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

ral Rico Act is equally applicable to claims under the Florida Rico statute). 2. Moore v. Potter, 142 Fed. Appx. WL 1600194 (11Th Cir. 2005). 3. Pilkington v. United Airlines 112 F.3d 1532, 1536 (11th Cir,1997) 4. Stansfield v. Starkey, 269 Cal.Rptr., 337, 348 (Cal. App.3d, 1990) 5. Zimmerman v. HBO

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

ral Rico Act is equally applicable to claims under the Florida Rico statute). 2. Moore v. Potter, 142 Fed. Appx. WL 1600194 (11Th Cir. 2005). 3. Pilkington v. United Airlines 112 F.3d 1532, 1536 (11th Cir,1997) 4. Stansfield v. Starkey, 269 Cal.Rptr., 337, 348 (Cal. App.3d, 1990) 5. Zimmerman v. HBO

2'2009 Page 1 of 26 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE, CASE NO.: 08-CIV- 80893 - MARRA/JOHNSON Plaintiff, v. JEFFREY EPSTEIN, Defendants. Defendant's, Epstein. Motion To Dismiss, For More Definite Statement & To Strike Directed To Plaintiff Jane Doe's Amended Complaint,

Plaintiff. . .was called on the telephone by. . .Epstein and other employees. . ., and transported to. . .

Florida Civil Rico action is, at this time, only defendant Epstein. . . ." However, the RICO enterprise must be dis

.: 08-CIV- 80893 - MARRA/JOHNSON Plaintiff, v. JEFFREY EPSTEIN, Defendants. Defendant's, Epstein. Moti

at the racketeering activity caused him to suffer an injary. . ., a claim stemming from personal injury is not cognizable under Rico." Id; see also Pilkington v. United Airlines. 112 F.3d 1532, 1536 (11th Cir. 1997); Federal Procedure, 5B Fed. Proc., L. Ed., §10:160, Sta a, Private Civil Actions Under ER

Son's Wrongdoing Colors DOJ Inquiry EFTA00160374 • Trump Suggests He Knowingly Took Documents From White House • Records of Florida Grand Jury's Jeffrey Epstein Investigation Can Be Made Public • Criminal Investigation Into Sen. Bob Menendez Expands With New Subpoenas • Lori Vallow Daybell Trial: Jurors Beg

and EFTA00160380 those who have not been criminally charged. There is a public interest in knowing whether the wealthy and politically connected Epstein, who lived in a Palm Beach mansion, was given special treatment, the court ruled. Criminal Investigation Into Sen. Bob Menendez Expands With New Sub

om White House • Records of Florida Grand Jury's Jeffrey Epstein Investigation Can Be Made Public • Crimi

as affiliated charities, rendering the websites inaccessible. Abu Zubaydah's Drawings Expose the US's Depraved Torture Policy The Guardian (05/11, Pilkington) discussed Abu Zubaydah, a detainee at Guantanamo Bay who was subjected to torture in the CIA's post-9/11 program. According to the article, Zubayda

e. The article noted that in the shadow of gangster James "Whitey" Bulger's 2018 beating death at a West Virginia federal penitentiary and financier Jeffrey Epstein's 2019 suicide at a Manhattan federal jail while awaiting trial on sex trafficking charges, the Bureau of Prisons is again under scrutiny for failing

rginia federal penitentiary and financier Jeffrey Epstein's 2019 suicide at a Manhattan federal jail while

West Virginia federal penitentiary and financier Jeffrey Epstein's 2019 suicide at a Manhattan federal ja

r), the Washington Post (12/10, Hsu, Weiner), USA Today (12/09, Jansen), Politico (12/10, Cheney), ABC News (12/11, Bruggeman), The Guardian (12/10, Pilkington), and The Hill (12/10, Lee) also reported on the story. Former Cleveland Schools Worker Convicted for Role in Capitol Riots Released Early From Pr

