006); accord Baxler v. Palmigiano, 425 U.S. 408, 318 (1976) (“the Fifth Amendment does not forbid adver

s. V. PLAINTIFF IS ENTITLED TO DEFENDANT'S HEALTH CARE INFORMATION IN DISCOVERY A. Interrogatory at Issue "Interrogatory No. 8. Identify all of Jeffrey Epstein's health care providers in the past (10) ten years, including without limitation, psychologists, psychiatrists, mental health counselors, physician,

to Plaintiff's discovery requests. - 1 - EFTA00222502 Case 9:08-cv-80119-KAM Document 57 Entered on FLSD Docket 03/02/2009 Page 2 of 16 II. EPSTEIN'S BLANKET ASSERTION OF PRIVILEGE AGAINST SELF-INCRIMINATION IN RESPONSES TO INTERROGATORIES IS INSUFFICIENT Defendant's response to each and every

cceptable). While Plaintiff does not dispute that Defendant Epstein's Fifth Amendment privilege may be asserted in a

-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. PLAINTIFF'S MOTION TO COMPE

some relief to the civil litigant whose case is unfairly prejudicial by a witness' assertion of the Fifth Amendment privilege ..." United States v. Custer Battles, L.L.C., 415 F. Supp. 2d 628, 632 (E.D. Va. 2006); accord Basler v. Palmigiano, 425 U.S. 408, 318 (1976) ("the Fifth Amendment does not forbid adver

t 198 Entered on FLSD Docket 07'13'2009 Page 1 of 24 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN Defendant. JANE DOE NO. 3, Plaintiff, vs. JEFFREY EPSTEIN Defendant. JANE DOE NO. 4, Plaintiff, vs. JEFFREY EPSTEIN! Defendant. JANE DOE

OPPOSITION TO 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 Defendant, JEFFERY EPSTEIN ("Epstein"), by and through his undersigned counsel, submi

ICT OF FLORIDA JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN Defendant. JANE DOE NO. 3, Plaintiff,

ly be drawn when independent evidence exists of the fact to which the party refuses to answer." Id. at 635 (emphasis added) (citations omitted). In Custer Battles. LLC unlike the instant case, the court found the record contained "ample evidence of Morris' involvement in the [fraudulent) billing ... which in