Epstein Secrets

driguez advised he had very limited contact with Mr. Epstein. If Rodriguez needed to relay a message to Mr. E

d Six, to-wit The Grand Jurors of the State of Florida, inquiring in end for the body of said County of Palm Beach, upon their oaths do present that JEFFREY E. EPSTEIN in the County of Palm Beach aforesaid. in the Circuit and State aforesaid. COUNT ONE FELONY SOLICITATION OF PROSTITUTION on or about or between th

esses and register himself as an agent. I also observed Epstein has his El Zorro Ranch Corporation, New York Strategy Group, Ghislaine Corporation, J Epstein and Company and the Financial Strategy Group registered to this same address. Finally, a third call is received by at 12:02 pm from the same corp

y of Palm Beach, upon their oaths do present that JEFFREY E. EPSTEIN in the County of Palm Beach aforesaid.

I wrote that, but I didn't write what you 13 said. 14 4. 15 16 you write that? 17 18 19 20 21 22 about what happened when you went to Jeff Epstein's house You wrote in this exhibit, "I got some stupid court s-h-i-t on the 20th. Bull s-h-i-t." Didn't A. Yes. Q. Referring to this deposition, d

his associates. ) (describing character of party defendant Epstein as a "sexual predator" (a term defined by Florida

y of Palm Beach, upon their oaths do present that JEFFREY E. EPSTEIN in the County of Palm Beach aforesaid. i

, prostitutes who sued a house of prostitution (as an "enterprise") for inflicting systematic and repetitive abuse on them, over time. See Bala: v. Ruzzo, 703 So. 2d 1076, 1077 (Fla. 5th DCA 1997) (offering an example of a civil RICO claim against the operators of an alleged "house of prostitution,"

ket 07)21:2008 Page 16 of 100 1. The plaintiff seeks damages in connection with her own illegal conduct. The plaintiff concedes that she went to Jeffrey Epstein's house "to give Epstein a massage for monetary compensation." (Am. Compl. ¶ 13.) The plaintiff also concedes, in the guise of an allegation, that "

respectfully state as follows: Introduction Six months ago, this plaintiff filed virtually the identical lawsuit in this Court. See Jane Doe #1 v. Epstein, Case No. 08-cv-80069-KAM (S.D. Fla. filed Doe v. Epstein et at, Case No. 50 2008 CA 006596 XXXX MB (Fla. 15th Cir. Ct. filed Mar. 6, 2008). Lewis

A. Yes. Q. Didn't you tell that to the police? A. Yes. And I will continue. I have never had sex with him. Q. Did what happened upstairs at Jeff Epstein's house take you completely by surprise,. A. Yes. Q. Now the civil complaint that you filed against Mr. Epstein for fifty million dollars alleged

in's house you had 17 never told Jeff that you were under 18, right? 18 A. No. 19 Q. Before you got to Epstein's house had you 20 ever told Jeffrey that you were under 18? 21 A. No. I never spoke to the man before that. 22 Q. And you only went to Jeff Epstein's house 23 that one time thre

his associates. ) (describing character of party defendant Epstein as a "sexual predator" (a term defined by Florida

the instant case, adding two nominal defendants Mr. Epstein's personal secretary, and MB one of Jane Doe #1'

e, prostitutes who sued a house of prostitution (as an "enterprise") for inflicting systematic and repetitive abuse on them, over time. See Baku v. Ruzzo, 703 So. 2d 1076, 1077 (Fla. 5th DCA 1997) (offering an example of a civil RICO claim against the operators of an alleged "house of prostitution,"

04/02/2009 Page 1 of 9 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA.JOHNSON JANE DOE NO. 2 Plaintiff, V. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION TO COMPEL PLAINTIFF. JANE DOE NO. 2. To ANSWER DEFENDANT'S FIRST SET OF INTERROGATORIES AND TO OVERRULE OB

rogatories nos. 10 and 14 are presently resolved. Case 9:08-cv-80119-KAM Document 68 Entered on FLSD Docket 04/02/2009 Page 2 of 9 Doe 2 v. Epstein Page No. 2 Also, Defendant has filed simultaneously with this motion a Motion To Compel directed to certain of Plaintiff's Responses to Defendant'

resses and phone numbers of all males, excluding Mr. Epstein, with whom you have had sexual activity since age

2 Plaintiff, V. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION TO COMPEL PLAINTIFF. JANE DOE NO. 2. To

1 [email protected] Co-Counsel for Defendant Jeffrey Epstein Respectfully sub By: __ -1-:....::.. _

anation for why victim exhibited behavioral manifestations of sexually abused child.). In further support of Defendant's motion, a copy of Balas v. Ruzzo, 703 So.2d 1076 (Fla. 5th DCA 1997), rev. denied, 719 So.2d 286 (Fla. 1998), is attached hereto as Exhibit A as it is on point to the discovery iss

