Epstein Secrets

t within his law firm and his client, that being Mr. Epstein. When further asked by the court, has Mr. Epstein

-RBR Doc 6482 Filed 10/19/18 Page 4 of 97 COURT: I disagree with you. .... Take that up in your state court litigation. (Apr. Tr. 43:19-45:6.) B. Epstein has Provided Sworn Testimony and His Attendance at the Show Cause Hearing is Not Necessary. The Court allowed Movants to take Epstein's deposition

bove cause, testified on his oath as follows: THE WITNESS: Yes. DIRECT EXAMINATION BY MR. SCAROLA: Q Would you please state your full name? A Jeffrey E. Epstein. Q Would you list for us, please, each of your residence addresses? MR. GOLDBERGER: I think it's beyond the scope. I'm going to object to Fifth

ief Expedited Hearing Requested on or before October 24, 2018, so that the Court may rule prior to the October 26, 2018, hearing) Jeffrey Epstein ("Epstein") moves the Court, on an expedited basis, to be excused from attending the October 26, 2018, show cause hearing, and states: INTRODUCTION On April

n the United States Virgin Islands, August /‘(2018. I declare under penalty of perjury that the foregoing is true and correct. APPROV FORM: RNEY REY EPSTEIN EFTA00793497

A: Q Would you please state your full name? A Jeffrey E. Epstein. Q Would you list for us, please, each

A: Q Would you please state your full name? A Jeffrey E. Epstein. Q Would you list for us, please, each

r LLC °tense or anner a e, ersstng, cards, Fistos & Lehrman, P.L. Paul G. Cassell S.J. Quinney College of Law at the Utah University of Doe Peter E. Shapiro Shapiro Law uite 3000 ounse or ., . . an ane Doe Counsel for L.M., E.W. and Jane Niall T. McLachlan Carlton Fields Jorden Burt P.A. 200 °ri

court litigation. 2The April 13, 2018, hearing transcript (D.E. 6367) shall be referred to as "Apr. Tr." 3 EFTA00794240 (Apr. Tr. 43:19-45:6.) B. Epstein has Provided Sworn Testimony and His Attendance at the Show Cause Hearing is Not Necessary. The Court allowed Movants to take Epstein's deposition

T OF FLORIDA FORT LAUDERDALE DIVISION www.flsb.uscourts.gov IN RE: ROTHSTEIN ROSENFELDT ADLER, P.A., Debtor. CASE NO. 09-34791-RBR CHAPTER 11 JEFFREY EPSTEIN'S EXPEDITED MOTION TO BE EXCUSED FROM ATTENDING SHOW CAUSE HEARING Jeffrey Epstein ("Epstein") moves the Court, on an expedited basis, to be excused

, Debtor. CASE NO. 09-34791-RBR CHAPTER 11 JEFFREY EPSTEIN'S EXPEDITED MOTION TO BE EXCUSED FROM ATTENDING SHOW CAUSE HEARING Jeffrey Epstein ("Epstein") moves the Court, on an expedited basis, to be excused from attending the October 26, 20181 show cause hearing, and states: INTRODUCTION On April

.A., Debtor. CASE NO. 09-34791-RBR CHAPTER 11 JEFFREY EPSTEIN'S EXPEDITED MOTION TO BE EXCUSED FROM AT

t within his law firm and his client, that being Mr. Epstein. When further asked by the court, has Mr. Epstein

eissing, Edwards, Fistos & Lehrman, P.L. Paul G. Cassell S.J. Quinney College of Law at the University of h Counsel for L.M., E.W. and Jane Doe Peter E. Shapiro Sha.iro Law Counsel for L.M., E.W. and Jane Doe Niall T. McLachlan Carlton Fields Jorden Burt, P.A. Isaac M. Marcushamer Berger Singerman LLP

bove cause, testified on his oath as follows: THE WITNESS: Yes. DIRECT EXAMINATION BY MR. SCAROLA: Q Would you please state your full name? A Jeffrey E. Epstein. Q Would you list for us, please, each of your residence addresses? MR. GOLDBERGER: I think it's beyond the scope. I'm going to object to Fifth

wed to intervene in this action, now respectfully submits this Motion to Compel Jeffrey Epstein to Provide Answers to Deposition Questions. Because Epstein has improperly refused to answer multiple questions at his recent deposition, the motion should be granted. Relevant Factual Background The facts

