Epstein Secrets

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in a to 1 $11702 Guest's signature Dale EFTA00188680 Case 9:08-cv-80736-KAM Document 310-1 Entered on FLSD Docket 02/06/2015 Page 20 of 28 11 J.EP.STEIN Royal Princess, Chiang Nal, 19/10/02 13:07 ROYAL PRINCESS O94/4 Alm I U Camir, lJan 114.4. Mon( I)44. A M.A.,. O4.4..44 W1O.4 TA: (0331 201.033

w about if I call you at 2 tomorrow? 1. The CVRA case is a Complaint about whether certain statutory rights were violated by the Govt. The Govt not JE is the defendant. Whether JD 3 or JD 4 are or are not victims is not the test of whether they are proper petitioners: they also must allege a basis

. . in the original pleading." Because the original petition in this case alleged that the Government violated the rights of all the girls who were Jeffrey Epstein's victims, the proposed amendment in this case would relate back to the date the petition was filed: July 7, 2008. This relation back eliminates any s

ered on FLSD Docket 02/06/2015 Page 24 of 28 1, SHOPPERS TRAVEL, INC. SHOPPERS TRAVEL AGENT RS/RS BOOKING RFF ZXL1 07 303 5TH AVENUE NEW YORK J EPSTEIN 457 MADISON AVE 4TH FLOOR NEWYORK NY 10027 DATE: SEP 27 2002 DOE 3 RECORD TERMS; PAYMENT OUE UPON PRESENTATION SINGAPORE AIRLINES 27SEP NEW

nt violated the rights of all the girls who were Jeffrey Epstein's victims, the proposed amendment in this

e entire agreement between the United States and Mr. Epstein." DE 290-I at 3 (emphasis added). This descriptio

strate the joinder is appropriate, even at very late stages of a proceeding, if justice will be served. See. e.g.. Data General Corp. Grumman Sys. Support Corp., 825 F. Supp. 340, 344 (D. Mass. 1993) (where common question of fact existed about plaintiff student suing under the Civil Rights and two other st

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Plaintiff Case No. 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant JEFFREY EPSTEIN'S MOTION TO QUASH TRIAL SUBPOENA Jeffrey Epstein, a non-party to the above captioned action, has been subpoenaed to testify at the trial of this case

at the trial of this case, being commanded to appear on March 13, 2017. He now moves to quash that subpoena for the reasons set forth herein. Mr. Epstein was deposed by the parties on November 10, 2016. At that deposition, he asserted his Fifth Amendment privilege and declined to answer all substantiv

-cv-07433-RWS v. Ghislaine Maxwell, Defendant JEFFREY EPSTEIN'S MOTION TO QUASH TRIAL SUBPOENA Jeffrey

that subpoena for the reasons set forth herein. Mr. Epstein was deposed by the parties on November 10, 2016.

slave-scandal-that-exposed- pedophile-billionaire-jeffrey-epstein/ (last visited February 17, 2017); Newsweek, "Jeff

rivilege in front of the jury, see, e.g., SEC v. Jasper, 678 F.3d 1116, 1125 (9th Cir. 2012); RAD, 808 F.2d at 272; Data Gen. Corp. v. Grumman Sys. Support Corp., 825 F. Supp. 340, 352 (D. Mass. 1993); East Coast Novelty Co. V. City of New York, 842 F. Supp. 117, 121 (S.D.N.Y. 1994); Penfield v. Venuti, 589 F

8. Moreover, on the facts of this case, the Government's construction leads to an absurd result. As the Court is aware, the Government arranged for Epstein to execute his NPA on about September 24, 2007 — in secret. At that time, the victims could not "assert[] the right to be heard before or during th

ommenced within three years after the disability ceases." 28 U.S.C. § 2401(a) (2012) (emphasis added). In this case, Jane Doe No. 3 was hiding from Jeffrey Epstein and his co-conspirators in Australia from the time her claim accrued until October 2013, when she returned to the United States. See Ex. I at 3 ("I

d). In this case, Jane Doe No. 3 was hiding from Jeffrey Epstein and his co-conspirators in Australia from

trate the joinder is appropriate, even at very late stages of a proceeding, if justice will be served. See, e.g., Data General Corp.'. Grumman Sys. Support Corp., 825 F. Supp. 340, 344 (D. Mass. 1993) (where common question of fact existed about plaintiff student suing under the Civil Rights and two other st