Epstein Secrets

privacy. 5. This is strictly a "fishing expedition" unrelated to any aspect of this case. A similar Request to Produce was served in the casel v. Jeffrey E. Epstein and , Case No. 502008CA025129XXXXMB Al, in front of Judge Garrison. A copy of the objection to the Notice is attached as Exhibit "B" and Judge Garr

BOARD CERTIFIED CVO-TRIAL LAWYER Sent by Fax and U.S. Mail Isidro M. Garcia, Esq. A LIMITED LIABILITY PARTNERSHIP April 13, 2009 Re: Doe II v. Epstein, et al. Case No. 09-80469-Civ-MARRA/JOHNSON ADELQUI.LBENAVENTE rmukumALINVBSTIOMOR BARBARA M. NkKENNA ASHLIE STOKEN-BARING BETTY STOKES PARALE

kKENNA ASHLIE STOKEN-BARING BETTY STOKES PARALEGALS RITA H. BUDNYK OP COUNSEL Dear Sid: Please be informed thal subpoenaed deposition in thel.L. Epstein case on April 16th, 2009 is hereby cancelled. Cordially Robert D. Critton, Jr. RDC/clz cc: Jack A. Goldberger, Esq. L•A•W•Y•E •R•S TELEPHONE

py of the case law and Florida Statutes cited in Defendant Epstein' otion to Dismiss, For More Definite Statement, a

ar Request to Produce was served in the casel v. Jeffrey E. Epstein and , Case No. 502008CA025129XXXXMB Al,

ar Request to Produce was served in the casel v. Jeffrey E. Epstein and , Case No. 502008CA025129XXXXMB Al,

OW CAB Defendant, Jeffrey Epstein, (hereinafter "Mr. Epstein"), by and through his undersigned attorneys, pur

ion Fidelity Life Ins., 439 So.2d 904 (Fla. 3d DCA 1988) 7. Bond v. Koscot Interplanetary, Inc., 246 So.2d 631 (Fla. 4th DCA 1971 8. Churruca v. Miami Jai-Alai, Inc. 353 So.2d 547 (Fla. 1977). 9. Snipes v. West Flaciler Kennel Club, 105 So.2d 164 (Fla. 1958) EFTA00722695 v. Epstein Page 2 10. Buchana

o privacy. 5. This is strictly a "fishing expedition" unrelated to any aspect of this case. A similar Request to Produce was served in the caa v. Jeffrey E. Epstein and Case No. 502008CA025129XXXXMB Al, in front of Judge Garrison. A copy of the objection to the Notice is attached as Exhibit "B" and Judge Garris

RIAL LAWYER Sent by Fax and U.S. Mail Isidro M. Garcia, Esq. Garcia Law firm P.A. A LIMITED LIABILITY PARTNERSHIP April 13, 2009 Re: Doe II v. Epstein, et al. Case No. 09-80469-Civ-MARRA/JOHNSON ADELQUI.LBENAVENTE rmemeom. I INVBSTIOMOR BARBARA M. NkKENNA ASHLER STOKEN-BARING BETTY STOKES PAR

OW CAB Defendant, Jeffrey Epstein, (hereinafter "Mr. Epstein"), by and through his undersigned attorneys, pur

ilar Request to Produce was served in the caa v. Jeffrey E. Epstein and Case No. 502008CA025129XXXXMB Al, i

py of the case law and Florida Statutes cited in Defendant Epstein' otion to Dismiss, For More Definite Statement, a

CASE NO. 502008CA037319XXXXMB AB Plaintiff, v. JE an Defendants. DEFENDANT'S, JEFFREY EPSTEIN, O

ilar Request to Produce was served in the caa v. Jeffrey E. Epstein and Case No. 502008CA025129XXXXMB Al, in

ion Fidelity Life Ins., 439 So.2d 904 (Fla. 3d DCA 1988) 7. Bond v. Koscot Interplanetary, Inc., 246 So.2d 631 (Fla. 4th DCA 1971 8. Churruca v. Miami Jai-Alai, Inc. 353 So.2d 547 (Fla. 1977). 9. Snipes v. West Flaciler Kennel Club, 105 So.2d 164 (Fla. 1958) EFTA00614425 • v. Epstein Page 2 10. Buch

driguez advised he had very limited contact with Mr. Epstein. If Rodriguez needed to relay a message to Mr. E

d Six, to-wit The Grand Jurors of the State of Florida, inquiring in end for the body of said County of Palm Beach, upon their oaths do present that JEFFREY E. EPSTEIN in the County of Palm Beach aforesaid. in the Circuit and State aforesaid. COUNT ONE FELONY SOLICITATION OF PROSTITUTION on or about or between th

esses and register himself as an agent. I also observed Epstein has his El Zorro Ranch Corporation, New York Strategy Group, Ghislaine Corporation, J Epstein and Company and the Financial Strategy Group registered to this same address. Finally, a third call is received by at 12:02 pm from the same corp

y of Palm Beach, upon their oaths do present that JEFFREY E. EPSTEIN in the County of Palm Beach aforesaid.

