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

ealth Insurance Portability and Accountability Act) objection, as noted in the case cited in Plaintiff's motion, Allen v. Woodford, 2007 WL 309485 (E.D. Cal. 2007), (p. 9), HIPPA institutes procedural safeguards to protect the privacy of an individual's medical information and history. In the context of

80119-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, V. JEFFREY EPSTEIN, Defendant. _____________ / 0 DEFENDANT EPSTE

ocket 05/06/2010 Page 2 of 31 Jane Doe No. 2 v. Epstein Case No. 08-CV-80119-Marra-Johnson Page 2 in m

f Count III, Plaintiff "demands judgment against Jeffery Epstein for all damages available under 18 U.S.C. §2255(a

JEFFREY EPSTEIN, Defendant. _____________ / 0 DEFENDANT EPSTEIN'S MOTION FOR SUMMARY JUDGMENT, INCLUDING SUPPORT

8691 [email protected] Counsel for Defendant Jeffrey Epstein Case 9:08-cv-80119-KAM Document 539

1, 2010); U.S. v. Renga, 2009 WL 2579103, fn. I (E.D. Cal. Aug. 19, 2009); U.S. v. Ferenci, 2009 WL 2579102

sts the legitimate concern that the agreement could be so used and the reality that any concern about such use significantly and unfairly burdens Mr Epstein's right to resort to the courts to resolve outstanding legal Issues regarding the criteria for payment and the amount of payment owed. I hope this

Jane Doe No. 103 1 0 - 80 (b) County of Residency of First Listed Plaintiff West Palm Beach (EXCEPT IN U.S. PLAINTIPP CASES) S int. NTS 0 it Fey stein (c) Attorney's (Tina Nam, Address. nod Telephone Hornbill) Robert C..losefsbag, Esq./Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 W. Flag' e

, Plaintiff, vs. JEFFERY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION TO DISMISS, & FOR MORE DEFINITE STATEME

Biscayne Blvd, Suite 1300 Miami, FL 33131 Re: Jeffrey Epstein Dear Mr. Black: Thank you for meeting w

it a breach of the Non- Prosecution Agreement for Mr. Epstein to file suit against the victim's attorney-repres

govern the minimum statutory damage amount (t50,000 rather than $150,000) under ex post facto laws, see United States I. Scheidt, 2010 W.L. 144837 (E.D. Cal., 2010) (indicating that the statute in effect at the time of the violation governs the minimum damage remedy)? Black, Srebnick. Komspan & Stumpf,

742, 754 (M.D. Pa. 2007); and the recent cases in front of this court on Defendant's Motions to Dismiss and For More Definite Statement — Doe No. 2 I. Epstein, 2009 WL 383332 (S.D. Fla. Feb. 12, 2009); Doe No. 3'. Epstein 2009 WL 383330 (S.D. Fla. Feb. 12, 2009); Doe No. 4'. Epstein 2009 WL 383286 (S.D. Fl

sts the legitimate concern that the agreement could be so used and the reality that any concern about such use significantly and unfairly burdens Mr Epstein's right to resort to the courts to resolve outstanding legal issues regarding the criteria for payment and the amount of payment owed. I hope this

, Plaintiff, vs. JEFFERY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION TO DISMISS. & FOR MORE DEFINITE STATEME

Biscayne Blvd, Suite 1300 Miami, FL 33131 Re: Jeffrey Epstein Dear Mr. Black: Thank you for meeting w

it a breach of the Non- Prosecution Agreement for Mr. Epstein to file suit against the victim's attorney-repres

) govern the minimum statutory damage amount ( 50,000 rather than $150,000) under ex post facto laws, see United States Scheidt, 2010 W.L. 144837 (E.D. Cal., 2010) (indicating that the statute in effect at the time of the violation governs the minimum damage remedy)? Black. SrebnIck, Kornspan & Stumpf.

09-80802, 09-81092 --------------~/ DEFENDANT, JEFFREY EPSTEIN'S RESPONSE IN OPPOSITION TO PLAINTIFF'S, JANE DOE,

d on FLSD Docket 10/06/2009 Page 2 of 23 Doe v. Epstein 08-CV80119 Page No. 2 herein. Portions of DE 28

nsuming. Request No. 16: All medical records of Defendant Epstein from Dr. Stephan Alexander. Response: Defendan

uant to Florida Statute 796.09 Against Defendant, Jeffrey Epstein". Erie R.Co. v. Tompkins, 58 S.Ct. 817

ld be upheld. Allen v. Woodford, 2007 WL 309485 (E.D. Cal. 2007), (p. 9)(HIPP A institutes procedural safegu

80232-MARRA-JOHNSON JANE DOE NO. 3, Plaintiff, V. JEFFREY EPSTEIN, Defendant. I DEFENDANT, EPSTEIN'S RESPONSE TO

Lawyers"). Plaintiffs' Lawyers always knew that Epstein's office was located on the 14th Floor of One Cle

Any suggestion that the chance "visual" between Mr. Epstein and Jane Doe No. 3 was "pre-planned" would be ab

n Jane Doe Number 3's allegations, resulted in a Jeffrey Epstein "sighting." 7. Importantly, Jeffrey Eps

cham v. City of West Sacramento, 2009 WL 689729 (E.D. Cal. 2009) Memorandum of Law In support of Motion 15

