Epstein Secrets

rth is in the hundreds of millions of dollars - if not, indeed, a billion dollars. See, e.g., New York Time, July 1, 2008, at A2 ("Over the weekend Jeffrey E. Epstein, who after years of advising billionaires became a billionaire himself, left his estate on Little St. James Island, with its staff of 70 and its fl

ant PLAINTIFF, JANE DOE'S MOTION FOR INJUNCTION RESTRAINING FRAUDULENT TRANSFER OF ASSETS, APPOINTMENT OF A RECEIVER TO TAKE CHARGE OF PROPERTY OF EPSTEIN, AND TO POST A $15 MILLION BOND, TO SECURE POTENTIAL JUDGMENT COMES NOW Plaintiff Jane Doe, by and through undersigned counsel, and hereby files t

IS ASSETS. As noted in the material facts above, defendant Epstein is currently making fraudulent transfers of his

ork Time, July 1, 2008, at A2 ("Over the weekend Jeffrey E. Epstein, who after years of advising billionair

ork Time, July 1, 2008, at A2 ("Over the weekend Jeffrey E. Epstein, who after years of advising billionaire

#23. 14. Epstein has blocked all discovery, in this and other related cases, regarding his assets. Affidavit of Paul Cassell at ¶¶ 7, 8. ARGUMENT I. EPSTEIN IS FRAUDULENTLY TRANSFERRING HIS ASSETS. As noted in the material facts above, defendant Epstein is currently making fraudulent transfers of his as

er First Request for Admissions to the Defendant, JEFFREY EPSTEIN, and requests said Defendant admit or deny the following facts, in accordance with Federal Rules of Civil Procedure: DEFINITIONS The term "you" means and refers to the Defendant, JEFFREY EPSTEIN. ADMISSIONS I. Your net worth is greater than $10 mill

), and the authority of the Court to administer proceedings before it, for approval of an agreed- upon protocol authorizing counsel for the Estate of Jeffrey E. Epstein (the "Epstein Estate") to review videorecorded materials and photographs in the possession, custody, or control of the Epstein Estate (the "Epstein

o assume that [there was possible] interstate transmission of child pornography...that could have changed the entire complexion of the case against Epsteinf OPR Report, p. 176. Six computer hard drives were suspiciously missing from Epstein's Florida home just before a police raid--leaving dangling wire

- investigation-into-the-u-s-attorney-s-office-for-the-southern-district-of- florida-s-resolution-of-its-2006-2008-federal-criminal-investigation-of- jeffrey-epstein-and-its-interactions-with-victims-during-the- investigation/db9373e8-22f8-4712-b4a7-be844d162de0/, p. iv. As acknowledged in the OPR Report, law enforce

on protocol authorizing counsel for the Estate of Jeffrey E. Epstein (the "Epstein Estate") to review videor

on protocol authorizing counsel for the Estate of Jeffrey E. Epstein (the "Epstein Estate") to review videore

ATERIALS Plaintiffs Jane Doe 1 and the Government of the United States Virgin Islands ("Government"), by their respective counsel, move pursuant to Federal Rules of Civil Procedure 26(c), and the authority of the Court to administer proceedings before it, for approval of an agreed- upon protocol authorizing counsel fo

ed that the names of girls on the handwritten lists came from his personal notes regarding payments he had made to girls during his employment with PSTEIN. RODRIGUEZ e plained that EPSTEIN would instruct him to •o to the bank and w hdraw a specified amount of funds. or GHISLAINE ELL would then inst

of birth , was contacted by Alfredo Rodriguez, date of birth . Edwards is an attorney who is representing four fema e in ividuals who are suing Jeffrey Epstein. Rodriguez was an employee for Epstein. Edward's deposed Rodriguez and served him with a federal subpoena to provide any and all documents relatin

, date of birth . Edwards is an attorney who is representing four fema e in ividuals who are suing Jeffrey Epstein. Rodriguez was an employee for Epstein. Edward's deposed Rodriguez and served him with a federal subpoena to provide any and all documents relating to the case. Rodriguez is trying to se

he following information. RODRIGUEZ advised that he had been told by GHISLAINE ELL not to disc s what had occurred at the home of his farmer oyer, JEFFERY STEIN approximately 3-4 months after he was fired from his po ition as house manager in March 2005. RODRIGUEZ further advised hat MAXWELL also told him n

presenting four fema e in ividuals who are suing Jeffrey Epstein. Rodriguez was an employee for Epstein.

ADDITIONAL INFORMATION As to who may serve a subpoena and the mama of its service see Rule 17(4 Federal Rules of Criminal Procedure, or Rule 45(b), Federal Rules of Civil Procedure. "Fees and mileage need not be tendered to the witness upon service of a subpoena issued on behalf of the United States or an officer or

), and the authority of the Court to administer proceedings before it, for approval of an agreed- upon protocol authorizing counsel for the Estate of Jeffrey E. Epstein (the "Epstein Estate") to review videorecorded materials and photographs in the possession, custody, or control of the Epstein Estate (the "Epstein

s meant to include Responsive Media that may consist of movies or You Tube videos, for example, but does not extend to Responsive Media relating to Epstein activities or properties that may have been publicly disclosed at any time. 2 In this motion, the parties use the term "child sex abuse imagery" or

on protocol authorizing counsel for the Estate of Jeffrey E. Epstein (the "Epstein Estate") to review videor

on protocol authorizing counsel for the Estate of Jeffrey E. Epstein (the "Epstein Estate") to review videore

