Epstein Secrets

Six, to-wit: The Grand Jurors of the State of Florida, inquiring in and for the body of said County of Palm Beach, upon their oaths do present that JEFFREY E. EPSTEIN in the County of Palm Beach aforesaid, in the Circuit and State aforesaid, COUNT ONE FELONY SOLICITATION OF PROSTITUTION on or about or between t

ion For Time Certain Based On Parallel Civil And Criminal Proceedings With Incorporated Memorandum Of Law Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN") by and through his undersigned attorneys, hereby moves this Court for the entry of an order staying or continuing this action for a time certain

13 In the instant case, the privilege applies as Defendant EPSTEIN "has reasonable cause to apprehend danger from a

of Palm Beach, upon their oaths do present that JEFFREY E. EPSTEIN in the County of Palm Beach aforesaid, i

of Palm Beach, upon their oaths do present that JEFFREY E. EPSTEIN in the County of Palm Beach aforesaid, in

attorney for JEFFREY EPSTEIN. 3. I represented Mr. EPSTEIN in the negotiation of and entering into a Non-Pr

465 U.S., at 613. and n. 11. 104 S.Ct. 1237; Fisher. 425 U.S., at 409-410. 96 S.Ct. 1569; id. at 428. 432. 96 S.Ct. 1569 (concurring opinions). See Braswell v. United States. [487 U.S..1 at 104, 108 S.Ct. 2284; J id.] at 122. 108 S.Ct. 2284 (dissenting opinion). Thus, the Court made clear that the Fifth

Six, to-wit: The Grand Jurors of the State of Florida, inquiring in and for the body of said County of Palm Beach, upon their oaths do present that JEFFREY E. EPSTEIN in the County of Palm Beach aforesaid, in the Circuit and State aforesaid, COUNT ONE FELONY SOLICITATION OF PROSTITUTION on or about or between t

ion For Time Certain Based On Parallel Civil And Criminal Proceedinas With Incorporated Memorandum Of Law Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN") by and through his undersigned attorneys, hereby moves this Court for the entry of an order staying or continuing this action for a time certain

attorney for JEFFREY EPSTEIN. 3. I represented Mr. EPSTEIN in the negotiation of and entering into a Non-Pr

6. In the instant case, the privilege applies as Defendant EPSTEIN "has reasonable cause to apprehend danger from a

of Palm Beach, upon their oaths do present that JEFFREY E. EPSTEIN in the County of Palm Beach aforesaid, i

of Palm Beach, upon their oaths do present that JEFFREY E. EPSTEIN in the County of Palm Beach aforesaid, in

30 causesabeftemenmisn R9seurniitilit51712 EngigMergrl-PPRP098(PkWago9 PatoRN 4 #24 C.M.A. v. Epstein, et al. Page 11 (concurring opinions). See Braswell v. United States. 1487 U.S.,1 at 104. 108 S.Ct. 2284; f id..I at 122. 108 S.Ct. 2284 (dissenting opinion). Thus, the Court made clear that the Fift

/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

65 U.S., at 613, and n. 11, 104 S.Ct. 1237; Fisher, 425 U.S., at 409-410, 96 S.Ct. 1569; id., at 428, 432, 96 S.Ct. 1569 (concurring opinions). See Braswell v. United States, [487 U.S.,) at 104, 108 S.Ct. 2284; [ id.,] at 122, 108 S.Ct. 2284 (dissenting opinion). Thus, the Court made clear that the Fift

, psychologists, psychiatrists, mental health counselors, physicians, hospitals and treatment facilities. No. 9. (Not at issue.)' List all items in Jeffrey Epstein's possession in Palm Beach, Florida, at any time during the period of these interrogatories, which were used or intended to be used as sexual aids, s

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 TO COMPEL ANSWERS TO INTERROGATORIES, and RESPONSES TO 1st and 2nd PRODUCTION OF DOCUMENTS, AND INCORPORATED MEMO

2, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S RESPONSE TO PLAINTIFF'S MOTION TO COMPEL ANSWE

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

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

465 U.S., at 613, and n. 11, 104 S.Ct. 123T Fisher, 425 U.S., at 409-410, 96 S.Ct. 1569; id., at 428, 432, 96 S.Ct. 1569 (concurring opinions). See Braswell v. United States, 1487 U.S..'! at 104, 108 S.Ct. 2284; J id.,1 at 122, 108 S.Ct. 2284 (dissenting opinion). Thus, the Court made clear that the Fif

