Epstein Secrets

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 10-CV-21586-ASG PODHURST ORSECK, Plaintiff, v. JEFFREY EPSTEIN, Defendant. Defendant's Reply to Plaintiff's Response to Defendant's Amended Notice and Motion for Leave to Deposit Funds into the Registry of the

0 into the Court and regarding the history and nature of the fee dispute that is at the core of the current litigation. 2. As background, defendant Epstein executed a Non-Prosecution Agreement with the United States Attorney's Office ("USAO") on September 24, 2007 (hereinafter "Agreement"). The Agreeme

ore of the current litigation. 2. As background, defendant Epstein executed a Non-Prosecution Agreement with the Un

0-CV-21586-ASG PODHURST ORSECK, Plaintiff, v. JEFFREY EPSTEIN, Defendant. Defendant's Reply to Plaint

icitly limit the fees and costs being charged to Mr. Epstein so that they were reasonable and not unnecessaril

se fees (or the equivalent of over 10 years of full-time legal work in this non-firm attorney's ordinary job) are requested for work performed by an Assistant State Attorney for Dade County who was not a civil litigator and had little or no specialized expertise in areas directly relevant to the consideration o

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 10-CV-21586-ASG PODHURST ORSECK, Plaintiff, v. JEFFREY EPSTEIN, Defendant. Defendant's Reply to Plaintiff's Response to Defendant's Amended Notice and Motion for Leave to Deposit Funds into the Registry of the

0 into the Court and regarding the history and nature of the fee dispute that is at the core of the current litigation; 2. As background, defendant Epstein executed a Non-Prosecution Agreement with the United States Attorney's Office ("USAO") on September 24, 2007 (hereinafter "Agreement"). The Agreeme

ore of the current litigation; 2. As background, defendant Epstein executed a Non-Prosecution Agreement with the Un

0-CV-21586-ASG PODHURST ORSECK, Plaintiff, v. JEFFREY EPSTEIN, Defendant. Defendant's Reply to Plaint

citly limited the fees and costs being charged to Mr. Epstein so that they were reasonable and not unnecessari

se fees (or the equivalent of over 10 years of full-time legal work in this non-firm attorney's ordinary job) are requested for work performed by an Assistant State Attorney for Dade County who was not a civil litigator and had little or no specialized expertise in areas directly relevant to the consideration o

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 10-CV-21586-ASG PODHURST ORSECK, Plaintiff, v. JEFFREY EPSTEIN, Defendant. Defendant's Reply to Plaintiff's Response to Defendant's Amended Notice and Motion for Leave to Deposit Funds into the Registry of the

0 into the Court and regarding the history and nature of the fee dispute that is at the core of the current litigation; 2. As background, defendant Epstein executed a Non-Prosecution Agreement with the United States Attorney's Office ("USAO") on September 24, 2007 (hereinafter "Agreement"). The Agreeme

ore of the current litigation; 2. As background, defendant Epstein executed a Non-Prosecution Agreement with the Un

0-CV-21586-ASG PODHURST ORSECK, Plaintiff, v. JEFFREY EPSTEIN, Defendant. Defendant's Reply to Plaint

citly limited the fees and costs being charged to Mr. Epstein so that they were reasonable and not unnecessari

se fees (or the equivalent of over 10 years of full-time legal work in this non-firm attorney's ordinary job) are requested for work performed by an Assistant State Attorney for Dade County who was not a civil litigator and had little or no specialized expertise in areas directly relevant to the consideration o

DRAFT ONLY PODHURST ORSECK PA V JEFFREY EPSTEIN Defendant's Reply to Plaintiff's Response to Defendant's Amended Notice and Motion for Leave to Deposit Funds into the Registry of the Court The d

0 into the Court and regarding the history and nature of the fee dispute that is at the core of the current litigation; 2. As background, defendant Epstein executed a Non-Prosecution Agreement with the United States Attorney's Office ("USAO") on September 24, 2007 (hereinafter "Agreement"). The Agreeme

ore of the current litigation; 2. As background, defendant Epstein executed a Non-Prosecution Agreement with the Un

DRAFT ONLY PODHURST ORSECK PA V JEFFREY EPSTEIN Defendant's Reply to Plaintiff's Respons

itly limited the fees and costs being charged to Mr. Epstein so that they were reasonable and not unnecessari

e fees (or the equivalent of over 10 years of full-time legal work in this non-firm attorney's ordinary job) are requested for work performed by an Assistant State Attorney for Dade County who has no specialized expertise in areas relevant to the consideration of civil settlements. These charges are not neces

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 10-CV-21586-ASG PODHURST ORSECK, Plaintiff, v. JEFFREY EPSTEIN, Defendant. Defendant's Reply to Plaintiff's Response to Defendant's Amended Notice and Motion for Leave to Deposit Funds into the Registry of the

