Epstein Secrets

ter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION TO STRIKE DEFENDANT/COUNTER-PLAINTIFF'S DAMAGES EXPERT WITNESS, DR. BERNARD JANSEN. AND TO EXCLUDE HIS TESTIMONY Plaintiff/Counter-Defendan

FENDANT/COUNTER-PLAINTIFF'S DAMAGES EXPERT WITNESS, DR. BERNARD JANSEN. AND TO EXCLUDE HIS TESTIMONY Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"), moves to strike the expert witness and to exclude the admission of any testimony from Defendant/Counter-Plaintiff, Bradley J. Edwards' ("Edwards

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

which he believes was "successful in discrediting Mr. Epstein's charges." (Jansen's 12/1/17 Tr. 62.) (Ex. E.)

ies of Mr. Scott Rothstein as a result of Mr. Jef•ey Epstein's lawsuit against Mr. Edwards have been dissemin

se, and 'certain kinds of damage necessarily follow from the wrongful prosecution itself, and so will be assumed by the law to exist ... .'; citing Tidwell v. Witherspoon, 21 Fla. 359, 361 (Fla. 1885) ("'An accusation of crime under the forms of the law or a pretense of bringing a guilty man to justice

ns Why She's Suing FBI After Agency Ignored Her Claims for 10 Years The Washington Examiner (07/25, Notheis) reported that Maria Farmer, a victim of Jeffrey Epstein who is suing the FBI, explained on Monday that she is suing the agency for ignoring her case for a decade. The article added that Farmer, who was E

n who is suing the FBI, explained on Monday that she is suing the agency for ignoring her case for a decade. The article added that Farmer, who was Epstein's first victim to go to the authorities regarding the sex offender, is one of two plaintiffs who are suing the FBI over the agency's failure to inve

ump's attempts to replace acting attorney general Jeffrey Rosen with Jeffrey Clark, a Justice Department l

inmate, identified only as "Individual 1" in court documents, in 2018 directed a close friend and business associate to wire $25,000 to a member of Tidwell's family, prosecutors said. Starting in 2019, Tidwell and the wealthy inmate entered into a property management agreement that resulted in $65,000 i

iolation of official duties, making false statements to a bank, and identity theft, the U.S. attorney in Boston said Monday. The article stated that Tidwell has worked for the Bureau of Prisons since 2000 and since 2008 has been at the Federal Medical Center-Devens. As a counselor, his duties included wo

S DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA GRAND JURY MATTER FILED UNDER SEAL IN RE GRAND JURY SUBPOENAS ) DUCES TECUM IS D TO ) MOTION OF JEFFREY EPSTEIN TO INTERVENE AND TO QUASH GRAND JURY SUBPOENAS AND INCORPORATED MEMORANDUM OF LAW Now comes Jeffrey Epstein and respectfully moves this Honorable

Mr. Jeffrey Epstein, including, but not ling to, retainer agreements; employment agreements; billing statements (whether submitted directly to Mr. Epstein or to a third party for reimbursement); records of the dates when services were performed and the hours worked; ••••••r telephone logs or records

Y SUBPOENAS ) DUCES TECUM IS D TO ) MOTION OF JEFFREY EPSTEIN TO INTERVENE AND TO QUASH GRAND JURY SUB

illing statements (whether submitted directly to Mr. Epstein or to a third party for reimbursement); records

dequately by the existing parties to the suit. Sierra Club v. Leavitt, 2007 WL 1649987 at *3 (11th Cir. June 8, 2007), quoting ManaSota-88, Inc. v. Tidwell, 896 F.2d 1318, 1321 (11.111 Cir. 1990). As detailed below, all font requirements are amply met here. First, the application is timely, as it is be

eement of the parties. that appearance was rescheduled for July 17, 2007. The day before that scheduled appearance, i.e.. July 16. 2007. counsel for Jeffrey Epstein, who seeks to intervene in this matter, was informed by Deputy Chief that Riley did not have to appear physically before the grand jury if a motio

nformed by Deputy Chief that Riley did not have to appear physically before the grand jury if a motion to quash the subpoena at issue was filed by Epstein before the end of the day on July 17. 2007. As the Government's Response states. Epstein's motion to quash was filed on July 17, 2007 before the clo

he Response of the United States to the Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Sub

d jury subpoenas to investigator and his firm, Mr. Epstein is represented by undersigned counsel Roy Black.

dequately by the existing parties to the suit. Sierra Club v. Leavitt, 2007 WL 1649987 at *3 (11th Cir. June 8, 2007), quoting ManaSota-88, Inc. v. Tidwell, 896 F.2d 1318, 1321 (11th Cir. 1990). As detailed below, all four requirements are amply met here. First, the application is timely, as it is bein

4. A CNN.com - Sandy Berger to plead guilty on documents charge - Apr I, 2005 (http://edition.am.com/2005/LAW/04/01/berger.plea0 15. na b Smith, is Jeffrey, Berger Case Still Roils Archives, Justice Dept., Washington Post, February 21, 2007 (http://www.washingtonpost.cotn/svp-dyn/content/article/2007/02

§ 2252 , which does not require that the named defendant be involved in any way in the production of e visual depiction. See 0I United States Tidwell, No. 89-5880, 1990 WL 17 2, '2 (6th Cir. Nov.6, 1990) (unpublished disposition) (discussing differences between §§ 2251 and 2252 for double je