Epstein Secrets

04/24/2007 BUSINESS INFORMATION Company Names J EPSTEIN FOUNDATION Address: 457 MADISON AVE NEW YORK,

25 Memorandum in opposition to plaintiffs motion for judgment on the pleadings as to count one - breach of contract, Certificate of service filed by JEFFREY E. EPSTEIN. (ph, ) Additional attachment(s) added on 9/4/2003 (ph, ). (Entered: 08/28/2003) 08/28/2003 26 Reply to EPSTEIN'S memorandum in opposition to plai

FREY A. SLOMOWITZ I. EPSTEIN, et al 33 EPSTEIN, JEFFREY E. Kelleher'. ADVO, Inc et al 34 EPSTEIN, JEFFREY

EFFREY LYDIA CAVAZOS PLASENCIA 3 EPSTEIN, JEFFREY YVONNE ROBLES CATHERINE 4 EPSTEIN, JEFFREY FRANCIS OLUSEGUN TIFASE 5 EPSTEIN, JEFFREY JAYSON LEE EPSTEIN 6 EPSTEIN, JEFFREY ERIC THOMAS 7 EPSTEIN, JEFFREY DONALD J REED AND SALLY A 8 EPSTEIN, JEFFREY ROSEMARY ELFIEDE BODEY PEREZ 9 EPSTEIN, JEFFREY

STEIN 22 EPSTEIN, JEFFREY CHARLES EDWARD NELSON 23 EPSTEIN, JEFFREY D JEFFREY D EPSTEIN 24 EPSTEIN, JEFFREY H. G. WARE TRAVELSTEAD 25 EPSTEIN, JEFFREY M. mdbkc 93-00207 05/05/1993 KAYE SCHOLER FIERMAN HAYS & HANDLER AND HAINLINE 26 EPSTEIN, JEFFREY R. pacbkc 03-34969 10/09/2003 JEFFREY R. EPSTEIN

EPSTEIN, JEFFREY E. Kelleher'. ADVO, Inc et al 34 EPSTEIN, JEFFREY E. DVO Inc et al 35 EPSTEIN, JEFFREY E. Golden I. Harding et al 36 EPSTEIN, JEFFREY-E. Field'. Advo Inc et al cacbkc 03-23966 cacbke 03-23968 flsbke 01-30953 flsbke 91-33375 mnbke 06-40989 cacbkc 02-45716 ilnbke 03-51468 mdbke

307 05/22/1998 230 03/17/1999 SA Epstein, et al 43 EPSTE ,JEFFREY K. nyedce 04/26/2004 08/10/2005 .1:2004mc00106 Epstein, Esq. 44 EPSTEIN, JEFFREY KENT nyedce 1:2004mc00106 04/26/2004 . 08/10/2005 Epstein, Esq. 45 EPSTEIN, JEFFREY ilndce 1;1991cv01926 01/09/1992 190 01/30/1992 Van Schouwen I

pieze 4 fitel ttotlittli Case No. 08-80736-CV-MARRA 4mq ORMli UW040)0704 EFTA00228084 relevant times, a principal and an offiper.of Defendant, J. Epstein and Company, :Inc, (collectively `Epstein"), which, at all relevant times, had its. principal piece of business at The villard House, 457 MadisOn A

tender of which was accepted by Epstein and/or the Wexners at Shanks' studio in Andalusia, Bucks County, Pennsylvania. 37. The subsequent attempts:Sy Epstein and/or the Wexners to reject the painting were based%on purely subjective grounds. 38. Subjective approval of the painting by the Wexner°, Maxwell

INDEX PURCHASE DATE: 08/29/1995; RJI PURCHASE FEE: YES; RJI PURCHASE DATE: 08/29/1995 PARTICIPANT INFORMATION J EPSTEIN i COMPANY INC PLAINTIFF EPSTEIN JEFFREY PLAINTIFF Names 457 MADISON AVENUE CORP 2007 Thomson/West. No Claim to Orig. U.S. Govt. Works. 7.00102 1 7 haps://web2.westlaw.com/print/princi

o Dade County, et al 30 EPSTEIN, JEFFREY codce Pierce Segerberg PC, et all. Epstein 31 EPSTEIN, JEFFREY Pierce Segerberg PC, et all. Epstein 32 EPSTEM, JEFFREY A. SLOMOWITZ I. EPSTEIN, et al 33 EPSTEIN, JEFFREY E. Kelleher'. ADVO, Inc et al 34 EPSTEIN, JEFFREY E. DVO Inc et al 35 EPSTEIN, JEFF

