Epstein Secrets

/25/2009 Page 1 of 37 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 -------------- DEFENDANT EPSTEIN'S RESPONSE TO PLAINTIFF'S MOTION TO COMPEL ANSWERS TO INTERROGATORIES, and RESPONSES TO 1st and 2

se protections meaningless in attempting Case 9:08-cv-80119-KAM Document 63 Entered on FLSD Docket 03/25/2009 Page 2 of 37 Jane Doe No. 2 v. Epstein Page2 to assert and argue the factual basis for the additional objections and privileges. See part II.A. herein. I. Defendant EPSTEIN has proper

ntains his principal home in New York and also owns residences in New Mexico, St. Thomas and Palm Beach, FL." Id, ,I?. "Upon information and belief, Jeffrey Epstein carried out his scheme and assaulted girls in Florida, New York and on his private island, known as Little St. James, in St. Thomas." Id, ,

name in an Indictment as victims of an offense by Mr. Epstein enumerated in 18 U.S.C. §2255. Request No. 2.

JEFFREY EPSTEIN, Defendant. I -------------- DEFENDANT EPSTEIN'S RESPONSE TO PLAINTIFF'S MOTION TO COMPEL ANSWE

rol what we shall reveal about our intimate selves, to whom, and for what purpose. Bryon, Harless, Schaffer, Reid & Assocs., Inc. v. State ex rel, Schellenberg, 360 So.2d 83, 92 (Fla. 1st DCA 1978), quashed and remanded on other grounds, 379 So.2d 633 (Fla.1980). Because this power is exercised in varying

09-80802, 09-81092 --------------~/ DEFENDANT, JEFFREY EPSTEIN'S RESPONSE IN OPPOSITION TO PLAINTIFF'S, JANE DOE,

d on FLSD Docket 10/06/2009 Page 2 of 23 Doe v. Epstein 08-CV80119 Page No. 2 herein. Portions of DE 28

nsuming. Request No. 16: All medical records of Defendant Epstein from Dr. Stephan Alexander. Response: Defendan

uant to Florida Statute 796.09 Against Defendant, Jeffrey Epstein". Erie R.Co. v. Tompkins, 58 S.Ct. 817

, Schaffer, Reid & Assocs., Inc. v. State ex rel, Schellenberg, 360 So.2d 83, 92 (Fla. 1st DCA 1978), quashed a

EW AND APPEAL OF PORTIONS OF THE MAGISTRATE'S ORDER DATED FEBRUARY 4, 2010 (DE 462), WITH INCORPORATED OBJECTIONS AND MEMORANDUM OF LAW Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through his undersigned attorneys, hereby files his Motion for Reconsideration and/or for Request Rule 4 Review and

HE MAGISTRATE'S ORDER DATED FEBRUARY 4, 2010 (DE 462), WITH INCORPORATED OBJECTIONS AND MEMORANDUM OF LAW Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through his undersigned attorneys, hereby files his Motion for Reconsideration and/or for Request Rule 4 Review and Appeal of Portions of

250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 561-659-8300 Fax: 561-835-8691 [email protected] Counsel for Defendant Jeffrey £stein 80893 Paul G. Cassell, Esq. Pro Hae Vice 332 South 1400 E, Room 101 Salt Lake City, UT 84112 801-585-5202 801-585-6833 Fax cassellp@law.

n fact and opinion attorney work product of both Mr. Epstein's attorneys and government attorneys. Particular

trol what we shall reveal about our intimate selves, to whom, and for what purpose. Bryon, Harless, Schaffer, Reid & Assocs., Inc. v. State ex rel, Schellenberg. 360 So.2d 83, 92 (Fla. 1st DCA 1978), quashed and remanded on other grounds, 379 So.2d 633 (Fla.1980). Because this power is exercised in varying

Case 9:08-cv-80119-KAM Document 545 Entered on FLSD Docket 05/12/2010 Page 1 of 37 JANE DOE NO. 2, Plaintiff, VS, JEFFREY EPSTEIN, Defendant. UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CIV-80119-MARRA/JOHNSON I -------------- Related cases: 08-

4, 2010 (DE 462), (DE 480) AND APRIL 1, 2010 (DE 513), WITH INCORPORATED OBJECTIONS AND MEMORANDUM OF LAW Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through his undersigned attorneys, hereby files his Consolidated Rule 4 Review and Appeal of Portions of the Magistrate's Orders (DE 462)

o. 19 Beach State Attorney and the USAO may not want to disclose their files for one reason or another. (ii) Third Party Privacy Rights And Judge Jeffrey's Colbath's Order The Magistrate's Order does not consider the privacy rights of other alleged victims. As this Court knows, attached to the NP A i

n fact and opinion attorney work product of both Mr. Epstein's attorneys and government attorneys. Particular

trol what we shall reveal about our intimate selves, to whom, and for what purpose. Bryon, Harless, Schaffer, Reid & Assocs., Inc. v. State ex rel, Schellenberg, 360 So.2d 83, 92 (Fla. 1st DCA 1978), quashed and remanded on other grounds, 379 So.2d 633 (Fla.1980). Because this power is exercised in varying

ent 477 Entered on FLSD Docket 0226;2010 Page 1 of 24 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. CASE NO.: 08-CIV-80119-MARRA/JOHNSON Related cases: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469,

