Epstein Secrets

fana, Ann Marie C. (USAFLS) From: Sloman, Jeff (USAFLS) Sent: Friday, June 13, 2008 6:15 PM To: Villafana, Ann Marie C. (USAFLS) Subject: FW: Epstein Sorry, forgot to cc you. From: Sloman, Jeff (USAFLS) Sent: Friday, June 13, 2008 6:09 PM To: Roth, John (ODAG) (SMO) Cc: Senior, Robert (USAFLS)

OS BF.ATON, JR. MATTHEW P. O'BRIEN JEMFER J. SOULIMAS NOAH FOX E-Mail: [email protected] You emailed me a letter on November 2, asking whether Jeffrey Epstein's place of employment remained constant. It has. I reviewed a Google map to confirm that the distance between that place of employment and the locati

ou? A: Never, never. (p. 21 — FBI) . . . Q: So he never pulled you closer to him in a sexual way? A: I wish. No, no, never, ever, ever, no, never. Jeffrey is an awesome man, no. (p. 21 - FBI) Yet, L.M. filed her second amended complaint In April 2009, after EDWARDS joined RRA, the allegations against

alm Beach County, State of Florida, (L.M. I. Epstein, Case No. 502008CA028051XWMB AB; E.W. I. Epstein, Case No. 502008CA028058XXXXMB EFTA00193821 Epstelri. RRA, et al. Page 8 AB), (hereinafter collectively referred to as the "Civil Actions," and L.M is a named Defendant herein). The Civil Actions wer

amount of fees and costs properly owed to him by Mr. Epstein pursuant to the NPA. On February 16, 2010 Mr. E

of L.M. alleging that EPSTEIN forced the minor into "oral sex," yet L.M. testified that she never engaged in oral, anal, or vaginal EFTA00193833 Epsteir$i. RRA, et al. Page 20 intercourse with EPSTEIN and she had never touched his genitalia. k) Told investors, as reported in an Associated Press arti

fices in Florida, New York, and Venezuela, and employed over 70 attorneys and 200 support staff. RRA also maintains an office at 1109 NE 2d Street, Hallendale Beach, Florida 33009-8515. RRA, through its attorneys, including those named as Defendants herein, conducted business throughout Florida, and relevant to

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:

In each of these civil actions, each of the Plaintiffs is represented by Bradley J. Edwards, William Berger and the RRA law firm, 1109 NE 2d Street, Hallendale Beach, Florida 33009-8515. Attorneys Russell Alder and Peter Feaman have also appeared for the Plaintiffs. 4. Based upon recent and ongoing media repor

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1.201 CASE NO. Plaintiff, v. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and M., i

VED FOR HUNG DEC u ( 2008 sriesnoN Ii poCK COMPLAINT pLefitt Elk COMPTRQw-liti CIRCUIT CIVIL olvisiON Plaintiff, JEFFREY EPSTEIN, (hereinafter "EPSTEIN"), by and through his undersigned attorneys, files this action against Defendants, SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually,

■ EPSTEIN and like other RRA clients, sought tens of millions of dollars. a. For example, in her sworn statement to the FBI, was insistent that "Jeffrey is an awesome man." (p. 21 — FBI); At the conclusion of she stated: "I hope Jeffrey, nothing happens to Jeffrey because he's an awesome man and it

hat the evidence is really going to show is that Mr. Epstein — at least dating back as EFTA00729419 Epstein

onymous females were represented by RRA, with the potential for hundreds of millions of dollars in settlements, and that RRA and its attorneys would El Epstein unless he paid exorbitant-settlement amounts to protect his high-profile friends. 26. Upon information and belief, EDWARDS knew or should have kno

fices in Florida, New York, and Venezuela, and employed over 70 attorneys and 200 support staff. RRA also maintains an office at 1109 NE 2d Street, Hallendale Beach, Florida 33009-8515. RRA, through its attorneys, including those named as Defendants herein, conducted business throughout Florida, and relevant to

• IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Plaintiff, v. cor.50.2929aufactigIVP111, CASE NO. • A Aq SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and .M., individu

OTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and .M., individually, Defendants. COMPL CO Plaintiff, JEFFREY EPSTEIN, (hereinafter "EPSTEIN"), by and through his undersigned attorneys, files this action against Defendants, SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually,

ases and thus by using the deposition sell the cases (or a part of them) to third parties. #4S 37. Because of these facts, ROTHSTEIN claimed that Epste wanted to make certain none of these individuals would be deposed and therefoie he had offered $200,000,000.00 to settle the claims of RRA female

EPSTEIN and like other RRA clients, sought tens of millions of dollars. a. For example, in her sworn statement to the FBI, L.M. was insistent that "Jeffrey is an awesome man." (p. 21 — FBI); At the conclusion of she stated: "I hope Jeffrey, nothing happens to Jeffrey because he's an awesome man and it

hat the evidence is really going to show is that Mr. Epstein — at least dating back as completely irrelevant

ffices in Florida, Cv York, and Venezuela, and employed over 70 attorneys and 200 support staff. RRA also maintains an office at 1109 NE 2d Street, Hallendale Beach, Florida 33009-85'15. RRA, through its attorneys, including those named as Defendant n, conducted business throughout Florida, and relevant to thi

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1.201 CASE NO. I Plaintiff, SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M.,

