Epstein Secrets

, psychologists, psychiatrists, mental health counselors, physicians, hospitals and treatment facilities. No. 9. (Not at issue.)' List all items in Jeffrey Epstein's possession in Palm Beach, Florida, at any time during the period of these interrogatories, which were used or intended to be used as sexual aids, s

CT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S RESPONSE TO PLAINTIFF'S MOTION TO COMPEL ANSWERS TO INTERROGATORIES, and RESPONSES TO 1st and 2nd PRODUCTION OF DOCUMENTS, AND INCORPORATED MEMO

2, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S RESPONSE TO PLAINTIFF'S MOTION TO COMPEL ANSWE

9-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S RESPONS

name in an Indictment as victims of an offense by Mr. Epstein enumerated in 18 U.S.C. §2255. Request No. 2.

(Health Insurance Portability and Accountability Act) objection, as noted in the case cited in Plaintiffs motion Allen v. Woodford, 2007 WL 309485 (E.D. Cal. 2007), (p. 9), HIPPA institutes procedural safeguards to protect the privacy of an individual's medical information and history. In the context of

ichard Barnett. The affidavit stated: 'On Wednesday, October 13, 2010, an unmarked and unpostrnarked envelope was discovered in the mailbox at Mr. E[psitein's vacation home in New York City at 9 East 7181 Street. The envelope contained a Summons and Complaint in the subject action, a Civil Rico Case S

ncluding an Order that Epstein is in default for failing to timely answer the complaint. Plaintiff M.J. was repeatedly sexually abused by defendant Jeffrey Epstein when she was a minor. Epstein is a politically-connected billionaire. M.J. filed suit in this Court against Epstein, seeking substantial damages. A

attan that was formerly owned by Les Wexner. a villa in Palm Beach, Florida, and a fortress on a ranch in Santa Fe, New Mexico. Wikipedia entry for Jeffrey Edward Epstein (visited on Oct. 30, 2010). Accordingly, it may be difficult to identify a single "dwelling" for Epstein. 3 The Court was referring to an earlier v

for a hearing to demonstrate fraud, to prove the defendant Epstein was properly served, to obtain sanctions for his

M.J. was repeatedly sexually abused by defendant Jeffrey Epstein when she was a minor. Epstein is a polit

e court must then "weigh and determine (the) disputed issues of facts on a Rule 12(b)(5) motion." Cranford v. United States, 359 F.Supp.2d 981, 984 (E.D. Cal. 2005). An evidentiary hearing is the proper vehicle for resolving this particular factual dispute. See Blair v. City of Worcester, 522 F.3d 105, 1

s. V. PLAINTIFF IS ENTITLED TO DEFENDANT'S HEALTH CARE INFORMATION IN DISCOVERY A. Interrogatory at Issue "Interrogatory No. 8. Identify all of Jeffrey Epstein's health care providers in the past (10) ten years, including without limitation, psychologists, psychiatrists, mental health counselors, physician,

to Plaintiff's discovery requests. - 1 - EFTA00728201 Case 9:08-cv-80119-KAM Document 57 Entered on FLSD Docket 03/02/2009 Page 2 of 16 II. EPSTEIN'S BLANKET ASSERTION OF PRIVILEGE AGAINST SELF-INCRIMINATION IN RESPONSES TO INTERROGATORIES IS INSUFFICIENT Defendant's response to each and every

cceptable). While Plaintiff does not dispute that Defendant Epstein's Fifth Amendment privilege may be asserted in a

-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. PLAINTIFF'S MOTION TO COMPE

ame in an Indictment as victims of an offense by Mr. Epstein enumerated in 18 U.S.C. §2255. Response: Defend

purely procedural in nature and does not create a federal physician-patient or hospital-patient privilege." Allen v. Woodford 2007 WL 309485 *I I (E.D. Cal. 2007). Under HIPAA, health care information may be disclosed in discovery under a qualified protective order, which prohibits using or disclosing

vision The United States Attorney's Office Southern District of Florida 99 NE 4th Street Miami, Florida 33132 Dear• Mr. Menthe': July 25, 2007 Jeffiry Epstein TELEPHONE la 1E)7370400 m ailman We have previously provided you with a memo as to why we believe no charge under 18 U.S.C. §2422(b) could or sho

ting this statute. We also posited that the language of the statute would have to be stretched beyond recognition to fit the particular facts of Mr. Epstein's ease.' Enclosed is data that strongly supports the arguments we previously made. We have thoroughly analyzed every prosecution brought under the

.S.C. §2422(b) could or should be brought against Jeffrey Epstein, even assuming the specific conduct that

beyond recognition to fit the particular facts of Mr. Epstein's ease.' Enclosed is data that strongly supports

onduct evidentiary hearing. 2422(b); 2423 Not Consummated Showed up for meeting Sting E.D. Cal. U.S. v. Carter, 2006 U.S. Dist. LEXIS 22501 (E.D. Cal. 2006) Internet Internet chat room "preteen parents who share"; defendant wants to have sex with daughter while mother watches; Internet email &

FLSD Docket 03/05/2010 Page 1 of 36 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80893-MARRA-JOHNSON Plaintiff; v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION FOR SUMMARY JUDGMENT, INCLUDING SUPPORTING MEMORANDUM OF LAW Defendant, JEFFREY EPSTEIN, ("EPSTEIN"), by a

TED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80893-MARRA-JOHNSON Plaintiff; v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION FOR SUMMARY JUDGMENT, INCLUDING SUPPORTING MEMORANDUM OF LAW Defendant, JEFFREY EPSTEIN, ("EPSTEIN"), by and through his undersigned coun

ON Plaintiff; v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION FOR SUMMARY JUDGMENT, INCLUDING SUPPORT