A: Q Would you please state your full name? A Jeffrey E. Epstein. Q Would you list for us, please, each

A: Q Would you please state your full name? A Jeffrey E. Epstein. Q Would you list for us, please, each

he Agreed Order." DE 6366 at 5 (citing DE 1194). Mr. Epstein improperly refused to answer many questions about

in compliance with the additional qualifications to practice in this court set forth in Local Rule 2090-1(A). SHAPIRO LAW By: /s/ Peter E. ha it Peter E. Shapiro (FBN Attorneys for Intervenors L.M., E.W., and Jane Doe 10 EFTA00793508 Case 09-34791-RBR Doc 6488 Filed 10/22/18 Page 11 of 165 Attorneys f

to anyone else. The Agreed Order Cancelling Hearing provides, in its entirety: The Motion for Relief From Amended Order (D.E. #1068) and to Compel Jeffrey Epstein to Pay for the Production of All Documents in Response to his Requests filed by Interested Party Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman,

ions" (id. at p. 17) or a finding of criminal contempt "as may be appropriate" and monetary sanctions of $25,000 for each of the intervenors against Epstein for any noncompliance with the order at issue, for which amounts "Epstein [be] permitted to seek reimbursement from any of his attorneys who may ha

E OF AN ORDER TO SHOW CAUSE WHY FOWLER WHITE AND JEFFREY EPSTEIN SHOULD NOT BE HELD IN CONTEMPT OF COURT,

in its files, having provided all hard files to Mr. Epstein's current counsel, Scott Link. Movants' Motions

Pugatch, Esq. Bradley J. Edwards Brittany N. Henderson Edwards Pottin er LLC Counsel for Fanner Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L Peter E. Shapiro Shapiro Law Counsel for LM., E.W. and Jane Doe Isaac M. Marcushamer Berger Sin erman LLP /s/ Niall T. McLachlan Niall T. McLachlan, Esq. 11442

gov IN RE: ROTHSTEIN ROSENFELDT ADLER, P.A., Debtor. CASE NO.: 09-34791-RBR CHAPTER 11 INTERVENOR-VICTIM L.M.'S WITHDRAWAL OF MOTION TO COMPEL JEFFREY EPSTEIN TO PROVIDE ANSWERS TO DEPOSITION QUESTIONS Intervenor L.M., proceeding pseudonymously, having previously been allowed to intervene in this action,

IM L.M.'S WITHDRAWAL OF MOTION TO COMPEL JEFFREY EPSTEIN TO PROVIDE ANSWERS TO DEPOSITION QUESTIONS Inter

NOR-VICTIM L.M.'S WITHDRAWAL OF MOTION TO COMPEL JEFFREY EPSTEIN TO PROVIDE ANSWERS TO DEPOSITION QUESTION

Florida and I am in compliance with the additional qualifications to practice in this court set forth in Local Rule 2090-1(A). SHAPIRO LAW By: /s/ Peter E. Shapiro Peter E. Shapiro (FBN [email protected] Attorneys for Intervenors E.W., and Jane Doe 2 EFTA00793665 Case 09-34791-RBR Doc 6495 File

T OF FLORIDA FORT LAUDERDALE DIVISION www.flsb.uscourts.gov IN RE: ROTHSTEIN ROSENFELDT ADLER, P.A., Debtor. CASE NO. 09-34791-RBR CHAPTER 11 JEFFREY EPSTEIN'S EXPEDITED MOTION IN LIMINE TO ENFORCE COURT'S RULING AND TO STRIKE IRRELEVANT. SCANDALOUS AND IMPERTINENT DEPOSITION OUESTIONS AND FOR ATTORNEYS' F

ief Expedited Hearing Requested on or before October 24, 2018, so that the Court may rule prior to the October 26, 2018, hearing) Jeffrey Epstein ("Epstein") moves this Court in limine to enforce this Court's ruling at the upcoming October 26, 2018, evidentiary hearing, and to strike irrelevant, scandal