I wrote that, but I didn't write what you 13 said. 14 4. 15 16 you write that? 17 18 19 20 21 22 about what happened when you went to Jeff Epstein's house You wrote in this exhibit, "I got some stupid court s-h-i-t on the 20th. Bull s-h-i-t." Didn't A. Yes. Q. Referring to this deposition, d

his associates. ) (describing character of party defendant Epstein as a "sexual predator" (a term defined by Florida

y of Palm Beach, upon their oaths do present that JEFFREY E. EPSTEIN in the County of Palm Beach aforesaid. i

ko, 446 So. 2d 1162, 1165 (Fla. 5th DCA 1984) (citations omitted) (emphasis added).10 10 This case is governed by the general rule. Cf. Churruca v. Miami Jai-Alai, Inc., 353 So. 2d 547, 550 (Fla. 1977) (noting that while there is "ordinarily ... no independent ton for conspiracy," there is a narrow exception

esses and register himself as an agent. I also observed Epstein has his El Zorro Ranch Corporation, New York Strategy Group, Ghislaine Corporation, J Epstein and Company and the Financial Strategy Group registered to this same address. Finally, a third call is received by at 12:02 pm from the same corp

d Six, to-wit The Grand Jurors of the State of Florida, inquiring in and for the body of said County of Palm Beach, upon their oaths do present that JEFFREY E. EPSTEIN in the County of Palm Beach aforesaid. in the Circuit and State aforesaid. COUNT ONE FELONY SOLICITATION OF PROSTITUTION on or about or between th

ourt. I was• later 20 informed that it was a deposition. 21 Q. I'm going to ask you some questions now 22 about what happened when you went to Jeff Epstein's house — 2S-- three-Yearragerr— Gkeig 24 A. Uh -huh. 25 Q. When the police interviewed you one month Ph. - Fax. 1655 Palm Beach Lakes Blvd.,

y of Palm Beach, upon their oaths do present that JEFFREY E. EPSTEIN in the County of Palm Beach aforesaid.

his associates. ) (describing character of party defendant Epstein as a "sexual predator" (a term defined by Florida

y of Palm Beach, upon their oaths do present that JEFFREY E. EPSTEIN in the County of Palm Beach aforesaid. i

ery well and did not want to speak with me about Mr. Epstein. She was very fond of Epstein and did not want t

urko, 446 So. 2d 1162, 1165 (Ha. 5th DCA 1984) (citations omitted) (emphasis added).1° 10 This case is governed by the general rule. CI Churruca v. Miami Jai-Alai, Inc., 353 So. 2d 547, 550 (Fla. 1977) (noting that while there is "ordinarily ... no independent tort for conspiracy," there is a narrow exception

ket 07)21:2008 Page 16 of 100 1. The plaintiff seeks damages in connection with her own illegal conduct. The plaintiff concedes that she went to Jeffrey Epstein's house "to give Epstein a massage for monetary compensation." (Am. Compl. ¶ 13.) The plaintiff also concedes, in the guise of an allegation, that "

respectfully state as follows: Introduction Six months ago, this plaintiff filed virtually the identical lawsuit in this Court. See Jane Doe #1 v. Epstein, Case No. 08-cv-80069-KAM (S.D. Fla. filed Doe v. Epstein et at, Case No. 50 2008 CA 006596 XXXX MB (Fla. 15th Cir. Ct. filed Mar. 6, 2008). Lewis

