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

suits filed against you. RFA's #6. • You are moving significant financial assets overseas, outside of the direct territorial reach of the U.S. and Florida Courts. RFA's #21. • You are making asset transfers with the intent to defeat any judgment that might be entered against you in this or similar cases. RFA

' Dominant 59 ',teed on FLSD Docked 077102009 Page 1 0110 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO 2 PlainSP vs JEFFREY EPSTEIN. Delendanl JANE DOE NO 3 Plawtstt vs JEFFREY EPSTEIN. DNendanl CASE NO: 08.CV.80119-MARRALIOHNSON CASE NO: 08.CY-80232-MARRA/JOHNSON JANE DOE

or. on mo alternative. to prove Mat Ms invocation of his Fifth Amendment pnwtegre is Proper Jane (Afro haS propowstal 23 requests for admission to Epstein includeng SuCh straightforward etvpuera as • YO. It net worth is greater than SI Maim 4 SDNY_GM_00328558 EFTA_0020 I 3 I () EFTA01308036 Case

OE'S MOTION TO COMPEL ANSWERS TO PLAINTEE'S FIRST REQUEST FOR PRODUCTION Plwaer Jane Doe hereby moves this Court for an order compelling defendant Jeffrey EpsI in pi answer her Psi request In. productce or in me allernatme. to Pove Mal his eiwocatron of his Frith AMOIldneflt priulego Is proper Jane Doe

eparation of a privilege log with rescect to all dryairnnMs one, er COmnionieationS (among other thvgsl that are ',simnel(' on the bass Or I.-wedge Epstein Ms failed 10 prepare such a log making it impossible for Jane Doe In effectively chalenge his generic assertions Indeed, with respect to a few request

y Florida Statutes C Sermal Battery 7I You are moving Hgnificant financial assets Overseas. outside of the direct fernforre rearri of Me It S and Florida Courts 22 You are maxim asset transfers with the intent to defeat any judgment that mot be entre° against yOu in this or smiler cases 73 You currently h

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

nt 195 Entered on FLSD Docket 07/10/2009 Page 1 of 10 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 CASE NO: 08-

, in the alternative, to prove that his invocation of his Fifth Amendment privilege is proper. Jane Doe has propounded 23 requests for admission to Epstein, including such straightforward requests as: • Your net worth is greater than $1 billion. 4 EFTA00221902 Case 9:08-cv-80119-KAM Document 195

ate property in foreign countries. • You are moving significant financial assets overseas, outside of the direct territorial reach of the U.S. and Florida Courts. • You currently have the ability to post a bond of $15 million to satisfy a judgment in this case without financial or other difficulty. In respo