Epstein Secrets

Case 9:08-cv-80119-KAM Document 16-2 Entered on FLSD Docket 07/01/2008 Page 2 of 4 : tiP • ' CASE PIO ±-122OO.1.:IFO-51/4 541sXXX CF V. JEFFREY E. EPSTEIN Z41 'FP ^i ria4 Y tr..mr.y..PRzia"rtnivz•zrt : . • . 7 'Crt. Rep. lun,L__ Date : • -17 vcri J „Asir )----=-- • / PD e--P:9fot Pres, D

events or omissions giving rise to the claim occurred in this District. Factual Allegations 7. At all relevant times, Defendant Jeffrey Epstein ("Epstein") was an adult male, 52 years old. Epstein is a financier and money manager with a secret clientele limited exclusively to billionaires. He is hims

, represented by Assistant United States , and Mr. Epstein, entered into a deferred- prosecution agreement (

' CASE PIO ±-122OO.1.:IFO-51/4 541sXXX CF V. JEFFREY E. EPSTEIN Z41 'FP ^i ria4 Y tr..mr.y..PRzia"r

ach, Florida 33401 Tel. 561 659 8300 Fax. 561 835 8691 By: Jack A. Goldberger Fla. Bar No. 262013 jgoldberger®agwpa.com Attorneys for Defendant Jay Epstein CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 711.A.3 While defense counsel admittedly did not confer with plaintiffs' counsel prior to filing the moti

l distress based on the same factual allegations. Defendant Epstein has moved to dismiss only Count I of the Complai

' CASE PIO ±-122OO.1.:IFO-51/4 541sXXX CF V. JEFFREY E. EPSTEIN Z41 'FP ^i ria4 Y tr..mr.y..PRzia"rt

izens who "inquire, upon their oaths, whether there be sufficient cause to call upon the party to answer" the charge of criminal activity. Beavers" Henkel, 194 U.S. 73, 84 (1904) (quoting William Blackstone, 4 Commentaries *303). The grand jury's sole purpose is to inquire into whether there is probabl

21 LRJ, MEDREQ, REF_DISCOV U.S. District Court Southern District of Florida (West Palm Beach) CIVIL DOCKET FOR CASE #: 9:08-cv-80119-1CAM Doe v. Epstein Assigned to: Judge Kenneth A. Marra Referred to: Magistrate Judge Linnea R. Johnson Member case: (View Member Case) Case: 9:09-cv-80802-KAM Caus

ON Plaintiffs Jane Doe No. 101 and Jane Doe 102's Motion for No- Contact Order Plaintiffs Jane Doe No. 101 and Jane Doe No. 102's Reply to Defendant Jeffrey Epstein's Response to Plaintiffi Jane Doe No. 101 and Jane Doe No. 102's Motion for a No-Contact Order filed by Jane Doe No. 101, Jane Doe No. 102. Associate

red: 02/08/2008) 05/22/2008 4 AFFIDAVIT of Service for Summons and Complaint served on Jeffrey Epstein on May 7, 2008, filed by Jane Doe. (Herman, Jeffrey) (Entered: 05/22/2008) 05/22/2008 5 SUMMONS Returned Executed by Jane Doe. Jeffrey Epstein served on 5/7/2008, Answer due 5/27/2008. (Ik) (Entere

FTA00175604 CM/ECF - Live Database - flsd Page 17 of 21 05/20/2009 Ma NOTICE be. of Filing Withdrawal of Previously Raise Lions to Defendant. Jetey Epstein's Motion to Ag And/Or IdentifyMf. in the Style of This Case and Motion to Identi . in Third-Party Subpoenas for Purposes of Discovery, Or, Alternati

. 2 I JEFFREY EPSTEIN, Plaintiff, Defendant. DEFENDANT EPSTEIN'S ANSWER & AFFIRMATIVE DEFENSES TO PLAINTIFF'S S

legations in her complaint, the plaintiff went to Mr. Epstein's house to give him "a massage for monetary comp

tizens who "inquire, upon their oaths, whether t4re be sufficient cause to call upon the party to answer" the charge of criminal activity. Beavers" Henkel, 194 U.S. 73, 84 (1904) (quoting William Blackstone, 4 Commentaries *303). The grand jury's sole purpose is to inquire into whether there is probabl