A. Yes. Q. Didn't you tell that to the police? A. Yes. And I will continue. I have never had sex with him. Q. Did what happened upstairs at Jeff Epstein's house take you completely by surprise,. A. Yes. Q. Now the civil complaint that you filed against Mr. Epstein for fifty million dollars alleged

in's house you had 17 never told Jeff that you were under 18, right? 18 A. No. 19 Q. Before you got to Epstein's house had you 20 ever told Jeffrey that you were under 18? 21 A. No. I never spoke to the man before that. 22 Q. And you only went to Jeff Epstein's house 23 that one time thre

his associates. ) (describing character of party defendant Epstein as a "sexual predator" (a term defined by Florida

the instant case, adding two nominal defendants Mr. Epstein's personal secretary, and MB one of Jane Doe #1'

ko, 446 So. 2d 1162, 1165 (Fla. 5th DCA 1984) (citations omitted) (emphasis added).1° 10 This case is governed by the general rule. Cf. Churruca v. Miami Jai-Alai, Inc., 353 So. 2d 547,550 (Fla. 1977) (noting that while there is "ordinarily . . . no independent tort for conspiracy," there is a narrow exceptio

011 Pages w/cover: 4 Fax #: Direct #: Please see the attached letter, in response to your letter to Martin Weinberg of July 27, 2011, concerning Jeffrey Epstein. Thank you. Documena EFTA00180294 07/29/2011 13: 12 FAX a 002/004 Jay P. LeatowItz. P.C. To ilaiactly: jay.lefkowitzekirklend.cOm KIRKLAND &

oncerning the request by the New York District Attorney for copies of the Non-Prosecution Agreement ("NPA") and the "victim list" in regards to Mr. Epstein. We continue for the reasons stated herein to believe that any such disclosure would violate the confidentiality agreement between your Office and

Jack 2:114:5 jackpot 32:9 jail 41:7 Jane 1:4,15,18,22 2:3,7 3:5,5,7,11 5:17 6:8,9,16 11:12 21:4 29:14 29:22 33:5 35:13 42:22 Jay 2:20 4:18 Jeffrey 1/ 37:12 jeopardize 9:15 Jeopardy 15:17 join 26:11,15 Josefsberg 2:1,2,5 3:18,20,21,23 19:7 19:7,1021:25 23:1 24:5 25:25 26:7,11 26:12,16 27:

ourt. I was• later 20 informed that it was a deposition. 21 Q. I'm going to ask you some questions now 22 about what happened when you went to Jeff Epstein's house 23 three years ago. Okay? 24 A. Oh-huh. 25 Q. When the police interviewed you one month Ph. 561.682.0905 - Fax. 561.682.1771 1655 Pal

. § 1446, this notice of removal is timely. Only defendant Epstein has been served with process. Defendants 21 Lew

ment ("NPA") and the "victim list" in regards to Mr. Epstein. We continue for the reasons stated herein to be

ko, 446 So. 2d 1162, 1165 (Fla. 5th DCA 1984) (citations omitted) (emphasis added).1° 10 This case is governed by the general rule. Cf. Churruca v. Miami Jai-Alai, Inc., 353 So. 2d 547, 550 (Fla. 1977) (noting that while there is "ordinarily . . . no independent tort for conspiracy," there is a narrow excepti

e meeting? 2 A. No. They -- yeah. No. They have it. I'm 3 guessing. I don't have it. 4 Q. How much money are you hoping to get out of 5 Mr. Epstein? 6 MR. LEOPOLD: Objection to the form of the 7 question. Attorney/client privilege. 8 BY MR. TEIN: 9 Q. How much money are you hoping to get

ket 07/21/2008 Page 16 of 100 1. The plaintiff seeks damages in connection with her own illegal conduct. The plaintiff concedes that she went to Jeffrey Epstein's house "to give Epstein a massage for monetary compensation." (Am. Compl. ¶ 13.) The plaintiff also concedes, in the guise of an allegation, that "

court. I was later 20 informed that it was a deposition. 21 Q. I'm going to ask you some questions now 22 about what happened when you went to Jeff Epstein's house 23 three years ago. Okay? 24 A. Uh-huh. 25 Q. When the police interviewed you one month You wrote in this exhibit, "I got some Ph. 56

you got to Epstein's house you had never told Jeff that you were under 18, right? A. No. Q. Before you got to Epstein's house had you ever told Jeffrey that you were under 18? A. No. I never spoke to the man before that. Q. And you only went to Jeff Epstein's house that one time three years ago,

his associates. ) (describing character of party defendant Epstein as a "sexual predator" (a term defined by Florida

How much money are you hoping to get out of 5 Mr. Epstein? 6 MR. LEOPOLD: Objection to the form of the 7

o, 446 So. 2d 1162, 1165 (Fla. 5th DCA 1984) (citations omitted) (emphasis added).1° 10 This case is governed by the general rule. CJ: Chztrnica v. Miami Jai-Alai, Inc., 353 So. 2d 547, 550 (Fla. 1977) (noting that while there is "ordinarily . . . no independent tort for conspiracy," there is a narrow excepti