/25/2009 Page 1 of 15 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, Jeffrey Epstein's Motion To Stay And Or Continue Action For Time Certain Based On Parallel Civil And Cri

Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 561-659-8300 Fax: 561-835-8691 [email protected] Co-Counsel for Defendant Jeffrey Epstein 14 Case 9:08-cv-80119-KAM Document 65 Entered on FLSD Docket 03/25/2009 Page 15 of 15 Page 15 By: --4~~--+--11---- ROB D. RI N

an Avenue South Suite 1400 West Palm Beach, FL 33401-5012 561-659-8300 Fax: 561-835-8691 [email protected] Co-Counsel for Defendant Jeffrey Epstein 14 Case 9:08-cv-80119-KAM Document 65 Entered on FLSD Docket 03/25/2009 Page 15 of 15 Page 15 By: --4~~--+--11---- ROB D. RI N, JR., ES

13 In the instant case, the privilege applies as Defendant EPSTEIN "has reasonable cause to apprehend danger from a

65 U.S., at 613, and n. 11, 104 S.Ct. 1237; Fisher, 425 U.S., at 409-410, 96 S.Ct. 1569; id., at 428, 432, 96 S.Ct. 1569 (concurring opinions). See Braswell v. United States, [487 U.S.,] at 104, 108 S.Ct. 2284; [ id.,] at 122, 108 S.Ct. 2284 (dissenting opinion). Thus, the Court made clear that the Fift

T COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, v. JEFFREY EPSTEIN, Defendant. Defendant, Jeffrey Epstein's Motion To Stay And Or Continue Action For Time Certain Based On Parallel Civil And Criminal Proceedings With Incorporated Memorandum Of Law Defenda

ion For Time Certain Based On Parallel Civil And Criminal Proceedings With Incorporated Memorandum Of Law Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN") by and through his undersigned attorneys, hereby moves this Court for the entry of an order staying or continuing this action for a time certain

13 In the instant case, the privilege applies as Defendant EPSTEIN "has reasonable cause to apprehend danger from a

9-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, v. JEFFREY EPSTEIN, Defendant. Defendant, Jeffrey Epstein'

465 U.S., at 613. and n. 11. 104 S.Ct. 1237; Fisher. 425 U.S., at 409-410. 96 S.Ct. 1569; id. at 428. 432. 96 S.Ct. 1569 (concurring opinions). See Braswell v. United States. [487 U.S..1 at 104, 108 S.Ct. 2284; J id.] at 122. 108 S.Ct. 2284 (dissenting opinion). Thus, the Court made clear that the Fifth

JANE DOE NO. 102, Plaintiff, JEI-HtEY EPSTEIN, Defendant. CASE NO.: 09-80591-CIV-MARRA-JOHNSON CASE NO.: 09-80656-CIV-MARRA/JOHNSON DEFENDANT JEFFREY EPSTEIN'S RESPONSE TO PLAINTIFFS JANE DOE NOS. 101 and 102's MOTION FOR AN ORDER FOR THE PRESERVATION OF EVIDENCE & INCORPORATED MEMORANDUM OF LAW (dated 5/2

CASE NO.: 08-CV-80381-MARRA/JOHNSON EFTA00221589 Case 9:08-cv-80119-KAM Document 151 Entered on FLSD Docket 06/10/2009 Page 2 of 11 Doe 101 v. Epstein Page 2 CASE NO.: 08-80994-CIV-MARRA/JOHNSON JANE DOE NO. 6, Plaintiff, JEFFREY EPSTEIN, Defendant. CASE NO.: 08-80993-CIV-MARRA/JOHNSON JANE

ICT OF FLORIDA JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN Defendant. JANE DOE NO. 3, Plaintiff,

cket 06/10/2009 Page 3 of 11 Doe 101 v. Epstein Page 3 JANE DOE NO. 101, Plaintiff, JEItREY EPSTEIN Defendant. JANE DOE NO. 102, Plaintiff, JEI-HtEY EPSTEIN, Defendant. CASE NO.: 09-80591-CIV-MARRA-JOHNSON CASE NO.: 09-80656-CIV-MARRA/JOHNSON DEFENDANT JEFFREY EPSTEIN'S RESPONSE TO PLAINTIFFS JANE DOE

