Epstein Secrets

Australian A venue South Suite 1400 West Palm Beach, FL 33401-5012 561-659-8300 Fax: 561-835-8691 iagesq(cv,bellsouth.net Counsel for Defendant Jeffi'ey Epstein Certificate of Service Jane Doe No. 2 v. Jeffrey Epstein Case No. 08-CV-80119-MARRA/JOHNSON Stuart S. Mermelstein, Esq .. Adam D. Horowitz, Esq.

:/ EPSTEIN'S MOTION FOR PROTECTIVE ORDER REGARDING THE DEPOSITION OF STORY COWLES AND INCORPORATED MEMORANDUM OF LAW Defendant, JEFFREY EPSTEIN ("Epstein"), pursuant to Rule 26(c), Federal Rules of Civil Procedure, moves for a protective order to prohibit the deposition of Story Cowles, and states:

as hired by Jack Goldberger, Esq., co-counsel for Mr. Epstein, on I July 16, 2008 and has been employed by Mr

esq(cv,bellsouth.net Counsel for Defendant Jeffi'ey Epstein Certificate of Service Jane Doe No. 2 v. Jeffre

pstein Certificate of Service Jane Doe No. 2 v. Jeffrey Epstein Case No. 08-CV-80119-MARRA/JOHNSON Stua

iscussed the claims asserted against him with Mr. Cowles other than when his attorneys were present or when he was transmitting information between Epstei11 and his attorneys. See Exhibit C. 2 i I ! Case 9:08-cv-80119-KAM Document 536 Entered on FLSD Docket 04/29/2010 Page 3 of 8 9. In Octob

s attorney. 12. The attorney-client privilege also extends to subordinates of a party's attorney. -- - - - - - ··- --·· -· -- . -- See Seebeck v. General Motors Corp., 1996 WL 742914 (N.D. Ga. 1996). In Seebeck, the court noted that to invoke the attorney client privilege: (1) the asserted holder of the privilege

80119-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, V. JEFFREY EPSTEIN, Defendant. _____________ / 0 DEFENDANT EPSTE

ocket 05/06/2010 Page 2 of 31 Jane Doe No. 2 v. Epstein Case No. 08-CV-80119-Marra-Johnson Page 2 in m

f Count III, Plaintiff "demands judgment against Jeffery Epstein for all damages available under 18 U.S.C. §2255(a

JEFFREY EPSTEIN, Defendant. _____________ / 0 DEFENDANT EPSTEIN'S MOTION FOR SUMMARY JUDGMENT, INCLUDING SUPPORT

8691 [email protected] Counsel for Defendant Jeffrey Epstein Case 9:08-cv-80119-KAM Document 539

e legal consequences of their actions. FNl8. See General Motors Corp. v. Romein, 503 U.S. 181, 191, 112 S.Ct. 1105, 11

4/17/2009 Page 1 of 7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, V. JEFFREY EPSTEIN, Defendant. ___________ ____..cl DEFENDANT EPSTEIN'S RESPONSE TO PLAINTIFF'S MOTION FOR PROTECTIVE ORDER AND TO QUASH SUBPOENA FOR DEPOSITION O

allowing for the relief requested herein and for such other relief a is court deems just and proper. obert D. Critton, Jr. Attorney for Defendant Epstein Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of the Court using CM/ECF. I als

FREY EPSTEIN, Defendant. ___________ ____..cl DEFENDANT EPSTEIN'S RESPONSE TO PLAINTIFF'S MOTION FOR PROTECTIVE

2, filed this federal lawsuit against Defendant, Jeffrey Epstein. In another separate matter, a Plaintiff

ttled that a Defendant may take the deposition of a party and/or a witness before trial. Rule 26, Fed.R.Civ. P., Rule 30, Fed.R. Civ.,P. and Leve v. General Motors Corp., 43 F.R.D. 508 (S.D.N.Y. 2967). Jane Doe. Nos. 2 and 3 commenced separate civil actions upon the filing of same against Jeffrey Epstein. Therefore,

10-80309-CIV- JANE DOE No. 103, Plaintiff, vs. JEFFERY EPSTEIN, Defendant. ------------~/ DEFENDANT EPSTEIN'S

[email protected] Counsel for Defendant Jeffrey Epstein By: =+-t-::±::::1=-::-:--:-::::--:::c: ROBER .

s. JEFFERY EPSTEIN, Defendant. ------------~/ DEFENDANT EPSTEIN'S MOTION TO DISMISS.COUNT VI & FOR MORE DEFINITE

8691 [email protected] Counsel for Defendant Jeffrey Epstein By: =+-t-::±::::1=-::-:--:-::::--:::c:

e legal consequences of their actions. FN18. See General Motors Corp. v. Romein, 503 U.S. 181, 191, 112 S.Ct. 1105, 11

cher By SUSAN SPENCER-WENDEL Palm Beath Rot Staff ;Voter WEST PALM BEACH — A judge on Friday declined to suspend his ruling to unseal financier Jeffrey Epstein's secret non-pros- ecution deal with federal prosecutors. but delayed the docwnent's release until Thursday. The delay gives Ep- stein's attorneys

g a Palm Beach Police Department investigation, five victims and 17 witnesses gave statements. They told of young women brought by his assistants to Eptstein's mansion on El Brillo Way for massages and sexual activity, and then being paid afterward. At Epstein's plea conference last year, his attorney, J

