Epstein Secrets

/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

'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 remand 381 F.3d

/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

he 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 381 F.3d

eutsche Asset & Wealth Management Detailed Portfolio Information As ow August 31. 2015 List of HOldnos • Cash and Cash Equivalents Account Name JEFFREY EPSTEIN Aonsunt Number aeos19 Base Currency: USD Ouomity fecurlty D000tiotion %A teal Unit Cool Paw In USD Adjuoted Coot Melts Value ACCIMMI Immo

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Oldnos • Cash and Cash Equivalents Account Name JEFFREY EPSTEIN Aonsunt Number aeos19 Base Currency:

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She Was Caught • Ex-CIA Official Warns Intel Agencies Will Be Politically Active in 2024 Election CRIMINAL INVESTIGATIONS • The Biggest Names from Jeffrey Epstein's Unsealed Court Documents • Florida Man Arrested for Threatening to Kill Bay Area Rep. Eric Swalwell • Attempted Murder Indictment Handed Down In Sh

and cover up his crimes. According to the article, the documents so far were sprinkled with names of celebrities and politicians who socialized with Epstein or worked with him in the years before he was publicly accused nearly two decades ago of paying underage girls for sex. The Daily Mail (01/04, Smith

CRIMINAL INVESTIGATIONS • The Biggest Names from Jeffrey Epstein's Unsealed Court Documents • Florida Man

lleging that former intelligence officers, including ex-FBI worker Asha Rangappa, downplayed it to aid the Biden campaign. According to the article, Gentry highlighted how former acting CIA Director Michael Morell's involvement in drafting a letter about the laptop story aimed to provide talking points