Epstein Secrets

ndersigned Assistant United States Attorney, and files this response to the Court's Order requesting the position of the United States on Defendant Jeffrey Epstein's Motion to Stay Proceedings [DE 99]. For the reasons set forth below, it is the United States' position that a stay of the proceedings is not necessa

f the civil proceedings in the "interests of justice" until the "expiration" of the Non- Prosecution Agreement ["NPA"] between the United States and Epstein? By filing this response, the United States does not make itself a party to this litigation and takes no position with respect to the outcome of an

Y. 1655 Pike DeleePh.„,.. .ML lt Fst!ii!lefleach, IR. »CI 1 0 C) Par 1 sprat your tether rear*, taw fifty sullierdoller 2 leoseit arrest Jeffrey ipater says that pH, lir with 3 your aunt and tale ad bar bra liar trots le that I Cerrees7 S Us. 6 0. Iles ray have you bra lira with P

es the United States take any position regarding Defendant Epstein's performance of hi s obligations pursuant to th

have prepared documents to charge at least one of Mr. Epstein's lady friends in state court. If they can push

thei't NW ass. sir. O. 00 yea know who Doff fey Slow NI A. N. Pie. 0. Clo yet hew who J'effroy Mnia 14/ A. 0. That.. the layer who flest and Spytein os ynr nYlf. tleht7 500•11 au In. Noun •Pmetted piet hally any M. LIN101.0i hey coriertetlere that ~et had with At. Soso 'Nordin.; Not Issue. y

atter will result in certain loss by automatic summary judgment. United States'. Two Parcels of Real Property, 92 F.3d 1123, 1129 (11th Cir. 1996); Pervis, 901 F.2d at 946-47. This must be an actual adverse judgment, and not "merely the loss of the defendant's most `effective defense."' Securities & E

/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

ry judgment." See generally, F.T.C., supra, at fn.4, citing United States v. Premises Located at Route 13. 946 F.2d 749, 756 (11th Cir.1991) (citing Pervis v. State Farm and Cas. Co., 901 F.2d 944, 948 (11th Cir.1990)). See also S.E.C. v. Keith Group of Companies. Inc., 1998 WL 1670405 (S.D. Fla. 1998)

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, CASE NO.: 08-CV-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ____________________________________/ JANE DOE NO. 3, CASE NO.: 08-CV-80232-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ___

of the civil proceedings in the “interests of justice” until the “expiration” of the Non- Prosecution Agreement [“NPA”] between the United States and Epstein? By filing this response, the United States does not make itself a party to this litigation and takes no position with respect to the outcome of any

oes the United States take any position regarding Defendant Epstein’s performance of his obligations pursuant to the

ng the position of the United States on Defendant Jeffrey Epstein’s Motion to Stay Proceedings [DE 99]. Fo

ilege, the defendant faces certain loss of the civil proceeding on summary judgment if the civil proceeding were to continue. Lot 5, 23 F.3d at 364; Pervis v. State Farm Fire & Casualty Co., 901 F.2d 944 (11th Cir. 1990). Under this standard, Movants must show that invocation of the privilege in the inst

matter will result in certain loss by automatic summary judgment. United States v. Two Parcels of Real Property, 92 F.3d 1123, 1129 (11th Cir. 1996); Pervis, 901 F.2d at 946-47. This must be an actual adverse judgment, and not “merely the loss of the defendant’s most ‘effective defense.’” Securities & Ex

, 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.

mary judgment." See generally, F.T.C. supra, at fn.4, citing United States v. Premises Located at Route 13 946 F.2d 749, 756 (11th Cir.1991) (citing Pervis v. State Farm and Cas. Co., 901 F.2d 944, 948 (11th Cir.1990)). See also S.E.C. v. Keith Group of Companies, Inc. 1998 WL 1670405 (S.D. Fla. 1998)(

