Epstein Secrets

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK JANE DOE 43, Plaintiff, VS. JEFFREY EPSTEIN, GHISLAINE MAXWELL, AND Defendants. CASE NO. 17 Civ 616 (JGK) MEMORANDUM OF LAW IN SUPPORT OF MOTION TO DISMISS EFTA00307096 ARGUMENT 1 A.

er Defendants 21 F. Venue Is Improperly Laid in the Southern District of New York 22 CONCLUSION 22 EFTA00307097 Defendants Jeffrey Epstein ("Epstein") and (a") (collectively "Defendants") submit this memorandum in support of their motion to dismiss the First Amended Complaint ("FAC") filed by

th substance and cited sources. See FAC at ¶11 ("Defendant Epstein is widely recognized..."), ¶22 ("Defendants Epst

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

rgin Islands. Dated: July 2017 Respectfully submitted, STEPTOE & JOHNSON, LLP By /s/ Michael Miller Justin Y.K. Chu Attorneys for Defendants JEFFREY EPSTEIN & To: FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. Brad Edwards Attorney for Plaintiff Jane Doe 43 ALSTON & BIRD, LLP Alexander S L

ns of fraud boil down to this: Epstein allegedly "confirmed to Plaintiff that he would use his wealth and influence to have Plaintiff admitted into the Fashion Institute of Technology" ("E") and to advanced her career, but had no intention of doing so. FAC ¶¶ 38, 53, 58-64. This is insufficient to satisfy Rule 9(b). First, the F

ss you from the podium there? THE COURT: Sure. MR. MILLER: Michael Miller from Steptoe & Johnson, and as I indicated we are here on behalf of and Jeffery Epstein, and Your Honor, we respectfully submit that the amended complaint before you is legally deficient and should be dismissed for several reasons, t

MILLER: Good afternoon, your Honor. Michael Miller and Justin Chu from the law firm of Steptoe & Johnson, and Darren Indyke, who is counsel to Mr. Epstein. We represent Jeffery Epstein and , and yesterday filed a substitution of counsel with respect to , whose previously existing counsel is also he

rdered by the defendant Maxwell to have sex with defendant Epstein. Defendants Maxwell, and Epstein each fraudulen

& Johnson, and Darren Indyke, who is counsel to Mr. Epstein. We represent Jeffery Epstein and , and yesterd

again that her sexual compliance would be SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00285645 16 I877DOEC rewarded with admission to the Fashion Institute of Technology or a comparable college, a promise which they knew to be false." 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

.S.C. § 1595 3, 4 Other Authorities Fed. R. Civ. P. 24 2, 9, 10 CONFIDENTIAL - FILED UNDER SEAL EFTA00805391 Third-Party Proposed Intervenors Jeffrey Epstein and Lesley Groff (the "Intervenors") respectfully submit this Memorandum of Law in support of their motion to intervene in v. Maxwell, No. 15 Civ.

tective Order") for the reasons set forth below. PRELIMINARY STATEMENT Intervenors are two of the defendants in an action captioned Jane Doe 43 v. Epstein, et al, No. 17 Civ. 616 (JGK), currently pending before Judge John G. Koeltl (the "Jane Doe Matter"). Jane Doe 43 ("Plaintiff" or "Jane Doe") filed

EFTA00805391 Third-Party Proposed Intervenors Jeffrey Epstein and Lesley Groff (the "Intervenors") res

are based primarily on the alleged misconduct of Mr. Epstein. Indeed, shortly after Jane Doe filed her suit ag

extravagant New York lifestyle, including a "massive" Upper East Side apartment, he failed to fulfill his alleged promise to "have her admitted" to the Fashion Institute of Technology ("FIT"). More than ten years later, based on these events, Jane Doe filed the original Complaint (and now the FAC) in which, astonishingly, she cla

CONTINUATION OF OFF THE RECORD 1. Jeffrey Epstein and Alan Dershowitz have been friends for years. The two met in July, 1996, when Mr. Epstein was introduced to Mr. Dershowitz by a mutual friend and

CONTINUATION OF OFF THE RECORD 1. Jeffrey Epstein and Alan Dershowitz have been friends for years. The two met in July, 1996, when Mr. Epstein was introduced to Mr. Dershowitz by a mutual friend and flew on his private jet to Martha's Vineyard to spend the day with Mr. Dershowitz. 2. Mr. E

iends for years. The two met in July, 1996, when Mr. Epstein was introduced to Mr. Dershowitz by a mutual frie

CONTINUATION OF OFF THE RECORD 1. Jeffrey Epstein and Alan Dershowitz have been friends for

y to his island, which she did several times in late 2006 and early 2007. Mr. Epstein and Ms. Maxwell told they could help arrange her admission at the Fashion Institute of Technology, where she dreamed of studying. 50. was told that if she refused to have sex with Mr. Epstein and his associates, her apartment would be taken aw

