Epstein Secrets

Counsel for Plaintiff Jane Doe 6 EFTA00175540 Case 9:08-cv-8uo04-KAM Document Entered ..i FLSD Docket 09115L . J8 Page 7 of 8 SERVICE LIST Doe Epstein, et. al. CASE NO: 08-80804-Civ-MARIUUJOHNSON United States District Court, Southern District of Florida Robert Critton, Esq. Burman, Critton, Lut

natabase - flsd Page 1 of 6 U.S. District Court Southern District of Florida (West Palm Beach) CIVIL DOCKET FOR CASE #: 9:08-cv-80804-KAM Doe v. Epstein et al Assigned to: Judge Kenneth A. Marra Referred to: Magistrate Judge Linnea R. Johnson ' Case in other court: 15th Judicial Circuit, 50 2008 C

stion Plaintiff Jane Doe represented by Spencer Todd Kuvin Ricci Leopold 2925 PGA Boulevard Suite 200 Palm Beach Gardens , FL 33410 Defendant Jeffrey Epstein Fax: 515-2610 Email: LEAD ATTORNEY ATTORNEY TO BE NOTICED Theodore Jon Leopold Leopold—Kuvin, P.A. 2925 PGA Boulevard Suite 200 Palm Beach Garden

SD Do t 3.8/1b,..,08 Page 4 of 21 Iktb4-1 PLEA IN THE CIRCUIT COURT THE FOLLOVVING IS TO REFLECT Al .l TERMS OF THE NEGOTIATED SETTLEMEN*1 Name: Jeffrey E. Epstein Plea: Guilty 1 NP.---_.. SIMI .,lister _Dellloe a D 06CF009454A Felony Solicitation of Prostitution 1 No 3.FEI rocuring Person Under 18 for

nying as moot 2 Motion for Hearing. Signed by Judge Kenneth A. Marra on 8/5/08. (ir) (Entered: 08/06/2008) 08/08/20(8 a r ns KB MOTION Defendant Jeffiwy Epstein's Opposed Motion to Align Response Date by Jeffrey Epstein. (Attachments: # 1 Text of Proposed OrderXTein, Michael) (Entered: 08/08/2008) 08/13/2008

F.3d at 1314. conditions, and sensitive protocols concerning the fact of Epstein's previously disclosed incarceration. See DE 24 in Jane Doe No. 2 I. Epstein, Case No. 9:08-CV-80119-KAM (S.D. Fla. filed Feb. 6, 2Q08) (disclosing fact of Epstein's criminal sentence and incarceration); DE 19 in Jane Doe No

1332: the amount in controversy exceeds $75,000; Defendant Epstein is a citizen of the U.S. Virgin Islands; and Def

Al .l TERMS OF THE NEGOTIATED SETTLEMEN*1 Name: Jeffrey E. Epstein Plea: Guilty 1 NP.---_.. SIMI .,liste

Al .l TERMS OF THE NEGOTIATED SETTLEMEN*1 Name: Jeffrey E. Epstein Plea: Guilty 1 NP.---_.. SIMI .,lister

a/k/a, JANE DOE NO. 1, Plaintiff, vs. IF'.F .EY EPSTEIN , and Defendants. PLAINTIFF'S REPLY TO OPPOSIT

joined to the action. As such, Plaintiff asserts that complete diversity does not exist, and this Court does not have jurisdiction over this case. Standard of Review A defendant may remove any civil action brought in a state court over which a federal court would also have original jurisdiction. 28 U.S.C. § 1441

A NO. 08-80811-CIV-MARRA/JOHNSON Plaintiff, v. JEFFREY EPSTEIN and Defendants. ORDER AND OPINION THIS CAUSE is before the Court upon Defendant Jeffrey Epstein's Motion to Dismiss First Amended Complaint for Failure to State a Cause of Action, and Motion for More Definite Statement; Motion to Strike (DE 47).

