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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
on Fifth Amendment grounds. Id. at 1129 (citing United States v. A Single Family Residence, 803 F.2d 625, 629 n.4 (11th Cir. 1986)). Similarly, in Arango v. U.S. Dept of the Treasury, 115 F.3d 922, 926 (11th Cir. 1997), the Eleventh Circuit explained that "the First Amendment 10 EFTA00234880 Case
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
on Fifth Amendment grounds. Id. at 1129 (citing United States v. A Single Family Residence, 803 F.2d 625, 629 n.4 (11th Cir. 1986)). Similarly, in Arango v. U.S. Dept. of the Treasury, 115 F.3d 922, 926 (11th Cir. 1997), the Eleventh Circuit explained that "the First Amendment Case 9:08-cv-80119-KA
akers." Among the outlets also reporting on the review are the Wall Street Journal <https://www.wsj.corn/articles/alex- acosta-used-poor-judgment-in-jeffrey-epstein-plea-deal-justice-dept-says-11605210737> (11/12, Gurman, Subscription Publication, 7.57M), the CNN <https://www.cnn.com/2020/11/12/politics/departmen
nal misconduct. Alex Acosta, who later became President Trump's labor secretary, was under fire for the generous plea deal that he entered into with Epstein, who was accused of abusing dozens of teenage girls. Well, today, a lawyer for Epstein's victims called the DOJ report a cover-up." The AP <https:/
d the prosecutor who handled a 2008 case against Jeffrey Epstein showed poor judgment but did not engage i
Justice Department that critics have said allowed Mr. Epstein to largely go unscrutinized in the face of years
to reach the "grim milestone." The New York Times <https://www.nytimes.com/2020/11/12/us/california-coronavirus-million-cases.html> (11/12, Fuller, Arango, Hubler, 18.61M) reports, "Citing an alarming increase in cases, San Francisco this week banned indoor dining at restaurants and paused a plan to re
sVi (11/12, story 10, 0:25, O'Donnell, 4.06M) reported, "This news today: The Justice Department said the prosecutor who handled a 2008 case against Jeffrey Epstein showed poor judgment but did not engage in professional misconduct. Alex Acosta, who later became President Trump's labor secretary, was under fire
al misconduct. Alex Acosta, who later became President Trump's labor secretary, was under fire for the generous plea deal that he entered into with Epstein, who was accused of abusing dozens of teenage girls. Well, today, a lawyer for Epstein's victims called the DOJ report a cover-up." The AP (11/12,
id the prosecutor who handled a 2008 case against Jeffrey Epstein showed poor judgment but did not engage
ustice Department that critics have said allowed Mr. Epstein to largely go unscrutinized in the face of years
onth known case of COVID-19 case on Thursday, following Texas as the second state to reach the "grim milestone." The New York Times (11/12, Fuller, Arango, Hubler, 18.61M) reports, "Citing an alarming increase in cases, San Francisco this week banned indoor dining at restaurants and paused a plan to r
sVi (11/12, story 10, 0:25, O'Donnell, 4.06M) reported, "This news today: The Justice Department said the prosecutor who handled a 2008 case against Jeffrey Epstein showed poor judgment but did not engage in professional misconduct. Alex Acosta, who later became President Trump's labor secretary, was under fire
al misconduct. Alex Acosta, who later became President Trump's labor secretary, was under fire for the generous plea deal that he entered into with Epstein, who was accused of abusing dozens of teenage girls. Well, today, a lawyer for Epstein's victims called the DOJ report a cover-up." The AP (11/12,
id the prosecutor who handled a 2008 case against Jeffrey Epstein showed poor judgment but did not engage
ustice Department that critics have said allowed Mr. Epstein to largely go unscrutinized in the face of years
onth known case of COVID-19 case on Thursday, following Texas as the second state to reach the "grim milestone." The New York Times (11/12, Fuller, Arango, Hubler, 18.61M) reports, "Citing an alarming increase in cases, San Francisco this week banned indoor dining at restaurants and paused a plan to r
t "sex trafficking charges and another alleged victim were added to a superseding indictment returned Monday in the criminal case against financier Jeffrey Epstein's ex-girlfriend as prosecutors alleged that a conspiracy to sexually abuse girls stretched over a decade." The AP says "the charges contained in a rew