465 U.S., at 613, and n. 11, 104 S.Ct. 1237; Fisher, 425 U.S., at 409-410, 96 S.Ct. 1569; id, at 428. 432, 96 S.Ct. 1569 (concurring opinions). See Braswell v. United States, 1487 U.S.,I at EFTA00221594 Case 9:08-cv-80119-KAM Document 151 Entered on FLSD Docket 06/10/2009 Page 7 of 11 Doe 101 v. Ep

om the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN's bedroom at 358 El Brillo Way. (113) In or around the last half of 2004, Defendantr FREY EPSTEIN asked Jane Doe #14 to provide her telephone number. 22 EFTA00191745 (114) In or around the last half of 2004, Defendant JEFFREY EPSTEIN instruc

nd the New York residence so that JEFFREY EPSTEIN could, in exchange for money, engage in lewd conduct with those minor females in order to satisfy JEFFREY EPSTEIN's prurient interests. 6 EFTA00191729 Manner and Means 29. The manner and means by which the Defendants and other participants sought to accompli

t 358 El Brillo Way, Palm Beach, Florida, in the Southern District of Florida (hereinafter referred to as "358 El Brillo Way"). 5. DefendRJEFFREY EPSTEIN owned a property located at 9 East 71st Street, New York, New York (hereinafter referred to as "the New York residence"). 6. Defendant JEFFREY EPS

JEFFREY EPSTEIN asked Jane Doe #3 to recruit additional females to come to 358 El Brillo Way. (29) On or about November 8, 2004, one of Defendant JEFFREY EIN's employees prepared a written telephone message for Defendant JEFFREY EPSTEIN's review regarding a telephone call received from Jane Doe #3 t

the evidence it pro- poses to use is derived from a legitimate source wholly independent" of the testimo- ny given under the grant of immunity. See Braswell v. United States, — US. —, 108 S.Ct. 2284, 2295, 101 LEd.2d 98 (1988); Kastigar, 406 U.S. at 460, 92 S.Ct at 1666. See also Murphy v. Waterfront C

2, Plaintiff, JEFFREY EPSTEIN, Defendant. ___________ _)! CASE NO.: 09-80591-CIV-MARRA-JOHNSON CASE NO.: 09-80656-CIV-MARRA/JOHNSON DEFENDANT .JEFFREY EPSTEIN'S RESPONSE TO PLAINTIFFS JANE DOE NOS. 101 and 102's MOTION FOR AN ORDER FOR THE PRESERVATION OF EVIDENCE & INCORPORATED MEMORANDUM OF LAW (dated 5/2

SON I CASE NO.: 08-CV-80381-MARRA/JOHNSON I Case 9:08-cv-80119-KAM Document 151 Entered on FLSD Docket 06/10/2009 Page 2 of 11 Doe 101 v. Epstein Page2 JANE DOE NO. 6, Plaintiff, JEFFREY EPSTEIN, Defendant. CASE NO.: 08-80994-CIV-MARRA/JOHNSON ----------~! CASE NO.: 08-80993-CIV-MARRA/JO

0 Phone 561/515-3148 Fax (Counsel for Defendant Jeffrey Epstein) Case 9:08-cv-80119-KAM Document 151

65 U.S., at 613, and n. 11, 104 S.Ct. 1237; Fisher, 425 U.S., at 409-410, 96 S.Ct. 1569; id., at 428, 432, 96 S.Ct. 1569 (concurring opinions). See Braswell v. United States, (487 U.S.,] at Case 9:08-cv-80119-KAM Document 151 Entered on FLSD Docket 06/10/2009 Page 7 of 11 Doe 101 v. Epstein Page

Case 9:08-cv-80811-KAM Document 39 Entered on FLSD Docket 02/09/2009 Page 89 of 91 at vs. Epstein, et al. o.: 08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint self-esteem, loss of dignity, invasion of personal privacy and other damages ass

08-CV-80811-CIV-MARRA/JOHNSON First Amended Complaint self-esteem, loss of dignity, invasion of personal privacy and other damages associated with JEFFREY EPSTEIN'S controlling , manipulating, and coercing MI into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical

rsonal privacy and other damages associated with JEFFREY EPSTEIN'S controlling , manipulating, and coercin

5 U.S.. at 613. and n. 11, 104 S.Ct. 1237., Fisher, 425 U.S.. at 409-410. 96 S.Ct. 1569., id. at 428. 432. 96 S.Ct. 1569 (concurring opinions). See Braswell v. United States. 1487 U.S.,1 at EFTA00175464 • Case 9:08-cv-80119-KAM Document 151 Entered on FLSD Docket 06/10/2009 Page 7 of 11 Doe 101 v.