CONTINUATION OF OFF THE RECORD 1. Jeffrey Epstein and Alan Dershowitz have been friends for years. The two met in July, 1996, when Mr. Epstein was introduced to Mr. Dershowitz by a mutual friend and flew on his private jet to Martha's Vineyard to spend the day with Mr. Dershowitz. LYNN FOR

CONTINUATION OF OFF THE RECORD 1. Jeffrey Epstein and Alan Dershowitz have been friends for years. The two met in July, 1996, when Mr. Epstein was introduced to Mr. Dershowitz by a mutual friend and

iends for years. The two met in July, 1996, when Mr. Epstein was introduced to Mr. Dershowitz by a mutual frie

CONTINUATION OF OFF THE RECORD 1. Jeffrey Epstein and Alan Dershowitz have been friends for

y to his island, which she did several times in late 2006 and early 2007. Mr. Epstein and Ms. Maxwell told they could help arrange her admission at the Fashion Institute of Technology, where she dreamed of studying. 50. was told that if she refused to have sex with Mr. Epstein and his associates, her apartment would be taken aw

ds, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Re: Jane Doe 43 v. Jeffery Epstein, et al. Civil Action No. 17-cv-616 Dear Brad: In accordance with the procedures directed by the Court at the initial case manar. conference in th

ordance with the procedures directed by the Court at the initial case manar. conference in the above-referenced matter, defendants Jeffrey Epstein ("Epstein") and ("=") (collectively "Defendants") set forth in this letter the pursuant to which the Complaint filed by plaintiff ("Plaintiff" or a") sho

addition to their requiring Plaintiff to provide Defendant Epstein with sex acts, Defendants continued to pressure h

erence in the above-referenced matter, defendants Jeffrey Epstein ("Epstein") and ("=") (collectively "De

ns of fraud boil down to this: Epstein allegedly "confirmed to Plaintiff that he would use his wealth and influence to have Plaintiff admitted into the Fashion Institute of Technology" ("E"), but had no intention of doing so. Cplt. ¶¶ 37, 50, 53-55. This is insufficient to satisfy Rule 9(b). First, the Complaint fails to identify

itional information concerning possible victim of Jeffrey Epstein & Ghislaine Maxwell in New York, NY. Stein prov

Time, Cell telephone number called the FBI National Threat Operations Center (NTOC) to report additional information concerning possible victim of Jeffrey Epstein & Ghislaine Maxwell in New York, NY. Stein provided the following information: Stein was a victim of Jeffrey Epstein & Ghislaine Maxwell, in NY in t

ICIAL RECORD Intake (Rev. 5-23-17) UNCLASSIFIED FEDERAL BUREAU OF INVESTIGATION Intake Date: 09/23/2021 Case ID #: 50D-NY-3027571 (U) EPSTEIN, JEFFREY; CHILD SEX TRAFFICKING Drafted By: ALKIRE BETHANY Date/Time Received: 09/23/2021 09:58 AM EDT Details: On 9/23/2021, at 9:58 AM Eastern Time, C

NY. Stein provided the following information: Stein was a victim of Jeffrey Epstein & Ghislaine Maxwell, in NY in the mid 1990s. met Maxwell and Epstein in approximately 1994. was a student at the Fashion Institute of Technology at NYC.= also worked at Henri Bendel at 5th Avenue, which was/is owned

Stein was a victim of Jeffrey Epstein & Ghislaine Maxwell, in NY in the mid 1990s. met Maxwell and Epstein in approximately 1994. was a student at the Fashion Institute of Technology at NYC.= also worked at Henri Bendel at 5th Avenue, which was/is owned by the CEO of The Limited at the time. Stein met Maxwell as a client working

8 (Directed to All Defendants) All documents relating to your travel from the period of 2000 — present, including but not limited to, any travel on Jeffrey Epstein's planes, commercial flights, helicopters, and records indicating passengers traveling with you, hotel records, and credit card receipts. DOCUMENT RE

Plaintiff, v. No. 17 Civ. 00616 (JGK) JEFFREY EPSTEIN, GHISLAINE MAXWELL, LESLEY GROW and Defendants.

EW YORK Plaintiff, v. No. 17 Civ. 00616 (JGK) JEFFREY EPSTEIN, GHISLAINE MAXWELL, LESLEY GROW and Def

All Defendants) All documents evidencing money paid to at any time. DOCUMENT REQUEST NO. 6 (Directed to All Defendants) All documents relating to the Fashion Institute of Technology ("F.I.T."). 7 EFTA00793331 DOCUMENT REQUEST NO. 7 (Directed to All Defendants) All communications with F.I.T. related in any way to DOCUMENT RE