Epstein Secrets

August 4, 2009 VIA ELECTRONIC MAIL Spencer T. Kuvin, Esq. Leopold—Kuvin, P.A. 2925 PGA Boulevard Suite 200 Palm Beach Gardens, FL 33410 Re: Jeffrey Epstein/B.B. — Requested Disclosure of Non-Prosecution Agreement Dear Mr. Kuvin: Thank you for your letter regarding the disclosure of the Non-Prosecution Agree

ter giving notice of breach. I respectfully submit that the Motion to Dismiss that is referenced therein did not constitute a willful breach of Mr. Epstein's obligations under the non-prosecution agreement. Mr. Epstein's counsel unanimously determined that the filing of this Motion to Dismiss was not a

tatement [DE 29] dated May 26, 2009. Counsel for Defendant EPSTEIN Certificate of Service I HEREBY CERTIFY that a

, Suite 400 West Palm Beach, Florida 33401 Re: Jeffrey Epstein Dear Ms. Villafana, M www.kirkland.com

d therein did not constitute a willful breach of Mr. Epstein's obligations under the non-prosecution agreement

tion against Jeffrey Epstein styled B.B.I. Jeffi-ey Epstein, case no.: 502008CA037319 MB AB. We are hereby r

an act which, if consummated, constitutes battery." 3A Fla.Jur.2d Assault §1. An assault and battery are intentional acts. See generally, Spivey'. Battaglia, 258 So.2d 815 (Fla. 1972); and Travelers Indem. Co.'. PCR, Inc., 889 So.2d 779 (Fla. 2004). On the face of the Complaint, the applicable four year

11, Plaintiff "demands judgment against Defendant Jeffrey Epstein for all damages available under 28 U.S.C

0/06/2008 Page 1 of 10 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'S. EPSTEIN. MOTION TO DISMISS AND MOTION FOR MORE DEFINITE STATEMENT DIRECTED TO PLAINTIFF'S AMENDED COMPL

------------'' DEFENDANT'S. EPSTEIN. MOTION TO DISMISS AND MOTION FOR MORE DEFINITE STATEMENT DIRECTED TO PLAINTIFF'S AMENDED COMPLAINT Defendant, JEFFERY EPSTEIN, by and through his undersigned counsel, moves to dismiss and for more definite statement of Plaintiff JANE DOE NO. 2's Amended Complaint. Rules 12

ntiff "demands judgment against Defendant Jeffrey Epstein for all damages available under 28 U.S.C. §2255(

an act which, if consummated, constitutes battery." 3A Fla.Jur.2d Assault §1. An assault and battery are intentional acts. See generally, Spivey v. Battaglia, 258 So.2d 815 (Fla. 1972}; and Travelers lndem. Co. v. PCR. Inc., 889 So.2d 779 (Fla. 2004). An "assault" is an intentional, unlawful offer of co

lsd Page 1 of 15 LRJ U.S. District Court Southern District of Florida (West Palm Beach) CIVIL DOCKET FOR CASE #: 9:08-cv-80232-KAM Doe No. 3 v. Epstein Assigned to: Judge Kenneth A. Marra Lead case: 2:flasaAhd Member case: (View Member Case) Case: 9:09-cv-80802-KAM Cause: 28:1332 Diversity-Perso

file this document. (Is) (Entered: 05/20/2009) 05/20/2009 2.$ NOTICE by C.M.A. of Filing Withdrawal of Previously Raised Objections to Defendant, Jeffrey 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 Discovery,

3/11/2008) 05/22/2008 4 AFFIDAVIT of Service for Summons and Complaint served on Jeffrey Epstein on May 7, 2008, filed by Jane Doe No. 3. (Herman, Jeffrey) (Entered: 05/22/2008) 05/29/2008 5 Plaintiffs MOTION for Entry of Default by Clerk Against Defendant by Jane Doe No. 3. (Attachments: # 1 Exhibi

plicable statute of limitations. WHEREFORE Defendant requests that this Court deny the re ' f sought by Plaintiff. Robert D. C itton, Jr. Attorney f. 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 also

of an act which, if consummated, constitutes battery." 3A Fla.Jur.2d Assault §1. An assault and battery are intentional acts. See generally Spivey'. Battaglia, 258 So.2d 815 (Fla. 1972); and Travelers Indem. Co.". PCR. Inc. 889 So.2d 779 (Fla. 2004). An "assault" is an intentional, unlawful offer of corp

O PLAINTIFF JANE DOE N0.6'S COMPLAINT Defendant, JEFFERY EPSTEIN, by and through his undersigned counsel, moves t

/515-3148 Fax ( Co-Counsel for Defendant Jeffrey Epstein)

!h day of October, 2008: Adam D. Horowitz, Esq. Jeffrey Marc Herman, Esq. Stuart S. Mermelstein, Esq. 1

ry are intentional acts. See generally, Spivey v. Battaglia, 258 So.2d 815 (Fla. 1972); and Travelers lndem.

She Was Caught • Ex-CIA Official Warns Intel Agencies Will Be Politically Active in 2024 Election CRIMINAL INVESTIGATIONS • The Biggest Names from Jeffrey Epstein's Unsealed Court Documents • Florida Man Arrested for Threatening to Kill Bay Area Rep. Eric Swalwell • Attempted Murder Indictment Handed Down In Sh

and cover up his crimes. According to the article, the documents so far were sprinkled with names of celebrities and politicians who socialized with Epstein or worked with him in the years before he was publicly accused nearly two decades ago of paying underage girls for sex. The Daily Mail (01/04, Smith

CRIMINAL INVESTIGATIONS • The Biggest Names from Jeffrey Epstein's Unsealed Court Documents • Florida Man

ention hearing. Oregon Police Releasing Few Details on Probe Into Alleged Deaths, Drug Thefts at Oregon Hospital Oregon Public Broadcasting (01/04, Battaglia, Higginbottom) reported that the Medford Oregon Police Department confirmed its investigation into the alleged theft of controlled substances at Asa

to Be Released Under Florida Law The Associated Press (02/29, Anderson) reported that grand jury transcripts from a 2006 Florida investigation into Jeffrey Epstein's abuse of dozens of underage girls will be released publicly later this year under legislation signed into law Thursday by Gov. Ron DeSantis. A local

fect July 1, would carve out a limited exception to the secrecy that generally shrouds grand jury testimony in specific cases such as that involving Epstein, DeSantis said at a signing ceremony in Palm Beach, Florida, where many of the crimes took place at Epstein's home. The Hill (02/29, Timotija), NPR

unter Biden Case Left Trail of Broken Promises • Jeffrey Epstein Grand Jury Records From Underage Girl Abu

n), Washington Post (02/29, Barr), CNN (02/29, Darcy), Daily Wire (02/29, Saavedra), Daily Caller (02/29, Angela), and the Los Angeles Times (02/29, Battaglia) also reported on the story. FBI Surprises Middle School Student in Alabama Who Dreams of Becoming an Agent EFTA01655800 WBRC (Fox-6) (02/29, Bro