LAINT COPY RECEIVED FOR FILING DEC Q t 2QP enAriory n. POCK CLARK OPMPiliOlt-OR omptirf aviLPIVISION Plaintiff, JEFFREY EPSTEIN, (hereinafter "EPSTEIN"), by and through his undersigned attorneys, files this action against Defendants, SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually,

hat the evidence is really going to show is that Mr. Epstein — at least dating back as EFTA00190041 Epstein

EPSTEIN and like other RRA clients, sought tens of millions of dollars. a. For example, in her sworn statement to the FBI, L.M. was insistent that "Jeffrey is an awesome man." (p. 21 — FBI); At the conclusion of she stated: "I hope Jeffrey, nothing happens to Jeffrey because he's an awesome man and it

fices in Florida, New York, and Venezuela, and employed over 70 attorneys and 200 support staff. RRA also maintains an office at 1109 NE 2d Street, Hallendale Beach, Florida 33009-8515. RRA, through its attorneys, including those named as Defendants herein, conducted business throughout Florida, and relevant to

EXHIBIT A EFTA00596488 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1.201 CASE NO. Plaintiff, v. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M.,

RECEIVED FOR FILING oic 0 1Mg EMIVION It PUCK COMPLAINT GlAilit QQMPTR966011 PINWIT CIVIk,P1\11algi Plaintiff, JEFFREY EPSTEIN, (hereinafter "EPSTEIN"), by and through his undersigned attorneys, files this action against Defendants, SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually,

EPSTEIN and like other RRA clients, sought tens of millions of dollars. a. For example, in her sworn statement to the FBI, L.M. was insistent that "Jeffrey is an awesome man." (p. 21 — FBI); At the conclusion of she stated: "I hope Jeffrey, nothing happens to Jeffrey because he's an awesome man and it

hat the evidence is really going to show is that Mr. Epstein — at least dating back as EFTA00596504 Epstein

fices in Florida, New York, and Venezuela, and employed over 70 attorneys and 200 support staff. RRA also maintains an office at 1109 NE 2d Street, Hallendale Beach, Florida 33009-8515. RRA, through its attorneys, including those named as Defendants herein, conducted business throughout Florida, and relevant to

AARON ANTHON MARCOS BEATON, JR. MATTHEW P. O'BRIEN JENIPER J. SOULII0AS NOAH Fox E-Mail: You emailed me a letter on November 2, asking whether Jeffrey Epstein's place of employment remained constant. It has. I reviewed a Google map to confirm that the distance between that place of employment and the locati

ime and effort. Over the past five weeks, the massive billion-dollar conspiracy created and run by Scott Rothstein has been exposed. On Monday, Mr. Epstein filed a state civil RICO lawsuit charging Rothstein, his partner Brad Edwards, and others with tortuous and fraudulent abuses of process that result

sue EPSTEIN and like other RRA clients, sought tens of millions of dollars. a. For example, in her sworn statement to the FBI, was insistent that "Jeffrey is an awesome man." (p. 21 — FBI); At the conclusion of she stated: "I hope Jeffrey, nothing happens to Jeffrey because he's an awesome man and it

by Scott Rothstein has been exposed. On Monday, Mr. Epstein filed a state civil RICO lawsuit charging Rothste

fices in Florida, New York, and Venezuela, and employed over 70 attorneys and 200 support staff. RRA also maintains an office at 1109 NE 2d Street, Hallendale Beach, Florida 33009-8515. RRA, through its attorneys, including those named as Defendants herein, conducted business throughout Florida, and relevant to

rls for sexual reasons, were you surprised? A. I didn't believe it. Q. Do you believe it today? A. I don't believe it. Q. You don't believe that Jeffrey Epstein was involved with underage girls in a sexual way? MR. CRITTON: Form. THE WITNESS: You're asking for my opinion, and I don't think my opinion is

ndividually, L.M., individually, E.W., individually, and JANE DOE, individually Defendants. COMPLAINT Plaintiff, JEFFERY EPSTEIN, (hereinafter "EPSTEIN"), by and through his undersigned attorneys, files this action against Defendants, SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individua

L CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1

employed over 70 attorneys and 200 support staff. RRA also maintains EFTA00725322 Epstein v. RRA, et al. Page 5 an office at 1109 NE 2d Street, Hallendale Beach, Florida 33009-8515. RRA, through its attorneys, including those named as Defendants herein, conducted business throughout Florida, and relevant to

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1.201 CASE NO. Plaintiff, v. SCOTT ROTHSTEIN, individually, STUART ROSENFELDT, individually, RUSSELL AD

NNETH JENNE, individually, MICHAEL FISTEN, individually, and L.M., individually, Defendants. COMPLAINT Plaintiff, JEFFERY EPSTEIN, (hereinafter "EPSTEIN"), by and through his undersigned attorneys, files this action against Defendants, SCOTT ROTHSTEIN, individually, STUART ROSENFELDT, individually,

her to Epstein; she was told that he likes topless massages "but you don't have to do anything you don't want to do." p. 7; She was also told that "Jeffrey doesn't want any underage girls so make sure you tell him you're 18". p. 8; L.M. admits that she willingly took off her top the first time, p. 9.,

employed over 70 attorneys and 200 support staff. RRA also maintains EFTA00725294 Epstein v. RRA, et al. Page 7 an office at 1109 NE 2d Street, Hallendale Beach, Florida 33009-8515. RRA, through its attorneys, including those named as Defendants herein, conducted business throughout Florida, and relevant to