Epstein Secrets

-BARING BETTY STOKES PARALEGALS RITA H. BUDNYK OP COUNSEL ED RICCI SPECIAL CONSUMER JUSTICE COUNSEL Dear Judge Hafele: Enclosed, please find Jeffrey Epstein's Response in Opposition to ll's Motion for Inspection and to Compel Discovery, which are set for hearing before Your Honor on December 14, 2009 at 8

E FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502008CA037319XWMB AB Plaintiff, v. JEFFREY EPSTEIN, Defendants. EPSTEIN'S RESPONSE IN OPPOSITION TO MOTION FOR INSPECTION AND TO COMPEL DISCOVERY AND MOTION FOR PROTECTIVE ORDER AND INCORPORATED MEMORANDUM OF LAW Defen

in from disclosing the identity of any person who has knowledge or are in possession of physical evidence (i.e. photographs, EFTA00723281 B,B. v, Eosteiq Case No. 502008CA03 XMB AB Epstein's Objections to Request and Motion for Protective Order Page 10 of 22 videos, written statements, etc.) pert

P. 1.280(c), and states: I. Introduction 1. Mr. Epstein's deposition was set for September 2, 2009, and M

Motion to Compel as to certain requests to which Defendant Epstein was asserting a Fifth Amendment privilege. By th

P.A. BERNARD LESEDEKER. MARK T. LL/TTIER. P.A. JEFFREY C. PEPIN MICHAEL J. PIKE HEATHER. MCNAMARA RUDA

e 5 of 8 the objection 'so general and sweeping in nature" that they aamount[ed] to a blanket assertion of the privilege: Id. p.11. In the instant Motion for Reconsideration, Epstein has set forth additional facts and detailed reasoning successfully demonstrating how forcing him to answer these requests would realistica

Epstein, Tyler McDonald, Tyler McDonald D/B/A/ YLORG Case No.: 14-21348 CA 01 Dear Judge Smith: Please find enclosed a courtesy copy of Defendant, Jeffrey Epstein's, Response to Motion for Ruling on Service of Process on Defendant, Jeffrey Epstein without a Hearing. Because the Plaintiffs attorney, Mr. Titone,

ion for Ruling on Service of Process Defendant, Jeffrey Epstein, filed his Memorandum in Opposition to Motion for Ruling on Service of Process. Mr. Epstein maintains his prior positions with regard to Plaintiffs failure to properly serve him in what is now 2 years and 10 months after the filing of Plain

that failed attempt. 3. The undersigned counsel promptly fded a motion to quash on behalf of Mr. Epstein in April 2015, which motion included Mr. Bpstoin's affidavit confirming the location of his residence and usual place of abode in the United States Virgin Islands. 4. Plaintiffs waited a full yea

dividually and MCI Model & Talent Miami, LLC vs. Jeffrey Epstein, Tyler McDonald, Tyler McDonald D/B/A/ YL

tion to Motion for Ruling on Service of Process. Mr. Epstein maintains his prior positions with regard to Plai

0, 2015. The required Notice of Service was never filed with the Court in respect of that attempt, which you, yourself, conceded in your later filed Motion for Reconsideration was improper service. After rescheduling the hearing on Mr. Epstein's April 29, 2015 Motion to Quash four separate times, you failed to appear at th

ent 477 Entered on FLSD Docket 0226;2010 Page 1 of 24 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. CASE NO.: 08-CIV-80119-MARRA/JOHNSON Related cases: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469,

HE MAGISTRATE'S ORDER DATED FEBRUARY 4, 2010 (DE 462), WITH INCORPORATED OBJECTIONS AND MEMORANDUM OF LAW Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through his undersigned attorneys, hereby files his Motion for Reconsideration and/or for Request Rule 4 Review and Appeal of Portions of

n this regard and/or providing self-incriminating information is substantial, real and not merely imaginative. 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 full well, attached to

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

ED OBJECTIONS AND MEMORANDUM OF LAW Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through his undersigned attorneys, hereby files his Motion for Reconsideration and/or for Request Rule 4 Review and Appeal of Portions of the Magistrate's Order (DE 462) pursuant to Rule 60, Fed.R.Civ.P. Rule 4, Rule 4(c) and

uring those negotiations against either party. BACKGROUND The Court is very familiar with this matter, having handled the civil suits filed against Jeffrey Epstein pursuant to the Non-Prosecution Agreement and this actions filed by Jane Does #1 and #2 against the United States. For purposes of this Supplemental

of the government, the Jane Does have only received the portions of the correspondence written by government attorneys — all of the writings of Mr. Epstein's attorneys, excepts for a few short portions by Jack Goldberger— have been redacted. The Intervenor Attorneys ask that the Court order that the Ja

gotiations between the Intervenors (on behalf of Jeffrey Epstein) and the U.S. Attorney's Office. The Inte

by government attorneys — all of the writings of Mr. Epstein's attorneys, excepts for a few short portions by

heir failure to seek a prompt resolution of the case. However, in light of the Court's Order, it would seem that this issue is better resolved in a Motion for Reconsideration or on appeal of that ruling rather than in this Supplemental Briefing. Accordingly, the Intervenors' third argument is not addressed herein. 5 EFT

uring those negotiations against either party. BACKGROUND The Court is very familiar with this matter, having handled the civil suits filed against Jeffrey Epstein pursuant to the Non-Prosecution Agreement and this actions filed by Jane Does #1 and #2 against the United States. For purposes of this Supplemental

of the government, the Jane Does have only received the portions of the correspondence written by government attorneys — all of the writings of Mr. Epstein's attorneys, excepts for a few short portions by Jack Goldberger— have been redacted. The Intervenor Attorneys ask that the Court order that the Ja

gotiations between the Intervenors (on behalf of Jeffrey Epstein) and the U.S. Attorney's Office. The Inte

by government attorneys — all of the writings of Mr. Epstein's attorneys, excepts for a few short portions by

heir failure to seek a prompt resolution of the case. However, in light of the Court's Order, it would seem that this issue is better resolved in a Motion for Reconsideration or on appeal of that ruling rather than in this Supplemental Briefing. Accordingly, the Intervenors' third argument is not addressed herein. 5 EFT