ASE NO.: 08-CV-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ____________________________________/

n Agreement [“NPA”] between the United States and Epstein? By filing this response, the United States does

oes the United States take any position regarding Defendant Epstein’s performance of his obligations pursuant to the

ng the position of the United States on Defendant Jeffrey Epstein’s Motion to Stay Proceedings [DE 99]. Fo

ceeding were to continue. Lot 5, 23 F.3d at 364; Pervis v. State Farm Fire & Casualty Co., 901 F.2d 944 (

ndersigned Assistant United States Attorney, and files this response to the Court's Order requesting the position of the United States on Defendant Jeffrey Epstein's Motion to Stay Proceedings [DE 99]. For the reasons set forth below, it is the United States' position that a stay of the proceedings is not necessa

oceedings in the "interests of justice" until the "expiration" of the Non-Prosecution EFTA00213025 Agreement ["NPA"] between the United States and Epstein? By filing this response, the United States does not make itself a party to this litigation and takes no position with respect to the outcome of an

es the United States take any position regarding Defendant Epstein's performance of his obligations pursuant to the

NO.: 08-CV-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. / JANE DOE NO. 3, CASE N

ant faces certain EFTA00213026 loss of the civil proceeding on summary judgment if the civil proceeding were to continue. Lot 5 , 23 F.3d at 364; Pervis v. State Farm Fire & Casualty Co. , 901 F.2d 944 (11th Cir. 1990). Under this standard, Movants must show that invocation of the privilege in the i

es the United States take any position regarding Defendant Epstein's performance of his obligations pursuant to the

NO.: 08-CV-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 3, CASE NO.:

spondence or oral communications between the parties in these civil suits. Based on the information presented by the Court and a review of 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 (Court

f the civil proceedings in the "interests of justice" until the "expiration" of the Non- Prosecution Agreement ["NPA"] between the United States and Epstein? By filing this response, the United States does not make itself a party to this litigation and takes no position with respect to the outcome of an

matter will result in certain loss by automatic summary judgment. United Stalest Two Parcels of Real Property, 92 F.3d 1123, 1129 (11th Cir. 1996); Pervis, 901 F.2d at 946-47. This must be an actual adverse judgment, and not "merely the loss of the defendant's most `effective defense.' Securities & Ex

spondence or oral communications between the parties in these civil suits. Based on the information presented by the Court and a review of 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 (Court

f the civil proceedings in the "interests of justice" until the "expiration" of the Non- Prosecution Agreement ["NPA"] between the United States and Epstein? By filing this response, the United States does not make itself a party to this litigation and takes no position with respect to the outcome of an

es the United States take any position regarding Defendant Epstein's performance of his obligations pursuant to the

NO.: 08-CV-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 3, CASE NO.:

matter will result in certain loss by automatic summary judgment. United Stalest Two Parcels of Real Property, 92 F.3d 1123, 1129 (11th Cir. 1996); Pervis, 901 F.2d at 946-47. This must be an actual adverse judgment, and not "merely the loss of the defendant's most `effective defense.' Securities & Ex

ndersigned Assistant United States Attorney, and files this response to the Court's Order requesting the position of the United States on Defendant Jeffrey Epstein's Motion to Stay Proceedings [DE 99]. For the reasons set forth below, it is the United States' position that a stay of the proceedings is not necessa

f the civil proceedings in the "interests of justice" until the "expiration" of the Non- Prosecution Agreement ("NPA"] between the United States and Epstein? By filing this response, the United States does not make itself a party to this litigation and takes no position with respect to the outcome of an

es the United States take any position regarding Defendant Epstein's performance of his obligations pursuant to the

NO.: 08-CV-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 3, CASE NO.:

tter will result in certain loss by automatic summary judgment. United States v. Two Parcels of Real Property, 92 F.3d 1123, 1129 (1Ith Cir. 1996); Pervis, 901 F.2d at 946-47. This must be an actual adverse judgment, and not "merely the loss of the defendant's most 'effective defense.'" Securities & E