" The AP says "the charges contained in a rewritten indictment returned by a grand jury in Manhattan federal court alleged that a conspiracy between Epstein and Ghislaine Maxwell occurred between 1994 and 2004." The indictment "returned after Maxwell's July arrest limited crimes to a three-year period i
y Middle Tennessee District U.S. Magistrate Judge Jeffrey S. Frensley, similar to those ordered in other C
he body cameras worn by the officers which he said will show the full interaction between Floyd and the police." The New York Times (3/29, Martinez, Arango, 20.6M) says that legal experts believe "the defense's best tool to minimize the impact of that video, which spurred the largest protests in the Un
at 'sex trafficking charges and another alleged victim were added to a superseding indictment returned Monday in the criminal case against financier Jeffrey Epstein's ex-girlfriend as prosecutors alleged that a conspiracy to sexually abuse girls stretched over a decade." The AP says -the charges contained in a rew
" The AP says -the charges contained in a rewritten indictment returned by a grand jury in Manhattan federal court alleged that a conspiracy between Epstein and Ghislaine Maxwell occurred between 1994 and 2004." The indictment "returned after Maxwell's July arrest limited crimes to a three-year period in
Middle Tennessee District U.S. Magistrate Judge Jeffrey S. Frensley, similar to those ordered in other Ca
he body cameras worn by the officers which he said will show the full interaction between Floyd and the police." The New York Times (3/29, Martinez, Arango, 20.6M) says that legal experts believe "the defense's best tool to minimize the impact of that video, which spurred the largest protests in the Uni
Menendez's Bribery Case Reminds Us Why Proving Corruption Is So Hard CRIMINAL INVESTIGATIONS • Ghislaine Maxwell's Lawyer Tell Appeals Judges That Jeffrey Epstein's Florida Plea Deal Protects Her • Republicans Subpoenaed 15 Years of Hunter Biden Phone Records, Democrats Reveal • Ex-Mar-a-Lago Employee Says He U
on. Lawyers for Maxwell are challenging her December 2021 conviction on multiple grounds, but the only topic at oral arguments was whether the deal Epstein struck in Florida to prevent a federal case against him there also protected Maxwell in New York. Samson said it did. A prosecutor said it didn't. M
islaine Maxwell's Lawyer Tell Appeals Judges That Jeffrey Epstein's Florida Plea Deal Protects Her • Repub
ken by the NMDO1 makes all of New Mexico a safer place." Warden Ousted From Federal Women's Prison Plagued by Sex Abuse The New York Times (03/12, Arango) reported that the warden of a federal women's prison in Northern California that has long been plagued by rampant sexual abuse was ousted from his
Menendez's Bribery Case Reminds Us Why Proving Corruption Is So Hard CRIMINAL INVESTIGATIONS • Ghislaine Maxwell's Lawyer Tells Appeals Judges That Jeffrey Epstein's Florida Plea Deal Protects Her • Republicans Subpoenaed 15 Years of Hunter Biden Phone Records, Democrats Reveal • Ex-Mar-a-Lago Employee Says He U
on. Lawyers for Maxwell are challenging her December 2021 conviction on multiple grounds, but the only topic at oral arguments was whether the deal Epstein struck in Florida to prevent a federal case against him there also protected Maxwell in New York. Samson said it did. A prosecutor said it didn't. M
slaine Maxwell's Lawyer Tells Appeals Judges That Jeffrey Epstein's Florida Plea Deal Protects Her • Repub
ken by the NMDO1 makes all of New Mexico a safer place." Warden Ousted From Federal Women's Prison Plagued by Sex Abuse The New York Times (03/12, Arango) reported that the warden of a federal women's prison in Northern California that has long been plagued by rampant sexual abuse was ousted from his
Entities connected to both Jeffrey Epstein and Arango

Marc Rich
PERSONLeon Black
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Woody Allen
PERSON
Eric Trump
PERSON
George Mitchell
PERSONDaphne Wallace
PERSON
Madison
LOCATION
George W. Bush
PERSON
Donald Trump
PERSON
Bradley Edwards
PERSON
United States
LOCATION
Condoleezza Rice
PERSON
Glenn Dubin
PERSON
Stephen Hawking
PERSONJack Goldberger
PERSON
Joe Biden
PERSON
Prince Charles
PERSONSouthern District
LOCATION