Epstein Secrets

sponse to Government's Cross-Motion for Summary Judgment, and states: I. JANE DOE 2 CLEARLY EXPRESSED HER DESIRE NOT TO BE TREATED AS A VICTIM OF EPSTEIN During the Government's investigation into Jeffrey Epstein in 2006, Jane Doe 2 expressed her clear and unequivocal desire not to be treated as a vi

as a victim of his conduct. 22. The Plaintiff is included in the list of victims identified by the Federal Government as victims of the Defendant, Jeffrey Epstein's illegal conduct. Defendant, Jeffrey Epstein, is thus estopped by his plea and agreement with the Federal Government from denying the acts alleged

did not want underage girls providing him massages. D.E. 403-3 at 9. She lamented that Epstein was the subject of a criminal investigation: I hope Jeffrey, nothing happens to Jeffrey because he's an awesome man and it would really be a shame. It's a shame that he has to go through this because he's an

e sole issue before the Circuit Court was whether defendant Epstein was entering pleas of guilty that were voluntary

ress acts to amend a statute, we presume it intends its amendment to have real and substantial effect." Stone v. INS, 514 U.S. 386, 397 (1995), and Pierce County v. Guillen, 537 U.S. 129, 145 (2003)(rejecting an argument under which a statutory amendment "would protect from disclosure only information that wa

sponse to Government's Cross-Motion for Summary Judgment, and states: I. JANE DOE 2 CLEARLY EXPRESSED HER DESIRE NOT TO BE TREATED AS A VICTIM OF EPSTEIN During the Government's investigation into Jeffrey Epstein in 2006, Jane Doe 2 expressed her clear and unequivocal desire not to be treated as a vi

as a victim of his conduct. 22. The Plaintiff is included in the list of victims identified by the Federal Government as victims of the Defendant, Jeffrey Epstein's illegal conduct. Defendant, Jeffrey Epstein, is thus estopped by his plea and agreement with the Federal Government from denying the acts alleged

did not want underage girls providing him massages. D.E. 403-3 at 9. She lamented that Epstein was the subject of a criminal investigation: I hope Jeffrey, nothing happens to Jeffrey because he's an awesome man and it would really be a shame. It's a shame that he has to go through this because he's an

e sole issue before the Circuit Court was whether defendant Epstein was entering pleas of guilty that were voluntary

ress acts to amend a statute, we presume it intends its amendment to have real and substantial effect." Stone v. INS, 514 U.S. 386, 397 (1995), and Pierce County v. Guillen, 537 U.S. 129, 145 (2003)(rejecting an argument under which a statutory amendment "would protect from disclosure only information that wa

Case 9:08-cv-80119-KAM Document 216 Entered on FLSD Docket 07/21/2009 Page 1 of 22 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, CASE N

13) (the "Notice of Conditional Reliance"), With Incorporated Memorandum of Law. An expeditious ruling by this Court is now critical. 3 In support, Epstein states: 1 DE 114 and DE 121 were stricken because they were incorrectly filed pursuant to the Court's Order consolidating cases. Plaintiff refilled

ocket 07/21/2009 Page 4 of 22 Page4 Defendant, Jeffrey Epstein's Response In Opposition to Plaintiff, Ca

I (Sexual Battery), '][199.) 13 Case 9:08-cv-80119-KAM Document 216 Entered on FLSD Docket 07/21/2009 Page 14 of 22 Page 14 See Fajardo v. Pierce County, 2009 WL 1765756 (W.D. Wash. 2009)(allegations of specific disorders amount to more than garden variety disorders and thus Plaintiff waived physicia

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, 09-80591,09-8065

d records from a "CMA" designation? Then, on May 20, 2009, C.M.A. capitulated and filed her Notice of Withdrawal of Previously Raised Objections to Epstein's Motion to Compel and/or Identify C.M.A. in the Style of this Case and Motion to Identify C.M.A. in Third-Party Subpoenas for Purposes of Discover

6,09-80802,09-81092 --------------~/ Defendant, Jeffrey Epstein's Reply to Plaintifrs Response In Opposit

79, 85, 91, 97, 103, 109, 115, 121, 127, 133, 139, 145, 151, 157, 163, 169, 175, 181, 187, 193; Count XXXI (Sexual Battery), iJl99.) See Fajardo v. Pierce County, 2009 WL 1765756 (W.D. Wash. 2009)(allegations of specific disorders amount to more than garden variety disorders and thus Plaintiff waived physici

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

evidence. Even so, at this juncture, it is without question that same is discoverable. Admissibility can be handled on another date. See Fajardo v. Pierce County, 2009 WL 1765756 (W.D. Wash. 2009)(allegations of specific disorders amount to more than garden variety disorders and thus Plaintiff waived physici