/Counter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff. / COUNTER-DEFENDANT JEFFREY EPSTEIN'S MEMORANDUM OF LAW ON EDWARDS' WAIVER OF ATTORNEY-CLIENT AND WORK PRODUCT PROTECTIONS Counter-Defendant Jeffrey Epstein ("Epstein"), submits this M

FENDANT JEFFREY EPSTEIN'S MEMORANDUM OF LAW ON EDWARDS' WAIVER OF ATTORNEY-CLIENT AND WORK PRODUCT PROTECTIONS Counter-Defendant Jeffrey Epstein ("Epstein"), submits this Memorandum of Law as to the Doctrines of Waiver of Attorney-Client and Work Product protections as claimed by Edwards and at issue

OUNTY, FLORIDA Case No. 50-2009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT

leged material to a third party waives the privilege as such disclosure is inconsistent with the confidential relationship."); Visual Scene, Inc. v. Pilkington 4 EFTA00805370 Bros., 508 So. 2d 437, 440 (Fla. 3d DCA 1987) ("In most cases, a voluntary disclosure to a third party of the privileged material

Menendez's Bribery Case Reminds Us Why Proving Corruption Is So Hard CRIMINAL INVESTIGATIONS • Ghislaine Maxwell's Lawyer Tell Appeals Judges That Jeffrey Epstein's Florida Plea Deal Protects Her • Republicans Subpoenaed 15 Years of Hunter Biden Phone Records, Democrats Reveal • Ex-Mar-a-Lago Employee Says He U

on. Lawyers for Maxwell are challenging her December 2021 conviction on multiple grounds, but the only topic at oral arguments was whether the deal Epstein struck in Florida to prevent a federal case against him there also protected Maxwell in New York. Samson said it did. A prosecutor said it didn't. M

islaine Maxwell's Lawyer Tell Appeals Judges That Jeffrey Epstein's Florida Plea Deal Protects Her • Repub

ODAY (3/12, Gomez). Back to Top COUNTERTERRORISM Man Who Sent Bomb Threat to Arizona Election Officials Jailed for 42 Months The Guardian (03/12, Pilkington) reported that James Clark, a 38-year-old Massachusetts man, was sentenced to 42 months in prison for threatening to bomb the Arizona Secretary of S

Menendez's Bribery Case Reminds Us Why Proving Corruption Is So Hard CRIMINAL INVESTIGATIONS • Ghislaine Maxwell's Lawyer Tells Appeals Judges That Jeffrey Epstein's Florida Plea Deal Protects Her • Republicans Subpoenaed 15 Years of Hunter Biden Phone Records, Democrats Reveal • Ex-Mar-a-Lago Employee Says He U

on. Lawyers for Maxwell are challenging her December 2021 conviction on multiple grounds, but the only topic at oral arguments was whether the deal Epstein struck in Florida to prevent a federal case against him there also protected Maxwell in New York. Samson said it did. A prosecutor said it didn't. M

slaine Maxwell's Lawyer Tells Appeals Judges That Jeffrey Epstein's Florida Plea Deal Protects Her • Repub

ODAY (3/12, Gomez). Back to Top COUNTERTERRORISM Man Who Sent Bomb Threat to Arizona Election Officials Jailed for 42 Months The Guardian (03/12, Pilkington) reported that James Clark, a 38-year-old Massachusetts man, was sentenced to 42 months in prison for threatening to bomb the Arizona Secretary of S

defendant-appellant Miguel Plascencia-Alvarado. Jeffrey E. Ellis, Law Offices of Ellis, Holmes & Witchley,

defendant-appellant Miguel Plascencia-Alvarado. Jeffrey E. Ellis, Law Offices of Ellis, Holmes & Witchley,

Browne, L.R. 10 Ch. 64, where I declined to inte ere with criminal proceedings or 1 to follow Lord rdwicke's doubtful decision in Mayor of York Pilkington, 2 Adc. 302. My decision was appea ed from, and the Lords Justices thought it a right decision. With the exception of that case before Lord Hardwi