1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA NO. 08-80119-CIV-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, v. JEFFREY EPSTEIN, Defendant. ___________________________/ ORDER DENYING MOTION TO STAY THIS CAUSE comes before the Court on Defendant Jeffrey Epstein’s Motion to Stay

nal action is pending until its final adjudication in the trial court. 18 U.S.C. § 3509 (k). In his motion, Defendant cites a state case, Florida v. Epstein, No. 2006 Case 9:08-cv-80119-KAM Document 33 Entered on FLSD Docket 08/05/2008 Page 1 of 5 As Defendant recognizes, the state court case was

AY THIS CAUSE comes before the Court on Defendant Jeffrey Epstein’s Motion to Stay (DE 12), filed June 20,

zens who “inquire, upon their oaths, whether there be sufficient cause to call upon the party to answer” the charge of criminal activity. Beavers v. Henkel, 194 U.S. 73, 84 (1904) (quoting William Blackstone, 4 Commentaries *303). The grand jury’s sole purpose is to inquire into whether there is probabl

lse and misleading statements about its anti-money laundering policies and failed to monitor `high-risk' customers including convicted sex offender Jeffrey Epstein." ABC News (7/19, Margolin, Katersky, 2.97M) reports, "The investigation is being led by the FBI, which declined to comment. The New Jersey State P

stomers including convicted sex offender Jeffrey Epstein." ABC News (7/19, Margolin, Katersky, 2.97M) rep

risk' customers including convicted sex offender Jeffrey Epstein." ABC News (7/19, Margolin, Katersky, 2.

sponsible for National Cherry Festival posters, several local art exhibitions and a statue placed at the Grand Traverse Commons." FBI agents "claim Henkel spent years forging other artists' work," and they "believe Henkel passed those near-indistinguishable copies off in galleries around the nation, ra

/JOHNSON JANE DOE NO. 2, Plaintiff, v. JEFFREY EPSTEIN, Defendant. ORDER DENYING MOTION TO STAY THIS CAUSE comes before the Court on Defendant Jeffrey Epstein's Motion to Stay (DE 12), filed June 20, 2008. The motion is now fully briefed and is ripe for review. The Court has carefully considered the motion

al action is pending until its final adjudication in the trial court. 18 U.S.C. § 3509 (k). In his motion, Defendant cites a state case, Florida v. Epstein, No. 2006 EFTA00215875 Case 9:08-cv-80119-KAM Document 33 Entered on FLSD Docket 08/05/2008 Page 2 of 5 CF 09454AXX (Fla. Cir. Ct. 2008)' and

V-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, v. JEFFREY EPSTEIN, Defendant. ORDER DENYING MOTION TO STA

ens who "inquire, upon their oaths, whether there be sufficient cause to call upon the party to answer" the charge of criminal activity. Beavers v. Henkel, 194 U.S. 73, 84 (1904) (quoting William Blackstone, 4 Commentaries *303). The grand jury's sole purpose is to inquire into whether there is probabl

V-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, 1. JEFFREY EPSTEIN, Defendant. ORDER DENYING MOTION TO STA

/JOHNSON JANE DOE NO. 2, Plaintiff, 1. JEFFREY EPSTEIN, Defendant. ORDER DENYING MOTION TO STAY THIS CAUSE comes before the Court on Defendant Jeffrey Epstein's Motion to Stay (DE 12), filed June 20, 2008. The motion is now fully briefed and is ripe for review. The Court has carefully considered the motion

nal action is pending until its final adjudication in the trial court. 18 U.S.C. § 3509 (k). In his motion, Defendant cites a state case, Florida.. Epstein, No. 2006 1 EFTA00221953 Case 9:08-cv-80119-KAM Document 33 Entered on FLSD Docket 08/05/2008 Page 2 of 5 CF 09454AXX (Fla. Cir. Ct. 2008)' a

izens who "inquire, upon their oaths, whether there be sufficient cause to call upon the party to answer" the charge of criminal activity. Beavers" Henkel, 194 U.S. 73, 84 (1904) (quoting William Blackstone, 4 Commentaries *303). The grand jury's sole purpose is to inquire into whether there is probabl

