Epstein Secrets

91(b)(2) 2 EFTA00304714 Case 1:17-cv-00616 Document 1 Filed 01/26/17 Page 3 of 21 11. At all times material to this cause of action, Defendants Jeffrey Epstein, Ghislaine Maxwell, and owed a duty to Plaintiff to treat her in a non-negligent manner and not to commit or conspire to commit intentional or tor

r. FACTUAL ALLEGATIONS 12. At all times material to this cause of action Defendant Jeffrey Epstein was an adult male over 50 years old. Defendant Epstein is known as a billionaire who uses his extraordinary wealth to commit illegal sexual crimes in violation of federal and state statutes and to emplo

rey Epstein was an adult male over 50 years old. Defendant Epstein is known as a billionaire who uses his extraordi

TRICT OF NEW YORK JANE DOE 43, Plaintiff, VS. JEFFREY EPSTEIN, GHISLAINE MAXWELL, Defendants. COMPLA

orth Andrews Ave., Ste. 2 Fort Lauderdale Florida 33301 T: E: Pro ac ice to e z e J. Stanley Pottinger J. Stanley Pottinger PLLC Suite 100 49 Twin Lakes Road South alem New York 10590 T: E: 21 EFTA00304733

ellaneous: Respondent: Sharon Churcher; Jeffrey Epstein DOCKET CASE NUMBER: 1:15cv7433 OTHER DOCKET CAS

s: Miscellaneous: Respondent: Sharon Churcher; Jeffrey Epstein DOCKET CASE NUMBER: 1:15cv7433 OTHER DO

s: Miscellaneous: Respondent: Sharon Churcher; Jeffrey Epstein DOCKET CASE NUMBER: 1:15cv7433 OTHER DOCKET CAS

L, USA 33301 (954)-524-2820 Fax: (954)-524-2822 Email:[email protected] John Pottinger [ATTORNEY TO BE NOTICED] J. Stanley Pottinger PLLC 49 Twin Lakes Road South Salem, NY, USA 10590 (917)-446-4641 Email:[email protected] Paul G Cassell [ATTORNEY TO BE NOTICED] S.J. Quinney College of Law At The

ecruitment of girls, including minors, for the purpose of sexual abuse. Plaintiff claims she was a minor when she was recruited by Defendant over to Jeffrey Epstein's house. Plaintiff further alleged that Defendant and Epstein commonly lured females to Jeffrey Epstein by telling them they would be paid for giving

Plaintiff claims she was a minor when she was recruited by Defendant over to Jeffrey Epstein's house. Plaintiff further alleged that Defendant and Epstein commonly lured females to Jeffrey Epstein by telling them they would be paid for giving a massage to Epstein; however, once at Epstein's house Plain

1-7364 Fax: 303-832-2628 [email protected] Jeffrey Pagliuca: Haddon Morgan and Foreman, P.C. 150 E

ards, Fistos & Lehrman 425 North Andrews Avenue, Suite 2 Ft. Lauderdale, FL 33301 Tel: 954-524-2820 Fax: 954-524-2822 [email protected] 49 Twin Lakes Road South Salem, NY 10590 Tel: 914-763-8333 [email protected] Defoulanes [dal Counsel: Laura Menninger: Haddon, Morgan and Foreman, P.C. 150 E

witnesses that Defendants have listed on their Witness List not objected to by Plaintiff, Jane Doe. 151. All rebuttal witnesses. 152. All People on Jeffrey Epstein's Inmate Visitor Log while he was in jail. WITNESS TESTIMONY EXPECTED TO BE PRESENTED BY MEANS OF DEPOSITION 153' Mark Epstein 30 VANDAM STREET NEW

s Boulevard West Palm Beach, Florida 33409 Phone: (561) 686-6300 Fax: 561-383-9451 Attorneys for Bradley J. Edwards EFTA00798039 EDWARDS ADV. EPSTEIN Case No.: 502009CA040800XXXXMBAG Notice of Serving Answers to Interrogatories COUNSEL LIST William Chester Brewer, Esquire [email protected]; wcbla

OUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff(s), vs. SCOTT ROTHSTEIN, in

, including on the issue of punitive dams es Sub'ect to assertions of privilege 4. do Stan Pottinger EFTA00798042 DESCRIPTION OF WITNESSES 49 Twin Lakes Road, Suite 100 South Salem NY 10590 2-3 Expected to testify about the malicious prosecution elements of absence of probable cause and malice. Will tes

ecruitment of girls, including minors, for the purpose of sexual abuse. Plaintiff claims she was a minor when she was recruited by Defendant over to Jeffrey Epstein's house. Plaintiff further alleged that Defendant and Epstein commonly lured females to Jeffrey Epstein by telling them they would be paid for giving

Plaintiff claims she was a minor when she was recruited by Defendant over to Jeffrey Epstein's house. Plaintiff further alleged that Defendant and Epstein commonly lured females to Jeffrey Epstein by telling them they would be paid for giving a massage to Epstein; however, once at Epstein's house Plain

l: Defendant's Trial Counsel: Laura Menninger: Jeffrey Pagliuca: Haddon, Morgan and Foreman, P.C. 150

UT 84112 Tel: Fax: Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman 425 North Andrews Avenue, Suite 2 Ft. Lauderdale, FL 33301 Tel: Fax: 49 Twin Lakes Road South Salem, NY 10590 Tel: Defendant's Trial Counsel: Laura Menninger: Jeffrey Pagliuca: Haddon, Morgan and Foreman, P.C. 150 East 10th Avenue

aim that "came forward" and "corroborated" Ms. accusations against Dershowitz when she "testified under oath that she had been trafficked by Mr. E stein and had had sex with Mr. Dershowitz." As plaintiffs counsel are well aware, Ms. testimony is marked confidential and remains under seal; indeed, pla

D DEBRA L GREENBERGER ZOE SALZMAN SAM SHAPIRO By Email EMERY CELLI BRINCKERHOFF & ABADY LLP J. Stanley Pottinger J. Stanley Pottinger PLLC 49 Twin Lakes Road South Salem, NY 10590 Email: [email protected] ATIORNEYS Ar LAW 6(X) VTII AVENUE AP ROCKIBIELIER CENTER 10m NIROR NM,' YORK, NEW YORK 1002

:Cassellp@law. Utah. Edu DEFENDANT ATTORNEY(S): Jeffrey S. Pagliuca [PRO HAC VICE;ATTORNEY TO] Haddon Mo

, USA 33301 (954)-524-2820 Fax: (954)-524-2822 Email:[email protected] John Pottinger [ATTORNEY TO BE NOTICED] J. Stanley Pottinger PLLC 49 Twin Lakes Road South Salem, NY, USA 10590 (917)-446-4641 Email:[email protected] Paul G Cassell [ATTORNEY TO BE NOTICED] S.J. Quinney College of Law At The