FL 33060 Re: Service of Process Dear Joe: I have had an opportunity to review the Notice Service of Process that you filed in the Jean Luc Brunel/Jeffrey Epstein case. From my careful review it is clear that once again the attempt to serve runs afoul of Florida Statutes 48.031, as well as the holding in the

of that case for your ready reference. It is now almost two years past the January 2015 filing date of your clients' amended complaint joining Mr. Epstein as a defendant to the original action filed in August 2014. I remind you that no attempt was made to even serve Mr. Epstein until March 10, 2015. I

of Process that you filed in the Jean Luc Brunel/Jeffrey Epstein case. From my careful review it is clear

date of your clients' amended complaint joining Mr. Epstein as a defendant to the original action filed in A

March 10, 2015. In that attempt the required Notice of Service was never filed with the Court, and which you, yourself, agreed in your later filed Motion for Reconsideration was an improper service. After rescheduling the hearing on Mr. Epstein's Motion to Quash, filed on April 29, 2015, and on four different occasions,

d his motion for reconsideration (DE #560). Jane Doe will respond to this amended motion for reconsideration. ARGUMENT Jane Doe has an interest in Jeffrey Epstein's Motion for Reconsideration (DE #560), which should be dismissed as utterly without merit (and seemingly filed simply for obstructionist purposes).

BE DENIED Plaintiff, Jane Doe, respectfully files this notice of interest in a matter that is currently pending before the Court — namely, DE #560, Epstein's (Revised) Motion for Modification and Reconsideration of the Magistrate's Order Dated June 10, 2010 (DE #555). While Jane Doe is not a direct pa

. 08-CV-80893-CIV-MARRA/JOHNSON Plaintiff, Vs. JEFFREY EPSTEIN, et al. Defendant. Related Cases: 08-8

econsideration (DE #560). Jane Doe will respond to this amended motion for reconsideration. ARGUMENT Jane Doe has an interest in Jeffrey Epstein's Motion for Reconsideration (DE #560), which should be dismissed as utterly without merit (and seemingly filed simply for obstructionist purposes). Epstein's claim that the b

d his motion for reconsideration (DE #560). Jane Doe will respond to this amended motion for reconsideration. ARGUMENT Jane Doe has an interest in Jeffrey Epstein's Motion for Reconsideration (DE #560), which should be dismissed as utterly without merit (and seemingly filed simply for obstructionist purposes).

BE DENIED Plaintiff, Jane Doe, respectfully files this notice of interest in a matter that is currently pending before the Court — namely, DE #560, Epstein's (Revised) Motion for Modification and Reconsideration of the Magistrate's Order Dated June 10, 2010 (DE #555). While Jane Doe is not a direct pa

. 08-CV-80893-CIV-MARRA/JOHNSON Plaintiff, Vs. JEFFREY EPSTEIN, et al. Defendant. Related Cases: 08-8

econsideration (DE #560). Jane Doe will respond to this amended motion for reconsideration. ARGUMENT Jane Doe has an interest in Jeffrey Epstein's Motion for Reconsideration (DE #560), which should be dismissed as utterly without merit (and seemingly filed simply for obstructionist purposes). Epstein's claim that the b

From: Darren Indyke To: Lesley Groff Subject: Fwd: Jeffrey Epstein vs. Fancelli Paneling, Inc. Date: Wed, 06 Jul 2011 14:21:48 +0000 Attachments: mime_part_Lpdf; Motion_for_Reconsideration_by_Plaintiff 2011-06-21.p

n Indyke To: Lesley Groff Subject: Fwd: Jeffrey Epstein vs. Fancelli Paneling, Inc. Date: Wed, 06 Jul 20

m: Darren Indyke To: Lesley Groff Subject: Fwd: Jeffrey Epstein vs. Fancelli Paneling, Inc. Date: Wed, 0

anying Affidavit Anoushka Anna McCoy Hodge & FRANCOIS EFTA00431073 The message is ready to be sent with the following file or link attachments: Motion for Reconsideration by Plaintiff -Affidavit 2011-06-21 Motion for Reconsideration by Plaintiff 2011-06-21 Motion for Reconsideration by Plaintiff - Memorandum 2011-06-

-Defendant, VS. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants/Counter- Plaintiffs. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S OBJECTION AND RESPONSE TO IMPROPER FILING OF SUPPLEMENTAL AUTHORITY INTRODUCTION In December 2009, Jeffrey Epstein ("Epstein") filed suit against

-DEFENDANT JEFFREY EPSTEIN'S OBJECTION AND RESPONSE TO IMPROPER FILING OF SUPPLEMENTAL AUTHORITY INTRODUCTION In December 2009, Jeffrey Epstein ("Epstein") filed suit against Scott Rothstein ("Rothstein") and Bradley J. Edwards ("Edwards"). In response to Epstein's lawsuit, Edwards filed a Countercla

COUNTY, FLORIDA CASE NO. 502009CA040800XXXXMB JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, VS. SCOT

, FL 33301. EFTA00613846 Reconsideration. Three months later, Edwards has filed this purported "supplemental authority" in support of his initial Motion for Reconsideration. However, this supplemental authority" does nothing more than establish the fact that another trial court, just as this Court did in the case at h