Epstein Secrets

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

must provide some kind of “independent evidence” of his fraudulent transfers in order to gain the inference of fraudulent transfers. The first is Avirgan v. Hull, 932 F.2d 1572, 1580 (11th Cir. 1991), in which Plaintiffs who had filed a frivolous lawsuit appealed from a district court decision grantin

ovided any evidence that the Court should not draw an adverse inference – or, indeed, any evidence at all in opposition to her motion. Accordingly, Avirgan is not on point and certainly does not suggest that Jane Doe needs to provide some sort of independent evidence to obtain an adverse inference.1

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

lent] billing ... which in tum ensures that the proposed adverse inferences, should the jury choose to draw them, are not unreliable." Id. See also Avirgan v. Hull, 932 F.2d 1572, 1580 (11th Cir. 1991) (holding that "the negative inference to be drawn from the assertion of the fifth amendment does not s

IN THE COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502008CA037319XXXXMB AB Plaintiff, v. JEFFREY EPSTEIN, Defendants. EPSTEIN'S RESPONSE IN OPPOSITION TO MOTION FOR LEAVE TO ADD A CLAIM FOR PUNITIVE DAMAGES Defendant, Jeffrey Epstein ("Epstein"), su

FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502008CA037319XXXXMB AB Plaintiff, v. JEFFREY EPSTEIN, Defendants. EPSTEIN'S RESPONSE IN OPPOSITION TO MOTION FOR LEAVE TO ADD A CLAIM FOR PUNITIVE DAMAGES Defendant, Jeffrey Epstein ("Epstein"), submits this Response in

inconceivable what relevance Ms. deposition has to claim for punitive damages if she has no knowledge of her. In addition, Ms. testified that: a. Epstein never used physical force or coercion, nor made any threats against her. Id. at 252-53; b. She was never afraid or concerned for her safety. Id: c

CASE NO. 502008CA037319XXXXMB AB Plaintiff, v. JEFFREY EPSTEIN, Defendants. EPSTEIN'S RESPONSE IN OPPO

inferences drawn from Fifth- Amendment-protected silence are treated as a substitute for the need for evidence on an ultimate issue of fact," citing Avirgan). EFTA00729295 v. Epstein Case No. 502008CA037319XXXXMIUD, Epsteln's Response in Opposition to Motion for Leave to Add a Claim for Punitive Dam

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,

inferences drawn from Fifth-Amendment-protected silence are treated as a substitute for the need for evidence on an ultimate issue of fact," citing Avirgan, supra). As belabored throughout this memorandum, Jane Doe cites no independent evidence that Epstein is fraudulently transferring assets. Accordi