5/05/2009 Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2 Plaintiff, V. JEFFREY EPSTEIN, Defendant. I ------------- MOTION TO COMPEL AND/OR IDENTIFY JANE DOE IN THE STYLE OF THIS CASE AND MOTION TO IDENTIFY JANE DOE IN THIRD-PARTY S

POENAS FOR PURPOSES OF DISCOVERY, OR ALTERNATIVELY, MOTION TO DISMISS SUA SPONTE, WITH INCORPORATED MEMORANDUM OF LAW Defendant, JEFFREY EPSTEIN ("Epstein" or "Defendant"), by and through his undersigned attorneys, hereby requests that this Court enter an order identifying in the style of this case th

Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 561-659-8300 Fax: 561-835-8691 [email protected] Co-Counsel for Defendant Jeffrey Epstein By: ~~~~~:.--ii:i'"""ccr- R D. CRI N, JR., ESQ. Florida Bar No. 224162 [email protected] MICHAEL J. PIKE, ESQ. Florida Bar #617296 m

to Dismiss Entire Action Sua Sponte. In support, Mr. Epstein states as follows: I. Motion And Incorporated Me

deem just an Robert D. • ton, Jr. Attorney for Defendant Epstein Certificate of Service I HEREBY CERTIFY that a

n medical doctors is a basic discovery need related to the claims alleged by JANE DOE for which Plaintiff's counsel refuses to compromise. Balas v. Ruzzo, 703 So.2d 1076 (Fla. 5th DCA 1997), rev. denied, 719 So.2d 286 (Fla. 8 Case 9:08-cv-80119-KAM Document 91 Entered on FLSD Docket 05/05/2009

TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA 2 3 4 E.W., ) 5 ) Plaintiff, ) 6 ) vs )Case No. 502008CA028058 7 )XXXXMB AD JEFFREY EPSTEIN, ) 8 ) Defendant. ) 9 X 10 11 PROCEEDINGS BEFORE THE 12 HONORABLE JUDGE DONALD W. HAFELE 13 14 15 May 22, 2009 8:30 a.m. - 9:30 a.m

nsual 17 sexual partners since the age of 10 of our 18 clients. 19 Now, going to the point about the timing 20 of the deposition, we took Mr. Epstein's 21 deposition on April 30th, a month ago. We got 22 approximately 153 refusals to answer in 155 23 pages of questions. 24 Let me back up a

er to see them through rose colored 6 glasses. 7 I would say one of the best examples is 8 statement. She basically says, "You 9 know, I love Jeffrey, he was good to us. I told 10 every girl I brought, including , you have 11 to do a topless massage and maybe the more you 12 do, the more mon

about the timing 20 of the deposition, we took Mr. Epstein's 21 deposition on April 30th, a month ago. We

76, and that was a decision of the Fifth District Court of Appeal, and I will quote headnote 3, "had the Petitioners brought their lawsuit against Ruzzo and the Board Room only under Section 769.09, evidence of Petitioner's past prostitution 8 including with the Board Room and their earnings 9 r

ourt they sit, is going to be entitled to a fair shake and a fair trial and entitled to the EFTA00776411 47 1 2 3 4 5 6 7 the Ballast vs. Ruzzo case. For the record, the citation is 703 So.2d. 1076, and that was a decision of the Fifth District Court of Appeal, and I will quote headnote 3,

4/02/2009 Page 1 of 12 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA.JOHNSON JANE DOE NO. 2 Plaintiff, V. JEFFREY EPSTEIN, Defendant. ----------------'' DEFENDANT EPSTEIN'S MOTION TO COMPEL PLAINTIFF, JANE DOE NO. 2, TO RESPOND TO DEFENDANT'S FIRST REQUEST TO PRODUCE

ues as to production request no. 14 are presently Case 9:08-cv-80119-KAM Document 67 Entered on FLSD Docket 04/02/2009 Page 2 of 12 Doe 2 v. Epstein Page No. 2 resolved. This motion addresses those requests on which the parties were unable to come to an agreement. Also, Defendant has filed sim