, 2009 by an Amended Complaint (DE 40). Plaintiff brings suit alleging Counts I-XXX - Cause of Action Pursuant to 18 U.S.C. § 2255 against Defendant Epstein; Count XXXI - Sexual Battery against Defendant Epstein; and Count XXXII - Conspiracy to Commit Tortious Assault Against Defendant 1 EFTA00731326

se of Action Pursuant to 18 U.S.C. § 2255 against Defendant Epstein; Count XXXI - Sexual Battery against Defendant E

NO. 08-80811-CIV-MARRA/JOHNSON Plaintiff, v. JEFFREY EPSTEIN and Defendants. ORDER AND OPINION THIS

eed under section 2255 as she would have had, if Mr. Epstein had been tried federally and convicted of an enu

et 12/10/2009 Page 6 of 9 provide Defendant with sufficient notice of the underlying factual bases for the claims raised in the thirty-one counts. Standard of Review In deciding a motion to dismiss pursuant to Federal Rule of Civil Procedure 12(b)(6), a court must accept all factual allegations in a complaint as

Docket 03/03;2010 Page 1 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80893-CIV-MARRA JANE DOE, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ORDER THIS CAUSE is before the Court upon Defendant Jeffrey Epstein ("Defendant")'s Motion to Dismiss, for More Definite Statement &

stein. A list of more than 30 such minor females has previously been provided by the U.S. Attorney's Office for the Southern District of Florida to Epstein (but not to Jane Doe). See DE 38-2 at ¶ 4. Finally, Defendant argues, and Plaintiff concedes, that punitive damages are not available under 18 U.S

ICO statement that the "enterprise" consisted of Defendant Epstein, and his paid employees and . See Am. Comp. ¶

. 08-80893-CIV-MARRA JANE DOE, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ORDER THIS CAUSE is before

rida Statute 796.09. Defendant seeks dismissal of Counts II and IV of the Amended Complaint or, alternatively, moves for a more definite statement. Standard of Review In deciding a motion to dismiss pursuant to Federal Rule of Civil Procedure 12(b)(6), a court must accept all factual allegations in a complaint as

9-CIV-MARRA/JOHNSON JANE DOE II, Plaintiff, v. JEFFREY EPSTEIN and Defendants. ORDER AND OPINION THIS CAUSE is before the Court upon Defendant Jeffrey Epstein's Motion to Dismiss Plaintiff's Complaint (DE 13), filed May 6, 2009. The motion is now fully briefed and ripe for review. The Court has carefully re

Complaint, are as follows: During the events giving rise to this claim, Plaintiff was a minor but has now reached majority. Compl. ¶ 4. Defendant Epstein has a history of enticing young women, who are minors, and soliciting them to engage in prostitution for his own sexual gratification. Compl. 8. Eps

minor but has now reached majority. Compl. ¶ 4. Defendant Epstein has a history of enticing young women, who are m

-CIV-MARRA/JOHNSON JANE DOE II, Plaintiff, v. JEFFREY EPSTEIN and Defendants. ORDER AND OPINION THIS

riate for a motion to dismiss, and the pleadings at issue provide Defendant with sufficient notice of the underlying factual bases for the claims. Standard of Review In deciding a motion to dismiss pursuant to Federal Rule of Civil Procedure 12(b)(6), a court must accept all factual allegations in a complaint as

RD DISTRICT DCA CASE NO.: 3D18-1997 L.T. CASE NO.: 2014-021348 CA 01 RECEIVED, 11/5/2018 4:55 PM, Mary Cay Blanks, Third District Court of Appeal JEFFREY EPSTEIN, Appellant/Defendant, VS. JEAN-LUC BRUNEL, individually, and MC2 MODEL & TALENT MIAMI, LLC, Appellees/Plaintiffs. I ANSWER BRIEF OF APPELLEE

roduction 8 I. The process server's affidavit does not definitively rule out the possibility that two prior attempts were made at service at Epstein's place of business II. The process servers' affidavit does not definitively reflect that the person served with process at Defendant's place o

s App. A). After an unsuccessful attempt to serve Defendant Epstein (Epstein) at his New York residential address, (

Mary Cay Blanks, Third District Court of Appeal JEFFREY EPSTEIN, Appellant/Defendant, VS. JEAN-LUC BRU

FTA00792289 TABLE OF CONTENTS TABLE OF AUTHORITIES 4 STATEMENT OF THE CASE AND OF THE FACTS 5 SUMMARY OF THE ARGUMENT 7 ARGUMENT 8 Standard of Review 8 Introduction 8 I. The process server's affidavit does not definitively rule out the possibility that two prior attempts were made at se

The names of all of the victims are unknown to the plaintiff at this time. However, they include Jane Doe herself as well as the victim in E.W. v. Jeffrey Epstein and L.M. v. Jeffrey Epstein. A list of more than 30 such minor females has previously been provided by the U.S. Attorney's Office for the Southern

stein. A list of more than 30 such minor females has previously been provided by the U.S. Attorney's Office for the Southern District of Florida to Epstein (but not to Jane Doe). See DE 38-2 at ¶ 4. Finally, Defendant argues, and Plaintiff concedes, that punitive damages are not available under 18 U.S

