Epstein Secrets

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:

is motion and proposed agreed orders to Kendall Coffey, Esq., counsel for Stuart A. Rosenfeldt, individually, and Rothstein Rosenfeldt Adler, P.A., Coffey Burlington 2699 South Bayshore Drive, Penthouse, Miami, Florida 33133, and Paul Singerman, Esq., counsel for Herbert Case 9:08-cv-80119-KAM Document 405

019 Lawrence P Visoski $57,000 Bank of America Southern Financial Loan 2/15/2019 301/66 Owners Co • $229,800 JP Morgan Chase NES, LLC 2018 J Epstein 2/22/2019 $15,300 JP Morgan Chase NES, LLC Reference 2018 Storage fees Condominium Co • 4/30/2019 Miss $19,395 Barclays Bank N/A LSJE, L

OUNT ACCOUNT # Jeffrey Epstein WIRING ACCOUNT # IN IRE DETAILS/ INSTRUCTIONS N/A 12/10/2013 MC2 Model Mana • ement $29,440 SunTrust Bank Jeffrey Epstein N/A 12/11/2013 Larry Visoski $225,000 Bank of America Jeffrey Epstein N/A 12/20/2013 Visoski $16,676 Bank of America Jeffrey Epstein Petty

s://www.crainsnewyork.corn/real-estate/unraveling-web-epsteins-manhattan-real-estate. Ossa Properties is a real estate company owned by Mark Epstein—Jeffrey's brother. appears to have opened bank accounts in multiple names, including 1=M," and The beneficiary name is listed as it appears in bank recor

2018 Haddon, Morgan and Foreman, P.C. (Ghislaine Maxwell) $25,000 Wells Fargo Bank Darren K. Indyke PLLC Reference Maxwell retainer Ransoms vEpstein 3/7/2018 Alston and Bird LLP 3 $50,000 Wells Fargo Bank Darren K. Indyke PLLC Reference invoice 10933853 4/26/2018 301/66 Owners Co • $20

NG ACCOUNT Butterfly Trust WIRING ACCOUNT # WIRE DETAILS/ INSTRUCTIONS N/A 2/6/2015 $15,000 JP Morgan Chase Butterfly Trust N/A 3/5/2015 Coffey Burlington (Alan Dershowitz)6 $20,532 Coconut Grove Bank Jeffrey Epstein Ref Account 2968 002M 3/27/2015 301/66 Owners Corp $189,304 Citibank NES, LL

ibank NES, LLC N/A 4/22/2015 $50,000 JP Morgan Chase Butterfly Trust N/A 4/24/2015 $10,000 Bank of America Butterfly Trust N/A 5/7/2015 Coffey Burlington (Alan D a $10,000 Coconut Grove Bank Jeffrey Epstein Ref account 2968 002M Escrow 8/25/2015 $14,000 JP Morgan Chase Jeffre E stein N/A

tein 12889705 NCA customised Closed - liit 16/06/2017 BIS RESULTS: Negative Media: Mali On I ine MailOnline May 24, 2017 Wednesday 10:53 PM GMT Jeffrey Epstein's 'sex slave' settles her defamation lawsuit against British socia xwell who 'passed her around for sex' and trained her to be 'everything a man wa

recruited her as a sex slave when she was 15 for convicted pedophile billionaire Jeffrey Epstein and passed around to his friends Maxwell, who was Epstein's girlfriend at the time, is also accused of forcing her to have sex with Maxwell and other underage girls The 55-year-old responded to the allegat

ion of Reed Elsevier Inc. All Rights Reserved. Date:6/16/2017 Report processed by: DEUTSCHE BANK AGII Full Name Address County Phone EPSTEIN. JEFFERY E 9 E 71ST ST NEW YORK (212) 750-9895 NEW YORK. NY 10021-4102 (212) 249.1122 NEW YORK COUNTY (212) 772-9416 ADDITIONAL PERSONAL INFORMATION SSN

2546965 (Age 64) Subject Summary Name Variations 1: EDWARDS. JEFFERY 2: EPSTEIN, J 3: EPSTEIN, JEFFERY 4: EPSTEIN, JEFFERY E 5: EPSTEIN, JEFFREY 6: EPSTEIN. JEFFREY E 7: EPSTEIN. JERRERY 8: EPSTIEN, JEFFERY 9: EPTSTEIN. JEFFERY SSNs Summary No. SSN 1: 090-44-XXXX DOBs Reported DO