33132 BLACK SREBNICK KORNSPAN & STUMPF =PA.= March 5, 2010 , Esq. Assistant United States Attorney 99 N.E. 4i° Street Miami, FL 33132 RE: Jeffrey Epstein Dear Counsel: JESSIC.A ForisEC-A-NADER ICATEazur P. PHILLIPS AARON AMMON MARCOS BEATON, JR. MATTHEW P. OBRIEN JEPHPER J. SOUUKULS NOAH Fox R

Attorney 99 N.E. 4th Street Miami, FL 33132 We write this letter to renew our request that the United States Attorney's Office provide us, as Mr. Epstein's counsel in the federal NPA matter, with clarity as to what legal issues we can advise his civil counsel can be litigated without causing you to c

torney 99 N.E. 4i° Street Miami, FL 33132 RE: Jeffrey Epstein Dear Counsel: JESSIC.A ForisEC-A-NADER

e United States Attorney's Office provide us, as Mr. Epstein's counsel in the federal NPA matter, with clarity

govern the minimum statutory damage amount ($50,000 rather than $150,000) under ex post facto laws, see United States'. Scheidt, 2010 W.L. 144837 (E.D. Cal., 2010) (indicating that the statute in effect at the time of the violation governs the minimum damage remedy)? Black. Srebnick. Komspan & Stump& P

ami, FL 33132 BLACK SREBNICK KORNSPAN & STUMPF =PA.= March 5, 2010 Assistant United States Attorney 99 N.E. 4i° Street Miami, FL 33132 RE: Jeffrey Epstein Dear Counsel: JESSIC.A ForisEC-A-NADER ICATEazur P. PHILLIPS AARON AMMON MARCOS BEATON, JR. MATTHEW P. OBRIEN JEPHPER J. SOUUKULS NOAH Fox R

Attorney 99 N.E. 4th Street Miami, FL 33132 We write this letter to renew our request that the United States Attorney's Office provide us, as Mr. Epstein's counsel in the federal NPA matter, with clarity as to what legal issues we can advise his civil counsel can be litigated without causing you to c

torney 99 N.E. 4i° Street Miami, FL 33132 RE: Jeffrey Epstein Dear Counsel: JESSIC.A ForisEC-A-NADER

e United States Attorney's Office provide us, as Mr. Epstein's counsel in the federal NPA matter, with clarity

govern the minimum statutory damage amount ($50,000 rather than $150,000) under ex post facto laws, see United States v. Scheidt 2010 W.L. 144837 (E.D. Cal., 2010) (indicating that the statute in effect at the time of the violation governs the minimum damage remedy)? Black. Srebnick. Komspan & Stump& P

KORNSPAN STUMPF September 1, 2009 Esq. Assistant U.S. Attorney United States Attorney's Office 99 N.E. 4`11 Street Miami, Florida 33132 RE: Jeffrey Epstein Dear JESSICA FONSECA-NADER KATHLEEN P. PHILIPS AARON Aerruom MARCOS BEATON, JR. MATTHEW P. O'Bitir.ti JENWER J. SouweAs NOAH Fox E-Mail: On

, mainly to keep you in the loop so we don't inadvertently violate any provision of his agreement with your office. As I am sure you are aware, Mr. Epstein has finished the incarceration portion of his sentence and is now serving the one year of community control as mandated by both his state plea and

99 N.E. 4`11 Street Miami, Florida 33132 RE: Jeffrey Epstein Dear JESSICA FONSECA-NADER KATHLEEN P.

nt with your office. As I am sure you are aware, Mr. Epstein has finished the incarceration portion of his se

govern the minimum statutory damage amount ($50,000 rather than $150,000) under ex post facto laws, see United States'. Scheidt, 2010 W.L. 144837 (E.D. Cal., 2010) (indicating that the statute in effect at the time of the violation governs the minimum damage remedy)? Black. Srebnick, Komspan & Stumpf.

ami, FL 33132 BLACK SREBNICK KORNSPAN &STUMPF -P.A.= March 5, 2010 Assistant Unit States Attorney 99 N.E. 4`11 Street Miami, FL 33132 RE: Jeffrey Epstein Dear Counsel: JESSICA FONSECA•NADER KATHLEEN P. PHILLIPS AARON ANTHON MARCOS BEATON, JR. NIArmEw P. O'BRIEN JENIFER J. SOULSOAS NOAH Fox Ass

Attorney 99 N.E. 41° Street Miami, FL 33132 We write this letter to renew our request that the United States Attorney's Office provide us, as Mr. Epstein's counsel in the federal NPA matter, with clarity as to what legal issues we can advise his civil counsel can be litigated without causing you to c

orney 99 N.E. 4`11 Street Miami, FL 33132 RE: Jeffrey Epstein Dear Counsel: JESSICA FONSECA•NADER KA

e United States Attorney's Office provide us, as Mr. Epstein's counsel in the federal NPA matter, with clarity

govern the minimum statutory damage amount ($50,000 rather than $150,000) under ex post facto laws, see United States v. Scheidt, 2010 W.L. 144837 (E.D. Cal., 2010) (indicating that the statute in effect at the time of the violation governs the minimum damage remedy)? Black. Srebnick. Komspan & Stumpf.