Epstein Secrets

RK, • App. Div. No. 6081 Respondent, • On Appeal from New York Supreme Court, • New York County, Index No. 30129/10 - against - (Pickholz, J.) JEFFREY E. EPSTEIN, Defendant-Appellant. : x MEMORANDUM OF LAW IN SUPPORT OF MOTION TO UNSEAL APPELLATE BRIEFS DAVIS WRIGHT TREMAINE LIP Robert D. Balin John M.

iction for Sex Crimes and Designation as a Level Three Sex Offender 3 B. Media Interest in New York and Florida Prosecutors' Lenient Handling of Epstein's Case 5 C. The Post's Efforts to Obtain the Appellate Briefing Filed with the First Department 8 ARGUMENT 9 I. THE POST HAS THE RIGHT TO M

had never spoken to the federal investigators in Florida who had reached the conclusion that Epstein was a serial abuser of underage girls. Id Ex. C. Epstein subsequently commenced this Appeal, seeking to overturn the trial court's ruling that he is a level three sex offender. The appellate briefs submitt

Index No. 30129/10 - against - (Pickholz, J.) JEFFREY E. EPSTEIN, Defendant-Appellant. : x MEMORANDUM

Index No. 30129/10 - against - (Pickholz, J.) JEFFREY E. EPSTEIN, Defendant-Appellant. : x MEMORANDUM O

008), available at https://nypost.com/2008/06/30/jeffrey-epstein-pleads-guilty-to-prostitution-chargest Mother se

n on the disclosure of the appellate briefs. Id. Mr. Epstein's lawyer stated that he would not take a positio

033-000039 EFTA00805353 FACTUAL BACKGROUND A. Epstein's Conviction for Sex Crimes and Designation as a Level Three Sex Offender In June 2008, a Florida Court sentenced Jeffrey Epstein to eighteen months in prison after he pleaded guilty to soliciting prostitution from a fourteen-year-old girl. Affirmation

3)(United States District Court, S.D. Fl.); v. Jeffrey Epstein (Case No. 502008CA028051XXXXMB AB)(Florida Circuit Court, 15th Judicial Circuit). v. Jeffrey Epstein (Case No. 502008CA028058XXXXMB ABXFlorida Circuit Court, 15th Judicial Circuit). 3. In December 2009, Epstein brought a vendetta action against me

itution in Florida. Subsequently, Bradley James Edwards, a Florida lawyer, brought civil actions on behalf of several girls alleging molestation by Epstein while they were minors. Jane Doe v. Jeffrey Epstein, (08- 80893)(United States District Court, S.D. Fl.); E v. Jeffrey Epstein (Case No. 502008CA

endant's alleged sexual abuse of her when she was a minor. The subpoenas seek the production of "(a)11 taped conversations between George Rush and Jeffrey Edward Epstein, including telephone recordings, all emails to and from Jeffrey Edward Epstein or someone representing themselves to be Jeffrey Epstein," and the t

n between George Rush, one of its reporters, and Jeffrey Epstein, and granting such other relief as the C

d civil legal proceedings in Florida relating to Mr. Epstein (Rush Aff., Apr. 6, 2010 [Carroll Decl., Apr. 7,

ourt, Southern District of New York. 2. The Court should issue the order for the production of the recording pursuant to CPLR 3102(e) because (i) a Florida Court has issued an order for the appointment of a Commissioner in New York to procure the tape; (ii) the tape's contents falls easily within the issues

ry appeals 2.00 1,500.00 05/09/18 SJL Work on Response to B. Edwards' Motion for 3.20 2,400.00 Rehearing; follow up on deposition schedule of J. Epstein; communications with D. Indyke and J. Epstein; work on trial strategies; work on Motion re V. Roberts' transcript 05/10/18 RJG Review 4th DCA Ord

Link & Rockenbach, PA 1555 Palm Beach Lakes Blvd. Suite 930 W • • • • 7 01 Jeffrey Epstein 6100 Red Hook Quarter, B3 St. Thomas, USV 00802 CLIENT: 0002 - Jeffrey Epstein Re: 0001 Bradley Edwards Date Services 05/01/18 TLC Work on M

,875.00 Requested Relief; meet with K. Rockenbach and R. Glasser re same; review hearing transcript, B. Edwards' Motion seeking permission to take J. Epstein's limited deposition and B. Edwards' proposed Order, work on edits to same; follow up with D. Indyke, M. Weinberg and J. Goldberger 05/26/18 SJL Co

Prepare Appendix to Response to B. Edwards' Motion for Rehearing Regarding Appellate Fees 05/14/18 SJL Work on Motion for Rehearing of Denial of Epstein's Motion for Appellate Attorneys' Fees and Costs and Response to Edwards' Motion for Rehearing Regarding Appellate Fees; review B. Edwards' "dama

Beach Lakes Blvd. Suite 930 W • • • • 7 01 Jeffrey Epstein 6100 Red Hook Quarter, B3 St. Thomas, U

ter 5/3/18 Hearing Attendance - Palm Beach Reporting Services, Inc. 05/04/18 Deposition transcripts 4/7/11 Phone Interview Recording - V. Giuffre - Florida Court Reporting 05/29/18 Miscellaneous Research and Transcript Comparison for Corrections - Florida Court Reporting 05/30/18 Transcript Fee 5/23/18 Copy

Continued) responded to also known as the I located the I located inside the foundation and informed her that I was inves igatin a case against Jeffrey Epstein and knew she had been at the house. started to cry and advised she had put that part of her life e in er. I explained that although she is sevent

