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tz, defense counsel for Jeffrey Epstein. The notification letter would have explained: "I am writing to inform you that the federal investigation of Jeffrey Epstein has been completed, and Mr. Epstein and the U.S. Attorney's Office have reached an agreement containing the following terms . . . ." The letter then
ein agreed to a "confidentiality" provision in the agreement barring its disclosure to anyone — including the victims. For the next nine months, as Epstein was well aware, the U.S. Attorney's Office assiduously concealed from the victims the existence of this signed non-prosecution agreement. Indeed, th
l: "On an 'avoid the press' note, I believe that Mr. Epstein's airplane was in Miami on the day of the la tel
t's desire that federal charges be filed against defendant Epstein. In particular, he wrote on behalf of his clients
formally signed a non-prosecution agreement with Jeffrey Epstein that barred his ' The victims are contem
ourt's direction. DATED: March 21.2011 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS. FIST LEHRMAN. P.L. and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah Attorneys for Jane Doe #1 and Jane Doe #2 40 EFT
45 Filed 06/05/17 Page 1 of 31 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE NO.: 1:17-CV-00616 JANE DOE 43, Plaintiff, vs. JEFFREY EPSTEIN GHISLAINE MAXWELL, AND Defendants. / FIRST AMENDED COMPLAINT Plaintiff JANE DOE 43, by and through her undersigned counsel, for her claims ag
5. FACTUAL ALLEGATIONS 11. At all times material to this cause of action, Defendant Jeffrey Epstein was an adult male over 50 years old. Defendant Epstein is widely recognized as a billionaire who uses his extraordinary wealth to commit illegal sexual crimes in violation of federal and state statutes
would not obtain formal education f she failed to provide the sexual favors desired by Defendant Epstein or abide by the instructions given her by Defendants Epstein, M, and Maxwell. 42. Plaintiff reasonably believed that her compliance with Defendants' demands was crucial to her physical, psychological, financial
O.: 1:17-CV-00616 JANE DOE 43, Plaintiff, vs. JEFFREY EPSTEIN GHISLAINE MAXWELL, AND Defendants. /
smission of Notices of Electronic Filing generated by CM/ECF. STEPTOE & JOHNSON, LLP Michael C. Miller Justin Y.K. Chu Attorneys for Defendants Jeffrey Epstein & By: /s/ Bradley J. Edwards 31 EFTA00615969
trial by jury on all issues triable as of right by a jury. Dated: June 5, 2017. Respectfully Submitted, FARMER, JAFFE, WEISSING. EDWARDS, FISTOS, LEHRMAN,. 29 EFTA00615967 Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 30 of 31 By: /s/ Bradley J. Edwards Bradley J. Edwards PRO HAC VICE
transmission of Notices of Electronic Filing generated by CM/ECF $TEPTOE & JOHNSON, LLP Michael C. Miller Justin Y.K. Chu Attorneys for Defendants Jeffrey Epstein & By: A/Bradley J. Edwards Farmer, Jaffe, Weissi43achiasEds=Ristasn lasgaaINM: Pr6(41GE-glee4040-111061 J,Stanley-Ilettingec J. Stanley Pottinger P
nd through her undersigned counsel, for her EFTA00615971 Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 2 of 31 claims against Defendants Jeffrey Epstein, Ghislaine Maxwell, and alleges upon personal knowledge with respect to her own acts and status, and upon personal knowledge. information and beli
nts transported young females from other places in the U.S. (including the Southern District of New York) and abroad and brought them to Defendant Epsteinns mansion in New York City and his private island in the Virgin Islands. 29. 3&In June of 2008, Epstein pleaded guilty to Florida state felony sex of
rey Epstein was an adult male over 50 years old. Defendant Epstein is knownwidely recognized as a billionaire who u
06/05/17 Page 2 of 31 claims against Defendants Jeffrey Epstein, Ghislaine Maxwell, and alleges upon pe
all issues triable as of right by a jury. Dated: Januafy-26r 201-7-.June 5, 2017. Respectfully Submitted, FARMER. JAFFE. WaVING. EDWARDS. FISTOS, LEHRMAN, M. EFTA00616000 Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 30 of 31 29 EFTA00616001 Case 1:17-cv-00616-JGK Document 45 Filed 06/0
s for Defendant 22 Denver, Colorado 80203 BY: JEFFREY S. PAGLIUCA, ESQUIRE 23 LAURA A. MENNIGER, ESQU
Did you engage in any sexual 10 activities with Mr. Epstein other than sexual 11 intercourse and oral sex?