) JAMES EDWARD STALEY ) ) Third-Party Defendant. ) ) Case Number: 1:22-cv-10904-JSR ORDER REGARDING REVIEW OF VIDEOMATERIALS Pursuant to Federal Rules of Civil Procedure 26(c) and the authority of this Court to administer its proceedings, and finding good cause established in the stipulated motion filed by

her response is required, BOP admits that Jeffrey Epstein died at the Metropolitan Defendant replicates th

a further response is required, BOP admits that Jeffrey Epstein died at the Metropolitan Defendant repli

rt to Plaintiff's FOIA request for a complete and accurate statement of its contents. To the extent a further response is required, BOP admits that Jeffrey Epstein died at the Metropolitan Defendant replicates the headings from Plaintiffs' Complaint solely for ease of reference, without admitting any allegatio

fendant reserves the right to assert each and every affirmative or other defense that may be available, including any defenses available pursuant to Federal Rules of Civil Procedure 8 and 12. 6 EFTA00088194 Case 1:20-cv-00833-PAE Document 7 Filed 03/04/20 Page 7 of 7 WHEREFORE, Defendant respectfully requests that

e wantelltillow why agents wants to talk to her so that she in turn could consult her attorney in this matter. SA areplied that this was regarding JEFFREY EPSTEIN. SA then askedIIIIIIII, "well you are familiar with JEFFREY EPSTEIN right?".. then answered "OK...", and then asked about travel arrangements to

could consult her r eplied attorney in this matter. SA r that this was regarding JEFFREY EPSTEIN. S then asked , "well you are familiar with JEFFREY right?". hen answered "OK...", and then asked about travel arrangements to Florida for grand jury. IIIIIIII was then referred to the printed mat

lassification Required) FEDERAL BUREAU OF INVESTIGATION Electronic Communication Title: ITE/FOU0) Drafted By: Missing Case ID #: 31E-MM-NEW (U) EPSTEIN, JEFFREY Date: 12/04/2018 Details: 05/29/2008 On May 29, 2008, Special Agents (SAs) and of the Federal Bureau of Investigation (FBI) met with

d oen-e,, , Q (2) As to who may save a subpoena and the manner of its service see Rule 17(d), Federal Rules of Criminal Procedure, or Rule 45411, Federal Rules of Civil Procedure. "Fees rear need not be tendered to the witness upon service of a subpoena issued on behalf of the United Slates or an officer or agency

O PLEASE BRING THE FOLLOWING DOCUMENTS, ITEMS, AND INFORMATION WITH YOU TO YOUR GRAND JURY APPEARANCE: 1. Any and all notes, let • • • effrey Epstein, Ghislaine Maxwe , an or any o cr emp oyee or associa e o e ey ps etn. 2. An and all hoto a hs whether rinted or di ital, of Jeffrey Epstein, his

• • effrey Epstein, Ghislaine Maxwe , an or any o cr emp oyee or associa e o e ey ps etn. 2. An and all hoto a hs whether rinted or di ital, of Jeffrey Epstein, hislaine Maxwe , an or any other employee or associate of Jeffrey Epstein. 3. Any and all e-mails, instant messages, chats, text messages, voice

n and all hoto a hs whether rinted or di ital, of Jeffrey Epstein, hislaine Maxwe , an or any other emplo

ej ovu"01- co/ itt As to who may serve a subpoena and the manner of its service see Rule 17(d), Federal Rules of Criminal Procedure, or Rule 45(b), Federal Rules of Civil Procedure. "Fees and mileage need not be tendered to the witness upon service of a subpoena issued on behalf of the United States or an officer or

mited to paystubs, W-2 forms, correspondence, employment applications, and employment reviews. Any and all information regarding methods to contact Jeffrey Epstein directly or via any secretaries/assistants from 1/1/2004 to the present, including but not limited to, telephone numbers, cellular telephone numbers

information regarding methods to contact Jeffrey Epstein directly or via any secretaries/assistants from 1

and all information regarding methods to contact Jeffrey Epstein directly or via any secretaries/assistant

ge need not be tendered to the witness upon service of a subpoena issued on behalf of the United States or an officer or agency thereof (Rule 45(c), Federal Rules of Civil Procedure:. Rule 17(d), Federal Rules of Criminal Procedure) or on behalf of certain indigent panics and criminal defendants who arc unable to pay s

mited to paystubs, W-2 forms, correspondence, employment applications, and employment reviews. Any and all information regarding methods to contact Jeffrey Epstein directly or via any secretaries/assistants from 1/1/2004 to the present, including but not limited to, telephone numbers, cellular telephone numbers

information regarding methods to contact Jeffrey Epstein directly or via any secretaries/assistants from 1

and all information regarding methods to contact Jeffrey Epstein directly or via any secretaries/assistant

ge need not be tendered to the witness upon service of a subpoena issued on behalf of the United States or an officer or agency thereof (Rule 45(c), Federal Rules of Civil Procedure:. Rule 17(d), Federal Rules of Criminal Procedure) or on behalf of certain indigent panics and criminal defendants who arc unable to pay s

mited to paystubs, W-2 forms, correspondence, employment applications, and employment reviews. Any and all information regarding methods to contact Jeffrey Epstein directly or via any secretaries/assistants from 1/1/2004 to the present, including but not limited to, telephone numbers, cellular telephone numbers

information regarding methods to contact Jeffrey Epstein directly or via any secretaries/assistants from 1

and all information regarding methods to contact Jeffrey Epstein directly or via any secretaries/assistant

ge need not be tendered to the witness upon service of a subpoena issued on behalf of the United States or an officer or agency thereof (Rule 45(c), Federal Rules of Civil Procedure:. Rule 17(d), Federal Rules of Criminal Procedure) or on behalf of certain indigent panics and criminal defendants who arc unable to pay s