Epstein Secrets

privacy. 5. This is strictly a "fishing expedition" unrelated to any aspect of this case. A similar Request to Produce was served in the casel v. Jeffrey E. Epstein and , Case No. 502008CA025129XXXXMB Al, in front of Judge Garrison. A copy of the objection to the Notice is attached as Exhibit "B" and Judge Garr

BOARD CERTIFIED CVO-TRIAL LAWYER Sent by Fax and U.S. Mail Isidro M. Garcia, Esq. A LIMITED LIABILITY PARTNERSHIP April 13, 2009 Re: Doe II v. Epstein, et al. Case No. 09-80469-Civ-MARRA/JOHNSON ADELQUI.LBENAVENTE rmukumALINVBSTIOMOR BARBARA M. NkKENNA ASHLIE STOKEN-BARING BETTY STOKES PARALE

kKENNA ASHLIE STOKEN-BARING BETTY STOKES PARALEGALS RITA H. BUDNYK OP COUNSEL Dear Sid: Please be informed thal subpoenaed deposition in thel.L. Epstein case on April 16th, 2009 is hereby cancelled. Cordially Robert D. Critton, Jr. RDC/clz cc: Jack A. Goldberger, Esq. L•A•W•Y•E •R•S TELEPHONE

py of the case law and Florida Statutes cited in Defendant Epstein' otion to Dismiss, For More Definite Statement, a

ar Request to Produce was served in the casel v. Jeffrey E. Epstein and , Case No. 502008CA025129XXXXMB Al,

ar Request to Produce was served in the casel v. Jeffrey E. Epstein and , Case No. 502008CA025129XXXXMB Al,

OW CAB Defendant, Jeffrey Epstein, (hereinafter "Mr. Epstein"), by and through his undersigned attorneys, pur

esent controversy but which might possibly lead to evidence supporting some subsequent cause of action is quashed. COBB and PETERSON, IL, concur. Fla.App. 5 Dist.,2001. State Farm Mut. Auto. Ins. Co. v. Parrish O 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works. Page 2 http://web2.westlaw

o privacy. 5. This is strictly a "fishing expedition" unrelated to any aspect of this case. A similar Request to Produce was served in the caa v. Jeffrey E. Epstein and Case No. 502008CA025129XXXXMB Al, in front of Judge Garrison. A copy of the objection to the Notice is attached as Exhibit "B" and Judge Garris

RIAL LAWYER Sent by Fax and U.S. Mail Isidro M. Garcia, Esq. Garcia Law firm P.A. A LIMITED LIABILITY PARTNERSHIP April 13, 2009 Re: Doe II v. Epstein, et al. Case No. 09-80469-Civ-MARRA/JOHNSON ADELQUI.LBENAVENTE rmemeom. I INVBSTIOMOR BARBARA M. NkKENNA ASHLER STOKEN-BARING BETTY STOKES PAR

OW CAB Defendant, Jeffrey Epstein, (hereinafter "Mr. Epstein"), by and through his undersigned attorneys, pur

ilar Request to Produce was served in the caa v. Jeffrey E. Epstein and Case No. 502008CA025129XXXXMB Al, i

py of the case law and Florida Statutes cited in Defendant Epstein' otion to Dismiss, For More Definite Statement, a

CASE NO. 502008CA037319XXXXMB AB Plaintiff, v. JE an Defendants. DEFENDANT'S, JEFFREY EPSTEIN, O

ilar Request to Produce was served in the caa v. Jeffrey E. Epstein and Case No. 502008CA025129XXXXMB Al, in

esent controversy but which might possibly lead to evidence supporting some subsequent cause of action is quashed. COBB and PETERSON, IL, concur. Fla.App. 5 Dist.,2001. State Farm Mut. Auto. Ins. Co. v. Parrish O 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works. http://web2.westlaw.corn/pr

08CF009381AXX STATE, vs. EPSTEIN, JE'FFREY INTERVENER'S E O u. 0 T i TAY AND UPPORTIN COMES NOW, Intervener,.. and files s Response endant Jeffrey Epstein's Motion to Stay, and states: In their motion, Defendant asks the Court to stay it mg on the production of the NPA agreement pending review by the

y's office that triggers as a 13 result of this plea agreement. In other 14 words, they have signed off and said they 15 will not prosecute Mr. Epstein in the 16 Southern District of Florida for any 17 offense upon his successful taking of this 18 plea today. That is a confidential 19 documen

RCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO: 2006CF009454AXX, 2008CF009381A)OC STATE, vs. EPSTEIN, JEFFREY E, Defendant. MOTION TO INTERVENE AND SUPPORTING MEMORANDUM OF LAW COMES NOW, Applicant, ■. and requests this Court, pursuant to Florida Rule of Civ

as it has been properly sealed. Furthermore, as Defendant EPSTEIN has failed to demonstrate that he is likely to s

09454AXX, 2008CF009381AXX STATE, vs. EPSTEIN, JE'FFREY INTERVENER'S E O u. 0 T i TAY AND UPPO

signed off and said they 15 will not prosecute Mr. Epstein in the 16 Southern District of Florida for any

conclu- sion that the guardian's sua sponse decision to hire counsel in this case, presumably at the expense of the parties, was highly im- ProPer- Fla.App. 3 Dist..1999. Perez v. Perez 769 So.2d 389,24 Fla. L. Weekly D2439 END OF DOCUMENT Q 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.