I informed her that although she did not wish to speak with us, I had sufficient information at this point in the investigation to know she was at Epstein's house and provided girls to Epstein to work. I also explained that prior to our arrival at her residence I had telephone contact with her father

ormed her that I was inves igatin a case against Jeffrey Epstein and knew she had been at the house. sta

have prepared documents to charge at least one of Mr. Epstein's lady friends in state court. If they can push

15 https://secure.accurint.com/app/bps/report 8/2/2006 EFTA01693165 Law Enforcement Report Page 4 of 32 N( 7 cr-3 Possible Criminal Records: Florida Court: Name SSN: Aliases: State or DOB Sex: cum Offenses: Offense el Component 0001 Offense Date: 09/18,2001 Court Statute: POSSESSION OF A TOBA

alm Beach Mall. I located the Simon Youth Foundation. I located la inside the foundation and informed her that I was investigating a case against Jeffrey Epstein and knew she had been at the house. started to cry and advised she had put that part of her life in her. I explained that although she is sevente

I informed her that although she did not wish to speak with us, I had sufficient information at this point in the investigation to know she was at Epstein's house and provided girls to Epstein to work. I also explained that prior to our arrival at her residence I had telephone contact with her father,

rmed her that I was investigating a case against Jeffrey Epstein and knew she had been at the house. sta

have prepared documents to charge at least one of Mr. Epstein's lady friends in state court. If they can push

ucation: 15 https://secure.accurint.corn/app/bps/report 8/2/2006 EFTA01712202 Law Enforcement Report Page 4 of 32 §Possible Criminal Records: Florida Court: Name SSN: Aliases. State DOB Sex: n nown Offenses: Offense #1 Component: 0001 Offense Date: 09/18/2001 Court Statute: POSSESSION OF A TOB

7/2018 01:07:11 PM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and M., individually Defendant(s). EMERGENCY VERIFIED MOTION T

FLORIDA CASE NO: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHSTEIN, individually,

COUNTY, FLORIDA CASE NO: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHSTEIN, indivi

BY NON- FLORIDA LAWYERS IN A FLORIDA COURT RULE 1-3.10. APPEARANCE BY NON-FLORIDA LAWYER IN A FLORIDA COURT (a) Non-Florida Lawyer Appearing in a Florida Court. A practicing lawyer of another state, in good standing and currently eligible to practice, may, upon association of a member of The Florida Bar an

3/06 Time: 9:27:55 Incident Report PALM BEACH POLICE DEPARTMENT Page: 48 Program: CMS301L Case No • 1-05-000368 Continued) who were taken to Epstein s house to provide massages. further stated she had been to the house approximate) 4 or 5 times in iiiiiigt ear. She accompanied III!! with the 14-

iated her coming to the police station for questioning regarding an on going investigation. She was told that I was investigating a crime involving Jeffrey Epstein and knew, based on the investigation, that she had encounters with him in the past. During a sworn taped statement, stated she had met Epstein a

told that I was investigating a crime involving Jeffrey Epstein and knew, based on the investigation, th

Age: 32 Median Household Interne: $44,432 Median Owner Occupied Home Value: $61,300 Average Years of Educaron: 11 CP Possible Criminal Records: Florida Court Name: SSN: xxxaachAliases: State of er r brite COB: Race: MEXICAN Sex: Female Offenses: Offense 81 Case onm vi Component: Offense Date: A

16 years Miend advised back in 2003 200 for •ivin- this man massa 1-06-001078 (Continued) 1400 HRS, Detective end I at the Boynton Beach Ma Jeffrey Epstein when she was a said it was either in 2003 or 2004 of age when they met. she was sai e introduced to advised said rove er to a •tag ouse in t

the home, a thin white female answered the door. said she and athroom. e an was near with entere said there said Epstei said to massage Epstein's egs an• c est. o on the balcon which did. en went •ownstairs. said she believes a Jeffrey Epstein by her she could make told her said co

0 HRS, Detective end I at the Boynton Beach Ma Jeffrey Epstein when she was a said it was either in 200

FL 33440-8310. PALM BEACH COUNTY (Apr 2004 • Sep 2007) urren es ens at Address: Curren go ee at this address: g's S'Possible Criminal Records: Florida Court: Name: SSN: itiodxx-roac Aliases: State of • Sex: Maio Offenses: Offense N1 Component: 0301 Court Statute: NO/IMPROPER DRIVER LICENSEJEXP M

3753-0434. SULLIVAN COUNTY (Feb 1991 - Jun 2015) JEFFREY RD. GREENWICH. CT 06830. FAIRFIELD COUNTY (Sep 20

, 8, 9, 10, 15, and 17 EFTA_00258943 EFTA01338334 11112/21.3:30 PM [None Found] 4- FAA AircraftsO [None Found] IPPossible Criminal Records:GI Florida Court: Name: AMBER B KREMBS LexID: 003842164142 SSN: 589-86-3873 Address: 7477 RIVERWALK CIR. WEST PALM BEACH. FL 33411-5741 State of Origin: Florida

1/01/1951 and 12/31/1952 y.sawcc-xxx< ssn in EW JE etw 01/01/1951 and 12/31/1952 DOB: Age: 72 DO

e Age: 24 Median Household Income: $34.449 Medan Owner Occupied Home Value: $88,300 Average Years of Education: 9 lit Possible Criminal Records: Florida Court: Name: https://secure.accurint.com/app/bps/report 7/11/2007 EFTA01693410 • Law Enforcement Report Page 6 of 26 SSN: xn-xx- Abases: Stot a