HE MAGISTRATE'S ORDER DATED FEBRUARY 4, 2010 (DE 462), WITH INCORPORATED OBJECTIONS AND MEMORANDUM OF LAW Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through his undersigned attorneys, hereby files his Motion for Reconsideration and/or for Request Rule 4 Review and Appeal of Portions of

n this regard and/or providing self-incriminating information is substantial, real and not merely imaginative. Third Party Privacy Rights And Judge Jeffrey's Colbath's Order The Magistrate's Order does not consider the privacy rights of other alleged victims. As this Court knows full well, attached to

n fact and opinion attorney work product of both Mr. Epstein's attorneys and government attorneys. Particular

ontrol what we shall reveal about our intimate selves, to whom, and for what purpose. Bryon, Hades& Schaffer, Reid & Assocs., Inc. v. State ex rel. Schellenberg, 360 So.2d 83, 92 (Fla. 1st DCA 1978), quashed and remanded on other grounds, 379 So.2d 633 (Fla.1980). Because this power is exercised in varying

ent 545 Entered on FLSD Docket 05/12/2010 Page 1 of 37 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. CASE NO.: 08-CIV-80119-MARR A/JOHNSON Related cases: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469,

4, 2010 (DE 462), (DE 480) AND APRIL 1, 2010 (DE 513), WITH INCORPORATED OBJECTIONS AND MEMORANDUM OF LAW Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through his undersigned attorneys, hereby files his Consolidated Rule 4 Review and Appeal of Portions of the Magistrate's Orders (DE 462)

o. 19 Beach State Attorney and the USAO may not want to disclose their files for one reason or another. (ii) Third Party Privacy Rights And Judge Jeffrey's Colbath's Order The Magistrate's Order does not consider the privacy rights of other alleged victims. As this Court knows, attached to the NPA is

n fact and opinion attorney work product of both Mr. Epstein's attorneys and government attorneys. Particular

trol what we shall reveal about our intimate selves, to whom, and for what purpose. Bryon. Hatless. Schaffer. Reid & Assocs.. Inc. v. State ex rel. Schellenberg. 360 So.2d 83, 92 (Fla. 1st DCA 1978), quashed and remanded on other grounds, 379 So.2d 633 (Fla.1980). Because this power is exercised in varying

From: "Jeffrey E." <[email protected]> To: Subject: Fwd: Alzhe

i wanted to talk to him about Forwarded message From: Date: Sat, Apr 8, 2017 at 9:17 AM Subject: Fwd: Alzheimer's R&D updates - March 2017 To: Jeffrey Epstein <[email protected]> Begin forwarded message: From:- > Datil.8 2017 at 3:38:14 AM EDT To: < > Subject: FW: Alzheimer's R&D updates - March

Alzheimer's R&D updates - March 2017 To: Jeffrey Epstein <[email protected]> Begin forwarded message:

From: "Jeffrey E." <[email protected]> To: Subject: Fwd: A

m LW, Yokoyama 1S, Rosen H1, Miller BL, Dillon WP, Wilson DM, Hess CP, Pericak-Vance M, Haines 1L, Farrer LA, Mayeux R, Hardy 1, Goate AM, Hyman BT, Schellenberg GD, McEvoy LK, Andreassen OA, Dale AM. 2017. Genetic assessment of age-associated Alzheimer disease risk: Development and validation of a polygenic

Page 1 of 24 JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. UNITED STATES DISTRICT COURT SOUTH

Of Law Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through his undersigned attorneys, her

, With Incorporated Memorandum Of Law Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through h

Schaffer, Reid & Assocs., Inc. v. State ex rel, Schellenberg, 360 So.2d 83, 92 (Fla. 1st DCA 1978), quashed an

15:25:52 +0000 Good morning - well received, thank you very much. Executive Assistant to Ronald S. Lauder RSL Management Corporation T F From: Jeffrey Epstein Date: Saturday, April 8, 2017 at 9:30 AM Subject: Fwd: Alzheimer's R&D updates - March 2017 Morning! please forward below to Ronald. ... tell him

R&D updates - March 2017 Morning! please forward below to Ronald. ... tell him Gates has decided to spend some money on alzhhiemers, that is what Jeffrey wanted to talk to him about Thanks, Forwarded message From: Date: Sat, Apr 8, 2017 at 9:17 AM Subject: Fwd: Alzheimer's R&D updates - March 201

RSL Management Corporation T F From: Jeffrey Epstein Date: Saturday, April 8, 2017 at 9:30 AM Subjec

m LW, Yokoyama JS, Rosen Hi, Miller BL, Dillon WP, Wilson DM, Hess CP, Pericak-Vance M, Haines JL, Farrer LA, Mayeux R, Hardy J, Goate AM, Hyman BT, Schellenberg GD, McEvoy LK, Andreassen OA, Dale AM. 2017. Genetic assessment of age-associated Alzheimer disease risk: Development and validation of a polygenic

at, 08 Apr 2017 13:30:11 +0000 Morning! please forward below to.. ... tell him Gates has decided to spend some money on alzhhiemers, that is what Jeffrey wanted to talk to him about Thanks, Forwarded message From: Date: Sat, Apr 8, 2017 at 9:17 AM Subject: Fwd: Alzheimer's R&D updates - March 201

m LW, Yokoyama JS, Rosen Hi, Miller BL, Dillon WP, Wilson DM, Hess CP, Pericak-Vance M, Haines JL, Farrer LA, Mayeux R, Hardy J, Goate AM, Hyman BT, Schellenberg GD, McEvoy LK, Andreassen OA, Dale AM. 2017. Genetic assessment of age-associated Alzheimer disease risk: Development and validation of a polygenic