Epstein Secrets

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

purposes only, not to imply institutional endorsement) By: /s/ Paul G. Cassell r N' Pro Hac Vice -AND — I HEREBY CERTIFY that I am admitted to the Bar of the United State District Court for the Southern District of Florida and I am in compliance with the additional qualifications to practice in this court set forth in Local Rule 20

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.

nstitutional endorsement) By: /s/ Paul G. Cassell Paul G. Cassell (Utah Bar No. 6078) Pro Hac Vice -AND — I HEREBY CERTIFY that I am admitted to the Bar of the United State District Court for the Southern District of Florida and I am in compliance with the additional qualifications to practice in this court set forth in Local Rule 20

RE: ROTHSTEIN ROSENFELDT ADLER, P.A., Debtor. CASE NO.: 09-34791-RBR CHAPTER 11 MOTION FOR RELIEF FROM AMENDED ORDER ID.E. 1068t AND TO COMPEL JEFFREY EPSTEIN TO PAY FOR THE PRODUCTION OF ALL DOCUMENTS IN RESPONSE TO HIS REOUEST Movants, LM and Bradley J. Edwards, move this Court for relief from Amended O

omen who allege that they were sexually exploited, sexually abused, and otherwise victims of intentional and despicable conduct of Jeffrey Epstein. Epstein's conduct has been the subject of several lawsuits vigorously litigated by Mr. Edwards, as well as similar lawsuits filed by other well-known attor

IEF FROM AMENDED ORDER ID.E. 1068t AND TO COMPEL JEFFREY EPSTEIN TO PAY FOR THE PRODUCTION OF ALL DOCUMEN

by email or U.S. Mail on those parties listed on the attached service list this 2nd day of November, 2010. I HEREBY CERTIFY that I am admitted to the Bar of the United State District Court for the Southern District of Florida and I am in compliance with the additional qualifications to practice in this court set forth in Local Rule 20

2 of 10 privilege and/or attorney work product. II. Background 3. Movant, L.M. is a party plaintiff in a civil lawsuit' against party defendant Jeffrey Epstein in which she alleges that Epstein sexually exploited, abused, and/or assaulted her when she was a minors. The parties recently reached a confidentia

ereof, states as follows: I. Introduction 1. Jeffrey Epstein, through his counsel, seeks to pull the wool over the eyes of this honorable Court. Epstein asks this Court to usurp the properly exercised jurisdiction of the Circuit Court over a subpoena duces tecum issued by the state court in connectio

STETTIN OF PRIVILEGED DOCUMENTS AND TESTIMONY TO JEFFREY EPSTEIN Movant, L.M., moves this Court pursuant

and by email or U.S. Mail on those parties listed on the attached service list this 19th day of July, 2010. I HEREBY CERTIFY that I am admitted to the Bar of the United State District Court for the Southern District of Florida and I am in compliance with the additional qualifications to practice in this court set forth in Local Rule 20

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

stitutional endorsement) By: /s/ Paul G. Cassell Paul G. Cassell (Utah Bar No. klu Pro Hac Vice -AND — I HEREBY CERTIFY that I am admitted to the Bar of the United State District Court for the Southern District of Florida and I am in compliance with the additional qualifications to practice in this court set forth in Local Rule 20

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

Other Appropriate Relief, and as grounds therefore states as follows: Jeffrey Epstein issued a subpoena, through the Palm Beach State Court case of Jeffrey Epstein v. Scott Rothstein, Bradley J. Edwards, and L.M., Fifteenth Judicial Circuit, in and for Palm Beach County, Florida Case No. 50-2009 CA 040800XXXX M

dley J. Edwards, and L.M., Fifteenth Judicial Circuit, in and for Palm Beach County, Florida Case No. 50-2009 CA 040800XXXX MB AG (hereinafter "the Epstein lawsuit"). The result of that subpoena was the production from the RRA trustee of approximately 27,000 emails to be delivered to Fanner Jaffe for th

s, and by email or U.S. Mail on those parties listed on the attached service list this 14ih day of May, 2018. I HEREBY CERTIFY that I am admitted to the Bar of the United State District Court for the Southern District of Florida and I am in compliance with the additional qualifications to practice in this court set forth in Local Rule 20

ve Order, which specifically only included emails relating to news reporters or the media. On May 7, 2012, Judge Crow entered an Order on Plaintiff Jeffrey Epstein's Motion to Compel Production of Documents from Defendant Bradley Edwards and for Sanctions stating, "Bradley Edwards shall within 30 days of the date

offender who has been sued by dozens of victims for sexual abuse of children. In the course of the above-captioned bankruptcy proceedings, in 2010, Epstein served a broad subpoena attempting to secure thousands of attorney communications by Fanner Jaffe attorney Bradley J. Edwards, Esq., who while prev

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

nd by email or U.S. Mail on those parties listed on the attached service list this 19th day of March, 2018. I HEREBY CERTIFY that I am admitted to the Bar of the United State District Court for the Southern District of Florida and I am in compliance with the additional qualifications to practice in this court set forth in Local Rule 20

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

t) By: /s/ Paul G. Cassell Paul G. Cassell (Utah Bar No. 6078) [email protected] Pro Hac Vice -AND — I HEREBY CERTIFY that I am admitted to the Bar of the United State District Court for the Southern District of Florida and I am in compliance with the additional qualifications to practice in this court set forth in Local Rule 20

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

y institutional endorsement) By: /s/ Paul G. Cassell Paul G. Cassell (Utah Bar No. M) Pro Hac Vice -AND — I HEREBY CERTIFY that I am admitted to the Bar of the United State District Court for the Southern District of Florida and I am in compliance with the additional qualifications to practice in this court set forth in Local Rule 20

tor. INTERVENOR-VICTIMS M., M.. AND RESPONSE TO JEFFREY EPSTEIN'S MOTION TO TAKE THEIR DEPOSITIONS AND T

lsb.uscourts.gov IN RE: CASE NO.: 09-34791-RBR ROTHSTEIN ROSENFELDT ADLER, P.A., CHAPTER 11 Debtor. INTERVENOR-VICTIMS M., M.. AND RESPONSE TO JEFFREY EPSTEIN'S MOTION TO TAKE THEIR DEPOSITIONS AND TO COMPEL THEIR MENTAL EXAMINATIONS Intervenors M., and " " (hereinafter collectively "the Victims"), procee

mously, having previously been allowed to intervene in this action, and having participated in the Court's hearings on these matters, now respond to Epstein's motion to compel their depositions and to compel their mental examinations. Epstein's motion, filed by a man who repeatedly sexually abused the v

y institutional endorsement) By: /s/ Paul G. Cassell Paul G. Cassell (Utah Bar No. M) Pro Hac Vice -AND — I HEREBY CERTIFY that I am admitted to the Bar of the United State District Court for the Southern District of Florida and I am in compliance with the additional qualifications to practice in this court set forth in Local Rule 20