N. MARK L SSN:117-444OOCX DOB:1955 (Age: 62) EPSTEIN, PAULA A Deceased • AKA EPSTEIN, PAULINE SSN:050-09-XXXX DOB:10/1918 (Age: 98) TUCKER. ELLYN EPSTEIN • AKA EPSTEIN, ELLY • AKA EPSTEIN, ELLYN ELLYN • AKA EPSTEINTUCKER. ELLYN EPSTEIN • AKA EPSTEIN. E • AKA TUCKER. EPSTEIN ELLYN • AKA EPSTEIN-TU

ck, Black Srebnick Kornspan & Stumpf, Miami, FL. For Alan M. Dershowitz, Intervenor: Kendall Brindley r21 Coffey, LEAD ATTORNEY, Gabriel Groisman, Coffey Burlington, P.L., Miami, FL; Steven Russell Safra, Thomas E. Scott, Jr., Cole Scott & Kissane, Miami, FL. For The Palm Beach Post, Palm Beach Daily News, Inte

to Intervene on a Limited Basis filed by United States of America. Replies due by 2/2/2015. ( ) (Entered: 01/22/2015) 295 MOTION Limited Intervenor Jeffrey Epstein's Response to Order Requesting Justification for Supplemental Protective Order re 286 Order by Jeffrey Epstein. (Black, Roy) Modified to re- docket, s

iled by Jane Doe. (Edwards, Bradley) (Entered: 10/28/2013) MOTION to Expedite Jane Doe #1 and Jane Doe #2 Unopposed Motion for Expedited Ruling on Epstein's Unopposed Motion for Intervention in Advance of Eleventh Circuit Argument by Jane Doe. (Attachments: # 1 Text of Proposed Order)(Edwards, Bradley)

t Palm Beach, Fl 33401 561-202-6360 Intervenor Jeffrey Epstein Intervenor Alan M. Dershowitz Interven

nt conference 385 386 388 , the Court finds that Mr. Epstein's interest in this case is adequately preserved b

yne Boulevard Suite 1300 ATTORNEY TO BE NOTICED Black Srebnick Kornspan & Stumpf — Kendall Brindley Coffey LEAD ATTORNEY;ATTORNEY TO BE NOTICED Coffey Burlington, P.L. NUM EFTA00211441 Fax: 305-858-5261 Email:[email protected] Gabriel Groisman ATTORNEY TO BE NOTICED Coffey Burlinaton. P.L.

ackground surrounding the Razorback Creditor's motion is important to the Court's ultimate resolution of that motion. It is therefore set out here: Epstein's Sexual Abuse Victims Obtain Legal Representation from Bradley Edwards I. Between approximately August 2002 and September 2005, Jeffrey Epstein se

w Involved with Teenage Girls? Pervert's Aide Quizzed Over Prince, Mirror (UK), March 14, 2011, at 11 (discussing involvement of Prince Andrew with Jeffrey Epstein's sexual affairs); Bill Knew, Says Perv's Masseuse, New York Post, March 7, 2011, at 7 (discussing former President Bill Clinton's knowledge of Epste

Judicial Circuit in Palm Beach County, Florida, defendant Epstein, entered pleas of "guilty" to various Florida sta

een approximately August 2002 and September 2005, Jeffrey Epstein sexually assaulted L.M., who was then a

(VIA CM/ECF and EMAIL) John H. Genovese, Esq. Robert F. Elgidely, Esq. Theresa M.B. Van Vliet, Esq. (VIA CM/ECF and EMAIL) Kendall Coffey, Esq. Coffey Burlington, (VIA CM/ECF and EMAIL) The Honorable Herbert M. Stettin One Biscayne Tower (VIA U.S. MAIL and EMAIL) John G. Bianco, Esq. John M. Mulli, Esqui

th Street $15,300 JP Morgan Chase NES, LLC 4295378 Reference 2018 Storage fees 4/30/2019 $19,395 Barclays Bank LSJE, LLC 42959295 N/A 14 Jeffrey Epstein's personal attorney, Darren Indyke, made three additional payments to Haddon, Morgan and Foreman, P.C. that may have been use to cover Ghislaine Maxwe

nk Darren K. Indyke PLLC 42953707 Reference invoice 10933853 4/26/2018 301/66 Owners Co . $202,840 JP Morgan Chase NES, LLC 4295378 2017 J Epstein 8/8/2018 $30,000 Bank of America Butterfly Trust 44130552 N/A 9/21/2018 Haddon Morgan and Foreman. P.C. $22,902 Wells Fargo Bank Darren K

://www.crainsnewyork.corn/real.-estate/unraveling-web.epsteins-manhattan•real-estate. Ossa Properties is a real estate company owned by Mark Epstein—Jeffrey's brother. ppears to have opened bank accounts in multiple names, includin it appears in bank records. The beneficiary name is listed as CONFIDEN

S 1/28/2015 $50,000 JP Morgan Chase Butterfly Trust 44130552 N/A 2/6/2015 $15,000 JP Morgan Chase Butterfly Trust 44130552 N/A 3/5/2015 Coffey Burlington (Alan Dershowitz)6 $20,532 Coconut Grove Bank Jeffrey Epstein 35266976 Ref Account 2968 002M 3/27/2015 301/66 Owners Co • $189,304 Citiban

