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 ., . . an ane Doe Counsel for L.M., E.W. and Jane Niall T. McLachlan Carlton Fields Jorden Burt P.A. 200 °rinse or ow er nr e urnett, P.A. Isaac M. Marcushamer Ber er Sin erman LLP Counsel for liquidating Trustee 2077028 8 EFTA00793408 Case 09-34791-RBR Doc 6482 Filed 10/19/18 Page 9 of 97 EXHIBIT

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

or 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 Counsel for Liquidating Trustee Counsel for Fowler White Burnett, P.A. 2077028 8 EFTA00794245

referred to as "Apr. Tr." 3 EFTA00794248 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

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

.M., E.W. and Jane Doe Counsel for L.M., E.W. and Jane Niall T. McLachlan Carlton Fields Jorden Burt, P.A. 200 ounse or ow er ite urnett, P.A. Isaac M. Marcushamer Berger Singerman LLP ounse orLiquidating rustee 2077028 8 EFTA00794253

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

ottin 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. 114428178.1 17 EFTA00793936 Case 09-34791-RBR Doc 6355-1 Filed 04/11/18

nymously, having previously moved to intervene in this action and having filed a motion for an order to show cause [DE 6345], now file this reply to Jeffrey Epstein's Response in Opposition to ■., ■., and Jane Doe's Joinder in Motion for Order to Show Cause and Motion for Discovery, to Assess Sanctions and Costs,

anctions and Costs, and for Other Appropriate Relief [DE 6353]. INTRODUCTION In their motion, the Victims sought sanctions against Fowler White and Epstein for illegally retaining copies of materials forbidden to be retained or copied by this Court's November 2010 order — including a disk of thousands

r to show cause [DE 6345], now file this reply to Jeffrey Epstein's Response in Opposition to ■., ■., and

e won't use them. MR. SCAROLA: Does that include Mr. Epstein? THE COURT: Does what include Mr. Epstein? MR.

, Suite 4200 Miami, FL 33131 Counsel for Fowler White Burnett, P.A. 13 EFTA00795957 Case 09-34791-RBR Doc 6357 Filed 04/12/18 Page 14 of 14 Isaac M. Marcushamer Berger Singerman LLPO 1450 Brickell Avenue, Suite 1900 Miami FL 33131 Counsel for Litigating Trustee 14 EFTA00795958

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

ah 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.A. Counsel for Liquidating Trustee 13 EFTA00794268

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

Boulevard, Suite 3000 Plantation, FL 33322 12-0730 Counsel for L.M., E. W. and Jane Doe Counsel for L.M., E.W. and Jane Doe Niall T. McLachlan Isaac M. Marcushamer Carlton Fields Jorden Burt, P.A. Berger Singerman LLP 100 S.E. Second Street, Suite 4200 1450 Brickell Avenue, Suite 1900 Miami, FL 33131 Miami

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

FL 33131 [email protected] Counsel for Fowler White Burnett, P.A. EFTA00808136 Case 09-34791-R BR Doc 6384 Filed 05/14/18 Page 6 of 6 Isaac M. Marcushamer Berger Singerman LLPO 1450 Brickell Avenue, Suite 1900 Miami, FL 33131 [email protected] Counsel for Litigating Trustee EFTA008

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

ane Doe Counsel for M . , M and Jane Doe Niall T. McLachlan Carlton Fields Jorden Burt, 100 S.E. Second Street, Suite 4200 Miami, FL 33131 Isaac M. Marcushamer Berger Singerman LLP 1450 Brickell Avenue, Suite 1900 Miami, FL 33131 Counsel for Fowler White Burnett,.. Counsel for Liquidating Trustee 20915

ne in this action, and having participated in the Court's hearings on these matters, and pursuant to this Court's order of August 16, 2018, denying Epstein's motion to strike the victims' previously filed list of requested relief (DE 6427), now file this summary of their damages. The factual background

hen, PLLC Ft. Lauderdale FL 33301 Attorneys for Jeffrey Epstein EFTA00809902 Niall T. McLachlan Carlton Field

hen, PLLC Ft. Lauderdale FL 33301 Attorneys for Jeffrey Epstein EFTA00809902 Niall T. McLachlan Carlt

neys for Jeffrey Epstein EFTA00809902 Niall T. McLachlan Carlton Fields Jorden Burt P.A. Miami FL 33131 Counsel for Fowler White Burnett, P.A. Isaac M. Marcushamer Ber er Sin erman LLPO Miami. FL 33131 Counsel for Litigating Trustee 5 EFTA00809903