/JOHNSON JANE DOE NO. 2, Plaintiff, 1. JEFFREY EPSTEIN, Defendant. ORDER DENYING MOTION TO STAY THIS CAUSE comes before the Court on Defendant Jeffrey Epstein's Motion to Stay (DE 12), filed June 20, 2008. The motion is now fully briefed and is ripe for review. The Court has carefully considered the motion

nal action is pending until its final adjudication in the trial court. 18 U.S.C. § 3509 (k). In his motion, Defendant cites a state case, Florida.. Epstein, No. 2006 1 EFTA00222382 Case 9:08-cv-80119-KAM Document 33 Entered on FLSD Docket 08/05/2008 Page 2 of 5 CF 09454AXX (Fla. Cir. Ct. 2008)' a

V-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, 1. JEFFREY EPSTEIN, Defendant. ORDER DENYING MOTION TO STA

izens who "inquire, upon their oaths, whether there be sufficient cause to call upon the party to answer" the charge of criminal activity. Beavers" Henkel, 194 U.S. 73, 84 (1904) (quoting William Blackstone, 4 Commentaries *303). The grand jury's sole purpose is to inquire into whether there is probabl

/JOHNSON JANE DOE NO. 2, Plaintiff, v. JEFFREY EPSTEIN, Defendant. ORDER DENYING MOTION TO STAY THIS CAUSE comes before the Court on Defendant Jeffrey Epstein's Motion to Stay (DE 12), filed June 20, 2008. The motion is now fully briefed and is ripe for review. The Court has carefully considered the motion

al action is pending until its final adjudication in the trial court. 18 U.S.C. § 3509 (k). In his motion, Defendant cites a state case, Florida v. Epstein, No. 2006 EFTA01660018 Case 9:08-cv-80119-KAM Document 33 Entered on FLSD Docket 08/05/2008 Page 2 of 5 CF 09454AXX (Fla. Cir. Ct. 2008)' and

V-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, v. JEFFREY EPSTEIN, Defendant. ORDER DENYING MOTION TO STA

ens who "inquire, upon their oaths, whether there be sufficient cause to call upon the party to answer" the charge of criminal activity. Beavers v. Henkel, 194 U.S. 73, 84 (1904) (quoting William Blackstone, 4 Commentaries *303). The grand jury's sole purpose is to inquire into whether there is probabl

ket 08:05:2008 Page 1 of 5 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA NO. 08-80119-CIV-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, v. JEFFREY EPSTEIN, Defendant. ORDER DENYING MOTION TO STAY THIS CAUSE comes before the Court on Defendant Jeffrey Epstein's Motion to Stay (DE 12), filed June 20,

al action is pending until its final adjudication in the trial court. 18 U.S.C. § 3509 (k). In his motion, Defendant cites a state case, Florida v. Epstein, No. 2006 1 EFTA00014187 --- PAGE BREAK --- Case 9:08-cv-80119-KAM Document 33 Entered on FLSD Docket 08/05/2008 Page 2 of 5 CF 09454AXX (Fl

Y THIS CAUSE comes before the Court on Defendant Jeffrey Epstein's Motion to Stay (DE 12), filed June 20,

ens who "inquire, upon their oaths, whether there be sufficient cause to call upon the party to answer" the charge of criminal activity. Beavers v. Henkel, 194 U.S. 73, 84 (1904) (quoting William Blackstone, 4 Commentaries *303). The grand jury's sole purpose is to inquire into whether there is probabl

SUBPOENA T AND TO DISMISS COUNTS FIVE AND SIX Jeffrey S. Pagliuca Laura A. Menninger HADDON MORGAN &

F.2d 1505 (9th Cir. 1985) 10 Doe v. Broderick, 225 F.3d 440 (4th Cir. 2000) 10, 13 Fisher v. United States, 425 U.S. 391 (1976) 3, 15 Hale v. Henkel, 201 U.S. 43 (1906) 2, 4 In re Grand Jury Subpoena Duces Tecum, 945 F.2d 1221 (2d Cir. 1991) 14 In re Grand Jury Subpoena, JK-I5-029, 828 F.3d 1