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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
ein, particularly given his phenomenal wealth. When this Court proceeds in equity, it "will not suffer a wrong to be without a remedy." Connell v. Mittendorf, 147 So.2d 169, 172 (Fla. Ct. Apps. 1962). This case cries out for the Court to intercede and take action to avoid allowing a confessed and wealthy
BURMAN CRITTON LUTTIER UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CIV- 80893 - MARRA/JOHNSON JANE DOE, Plaintiff, V. JEFFREY EPSTEIN, Defendant. ____________ ___;/ DEFENDANT EPSTEIN'S RESPONSE TO PLAINTIFF JANE DOE'S FIRST REQUEST FOR ADMISSIONS (dated 03/23/09) 14] 023/031 D
unsel, and hereby files this Motion for Injunction, 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, for the reasons explained in the accompanying supporting
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
IS ASSETS. As noted in the material facts above, defendant Epstein is currently making fraudulent transfers of his
ein, particularly given his phenomenal wealth. When this Court proceeds in equity, it "will not suffer a wrong to be without a remedy." Connell v. Mittendorf, 147 So.2d 169, 172 (Fla. Ct. Apps. 1962). This case cries out for the Court to intercede and take action to avoid allowing a confessed and wealthy
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
any judgment the jury might ultimately return. When this Court proceeds in equity, it “will not suffer a wrong to be without a remedy.” Connell v. Mittendorf, 147 So.2d 169, 172 (Fla. Ct. Apps. 1962). Jane Doe asks for the straightforward relief of appointing a receiver to take control over Epstein’s as
Entities connected to both Jeffrey Epstein and Mittendorf

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Donald Trump
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Bradley Edwards
PERSONJack Goldberger
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Kenneth Marra
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Bill Clinton
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Paul Cassell
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U.S. Virgin Islands
LOCATIONScott Rothstein
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Les Wexner
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Vicky Ward
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Adam D. Horowitz
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Bear Stearns
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