RE: ROTHSTEIN ROSENFELDT ADLER, P.A., Debtor. CASE NO.: 09-34791-RBR CHAPTER 11 MOTION FOR RELIEF FROM AMENDED ORDER ID.E. 1068t AND TO COMPEL JEFFREY EPSTEIN TO PAY FOR THE PRODUCTION OF ALL DOCUMENTS IN RESPONSE TO HIS REOUEST Movants, LM and Bradley J. Edwards, move this Court for relief from Amended O

omen who allege that they were sexually exploited, sexually abused, and otherwise victims of intentional and despicable conduct of Jeffrey Epstein. Epstein's conduct has been the subject of several lawsuits vigorously litigated by Mr. Edwards, as well as similar lawsuits filed by other well-known attor

IEF FROM AMENDED ORDER ID.E. 1068t AND TO COMPEL JEFFREY EPSTEIN TO PAY FOR THE PRODUCTION OF ALL DOCUMEN

Bank Of America Tower at International Place 100 S.E. 2nd Street, Suite 4400 Miami, Florida 33131 (VIA CM/ECF and EMAIL) Kendall Coffey, Esq. Coffey Burlington, Office in the Grove Penthouse 2699 South Bayshore Drive Miami, Florida 33133 kcoffey®coffeyburlington.com (VIA CM/ECF and EMAIL) The Honorabl

2 of 10 privilege and/or attorney work product. II. Background 3. Movant, L.M. is a party plaintiff in a civil lawsuit' against party defendant Jeffrey Epstein in which she alleges that Epstein sexually exploited, abused, and/or assaulted her when she was a minors. The parties recently reached a confidentia

ereof, states as follows: I. Introduction 1. Jeffrey Epstein, through his counsel, seeks to pull the wool over the eyes of this honorable Court. Epstein asks this Court to usurp the properly exercised jurisdiction of the Circuit Court over a subpoena duces tecum issued by the state court in connectio

STETTIN OF PRIVILEGED DOCUMENTS AND TESTIMONY TO JEFFREY EPSTEIN Movant, L.M., moves this Court pursuant

rnational Place 100 S.E. 2nd Street Suite 4400 Miami, Florida 33131 Phone: (305) 349-2300 Fax (305) 349-2310 Kendall Coffey, Esq. (VIA EMAIL) Coffey Burlington, Office in the Grove Penthouse 2699 South Bayshore Drive Miami, Florida 33133 [email protected] Hon. Herbert M. Stettin (VIA EMAIL)

, FJW on behalf of LM states as follows: I. BACKGROUND A. The Pending Summary Judgment and Protective Order Motions As this Court is well aware, Jeffrey Epstein (a convicted sex offender) has sued one of his alleged victims, ■ as well as attorney, Bradley J. Edwards, Esq.', in Florida state court for cond

rds, Esq.', in Florida state court for conduct that allegedly occurred in the course of Edwards' representation of multiple young female victims of Epstein's sexual abuse. While an employee of the now defunct Rothstein, Rosenfeldt, Adler firm and with his current firm, Edwards filed and pursued civil la

ctive Order Motions As this Court is well aware, Jeffrey Epstein (a convicted sex offender) has sued one o

Bank Of America Tower at International Place 100 S.E. 2nd Street, Suite 4400 Miami, Florida 33131 (VIA CM/ECF and EMAIL) Kendall Coffey, Esq. Coffey Burlington, Office in the Grove Penthouse 2699 South Bayshore Drive Miami, Florida 33133 (VIA CM/ECF and EMAIL) Joseph L. Ackerman, Jr. Esquire Fowler Wh

statement to the government, were not made to the FBI when she was initially contacted by that agency, were not included in her civil action against Epstein in 2009, were not included in her recorded interview with her attorneys in 2011 and were not included in her interview with the British press in 2011

luding their parents’ names. Prof. Dershowitz, as Epstein’s former legal counsel, is one of hundreds of people listed in an address book purloined by Jeffrey Epstein’s criminal butler; yet because Prof. Dershowitz’s name is circled in the address book by an unknown person for unknown reasons, the argument is made th

e both separately mentioned in the flight logs of Mr. Epstein’s private plane, they are never listed on the sam

9:08-cv-80736-KAM Document 306 Entered on FLSD Docket 02/02/2015 Page 18 of 19 Benjamin H. Brodsky, Fla. Bar No. 73748 [email protected] COFFEY BURLINGTON, P.L. 2601 South Bayshore Drive, PH1 Miami, Florida 33133 Telephone: (305) 858-2900 Facsimile: (305) 858-5261 - and— Thomas Scott, Fla. Bar No.