.A., Debtor. CASE NO. 09-34791-RBR CHAPTER 11 JEFFREY EPSTEIN'S EXPEDITED MOTION IN LIMINE TO ENFORCE C

sing, Edwards, Fistos & Lehrman, P.L. Paul G. Cassell S.J. Quinney College of Law at the University of Utah Counsel for L.M., E.W. and Jane Doe Peter E. Shapiro Counsel for L.M., E.W. and Jane Doe Niall T. McLachlan Carlton Fields Jorden Burt, P.A. Isaac M. Marcushamer Counsel for Fowler White Burnett, P

issing Edwards Fistos & Lehrman, Bradley J. Edwards and Intervenors L.M., E.W. and Jane Doe, voluntarily dismiss their Motions for Contempt against Jeffrey Epstein with prejudice and all causes of action which have or could have been asserted in this action and all claims for all forms of damages, including co

compensatory damages, sanctions, punitive damages, prejudgment interest, costs and attorneys' fees. Farmer Jaffe, Edwards, L.M., E.W., Jane Doe and Epstein will each bear their own attorneys' fees and costs. Dated: , 2018. Respectfully submitted, EDWARDS POTTINGER LLC Bradley J. Edwards FLBN Britt

arily dismiss their Motions for Contempt against Jeffrey Epstein with prejudice and all causes of action

25 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301-3268 Counsel for Farmer Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. Paul G. Cassell Peter E. Shapiro S.J. Quinney College of Law at the University of Shapiro Law Utah 332 S. University St. 8551 West Sunrise Boulevard, Suite 3000 Plantation, FL

of the requested relief they are seeking in this case. The Victims now file that list. The victims seek the following relief: I. Fowler White and Epstein (including all of Epstein's past and present legal counsel) will provide to the Victims' counsel, within seven days of the Court's order, a listing

buted, as well as a certification that they have asked for return of the subject materials. 2. A letter written and signed by both Fowler White and Jeffrey Epstein, and sent to all persons known or suspected to have reviewed or obtained any copies of the documents at issue, to the following effect: "To Whom It

etter written and signed by both Fowler White and Jeffrey Epstein, and sent to all persons known or suspec

et forth in Local Rule 2090-1(A). SHAPIRO LAW 8551 West Sunrise Boulevard Suite 300 Plantation, Florida 33322 Telephone: (954) 315-1157 By: Is/ Peter E. Shapiro Peter E. Shapiro (FBN 615551) pshapiro @shapirolawpa.com Attorneys for Intervenors L.M., E.W., and Jane Doe 4 EFTA00808135 Case 09-34791-R BR

ICT OF FLORIDA FORT LAUDERDALE DIVISION www.flsb.uscourts.gov IN RE: ROTHSTEIN ROSENFELDT ADLER, M., Debtor. CASE NO. 09-34791-RBR CHAPTER 11 JEFFREY EPSTEIN'S REPLY TO THE INTERVENORS' RESPONSE TO EPSTEIN'S MOTION TO TAKE THE INTERVENORS' DEPOSITIONS AND TO COMPEL THEIR MENTAL EXAMINATIONS Jeffrey Epstei

rts.gov IN RE: ROTHSTEIN ROSENFELDT ADLER, M., Debtor. CASE NO. 09-34791-RBR CHAPTER 11 JEFFREY EPSTEIN'S REPLY TO THE INTERVENORS' RESPONSE TO EPSTEIN'S MOTION TO TAKE THE INTERVENORS' DEPOSITIONS AND TO COMPEL THEIR MENTAL EXAMINATIONS Jeffrey Epstein ("Epstein") replies to the Intervenors, IM

M., Debtor. CASE NO. 09-34791-RBR CHAPTER 11 JEFFREY EPSTEIN'S REPLY TO THE INTERVENORS' RESPONSE TO E

l G. Cassell S.J. Quinney College of Law at the University of Utah 383 S. University Street Salt Lake City, UT 84112-0730 casse11p08aw.utah.edu Peter E. Shapiro Shapiro Law 8551 West Sunrise Boulevard, Suite 3000 Plantation, FL 33322 Counsel for , and Jane Doe Counsel for M . , M and Jane Doe Nia