10/02/2002 195 10/21/2003 S WEXNER et al 40 EPSTEIN, JEFF nysdce 1:199.fici08307 05/22/1998 230 03/17/1999 USA Epstein, et al 41 EPSTEIN, JEFFRE nysdce 11996cv08307 05/22/1998 230 03/17/1999 USA Epstein, et al 42 EPSTEIN, JEFFREY nysdce 11996cv08307 05/22/1998 230 03/17/1999 SA Epst

PIES MAILED (ph, ) (Entered: 02/10/2003) 02/14/2003 6 REPLY filed by NELSON SHANKS to Defendant's Motion to Dismiss pursuant to F.R.C.P. 12(bX2), Certificate of Service. (rv, ) (Entered: 02/18/2003) 02/27/2003 7 REPLY to Plaintiff's Response to Defendants' Motion to Dismiss filed by JEFFREY E. EPSTEIN, GHISLAINE M

econd amended complaint (the "Fisher counterclaim"), is granted in all respects. The Soffer ejectment motion is granted as against deft Ron Soffer. Defls Jeffrey E. Epstein, Ivan S. Fisher, Ellyn Bank, Debra Elisa Cohen, Dianeataga?/a The Fisher Group, Fisher & Soffer a/k/a Fisher & Sophir, D. Gerzog, Robert Heilbum,

the house to the tenant we have selected should Mr. Epstein decide not to reoccupy the premises under the ne

on of the budding pursuant to the Foreign Missions Act, 22 U.S.C. § 4301 of seq. 0FM leased the building to defen- dant Jeffrey E. Epstein in 1992. Epstein sublet the building to defendant Ivan S. Fish- er in 1996, purportedly without the Govern- ment's consent. Fisher, in turn, sublet a portion of the

n personally liable because Epstein did not sign the con- tract as an agent or as a corporate officer. Epstein signed the contract as follows: /s/ Jeffery Epstein 1AG. Under New York law, a signature in a representative capacity would have been "Jeffrey Epstein for I.A.G." or "I.A.G., by Jeffrey Epstein". 2

atters extrinsic to the complaint. we will treat defendant Epstein's motion to dismiss as a motion for summary judg

RDERED. UNITED STATES of America, Plaintiff, I Jeffrey E. EPSTEIN, Ivan S. Fisher, Ellyn Bank, Debra Elis

RDERED. UNITED STATES of America, Plaintiff, I Jeffrey E. EPSTEIN, Ivan S. Fisher, Ellyn Bank, Debra Elise

PIES MAILED (ph, ) (Entered: 02/10/2003) 02/14/2003 6 REPLY filed by NELSON SHANKS to Defendant's Motion to Dismiss pursuant to F.R.C.P. 12(b)(2), Certificate of Service. (rv, ) (Entered: 02/18/2003) 02/27/2003 7 REPLY to Plaintiffs Response to Defendants' Motion to Dismiss filed by JEFFREY E. EPSTEIN, GHISLAINE M

rtedly between Ms. Maxwell and third-party "influential" men whom she allegedly tried to set up on dates, and (b) a witness a woman who worked for Epstein between 2005-06 (after the conclusion of the charged conspiracy) whom the Government said it "may call" at trial. The Government asserted in the Le

ified] documentary evidence relating to the 4 EFTA00105960 charged crimes [and (ii)] her [unspecified] role in scheduling sexualized massages for Jeffrey Epstein with underage girls," apparently in 2005-06. This is hardly the type of "identiff ied]" evidence the Rule contemplates. What "documentary evidence"

RE TO COMPLY WITH THE RULE'S NOTICE REQUIREMENT Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

e Letter makes clear that the witness worked for Mr. Epstein from 2005-06, after the conclusion of the charged