vities. 7 We've been talking about intercourse and 8 we've been talking about oral sex. 9 Did you engage in any sexual 10 activities with Mr. Epstein other than sexual 11 intercourse and oral sex? 12 MR. PAGLIUCA: Objection to form 13 and foundation. 14 A. Can you ask the question again,
der, including 7 where it says: Defendant is ordered to 8 answer questions relating to defendant's 9 own sexual activity with or involving 10 Jeffrey Epstein, with or involving 11 plaintiff, with or involving underage 12 females, involving or including massage 13 with individuals defendant knew to be
le, Florida 33301 MEREDITH SCHULTZ, ESQUIRE SIGRID McCAWLEY, ESQUIRE 9 SANDRA PERKINS, PARALEGAL 10 FARMER JAFFE WEISSING EDWARDS FISTOS & 11 LEHRMAN, 12 Fort Lauderdale, Florida 33301 BY: BRAD EDWARDS, ESQUIRE 13 14 PAUL G. CASSELL ES UIRE 15 at ace ity, to 16 J. STANLEY POTTINGER PLLC
if you want to, we can schedule this so you can have lunch. On the other hand, if you don't want lunch, that's okay. I can endure. By the way, the Epstein motion will go over to tomorrow because we were told, if I understand it correctly, that they didn't know it was on for today. How that ignorance
7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 deals with the admissibility of things like the nonprosecution agreement, Jeffrey Epstein's plea, his sex offender registration, because if it relates to Ms. Maxwell's statement or the statement that Ms. Maxwell refers to, then it's relev
9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MS. McCAWLEY: Well, we're entitled to ask her on the stand; we're entitled to ask Jeffrey what he told her. THE COURT: That's a different issue. That's a different issue. I mean, that's a wholly different thing. You're talking about you
ure off her and to satisfy the sexual desires of Mr. Epstein. That's why there was this vast -- THE COURT: An
LTZ, ESQ. S.J. QUINNEY COLLEGE OF LAW AT THE UNIVERSITY OF UTAH For Plaintiff BY: PAUL G. CASSELL, ESQ. FARMER, JAFFE, WEISSING, EDWARDS, FISTOS, LEHRMAN, P.L. Attorneys for Plaintiff BY: BRADLEY J. EDWARDS, ESQ. HADDON, MORGAN AND FOREMAN, P.C. Attorneys for Defendant BY: JEFFREY S. PAGLIUCA, ESQ
18 19 20 21 22 23 24 25 Pagc 35 MR. ACKERMAN: Very brief. THE COURT: Give the court reporter your name. MR. ACKERMAN: Joseph Ackerman for Jeffrey Epstein. The Court will recall when we were here last time, Mr. Scherer stood up and said his clients were shown the files for LM as part of a Ponzi Schem
Rothstein, individually, and Mr. Edwards, individually, regarding -- the genesis of which was a civil suit that Mr. Edwards had filed against Mr. Epstein, which has since settled. That civil suit was brought by Mr. Edwards to the Rothstein firm. It was the linchpin of the settlements that Mr. Rothst
E JOSEPH L. ACKERMAN, JR., ESQUIRE On behalf of Jeffrey Epstein OUELLETTE & MAULDIN COURT REPORTERS. INC
a civil suit that Mr. Edwards had filed against Mr. Epstein, which has since settled. That civil suit was br
ttin, Chapter 11 Trustee CONRAD & SCHERER, by JAMES D. SILVER, ESQUIRE On behalf of Razorback Funding FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L., by GARY M. FARMER, JR., ESQUIRE BRAD EDWARDS, ESQUIRE On behalf of the Former RRA Clients FOWLER WHITE BURNETT, P.A., by CHRISTOPHER E. K
to, we 11 can schedule this so you can have lunch. On the other hand, if 12 you don't want lunch, that's okay. I can endure. 13 By the way, the Epstein motion will go over to 14 tomorrow because we were told, if I understand it correctly, 15 that they didn't know it was on for today. How that ign
S, P.C. EFTA00794461 (212) 805-0300 EFTA00794462 49 H3ulgiva 1 deals with the admissibility of things like the nonprosecution 2 agreement, Jeffrey Epstein's plea, his sex offender 3 registration, because if it relates to Ms. Maxwell's statement 4 or the statement that Ms. Maxwell refers to, then it's