E NO.: 08-CV-80893-MARRA-JOHNSON Plaintiff; v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION

CV-80893-Marra-Johnson Page 7 Cal. Aug. 19, 2009); U.S. v. Ferenci, 2009 WL 2579102, fn. 1 (ED. Cal. Aug. 19, 2009); U.S. 2009 WL 2567831, fn. 1 (E.D. Cal. Aug. 18, 2009); U.S. v. Zane, 2009 WL 2567832, al (ED. Cal. Aug. 18 2009). In each of these cases, the referenced footnote states — Prior to July

s. V. PLAINTIFF IS ENTITLED TO DEFENDANT'S HEALTH CARE INFORMATION IN DISCOVERY A. Interrogatory at Issue "Interrogatory No. 8. Identify all of Jeffrey Epstein's health care providers in the past (10) ten years, including without limitation, psychologists, psychiatrists, mental health counselors, physician,

to Plaintiff's discovery requests. - 1 - EFTA00222502 Case 9:08-cv-80119-KAM Document 57 Entered on FLSD Docket 03/02/2009 Page 2 of 16 II. EPSTEIN'S BLANKET ASSERTION OF PRIVILEGE AGAINST SELF-INCRIMINATION IN RESPONSES TO INTERROGATORIES IS INSUFFICIENT Defendant's response to each and every

cceptable). While Plaintiff does not dispute that Defendant Epstein's Fifth Amendment privilege may be asserted in a

-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. PLAINTIFF'S MOTION TO COMPE

purely procedural in nature and does not create a federal physician-patient or hospital-patient privilege." Allen v. Woodford 2007 WL 309485 *I I (E.D. Cal. 2007). Under HIPAA, health care information may be disclosed in discovery under a qualified protective order, which prohibits using or disclosing

ivision The United States Attorney's Office Southern District of Florida 99 NE 41' Street Miami, Florida 33132 Dear Mr. Menchel: July 25, 2007 Jeffrey Epstein TELEPHONE '212)737-0400 FACSIMILE 12i P) 9/313-SI92 We have previously provided you with a memo as to why we believe no charge under 18 U.S.C.

ting this statute. We also posited that the language of the statute would have to be stretched beyond recognition to fit the particular facts of Mr. Epstein's case.t Enclosed is data that strongly supports the arguments we previously made. We have thoroughly analyzed every prosecution brought under the

Florida 33132 Dear Mr. Menchel: July 25, 2007 Jeffrey Epstein TELEPHONE '212)737-0400 FACSIMILE 12i

beyond recognition to fit the particular facts of Mr. Epstein's case.t Enclosed is data that strongly supports

conduct evidentiary hearing. 2422(b); 2423 Not Consummated Showed up for meeting Sting E.D. Cal. U.S. I Carter, 2006 U.S. Dist. LEXIS 22501 (E.D. Cal. 2006) Internet Internet chat room "preteen parents who share"; defendant wants to have sex with daughter while mother watches; Internet email &

RENA FAITH BY HAND of of the Criminal Division The United States Attorney's Office Southern Distri of Florida tams, on a 3132 July 25, 2007 Jeffrey Epstein •ELE.T., FACSIMILE Dear Mr. We have previously provided you with a memo as to why we believe no charge under 18 U.S.C. §2422(b) could or should b

ting this statute. We also posited that the language of the statute would have to be stretched beyond recognition to fit the particular facts of Mr. Epstein's case! Enclosed is data that strongly supports the arguments we previously made. We have thoroughly analyzed every prosecution brought under the s

istri of Florida tams, on a 3132 July 25, 2007 Jeffrey Epstein •ELE.T., FACSIMILE Dear Mr. We have pr

beyond recognition to fit the particular facts of Mr. Epstein's case! Enclosed is data that strongly supports

uct evidentiary hearing. 2422(b); 2423 Not Consummated Showed up for meeting Sting G.D. Cal. • U.S. v. Carter, 2006 U.S. Dist. LEXIS 22501 (E.D. Cal. 2006) . Internet Internet chat room "preteen parents who share"; defendant wants to have sex with daughter while mother watches; Internet emai

kept anonymous in the Federal Court criminal case and all documents containing her name were redacted by the United States Government and Defendant, Jeffrey Epstein's attorney. The Defendant, Jeffrey Epstein, will not be prejudiced in any way by this pseudonym pleading, as he has been provided with her name in the

80893-Civ-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. AUGUST 13, 2008 STEVEN M. LARIMORE

OE, 08-80893-Civ-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. AUGUST 13, 2008 STEVEN M.

ases, with minimal discussion. Roe v. Wade, 410 U.S. 113, 120-121, 93 S.Ct. 705 (1973); See also, E.E.O.C. v. ABM Industries, Inc., 249 F.R.D. 588 (E.D. Cal. 2008). Likewise, pseudonym filing is typically accepted by the courts in other cases where the nature of the pleading unveils highly sensitive inf

on to take notes during his meetings with probation officers.° (Petition at 10-15.) The petition asserts that a non- party "multi-billionaire" named Jeffrey Epstein can "easily" provide for restitution through his "over one hundred billion dollar hedge fund" that was formed with Hoffenberg's assistance. (Petiti

at a non- party "multi-billionaire" named Jeffrey Epstein can "easily" provide for restitution through his

serts that a non- party "multi-billionaire" named Jeffrey Epstein can "easily" provide for restitution thro

ief may be had under CVRA because that statute does not allow a private party to sue for enforcement."); Upton v. Fakhoury, 2011 WL 3703364, at *1 (E.D. Cal. Aug. 23, 2011) ("no independent right of action was created by" the CVRA). The petition invokes no other basis for relief or for exercising federa