Epstein Secrets

f, C.M.A., by and through her undersigned attorneys, respectfully moves this Court for an extension of time in which file to a response to Defendant Jeffrey Epstein's Motion to Stay And Or Continue Action For Time Certain Based. On Parallel Civil And Criminal Proceedings With Incorporated Memorandum of Law. Local

Plaintiff, Jane Doe, hereby moves this Court to strike all references to a "non- prosecution agreement" contained in defendant, Jeffrey Epstein's ("Epstein") Motion to Stay these proceedings. Under the Best Evidence Rule, Fed. R. Evid. 1002, and the principles underlying the rule, Epstein is required t

eement. In his motion to stay these proceedings, defendant Epstein has argued that he must invoke his Fifth Amendme

80893 - MARRA/JOHNSON JANE DOE, Plaintiff, v. JEFFREY EPSTEIN, Defendant. NOTICE OF CHANGE OF ADDRESS

ed on FLSD Docket 04/09/2009 Page 2 of 14 against any stay -- particularly since it involves allegations of serious sexual abuse against a minor. I. EPSTEIN IS NOT FACING PENDING CRIMINAL CHARGES AGAINST HIM RELATED TO JANE DOE. Epstein's initial burden is to show some sort of risk of criminal prosecuti

n defending the civil claims in that he has no idea what the USAO will define as a breach in the event he does not assert his 5th Amendment rights? Epstein Motion to Stay at 2. Epstein goes on to state: 'As an example, the USAO has already claimed that Epstein violated the [non-prosecution agreement) by: 1. Investiga

ed on FLSD Docket 04/09/2009. Page 2 of 14 against any stay — particularly since it involves allegations of serious sexual abuse against a minor. I. EPSTEIN IS NOT FACING PENDING CRIMINAL CHARGES AGAINST HIM RELATED TO JANE DOE. Epstein's initial burden is to show some sort of risk of criminal prosecuti

9/2009! Page 1 of 14 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No.: 08-CIV-80893 - MARRA/JOHNSON JANE DOE, Plaintiff, v. JEFFREY EPSTEIN, Defendant PLAINTIFF'S RESPONSE IN OPPOSITION TO DEFENDANT'S MOTION TO STAY COMPLAINT . Plaintiff, Jane Doe, hereby responds to the motion by def

RESPONSE IN OPPOSITION TO DEFENDANT'S MOTION TO STAY COMPLAINT . Plaintiff, Jane Doe, hereby responds to the motion by defendant Jeffrey Epstein ("Epstein') to stay this action until late 2010. The motion for a stay should be denied. Defendant has not carried his heavy burden of justifying a stay in th

80893 - MARRA/JOHNSON JANE DOE, Plaintiff, v. JEFFREY EPSTEIN, Defendant PLAINTIFF'S RESPONSE IN OPPO

defending the civil claims in that he has no Idea what the USAO will define as a breach in the event he does not assert his 5th Amendment rights." Epstein Motion to Stay at 2. Epstein goes on to state: "As an example, the USAO has already claimed that Epstein violated the [non-prosecution agreement] by: 1. Investiga

/2009 Page 1 of 9 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, CASE NO.: 08-CV-80119-MARRA/JOHNSON Plaintiff vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 3, CASE NO.: 08-CV-80232-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 4, CASE NO.: 08-CV-8

has failed to satisfy this burden. There is no pending motion for summary judgment. There is also no criminal proceeding at this time arising from Epstein's acts against the Plaintiffs or other victims. Indeed, whether such a criminal proceeding is ever commenced is entirely within the Defendant's cont

revent an unconstitutional infringement of the ' Defendant Epstein filed an identical Motion to Stay in the case Jan

E NO.: 08-CV-80119-MARRA/JOHNSON Plaintiff vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 3, CASE NO.:

er plaintiffs. Finally, Epstein concedes that the Court should consider 'the interest of the public" in being the litigation to a rapid conclusion. Epstein Motion to Stay at 6. As the Court is aware, this case involves a non-prosecution agreement with a politically- connected billionaire that has drawn considerable pu

09/2009 Page 1 of 14 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No.: 08-CIV-80893 - MARRA/JOHNSON JANE DOE, 1. Plaintiff, JEFFREY EPSTEIN, Defendant. / PLAINTIFF'S RESPONSE IN OPPOSITION TO DEFENDANT'S MOTION TO STAY COMPLAINT Plaintiff, Jane Doe, hereby responds to the motion by d

S RESPONSE IN OPPOSITION TO DEFENDANT'S MOTION TO STAY COMPLAINT Plaintiff, Jane Doe, hereby responds to the motion by defendant Jeffrey Epstein ("Epstein") to stay this action until late 2010. The motion for a stay should be denied. Defendant has not carried his heavy burden of justifying a stay in th

80893 - MARRA/JOHNSON JANE DOE, 1. Plaintiff, JEFFREY EPSTEIN, Defendant. / PLAINTIFF'S RESPONSE IN

ed on FLSD Docket 04/09/2009 Page 2 of 14 against any stay -- particularly since it involves allegations of serious sexual abuse against a minor. I. EPSTEIN IS NOT FACING PENDING CRIMINAL CHARGES AGAINST HIM RELATED TO JANE DOE. Epstein's initial burden is to show some sort of risk of criminal prosecuti

defending the civil claims in that he has no idea what the USAO will define as a breach in the event he does not assert his 5th Amendment rights." Epstein Motion to Stay at 2. Epstein goes on to state: "As an example, the USAO has already claimed that Epstein violated the [non-prosecution agreement] by: 1. Investiga