Epstein Secrets

ercial sex act. Page 2 of 9 EFTA00182943 CT DATE(S) DEFENDANT(S) VICTIM(S) STATUTES/CHARGE 9 November 2004 - March 2005 --a N EPSTEIN ..NEPSTEIN Jane Doe #14 18 U.S.C. §§ 1591(aX1) and 2 Knowingly, in or affecting interstate or foreign commerce, recruiting, enticing, providing, and obtaini

ravel to 358 El Brillo Way so that JEFFREY EPSTEIN could, in exchange for money, engage in lewd conduct with those minor females in order to satisfy JEFFREY EPSTEIN's prurient interests. Manner and Means 27. The manner and means by which the Defendants and other participants sought to accomplish the purpose and

ments to be made to, minor females in exchange for engaging in lewd conduct. EPSTEIN, (c) It was further a part of the conspiracy that Defendants JEFFREY a/k/a ," and other participants would ask females to recruit other minor females to engage in lewd conduct with Defendant JEFFREY EPSTEIN. (d)

the public association of their identities with Defendant Epstein and these assaults. 3. Dr. Gilbert Kliman,2 a w

ober 28, 2006 132. Lawrence LE, Viron M, Johnson JE, Hudkins A, Samples G, Kliman G: A school-based m

SISTANT UNITED STATES ATTORNEY 52 EFTA00182941 INDICTMENT SUMMARY CT DATE(S) kEFENDANT(S) VICTIM(S) STATUTES/CHARGE 1 2001 - October 2005 NEPSTEIN Jane Does 1-19 18 U.S.C. §§ 371 and 2 Conspiracy to use a facility or means of interstate commerce to persuade, induce, or entice minors to enga

cial circumstances warrant anonymity. See, e.g., Roe v. Aware Woman Cm for Choice, Inc., 253 F.3d 678, 685-87 (11th Cir.2001); Does I thru XXIII v. Advanced Textile Corp., 214 F.3d 1058, 1068-69 (9th Cir.2000); James v. Jacobson, 6 F.3d 233, 238-39 (4th Cir.I 993); Ill v. New York Blood Center, 213 F.R.D. 108, 110-12

nd completeness of the records. 10. Finally, Jeffrey Epstein’s request that this Court order a “sua sponte” dism

c association of their identities with Defendant Epstein and these assaults. 3. Dr. Gilbert Kliman,2 a w

the public association of their identities with Defendant Epstein and these assaults. 3. Dr. Gilbert Kliman,2 a w

ldhood sexual abuse and exploitation by Defendant Jeffrey Epstein. 3 Case 9:08-cv-80119-KAM Document

78, 685-87 (11th Cir.2001); Does I thru XXIII v. Advanced Textile Corp., 214 F.3d 1058, 1068-69 (9th Cir.2000); James v.

records concerning Plaintiffs is the appointment of a special master, who would verify authenticity and completeness of the records. 10. Finally, Jeffrey Epstein's request that this Court order a "sua sponte" dismissal is illogical. Sua sponte means "[w]ithout prompting or suggestion; on its own motion." Black'

the private, highly sensitive and intimate facts pertaining to their sexual assaults, and the public association of their identities with Defendant Epstein and these assaults. 3. Dr. Gilbert Kliman,2 a well-known forensic psychiatrist with an expertise in the field of child trauma, has met with and ev

the public association of their identities with Defendant Epstein and these assaults. 3. Dr. Gilbert Kliman,2 a w

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

ecial circumstances warrant anonymity. See, e.g., Roe,. Aware Woman Ctr. for Choice, Inc., 253 F.3d 678, 685-87 (11th Cir.2001); Does I thnt XXIII Advanced Textile Corp., 214 F.3d 1058, 1068-69 (9th Cir.2000); James , Jacobson, 6 F.3d 233, 238-39 (4th Cir.1993); EWI. New York Blood Center, 213 F.R.D. 108, 110-12 (E.

kept anonymous in the Federal Court criminal case and all documents containing her name were redacted by the United States Government and Defendant, Jeffrey Epstein's attorney. The Defendant, Jeffrey Epstein, will not be prejudiced in any way by this pseudonym pleading, as he has been provided with her name in the

80893-Civ-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. AUGUST 13, 2008 STEVEN M. LARIMORE

OE, 08-80893-Civ-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. AUGUST 13, 2008 STEVEN M.

such that the non-disclosure of the party's name is necessary to protect her from harassment, injury, ridicule, or personal embarrassment. Does v. Advanced Textile Corp., 214 F.3d 1058, 1067-1068 (9th Cir. 2000) (citing United States v. Doe, 655 F.2d 920; E.E.O.C., 249 F.R.D. at 588). Page 3 of 4 3414 EFTA00234743