Epstein Secrets

have known that Plaintiff had no credentials to provide massage therapy. b. She observed the Plaintiff being brought to the Palm Beach mansion of JEFFREYEPSTEIN, when the Plaintiff was a minor, andsometimes escorted the Plaintiff to a room in that mansion where JEFFREY EPSTEIN was waiting, for the ostensibl

atabase - flsd Page 1 of 5 LSS U.S. District Court Southern District of Florida (West Palm Beach) CIVIL DOCKET FOR CASE #: 9:08-cv-80811-KAM v. Epstein et al Assigned to: Judge Kenneth A. Marra Cause: 28:1332 Diversity Plaintiff V. Defendant Jeffrey Epstein Date Filed: 07/21/2008 Jury Demand:

e Plaintiff, when the Plaintiff was a minor, which depicted fhe Plaintiff in the nude. She told the Plaintiff that the pictures were at the request ofJEFFREY EPSTEIN, and paid the Plainlifffor posing for the photographs. 12. As a icsult, the Plaintiff sufferedmental anguish, mental pain and suffeaing, psychic

on which alleges sexual abuse of a female minor by the defendant JEFFREY EPSTEIN. 4. It has come to the attention of the undersigned that Defendant JEFFREY EPSTEIN filed a Motion with the Florida State Court to return the evidence seized at his home in conjunction with his criminal prosecution. With re

instant claim, but for other suits filed against Defendant EPSTEIN, including but not limited to the Florida RICO c

e 4 of 40 (b) While the Complaint suggests that Mr. Epstein might be a citizen of New York or Florida, he is

the Federal Rules of Civil Procedure, this court has the authority to modify the normal time limitations under the Rules. See AT&T Mobility LLC v. Dynamic Cellular Corp., 2008 WL 2139518 (S.D. Fla. 2008); see also Tradone Wireless, Inc. v.King Trading, Inc., 2008 WL 918243 (N.D. Tex. 2008). Additionally, when there

Counsel for Defendant Jeffrey Epstein Case 9:08-cv-80119-KAM Document 405 Entered on FLSD Docket 11/12/2009 Page 10 of 33 L.M. Plaintiff, V. JEFFREY EPSTEIN, Defendant. ____________ __;/ IN THE COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502008CA028051XXXX

IDENCE, & INCORPORATED MEMORANDUM OF LAW (AS TO JANE DOE v. EPSTEIN, Case No. 08-CIV-80893 Marra/Johnson) Defendant, Jeffrey Epstein, (hereinafter "Epstein"), by and through his undersigned attorneys, pursuant to Rules 26, 34, and 37, Fed.R.Civ.P. (2009), moves for entry of an order for the preservatio

eturn for settlement funds alleged paid or to be paid on behalf of Jeffrey Epstein; c. Soliciting money to help finance ongoing litigation against Jeffrey Epstein; d. Soliciting money to be given to, or used on behalf of, the plaintiffs in litigation against Jeffrey Epstein; Case 9:08-cv-80119-KAM

ORE CLERK U.S. DIST. CT. S.D. OF FLA. - W.P.B. DEFENDANT EPSTEIN'S EMERGENCY MOTION FOR ORDER FOR THE PRESERVATIO

18 of 33 e. Communication between third party investors or potential investors and the plaintiffs or their attorneys involved in litigation against Jeffrey Epstein; f. Payments made by RRA to or on behalf of any plaintiff 2. Any and all fee agreements that exist or have existed between the following:

ith belief that evidence may be lost or destroyed, the Court has the authority to enter an order preserving such evidence. See AT&T Mobility LLC v. Dynamic Cellular Corp., 2008 WL 2139518 (S.D. Fla. May 7, 2008); Tracfone Wireless, Inc. v. King Trading, Inc., 2008 WL 918243, at *1 (N.D. Tex. Mar. 13, 2008) (finding "

NITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-80804-CIV-MARRA/JOIINSON JANE DOE, a/k/a, JANE DOE NO. I, Plaintiff, vs. JEFFREY EPSTEIN, S SN1 and Defendants. PLAINTIFF'S MOTION TO PRESERVE EVIDENCE AND EXPEDITE CERTAIN DISCOVERY Plaintiff Jane Doe moves, pursuant to Rules 26 an

). 4. This evidence is relevant and critical to the prosecution of not only the instant claim, but for six (6) other claims filed against Defendant EPSTEIN, including but not limited to the Florida RICO claims filed in State Court. WHEREFORE, Plaintiff respectfully request the Court grant her Motion to

laim, but for six (6) other claims filed against Defendant EPSTEIN, including but not limited to the Florida RICO c

NE DOE, a/k/a, JANE DOE NO. I, Plaintiff, vs. JEFFREY EPSTEIN, S SN1 and Defendants. PLAINTIFF'S MO

the Federal Rules of Civil Procedure, this court has the authority to modify the normal time limitations under the Rules. See AT&T Mobility LLC v. Dynamic Cellular Corp., 2008 WL 2139518 (S.D. Fla. 2008); see also Tracfone Wireless, Inc. v. King Trading, Inc., 2008 WL 918243 (N.D. Tex. 2008). Additionally, when there

Case 9:08-cv-80119-KAM Document 114 Entered on FLSD Docket 05/26/2009 Page 1 of 15 JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 3, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 4, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DO

asonably available to the defendant. See 18 U.S.C. § 3509(m)(2)(A) (2008). 8. In addition to evidence related to the October 25 search, Defendant, Jeffrey Epstein, exercises sole custody and control over specific evidence relevant and material to this lawsuit relating to Defendant's sexual abuse of Pl

t's counsel have asserted that a motion requesting to preserve evidence would be moot because of an order previously entered in Jane Doe v. Jeffrey Epstein, et al., Case No. 08-80804-CIV-MARRA/JOHNSON. Plaintiffs respectfully submit that an enforceable order is needed in their particular cases and that

is a good faith belief that evidence may be lost, the Court has the authority to enter an order preserving such evidence. See AT & T Mobility LLC v. Dynamic Cellular Corp., No. 08-20537-Civ., 2008 WL 2139518, at *2 (S.D. Fla. May 7, 2008); see also Trac/one Wireless. Inc. v. King Trading, Inc., No. 3-08-CV-0398-B, 200