h federal prosecutors to avoid charges should be sealed, according to a transcript of the hearing. Jeffrey Epstein And so it was. . Billionaire Jeffrey ff • Epstein has been sentenced to 18 months for felony solicitation of prostitution following accusations by teen girls. Past coverage - O

the attorney for Palm Beach Marine. "Apparently, Mr. Epstein blew his top when he saw the bill. Still, 100 gra

ere 34 percent lower than a year ago. "Stimulating sales is the only way to get the auto industry back on its led," said Rep. Donald Manzullo, General Motors Corp. and Chrysler LLC have received billions of dol- lars in government aid and the entire auto indus- try has watched car sales plummet during the pa

ntiff, JANE DOE 3, by and through their undersigned counsel, and pursuant to Federal Rules of Civil Procedure Rule 33, hereby responds to Defendant, JEFFREY EPSTEIN'S First Set of Interrogatories to Plaintiff as follows: General Oblections 1. Plaintiff objects to Defendant's Interrogatories to the extent that th

CT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S RESPONSE TO PLAINTIFF'S MOTION FOR PROTECTIVE ORDER AND TO QUASH SUBPOENA FOR DEPOSITION OF JANE DOE NO.3. MOTION TO CONSOLIDATE CASES FOR PURPO

2, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S RESPONSE TO PLAINTIFF'S MOTION FOR PROTECTIVE

9-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S RESPONS

settled that a Defendant may take the deposition of a ma and/or a witty-cc before trial. Rule 26, Fed.R.Civ. P., Rule 30, Fed.R. Civ.,P. and lave v. General Motors Corp., 43 F.R.D. 508 (S.D.N.Y. 2967). Jane Doe. Nos. 2-7 commenced separate civil actions upon the filing of same against Jeffrey Epstein. Therefore, Def

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CIV-80119-MARRA 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, 09-80802, 09-8109

Defendant. Related cases: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 EPSTEIN'S MOTION FOR PROTECTIVE ORDER REGARDING THE DEPOSITION OF STORY COWLES AND INCORPORATED MEMORANDUM OF LAW Defendant, JEFFREY EPSTEIN ("Epstein"),

IV-80119-MARRA JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. Related cases: 08-80232, 0

as hired by Jack Goldberger, Esq., co-counsel for Mr. Epstein, on July 16, 2008 and has been employed by Mr. G

ts or representatives of a party's attorney. 12. The attorney-client privilege also extends to subordinates of a party's attorney. See Seebeck v. General Motors Corp., 1996 WL 742914 (N.D. Ga. 1996). In Seebeck, the court noted that to invoke the attorney client privilege: (1) the asserted holder of the privilege

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE, CASE NO. 08-CV-80893-CIV-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, et al. Defendant. Related Cases: 08-80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802,

08-80994, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 PLAINTIFF JANE DOE'S EMERGENCY MOTION FOR A HEARING, FINDING THAT EPSTEIN IS IN CIVIL CONTEMPT OF THE COURT'S TWO ORDERS FORBIDDING HARASSMENT AND INDIRECT CONTACT, FOR APPROPRIATE SANCTIONS AND ADDITIONAL REMEDIES INCLUD

of criminal contempt. To put the matter bluntly, defendant Epstein is intimidating Jane Doe in violation of three j

. 08-CV-80893-CIV-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, et al. Defendant. Related Cases: 08-8

er home (or, if necessary, other place of safety) without facing the threat of any further harassment or intimidation. See Serra Chevrolet, Inc. v. General Motors Corp., 446 F.3d 1137, 1147 (11th Cir. 2006) ("Civil contempt may be imposed in an ordinary civil proceeding upon notice and an opportunity to be heard.")

, including any sovereign or government, relating to or arising from any Member of the Class's harm, injury, abuse, exploitation, or trafficking by Jeffrey Epstein or by any person who is in any way connected to or otherwise associated with Jeffrey Epstein, as well as any right to recovery on account thereof.

, abuse, exploitation, or trafficking by Jeffrey Epstein or by any person who is in any way connected to

, injury, abuse, exploitation, or trafficking by Jeffrey Epstein or by any person who is in any way conne

S.C. § 7706(0(1); 18 U.S.C. § 248(c)(3). States may seek damages for residents within their authority as parens patriae. See New York by Abrams v. General Motors Corp., 547 F Supp at 706-07 (S.D.N.Y. 1983) ("The State's goal of securing an honest marketplace in which to transact business is a quasi-sovereign intere

TO: MARTY WEINBERG FROM: KIM HOMAN RE: EPSTEIN/DEPOSITION SUBPOENA DATE: APRIL 8, 2016 Under Fed. R. Civ. P. 45(c)(1)(A), a subpoena may compel a person to appear for a deposition only "within

w York for a few months before returning to live and work in Russia did not reside in New York for purposes of Rule 45. It is my understanding that JE's primary and permanent residence is in the Virgin Islands but that he regularly spends time living in a home over which he has dominion and contro

er requiring "[e]stablishment of .. . a physical presence in the State and an intention to make the State a permanent home." Id., quoting Antone v. General Motors Corp., 64 N.Y.2d 20, 28 (1984). Under New York law, therefore, residence means something less than a permanent home. According to Yukos Hydrocarbons, "[t