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

Stansfield v. Starkey, 269 Cal.Rptr., 337, 348 (Cal. App.3d, 1990) 5. Zimmerman v. HBO Affiliate Group, 834 F.2d 1163, 1169 (3d Cir. 1987). 6. Connor v. Halifax Hospital Medical Center, 135 F. Supp.2d 1198, 1219 (M.D. Fla. 2001). EFTA00722697 M v. Epstein Page 2 7. Magnum v. Archdiocese of Philadelphia , 253 Fed. Appx. 224

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

Stansfield v. Starkey, 269 Cal.Rptr., 337, 348 (Cal. App.3d, 1990) 5. Zimmerman v. HBO Affiliate Group, 834 F.2d 1163, 1169 (3d Cir. 1987). 6. Connor v. Halifax Hospital Medical Center, 135 F. Supp.2d 1198, 1219 (M.D. Fla. 2001). EFTA00614427 v. Epstein Page 2 7. Magnum v. Archdiocese of Philadelphia , 253 Fed. Appx. 224 (3d

2'2009 Page 1 of 26 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE, CASE NO.: 08-CIV- 80893 - MARRA/JOHNSON Plaintiff, v. JEFFREY EPSTEIN, Defendants. Defendant's, Epstein. Motion To Dismiss, For More Definite Statement & To Strike Directed To Plaintiff Jane Doe's Amended Complaint,

Plaintiff. . .was called on the telephone by. . .Epstein and other employees. . ., and transported to. . .

Florida Civil Rico action is, at this time, only defendant Epstein. . . ." However, the RICO enterprise must be dis

.: 08-CIV- 80893 - MARRA/JOHNSON Plaintiff, v. JEFFREY EPSTEIN, Defendants. Defendant's, Epstein. Moti

, citing Zimmerman v. HBO Affiliate Group, 834 F.2d 1163, 1169 (3d Cir. 1987)(congress intended RICO to exclude personnel injuries). 14. at 348. In Connor v. Halifax Hospital Medical Center, 135 F.Supp.2d, 1198, 1219 (M.D. Fla. 2001), the court held that claims for money damages relating to nursing home patients' deaths following massi

CT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE, CASE NO.: 08-C1V- 80893 - MARRA/JOHNSON Plaintiff, v. JEFFREY EPSTEIN, Defendants. Defendant, Jeffrey Epstein's Reply to Plaintiff's Response In Opposition to Defendant's Motion To Dismiss, For More Definite Statement & To Strike Directed To Plaintiff Jane Do

as requested. Plaintiff filed her Response in Opposition to the Motion to Dismiss. As to Count II, Plaintiff conceded in her opposition motion that Epstein correctly argued that punitive damages EFTA00729110 Doe v. Epstein Page No. 2 are not recoverable under 18 U.S.C. §2255. Therefore Plaintiff "ag

.: 08-C1V- 80893 - MARRA/JOHNSON Plaintiff, v. JEFFREY EPSTEIN, Defendants. Defendant, Jeffrey Epstein

ts have held that cases interpreting the Federal Rico Statute, title 18, U.S.C., are persuasive as to the meaning of Florida's Rico statute. . . "); Connor v. Halifax Hospital Medical Center, EFTA00729113 Doe v. Epstein Page No. 5 135 F.Supp.2d, 1198, 1219 i . Fla. 2001); and Magnum v. Archdiocese of Philadelphia, 253 Fed.Appx. 2

CT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE, CASE NO.: 08-C1V- 80893 - MARRA/JOHNSON Plaintiff, v. JEFFREY EPSTEIN, Defendants. Defendant, Jeffrey Epstein's Reply to Plaintiff's Response In Opposition to Defendant's Motion To Dismiss, For More Definite Statement & To Strike Directed To Plaintiff Jane Do

as requested. Plaintiff filed her Response in Opposition to the Motion to Dismiss. As to Count II, Plaintiff conceded in her opposition motion that Epstein correctly argued that punitive damages EFTA00729105 Doe v. Epstein Page No. 2 are not recoverable under 18 U.S.C. §2255. Therefore Plaintiff "ag

.: 08-C1V- 80893 - MARRA/JOHNSON Plaintiff, v. JEFFREY EPSTEIN, Defendants. Defendant, Jeffrey Epstein

ts have held that cases interpreting the Federal Rico Statute, title 18, U.S.C., are persuasive as to the meaning of Florida's Rico statute. . . "); Connor v. Halifax Hospital Medical Center, EFTA00729108 Doe v. Epstein Page No. 5 135 F.Supp.2d, 1198, 1219 i . Fla. 2001); and Magnum v. Archdiocese of Philadelphia, 253 Fed.Appx. 2