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

assertion of the Fifth Amendment privilege is the guarantee of effective assistance of counsel by the Sixth Amendment of the U.S. Constitution. See Yarborough v. Gentry, 124 S.Ct. 1, 540 U.S. 1, 157 L.Ed.2d 1 (2003)(Sixth Amendment guarantees criminal defendants effective assistance of counsel.), on remand

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

assertion of the Fifth Amendment privilege is the guarantee of effective assistance of counsel by the Sixth Amendment of the U.S. Constitution. See Yarborough v. Gentry 124 S.Ct. 1, 540 U.S. 1, 157 L.Ed.2d 1 (2003)(Sixth Amendment guarantees criminal defendants effective assistance of counsel.), on remand

/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

n of Defendant's Fifth Amendment privilege is the guarantee of effective assistance of counsel by the Sixth Amendment of the U.S. Constitution. See Yarborough v. Gentry, 124 S.Ct. 1, 540 U.S. 1, 157 L.Ed.2d 1 (2003)(Sixth Amendment guarantees criminal defendants effective assistance of counsel.), on reman

, 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.

n of Defendant's Fifth Amendment privilege is the guarantee of effective assistance of counsel by the Sixth Amendment of the U.S. Constitution. See Yarborough v. Gentry, 124 S.Ct. 1, 540 U.S. 1, 157 L.Ed.2d 1 (2003)(Sixth Amendment guarantees criminal defendants effective assistance of counsel.), on reman

/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

assertion of the Fifth Amendment privilege is the guarantee of effective assistance of counsel by the Sixth Amendment of the U.S. Constitution. See Yarborough v. Gentry, 124 S.Ct. 1, 540 U.S. 1, 157 L.Ed.2d 1 (2003)(Sixth Amendment guarantees criminal defendants effective assistance of counsel.), on remand

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'

assertion of the Fifth Amendment privilege is the guarantee of effective assistance of counsel by the Sixth Amendment of the U.S. Constitution. See Yarborough v. Gentry, 124 S.Ct. 1, 540 U.S. 1, 157 L.Ed.2d 1 (2003)(Sixth Amendment guarantees criminal defendants effective assistance of counsel.), on remand

[email protected]>; AQ-CI1 <[email protected]>; Arndt, Jeffrey Paul (BF) (FBI) <[email protected]>; AT-CI-1

tt, Jonathan (LR) (FBI) <[email protected]>; Wolf, David R. (CD) (FBI) <[email protected]>; Yaddof, Conrad (MP) (FBI) <[email protected]>; Yarborough, Katie (AN) (FBI) <[email protected]>; Yassin, Nadia (SF) (FBI) <[email protected]>; Yeo, Jessica (LA) (FBI) <[email protected]>; Yonkers