Epstein Secrets

IN, Plaintiff/Counter-Defendant, Case No. 50 2009 CA 040800XXXXMBAG v. BRADLEY J. EDWARDS, et al., Defendants/Counter-Plaintiff. JUDGE: HAFELE JEFFREY EPSTEIN'S RESPONSE TO BRADLEY EDWARDS'S MOTION IN LIMINE TO STRIKE THE JUNE 30.2017 AFFIDAVIT OF JEFFREY EPSTEIN AND TO EXCLUDE EVIDENCE AS TO WHICU DISCOVE

JEFFREY EPSTEIN AND TO EXCLUDE EVIDENCE AS TO WHICU DISCOVERY WAS WITHHELD UNDER CLAIMS OF PRIVILEGE Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel, hereby files his Response to Defendant/Counter-Plaintiff Bradley Edwards's ("Edwards") Motion in Limine

DICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FL JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, Case No.

millions of dollars. Q. And trying to find out, Mr. Epstein, whether you have any evidence whatsoever that

and 6 generate cases. See Deposition of Jeffi•ey Epstein, p. 28; line13-p. 29; line 6. BY MR. SCAROLA: Q

of reliance on Fifth Amendment; there must be other evidence. Baxter, 425 U.S. at 318; Lefkowitz, 431 U.S. at 808, n. 5;Lasalle Banks Lake View v. Seguban, 54 F.3d 387 (7th Cir. 1995); National Acceptance Co.of America v. Bathalter, 705 F.2d 924 (7th Cir. 1963) (assertion of Fifth Amendment in an answ

dant, SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff, JUDGE: HAFELE PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S OMNIBUS MOTION IN LIMINE Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel, herein moves for an Orde

er-Plaintiff, JUDGE: HAFELE PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S OMNIBUS MOTION IN LIMINE Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel, herein moves for an Order in Limine precluding Defendant/Counter-Plaintiff Bradley Edwards ("Edwards") a

OUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, vs. Plaintiff/Counter-Defendant, SCOT

laintiff has no evidence, nor can he prove, that Mr. Epstein lacked probable cause at the time he filed his l

his litigation. See Deposition Transcript of Jef•ey Epstein. When Edwards's inquiry turned to questions rega

upon the basis of reliance on Fifth Amendment; there must be other evidence. Baxter v. Pahnigiano, 425 U.S. 308 (1976); Lasalle Banks Lake View v. Seguban, 54 F.3d 387 (7th Cir. 1995); National Acceptance Co.of America v. Bathalter, 705 F.2d 924 (7th Cir. 1963) (assertion of Fifth Amendment in an answ

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

ng the relief sought by Jane Doe based solely on an adverse inference would violate Epstein's Fifth Amendment rights. See LaSalle Bank Lake View v. Seguban, 54 F.3d 387, 389 (7th Cir. 1995) (noting that "the Supreme Court has prohibited practices that are coercive in that they make the exercise of the p

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

solely upon a privileged refusal to admit or deny at the pleading stage.” Epstein Memo. in Opp. [DE 198 at 10] (quoting LaSalle Bank Lake View v. Seguban, 54 F.3d 387, 391 (7th Cir. 1995) (emphasis added)). As just Case 9:08-cv-80119-KAM Document 217 Entered on FLSD Docket 07/23/2009 Page 15 of

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,

nting the relief sought by Jane Doc based solely on an adverse inference would violate Epstein's Fifth Amendment rights. LaSalle Bank Lake View v. Seguban, 54 F.3d 387, 389 (7th Cir. 1995) (noting that "the Supreme Court has prohibited practices that are coercive in that they make the exercise of the p

UIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION AG CASE NO. 502009CA040800XXXXMB Judge David F. Crow JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiffs. PLAINTIFF'

aintiffs. PLAINTIFF'S RESPONSE IN OPPOSITION TO DEFENDANT EDWARDS' RENEWED MOTION FOR SUMMARY JUDGMENT Plaintiff, Jeffrey Epstein ("Plaintiff" or "Epstein"), hereby files the following Response in Opposition to Defendant Bradley J. Edwards' ("Edwards") Renewed Motion for Summary Judgment ("Motion") an

SE NO. 502009CA040800XXXXMB Judge David F. Crow JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT

n for summary judgment." Fid. Funding of Cal., Inc. v. Reinhold, 79 F. Supp. 2d 110, 116 (E.D. N.Y. 1997). As explained in LaSalle Bank Lake View v. Seguban, 54 F. 3d 387, 391 n.7 (7th Cir. 1995): Treating Segubans' silence as a separate piece of evidence supporting the Bank's motion for summary judgme