IL/ I I/ 4VVI II . KIRKLAND & ELLIS LLP AND AtIlLIATIM Honorable R. Alexander Acosta United States Attorney Re: Jeffrey Fastein Dear Alex: vnvw.kiaklunU.CCun December 17, 2007 IL UV'S/ I IU Thank you for meeting with us on Friday, December 14. 2007. The meeting demonstr

emonstrated significant agreement un broad issues of policy. We all agree on the centrality of the principle of horizontal equality, namely that Mr. Epstein should be treated no differently • - neither more nor less favorably — than a less prominent or less wealthy detimdant accused of similar conduct. W

01 s testimony establishing each of these pivotal points are set forth below: • Consent Q: Okay. When did you meet him and who introduced you to Jeffrey? A: My girlfriend introduced me to Jeffrey.* (M• Sworn Statement at 5- 6) Q: Now you said thatMitold you that he likes massages. Did she elaborate

the principle of horizontal equality, namely that Mr. Epstein should be treated no differently • - neither more

s inducement." because ari Inducement entails some semblance of 'arm-twisting; pleading, or coercive tactic,:'. Marred v. State. 841 So.2d 600. 603 (Fla.App. 4th Dist. 2003) (finding no government inducement because "appellant had already demonstrated his predisposition to commit the offense"). Here. Mr

IT, IN AND FOR DADE COUNTY, FLORIDA CASE NO. 14-21348-CA-01 JEAN-LUC BRUNEL, individually, and MC2 MODEL & TALENT MIAMI, LLC. Plaintiffs, VS. JEFFREY EPSTEIN, TYLER MCDONALD, TYLER MCDONALD D/B/A/ YI.ORG Defendants. MEMORANDUM IN OPPOSITION TO MOTION FOR RULING ON SERVICE OF PROCESS Having already on

4, Defendant Jeffrey Epstein was not even a party. Plaintiffs amended their complaint in January 2015 to assert two non-business counts against Mr. Epstein personally and caused a summons to be issued on February 9, 2015. In more than two years since Plaintiffs amended their complaint to include Mr. Eps

C2 MODEL & TALENT MIAMI, LLC. Plaintiffs, VS. JEFFREY EPSTEIN, TYLER MCDONALD, TYLER MCDONALD D/B/A/

y 2015 to assert two non-business counts against Mr. Epstein personally and caused a summons to be issued on F

rning substitute service of process must be strictly construed and must be strictly complied with. See Hauser Vs. Schiff, Florida Appellate Court or Fla.App., 341 So.2d S31 and cases cited therein. Moreover, nowhere in any of the papers filed by Plaintiffs is it alleged that Mr. Epstein was the owner o

emonstrated significant agreement on broad issues or policy. We all agree on the centrality of the principle of horizontal equality. namely that Mr. Epstein should be treated no differently • - neither more nor less favorably — than a less prominent or less wealthy defendant accused of similar conduct. W

f Ms. testimony establishing each of these pivotal points arc set forth below: • Consent 0: Okay. When did you meet him and who introduced you to Jeffrey? A: My girlfriend. (r) introduced me to Jelirey.$ Sworn Statement al - 9: Now you said that old you that he likes massages. Did she elaborate o

demonstrating that the reach of § 2422(h) being advanced by your Office in this matter is unprecedented. Attempts by CMS to match the facts of Mr. F.pstein's conduct with any prior ease — reported or otherwise -- generated a single distinguishable precedent that had no relationship to the facts under c

the principle of horizontal equality. namely that Mr. Epstein should be treated no differently • - neither more

ises inducement." because "filnducement entails some semblance of 'arm-twisting; pleading. or coercive tactics-. Marred v. Sane, 841 So.2d 600. 603 (Fla.App. 4th Dist. 2003) (finding no government inducement because "appellant had already demonstrated his predisposition to commit the offense"). Here. Mr

Records b) Palm Beach Post's Motions to Intervene and Petition for Access c) B.B.'s Motions to Intervene and for an Order to Unseal Records d) Jeffrey Epstein's Motion to Make Court Records Confidential A hearing was conducted on these matters on June 25, 2009. The Court notes that Mr. Goldberger, Esq. and

4AXXMB 1. The State of Florida charged the Defendant, Jeffrey Epstein, with Felony Solicitation of Prostitution. 2. The State of Florida and Mr. Epstein came to a negotiated resolution of the charges. Part of that resolution included an agreement entered into between Mr. Epstein and the United State

, p.m. with appearances 8 as hereinbefore noted, to wit: 9 THEREUPON: 10 THE COURT: Let me call up the case 11 of the state of Florida versus Jeffrey 12 Epstein. Let me have counsel announce 13 their appearances for the record. 14 MS. SHULLMAN: Deanna Shullman of 15 16 17 18 you again, g

on of Prostitution. 2. The State of Florida and Mr. Epstein came to a negotiated resolution of the charges.

onclu- sion that the guardian's sua sponte decision to hire counsel in this case, presumably at the expense of the parties, was highly im- proper. Fla.App. 3 Dist.,1999. Perez v. Perez 769 So.2d 389, 24 Fla. L. Weekly D2439 END OF DOCUMENT 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.