Epstein Secrets

04/02/2009 Page 1 of 7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2 Plaintiff, V. JEFFREY EPSTEIN, Defendant. ----------------'/ DEFENDANT EPSTEIN'S ANSWER & AFFIRMATIVE DEFENSES TO PLAINTIFF'S SECOND AMENDED COMPLAINT Defendant, JEFFREY EPST

e defense is not precluded from asserting Case 9:08-cv-80119-KAM Document 69 Entered on FLSD Docket 04/02/2009 Page 2 of 7 Jane Doe No. 2 v. Epstein Page2 the privilege [against self-incrimination], because affirmative defenses do not constitute the kind of voluntary application for affirmative

JEFFREY EPSTEIN, Defendant. ----------------'/ DEFENDANT EPSTEIN'S ANSWER & AFFIRMATIVE DEFENSES TO PLAINTIFF'S S

1 [email protected] Co-Counsel for Defendant Jeffrey Epstein By::-=::-=-=---i~=c:--:--:---:-::----::=

ledge and deny. 2. As to the allegations in paragraphs 2, Defendant asserts his Fifth Amendment privilege against self-incrimination. See Delisi v. Bankers Ins. Company, 436 So.2d 1099 (Fla. 4th DCA 1983); Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth Amendment's Self-Incrimination Clause applies to

ocket 06/10/2009 Page 2 of 10 Jane Doe No. 2 v. Epstein Page2 " ... a civil defendant who raises an aff

-80119-MARRA-JOHNSON JANE DOE NO. 2 Plaintiff, V. JEFFREY EPSTEIN, Defendant. I DEFENDANT EPSTEIN'S FIRST AMENDE

Plaintiff, V. JEFFREY EPSTEIN, Defendant. I DEFENDANT EPSTEIN'S FIRST AMENDED ANSWER & AFFIRMATIVE DEFENSES TO

1 [email protected] Co-Counsel for Defendant Jeffrey Epstein Respectfully sub By:---;--.,,--.,...---

ivilege against self-incrimination. See Delisi v. Bankers Ins. Company. 436 So.2d 1099 (Fla. 4th DCA 1983); Mal

Page 1 of 18 JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. UNITED STATES DISTRICT COURT SOUTH

e the tax returns to advance her theory that ". . .Epstein used his wealth and power to lure economically d

n her possession. For example, at a deposition of Mr. Epstein on February 17, 2010, the following exchange occ

, WITH INCORPORATED MEMORANDUM OF LAW Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through h

Epstein 08-CV80119 Page No. 10 2 See DeLisi v. Bankers Ins. Company, 436 So.2d 1099 (Fla. 4th DCA 1983); Mall

Case 9:08-cv-80119-KAM Document 545 Entered on FLSD Docket 05/12/2010 Page 1 of 37 JANE DOE NO. 2, Plaintiff, VS, JEFFREY EPSTEIN, Defendant. UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CIV-80119-MARRA/JOHNSON I -------------- Related cases: 08-

4, 2010 (DE 462), (DE 480) AND APRIL 1, 2010 (DE 513), WITH INCORPORATED OBJECTIONS AND MEMORANDUM OF LAW Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through his undersigned attorneys, hereby files his Consolidated Rule 4 Review and Appeal of Portions of the Magistrate's Orders (DE 462)

o. 19 Beach State Attorney and the USAO may not want to disclose their files for one reason or another. (ii) Third Party Privacy Rights And Judge Jeffrey's Colbath's Order The Magistrate's Order does not consider the privacy rights of other alleged victims. As this Court knows, attached to the NP A i

n fact and opinion attorney work product of both Mr. Epstein's attorneys and government attorneys. Particular

occurrence of the assaults alleged and still maintain the safe harbor of the 5 Amendment.2 See Ohio v. Reiner, 532 U.S. 17(1991). 2 See DeLisi v. Bankers Ins. Company. 436 So.2d 1099 (Fla. 4th DCA 1983); Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth Amendment's Self-Incrimination Clause applies to