ICO statement that the "enterprise" consisted of Defendant Epstein, and his paid employees Sarah Kellen and Nadia Ma

. 08-80893-CIV-MARRA JANE DOE, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ORDER THIS CAUSE is before

orida Statute 796.09. Defendant seeks dismissal of Counts H and IV of the Amended Complaint or, alternatively, moves for a more definite statement. Standard of Review In deciding a motion to dismiss pursuant to Federal Rule of Civil Procedure 12(bX6), a court must accept all factual allegations in a complaint as

The names of all of the victims are unknown to the plaintiff at this time. However, they include Jane Doe herself as well as the victim in E.W. v. Jeffrey Epstein and L.M. v. Jeffrey Epstein. A list of more than 30 such minor females has previously been provided by the U.S. Attorney's Office for the Southern

stein. A list of more than 30 such minor females has previously been provided by the U.S. Attorney's Office for the Southern District of Florida to Epstein (but not to Jane Doe). See DE 38-2 at ¶ 4. Finally, Defendant argues, and Plaintiff concedes, that punitive damages are not available under 18 U.S

ICO statement that the "enterprise" consisted of Defendant Epstein, and his paid employees and Sec Am. Comp. 1 43

. 08-80893-CIV-MARRA JANE DOE, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ORDER THIS CAUSE is before

orida Statute 796.09. Defendant seeks dismissal of Counts H and IV of the Amended Complaint or, alternatively, moves for a more definite statement. Standard of Review In deciding a motion to dismiss pursuant to Federal Rule of Civil Procedure 12(bX6), a court must accept all factual allegations in a complaint as

f the Palm Beach Post (“the Post”), appeals a final judgment denying the Post’s request for access to the grand jury proceedings involving the late Jeffrey Epstein. The Post argues the final judgment should be reversed for three reasons: (1) section 905.27, Florida Statutes (2019), provides a private right

is a party before the “in furtherance of justice” provision could be invoked. The trial court agreed “the established matters surrounding Mr. Epstein’s conduct, the circumstances of his resolution of the 2006 state charges and potential federal charges, and his 2008 guilty plea and incarceration

to the grand jury proceedings involving the late Jeffrey Epstein. The Post argues the final judgment sho

the Post appeals and reiterates its trial court arguments. The clerk maintains a neutral position.1 No one opposes the requested disclosure. • Standard of Review We review de novo a final summary judgment. Cleveland v. Westport Recovery Corp., 331 So. 3d 728, 730 (Fla. 4th DCA 2021). • Florida Rule o

of their plea negotiations; and, if so, whether a privilege bars crime victims from discovering plea negotiations. The United States investigated Jeffrey Epstein's sexual abuse of minors, but failed to confer with the victims before entering a non-prosecution agreement with Epstein. Two victims filed suit agai

States investigated Jeffrey Epstein's sexual abuse of minors, but failed to confer with the victims before entering a non-prosecution agreement with Epstein. Two victims filed suit against the United States to enforce their rights under the Crime Victims' Rights Act, 18 U.S.C. § 3771, and sought to disc

erica, Defendant. Roy Black, Martin G. Weinberg, Jeffrey Epstein, Intervenors-Appellants. No. 13-12923.

dnotes (1] Federal Courts 170E E..t.. 3581(1) 170B Federal Courts 170BXVII Courts of Appeals 170BXVII(K) Scope and Extent of Review 170BXVII(K)2 Standard of Review 170Bk3576 Procedural Matters 170Bk3581 Jurisdiction 170Bk3581(1) k. In general. Most Cited Cases The court of appeals reviews de novo whether it

02/12/2009 Page 1 of 12 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80119-CIV-MARRA Jane Doe No. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. OPINION AND ORDER ON MOTION TO DISMISS AND MOTION FOR MORE DEFINITE STATEMENT THIS CAUSE is before the Court upon Defendant Jeffrey E

ed as less likely to complain to authorities or have credibility if allegations of improper conduct were made. Id. This was an important element of Epstein's plan. Id. Defendant's plan and scheme reflected a particular pattern and method. Am. Compl. ¶ 11. Upon arrival at Defendant's mansion, the undera

0119-CIV-MARRA Jane Doe No. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. OPINION AND ORDER ON MOTION

iff contends that the specific facts sought by Defendant may properly be the subject of discovery, but are not necessary for purposes of pleading. Standard of Review In deciding a motion to dismiss pursuant to Federal Rule of Civil Procedure 12(b)(6), a court must accept all factual allegations in a complaint as