JEFFREY EPSTEIN, Defendant. ----------------'' DEFENDANT EPSTEIN'S MOTION TO COMPEL PLAINTIFF, JANE DOE NO. 2, TO

1 [email protected] Co-Counsel for Defendant Jeffrey Epstein Respectfully sub By: c-=-:::-:::-,:::--

anation for why victim exhibited behavioral manifestations of sexually abused child.). In further support of Defendant's motion, a copy of Balas v. Ruzzo, 703 So.2d 1076 {Fla. 5th DCA 1997), rev. denied, 719 So.2d 286 (Fla. 1998), is attached hereto as Exhibit A as it is on point to the discovery iss

t 104 Entered on FLSD Docket 05/19/2009 Page 1 of 13 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO.2, Plaintiff, vs. IBFFREY EPSTEIN, Defendant. ---------~' JANEDOENO.3, Plaintiff, vs. IBFFREY EPSTEIN, Defendant. ---------~' JANE DOE NO.4, Plaintiff, vs. JEFFREY EPSTEIN

ted Memorandum of Law1 1. C.M.A. was filed on February 23, 2008. C.M.A. filed her First Amended Complaint on February 10, 2009. (C.M.A. DE 39-40). Epstein's Motion to Dismiss same was filed on March 12, 2009. (C.M.A. DE 47). The Motion to Dismiss remains outstanding. 2. Jane Doe (80893) was filed on

resses and phone numbers of all males, excluding Mr. Epstein, with whom you have had sexual activity since age

CASE NO.; 08-CV-80656-MARRA/JOHNSON Defendant, Jeffrey Epstein's Motion To Strike Cases From Current Tri

08-cv-80119-KAM Document 104 Entered on FLSD Docket 05/19/2009 Page 9 of 13 Page9 States v. Bear Stops. 997 F.2d 451 (8th Cir. 1993); Balas v. Ruzzo, 703 So.2d 1076 (Fla. 5th DCA 1997), rev. denied, 719 So.2d 286 (Fla. 1998). The information sought in 4(e) is relevant and discoverable even if no

t 110 Entered on FLSD Docket 05/20/2009 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. ---------~! JANEDOENO.4, Plaintiff, vs. JEFFREY EPSTEIN

ndant. CASE NO.; 08-CV-80591-MARRA/JOHNSON CASE NO.; 08-CV-80656-MARRA/JOHNSON Defendant, Jeffrey Epstein's Reply To Memorandums In Opposition To Epstein's Motion To Compel Answers To First Set Of Interrogatories And First Request To Produce Directed To Jane Doe Numbers2-7 Defendant, JEFFREY EPSTEIN

-4------- R ob e rt D. Critton, Jr. Attorney for Defendant Epstein Certificate of Service I HEREBY CERTIFY that a

CASE NO.; 08-CV-80656-MARRA/JOHNSON Defendant, Jeffrey Epstein's Reply To Memorandums In Opposition To

requested information is not relevant? 7. Next, despite Plaintiffs' strained interpretation and application of the discovery requests in Balas v. Ruzzo, 703 So.2d 1076 (Fla. 5th DCA 1997), rev. denied, 719 So.2d 286 (Fla. 1998), that case is instrumental in that, once again, we are at the "discovery

1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ____________________________________/ Related cases: 08-80232, 08-80380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469

0656, 09-80802, 09-81092 ____________________________________/ OMNIBUS ORDER THIS CAUSE is before the Court on the following motions: (1) Defendant Epstein’s Motion to Compel Plaintiff Jane Doe 2 to Respond to Defendant’s First Request to Produce and to Overrule Objections and For an Award of Defendant’s

is before the Court on the following motions: (1) Defendant Epstein’s Motion to Compel Plaintiff Jane Doe 2 to Respon

allege they were sexually assaulted by Defendant, Jeffrey Epstein (“Epstein”), at his Palm Beach mansion ho

ces may be held to prevent mere discovery, is not applicable in this instance, where Plaintiff has placed her past sexual history at issue. Balas v. Ruzzo, 703 So.2d 1076 (Fla. 5 DCA 1997), rev. th denied,719 So.2d 286 (Fla. 1998)(allowing discovery of plaintiff’s employment history which included pros

09 Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. _______________ / Related cases: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656

ent questioning of their past sexual histories in order to prevent the Defendant and a jury from properly analyzing their damages as it pertains to Epstein while, at the same time, blinding the jury from instances in each of the Plaintiffs' lives where psychological, mental, physical and sexual trauma m

0591, 09-80656, 09-80802, 09-81092 I Defendant, Jeffrey Epstein's Reply to Plaintiff, Jane Doe 2-8, Respo

lanation for why victim exhibited behavioral manifestations of sexually abused child.). 14. In further support of Defendant's motion, See Balas v. Ruzzo, 703 So.2d 1076 (Fla. 5th DCA 1997), rev. denied, 719 So.2d 286 (Fla. 1998), as it is on point to the discovery issues in this action, and the rele