D FOREMAN, P.C. Attorneys for Defendant 22 BY: JEFFREY S. PAGLIUCA, ESQ. LAURA A. MENNINGER, ESQ. 23
off her and to satisfy 7 the sexual desires of Mr. Epstein. That's why there was this 8 vast -- 9 THE COU
7 S.J. QUINNEY COLLEGE OF LAW AT THE UNIVERSITY OF UTAH For Plaintiff 18 BY: PAUL G. CASSELL, ESQ. 19 FARMER, JAFFE, WEISSING, EDWARDS, FISTOS, LEHRMAN, P.L. Attorneys for Plaintiff 20 BY: BRADLEY J. EDWARDS, ESQ. 21 HADDON, MORGAN AND FOREMAN, P.C. Attorneys for Defendant 22 BY: JEFFREY S. P
e No. 4 (hereinafter collectively referred to as "the petitioners"), now adults, were as minor girls the victims of federal sex crimes committed by Jeffrey Epstein (hereinafter "Defendant") and by other co-conspirators between about 1998 and 2006. These crimes included sex trafficking of children (in violation
violation of their rights, (2) a declaration that if after consultation with the victims the U.S. Attorney's Office determines that prosecution of Epstein and of others is appropriate then prosecution is permitted, (3) a declaration that the Office shall reasonably confer with the petitioners and other
ls the victims of federal sex crimes committed by Jeffrey Epstein (hereinafter "Defendant") and by other c
ted above. DATED: February 6. 2015 Respectfully Submitted, /s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS LEHRMAN, P.L. and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah. Attorneys for Victims • This daytime business add
e No. 4 (hereinafter collectively referred to as "the petitioners"), now adults, were as minor girls the victims of federal sex crimes committed by Jeffrey Epstein (hereinafter "Defendant") and by other co-conspirators between about 1998 and 2006. These crimes included sex trafficking of children (in violation
violation of their rights, (2) a declaration that if after consultation with the victims the U.S. Attorney's Office determines that prosecution of Epstein and of others is appropriate then prosecution is permitted, (3) a declaration that the Office shall reasonably confer with the petitioners and other
ls the victims of federal sex crimes committed by Jeffrey Epstein (hereinafter "Defendant") and by other c
ted above. DATED: February 6. 2015 Respectfully Submitted, /s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale. Florida 33301 Telephon Facsimile E-mail: and Paul G. Cassell Pro Hac Vice S.J. Quin
AUDERDALE, FL 33301 FACSIMILE COVER SHEET DATE: July 17, 2017 TO: Honorable John G. Koeld FAX NO: FROM: Maria Kelljchian RE: Jane Doe 43 v. Jeffrey Epstein Case No.: 17 civ. 00616 MESSAGE: Please see attached # OF PAGES 4 (including cover sheet) IF YOU DO NOT RECEIVE THE DESIGNATED NUMBER OF PAGES, O
or the Southern District of New York Daniel Patrick Moynihan United States Courthouse 500 Pearl Street New York, NY 10007-1312 RE: Jane Doe 43 v. Epstein et al., No. 17 Civ. 616 (JOK) Dear Judge. Koeltl: We represent Plaintiff Jane Doe 43 in the above-captioned action. We write in response to a lett
NO: FROM: Maria Kelljchian RE: Jane Doe 43 v. Jeffrey Epstein Case No.: 17 civ. 00616 MESSAGE: Please
e Motion to Dismiss. EFTA00792777 Honorable John G. Koeltl July 17, 2017 Page 3 Very Truly Yours, FARMER, JAFFE, WEISSING, EDWARDS, FISTOS and LEHRMAN, PL Bradley J. BJE:mwk EFTA00792778 2502658500 TRANSACTION REPORT FAX( TX) P.01/01 JUL/17/2017/MON 11:09 AM 001 DATE JUL/17 START T. RE
Entities connected to both Jeffrey Epstein and LEHRMAN

Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
Bradley Edwards
PERSON
United States
LOCATIONJack Goldberger
PERSONSouthern District
LOCATIONJane Doe
PERSONMaria Farmer
PERSON
Kenneth Marra
PERSON
Alexander Acosta
PERSONthe Southern District
LOCATION
Paul Cassell
PERSON
Justin Trudeau
PERSON
New York
LOCATION
U.S. Virgin Islands
LOCATION
Virginia Giuffre
PERSON
David Boies
PERSON
Southern District of New York
ORGANIZATION