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

0811-KAM Document 55 Entered on FLSD Docket 04/09/2609 Page 3 of 6 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRAMOHNSON Plaintiffs Motion for Extension of Time in Which to File a Response to Defendant's Motion to Stay And Or Continue 6. The requested extension is fair and reasonable under the circumstance

ege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02109 05/13/2009 I. Epstein info — List of Plaintiff lawyers Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of

privilege and/or work product 02933 06/17/2009 --; I I Jane Doe v. Roe Attorney/Client privilege and/or work product 01292 09/18/2009 1-- Epstein article Attorney/Client privilege and/or work product 01068.01070 04/02/2009 All Staff Current case list of Attorney/Client privilege and/or wor

asonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01003.01005 10/12/2009 Asset movement by Jeffrey Epstein Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protect

privacy rights 06744.06747 05/01/2009 Depo of Jeffrey Epstein Work product; attorney/client privile

f the admissible evidence; protected by privacy rights 01808-01809 09/10/2009 I Activity in case 9:08-cv-80119- KAM Doe v. Epstein - Order on Motion for Extension of Time to File Response/Reply/Answer Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of th

02, CASE NO.: 09-80656-CIV-MARRA/JOHNSON Plaintiff, JEItItEY EPSTEIN, Defendant. PROPOSED ORDER This matter came before the Court on Defendant, JEFFREY EPSTEIN's, Unopposed Motion for Extension of Time to file Reply to Plaintiffs' Jane Does 2-7 EFTA00727465 Case 9:08-cy-80119-KAM Document 123-2 Entered o

Defendant. JANE DOE NO. 102, CASE NO.; 08-CV-80656-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. NOTICE OF FILING The Defendant, EPSTEIN, by and through his undersigned attorneys, hereby files this Proposed Order Granting Unopposed Motion for Extension of Time to File Reply to Plainti

ntiff, CASE NO.; 08-CV-80119-MARRA/JOHNSON vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO.3, CASE NO.; 0

NO.; 08-CV-80380-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 5, CASE NO.; 08-CV-80381-MARRA/JOHNSON Plaintiff, vs. JEH-REY EPSTEIN, Defendant. EFTA00727459 Case 9:08-cv-80119-KAM Document 123 Entered on FLSD Docket 05/29/2009 Page 2 of 4 Page 2 JANE DOE NO. 6, Plaintiff

RRA/JOHNSON Plaintiff, JEItItEY EPSTEIN, Defendant. PROPOSED ORDER This matter came before the Court on Defendant, JEFFREY EPSTEIN's, Unopposed Motion for Extension of Time to file Reply to Plaintiffs' Jane Does 2-7 EFTA00727465 Case 9:08-cy-80119-KAM Document 123-2 Entered on FLSD Docket 05/29/2009 Page 4 of 5 Re

the discovery of admissible evidence; protected by privacy rights 02411-02413 05/12/2009 Attorneys at RRA Bradley J. Edwards Jane Doe II v. Epstein Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protect

the discovery of the admissible evidence; protected by privacy rights 01003.01005 10/12/2009 Bradley Edwards Paul Cassell Asset movement by Jeffrey Epstein Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protect

calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05403-05405 04/27/2009 Marc Nurik Bradley Edwards Jeffrey Epstein Wikipedia page Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; pr

0 09/13/2009 Bradley Edwards Paul Cassell "Is Jeffrey Epstein the new Madoff — Running a giant Ponzi

ected by privacy rights 01808-01809 09/10/2009 Paul Cassell Bradley J. Edwards Activity in case 9:08-cv-80119- KAM Doe v. Epstein - Order on Motion for Extension of Time to File Response/Reply/Answer Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of th

C, LLC d/b/a Sound X Location: 2775 ALGONQUIN RD STR 250, Roiling Meadows, IL 60008 Received: 2/11/2012 Completed: 2/17/2012 1:20 PM Reference: Mier/Jeffrey Epstein vs Item Qty. Unit Total 6. National P3 Fuel Surettaige National 1 $120.00 5120.00 $9.90 $9.9C Sub-Total $129.90 Thank Vont TERMS: °NET

judgment hearing. Accordingly, a total of an additional 4 hours is added to the instant fees sought but not contained in Exhibit A. EFTA00622684 Epstein, of al. v. Lambros, et al Case NO. ST-12-CV-21 Affirmation Paget 4. Based on my review of the.file and the underlying bills, the total and reason

12/10112 01/12/2012 BG 01/13/2012 CK 01/17/2012 BC 9100 Havensight, Port of Sate Suite 15/16 St. ThoS Phone: KELLERHALS7FERGUSON Epstein, Jeffrey Invoice 22414 Date Feb 08, 2012 Terms Service Thru Jan 31, 2012 Date By Services Hours Rates Amount 01/04/2012 01/05/2012 01/06/2012 0

,00/hr $325 00thr $24.00 $97.50 06/19/2012 CK Preparation of Motion for extension of lime. 0.90 $325.00/ir $292.50 Proofread/ edit/ prepare Motion for Extension of Time by Wnich to Fie Plaintiffs' Motion for Default Judgment, and 08/20/2012 NM proposed Order, TC's with C. Kroblin, Esq. re. same; TC with 1.00 $8