0 into the Court and regarding the history and nature of the fee dispute that is at the core of the current litigation. 2. As background, defendant Epstein executed a Non-Prosecution Agreement with the United States Attorney's Office ("USAO") on September 24, 2007 (hereinafter "Agreement"). The Agreeme

ore of the current litigation. 2. As background, defendant Epstein executed a Non-Prosecution Agreement with the Un

0-CV-21586-ASG PODHURST ORSECK, Plaintiff, v. JEFFREY EPSTEIN, Defendant. Defendant's Reply to Plaint

icitly limit the fees and costs being charged to Mr. Epstein so that they were reasonable and not unnecessaril

se fees (or the equivalent of over 10 years of full-time legal work in this non-firm attorney's ordinary job) are requested for work performed by an Assistant State Attorney for Dade County who was not a civil litigator and had little or no specialized expertise in areas directly relevant to the consideration o

Six, to•wit: The Grand Jurors of the State cf Florida, inquiring in and for the body of said County of Palm Beach, upon their oaths do present that JEFFREY E. EPSTEIN in the County of Palm Beach aforesaid. in the Circuit and State aforesaid. COUNT ONE FELONY SOLICITATION OF PROSTITUTION • on or about or between

not to be placed on the electronic monitor. DONE AND ORDERED in chambers, West Palm Beach, Palm Beach County, Florida this 7 day of May, 2009. JEFFREY C BA1F / Circuit Court udge Copies Furnished: Jack A. Goldberger, Esq., Attorney for Defendant SCANNED MAY051009 Barbara Burns, Esq., Assistant

had one of his personnel go into the airport to ensure the ema e targets were not present inside the terminal. The CBP officer returned and advised Epstein was alone and was still processing through customs. At Approximate) 8:55 AN, this writer contacted at ATC. This writer told the plane had been c

y of Palm Beach, upon their oaths do present that JEFFREY E. EPSTEIN in the County of Palm Beach aforesaid. i

JEFFREY C BA1F / Circuit Court udge Copies Furnished: Jack A. Goldberger, Esq., Attorney for Defendant SCANNED MAY051009 Barbara Burns, Esq., Assistant State,AtIorreystAm R. A. of oa Rum was cou„ny Department of Corrections - Probe r\'' (P.arole I t e fay Only thet the fctecp:44 is a the ooPY of t • eo

bsolutely not. 9 Q. Have you ever spoken with any independent 10 investigators regarding the actions, the criminal 11 actions that occurred at Jeffrey Epstein's home? 12 A. Yes. 13 Q. When did that occur? 14 A. Right after I receive a card from the police 15 department, when I call Jeffrey and I as

you -- 16 MR. CRITTON: Before you get started, let me 17 just put on my objection. 18 Adam, your client i. who alleges that 19 she was at Mr. Epstein's house sometime, I think, 20 on one occasion in the summer of '03. 21 This witness is neither relevant, nor 22 material, nor can it lead to th

11 And I called the office in New York. 12 I says, I would like to speak to Mr. Epstein. 13 And he come on, and I said, I told him, I 14 says, Jeffrey, what's going on? What's happening? I 15 thought it was related to the problem that I had 16 personally with him settled. 17 And I says -- no,

, your client i. who alleges that 19 she was at Mr. Epstein's house sometime, I think, 20 on one occasion i

? 7 A. Yes. 8 Q. And you did have your statement taken at the 9 State Attorney's Office? 10 A. Yes. 11 Q. But you -- but that was by an Assistant State 12 Attorney, correct? 13 A. Yes. 14 Q. The questioning? 15 A. (Nods head.) 16 Q. Is that correct? 17 A. That's correct. 18 Q. You

bsolutely not. 9 Q. Have you ever spoken with any independent 10 investigators regarding the actions, the criminal 11 actions that occurred at Jeffrey Epstein's home? 12 A. Yes. 13 Q. When did that occur? 14 A. Right after I receive a card from the police 15 department, when I call Jeffrey and I as

ou 16 MR. CRITTON: Before you get started, let me 17 just put on my objection. 18 Adam, your client is ., who alleges that 19 she was at Mr. Epstein's house sometime, I think, 20 on one occasion in the summer of '03. 21 This witness is neither relevant, nor 22 material, nor can it lead to th

11 And I called the office in New York. 12 I says, I would like to speak to Mr. Epstein. 13 And he come on, and I said, I told him, I 14 says, Jeffrey, what's going on? What's happening? I 15 thought it was related to the problem that I had 16 personally with him settled. 17 And I says -- no,

ur client is ., who alleges that 19 she was at Mr. Epstein's house sometime, I think, 20 on one occasion i

? 7 A. Yes. 8 Q. And you did have your statement taken at the 9 State Attorney's Office? 10 A. Yes. 11 Q. But you -- but that was by an Assistant State 12 Attorney, correct? 13 A. Yes. 14 Q. The questioning? 15 A. (Nods head.) 16 Q. Is that correct? 17 A. That's correct. 18 Q. You