C. Stemheim Law Offices of Bobbi C. Stemheim 225 Broadway, Suite 715 New York, NY 10007 Phone Attorneys for Ghislaine Maxwell 8 EFTA00105964 Certificate of Service I hereby certify that on October 18, 2021, I electronically filed the foregoing Ghislaine Maxwell's Motion to Exclude Any Evidence Offered by the G

ir. 1996) 2 Young v. United States, 481 U.S. 787 (1987) 24 Other Authorities Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016, New York Daily News (Oct. 13, 2020) 11 U.S. Dept. of Justice, JUSTICE MANUAL, JM § 9-11.151 15 Rules Fed.

al abuse and trafficking by Jeffrey Epstein and Maxwell. Ex. J, pp 1-3. • At the meeting, attorneys told AUSA the following: o That Maxwell was Epstein's "head recruiter" of underage victims. Id. at 2. o That =vas underage when she was brought to New York "for training by Maxwell and Epstein [in]

OLES SCHILLER AND TO DISMISS COUNTS FIVE AND SIX Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

m Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone: Attorneys for Ghislaine Maxwell 28 EFTA00077603 Certificate of Service I hereby certify that on March 15, 2021, I served by email, pursuant Rule 2(B) of the Court's individual practices in criminal cases, the Reply Mem

The Perjury Counts allegedly occurred 22 years after the Mann Act Counts, during a defamation action concerning not whether Accuser-1 had sex with Jeffrey Epstein or Accusers-2 or 3 got a "massage," but whether the fantastical statements made by in 2015 were "obvious lies." Those wild, now known to be false,

cked to famous people and her purported four years as a sex slave. None of the Accusers in the Indictment claim to have been sexually trafficked by Epstein or Ms. Maxwell to anyone, let alone any famous people. And the defamation case had nothing to do with any allegations by Ms. of being enticed to t

OUNTS FIVE AND SIX OF THE SUPERSEDING INDICTMENT Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

an R. Everdell COHEN & GRESSER LLP Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim Phone: Attorneys for Ghislaine Maxwell 12 EFTA00097327 Certificate of Service I hereby certify that on March 15, 2021, I served by email, pursuant Rule 2(B) of the Court's individual practices in criminal cases, the Reply Mem

12 WL 5395249 (S.D.N.Y. Nov. 5, 2012) 2 iii EFTA00097651 Other Authorities Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016, New York Daily News (Oct. 13, 2020) 11 Rules Fed. R. Civ. P. 24(b) 4 Fed. R. Civ. P. 26(c) 13 Fed. R. Cr

is this: The defamation case should have been extremely narrow, but Boies Schiller transformed it into something much broader—a proxy prosecution of Epstein and Maxwell for allegedly trafficking and abusing which then compelled Maxwell, over objection, to answer irrelevant and highly prejudicial person

LES SCHILLER AND TO DISMISS COUNTS FIVE AND SIX Jeffrey S. Pagliuca Laura A. Mennin • er Christian R. E

hristian R. Everdell COHEN & GRESSER LLP Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim Attorneys for Ghislaine Maxwell 14 EFTA00097667 Certificate of Service I hereby certify that on March 15, 2021, I served by email, pursuant Rule 2(B) of the Court's individual practices in criminal cases, the Reply Mem

lose my abuse until I was in high school," he said. Juror No. 50 also had an excuse for why the alleged victims in this case kept going back to Mr. Epstein and Ms. Maxwell and accepting help from them even after they had been abused. The alleged victims' conduct, explained Juror No. 50, was irrelevant t

JN) GIIISLAINE MAXWE 'S MOTION FOR A NEW TRIAL Jeffrey S. Pagliuca Laura A. Menninger HADDON. M R AN &

alleged victims in this case kept going back to Mr. Epstein and Ms. Maxwell and accepting help from them even

MORGAN & FOREMAN P.C. Christian R. Everdell COHEN & GRESSER LLP Bobbi C. Sternheim Sternheim Attorneys for Ghislain Maxwell 58 EFTA00155965 Certificate of Service I hereby certify that on January 19, 2022, I electronically filed the foregoing Ohislaine Maxwell's Motion for a New Trial, with the Court and coun