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

on Lee Stedman, PA., Orlando, and Jack E. Carstensen of Rigdon, Alexander & Rigdon, L.L.P., Cocoa, for Petitioner. '707 Julie H. Littlty-Rubin, of Lytal, Reiter, Clark, Fountain & Williams, L.L.P., West Palm Beach, and Robert M. Moletteire, of Graham, Moletteire, 'futile & Torpy, PA., Melbourne, fo

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

Sharon Lee Stedman, PA., Orlando, and Jack E. Carstensen of Rigdon, Alexander & Rigdon, M, Cocoa, for Petitioner. '707 Julie H. Littity-Rubin of Lytal, Reiter, Clark, Fountain & Williams, West Paint Beach, and Robert M. Moletterre, o Graham, Moletteire, 'futile & Torpy, PA., Melbourne, for Respo

of 2007 through September of 2007, discussions took place between the U.S. Attorney's Office for the Southern District of Florida ("the Office") and Jeffrey Epstein's attorneys. (DE 407 at ¶ 9.) On February I, 2007, Epstein's defense team sent a 24-page letter to the Office going over what they intended to presen

ial Facts (hereinafter, "DE 407" at 9 1.) Because EFTA00040739 Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 2 of 33 Epstein and his co-conspirators knowingly traveled in interstate and international commerce to sexually abuse Jane Doe 1, Jane Doe 2 and others, they commit

re as follows: From between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls

ern about "the effect of taking the position that Mr. Epstein's house is in the special maritime and territori

September 25, 2007, the line prosecutor sent an email to Lefkowitz which stated in part: "They [Ted Babbitt, Stuart Grossman, Chris Searcy, [L]ake Lytal] are all very good personal injury lawyers, but I have concerns about whether there would be an inherent tension because they may feel that THEY mig

of 2007 through September of 2007, discussions took place between the U.S. Attorney's Office for the Southern District of Florida ("the Office") and Jeffrey Epstein's attorneys. (DE 407 at ¶ 9.) On February I, 2007, Epstein's defense team sent a 24-page letter to the Office going over what they intended to presen

ial Facts (hereinafter, "DE 407" at 9 1.) Because EFTA00081333 Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 2 of 33 Epstein and his co-conspirators knowingly traveled in interstate and international commerce to sexually abuse Jane Doe 1, Jane Doe 2 and others, they commit

re as follows: From between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls

ern about "the effect of taking the position that Mr. Epstein's house is in the special maritime and territori

September 25, 2007, the line prosecutor sent an email to Lefkowitz which stated in part: "They [Ted Babbitt, Stuart Grossman, Chris Searcy, [L]ake Lytal] are all very good personal injury lawyers, but I have concerns about whether there would be an inherent tension because they may feel that THEY mig

of 2007 through September of 2007, discussions took place between the U.S. Attorney's Office for the Southern District of Florida ("the Office") and Jeffrey Epstein's attorneys. (DE 407 at ¶ 9.) On February I, 2007, Epstein's defense team sent a 24-page letter to the Office going over what they intended to presen

ial Facts (hereinafter, "DE 407" at 9 1.) Because EFTA00083566 Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 2 of 33 Epstein and his co-conspirators knowingly traveled in interstate and international commerce to sexually abuse Jane Doe 1, Jane Doe 2 and others, they commit

re as follows: From between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls

ern about "the effect of taking the position that Mr. Epstein's house is in the special maritime and territori

September 25, 2007, the line prosecutor sent an email to Lefkowitz which stated in part: "They [Ted Babbitt, Stuart Grossman, Chris Searcy, [L]ake Lytal] are all very good personal injury lawyers, but I have concerns about whether there would be an inherent tension because they may feel that THEY mig

of 2007 through September of 2007, discussions took place between the U.S. Attorney's Office for the Southern District of Florida ("the Office") and Jeffrey Epstein's attorneys. (DE 407 at ¶ 9.) On February I, 2007, Epstein's defense team sent a 24-page letter to the Office going over what they intended to presen

ial Facts (hereinafter, "DE 407" at 9 1.) Because EFTA00098414 Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 2 of 33 Epstein and his co-conspirators knowingly traveled in interstate and international commerce to sexually abuse Jane Doe 1, Jane Doe 2 and others, they commit

re as follows: From between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls

ern about "the effect of taking the position that Mr. Epstein's house is in the special maritime and territori

September 25, 2007, the line prosecutor sent an email to Lefkowitz which stated in part: "They [Ted Babbitt, Stuart Grossman, Chris Searcy, [L]ake Lytal] are all very good personal injury lawyers, but I have concerns about whether there would be an inherent tension because they may feel that THEY mig

of 2007 through September of 2007, discussions took place between the U.S. Attorney's Office for the Southern District of Florida ("the Office") and Jeffrey Epstein's attorneys. (DE 407 at ¶ 9.) On February I, 2007, Epstein's defense team sent a 24-page letter to the Office going over what they intended to presen

ial Facts (hereinafter, "DE 407" at 9 1.) Because EFTA00794122 Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 2 of 33 Epstein and his co-conspirators knowingly traveled in interstate and international commerce to sexually abuse Jane Doe 1, Jane Doe 2 and others, they commit

re as follows: From between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls

ern about "the effect of taking the position that Mr. Epstein's house is in the special maritime and territori

September 25, 2007, the line prosecutor sent an email to Lefkowitz which stated in part: "They [Ted Babbitt, Stuart Grossman, Chris Searcy, [L]ake Lytal] are all very good personal injury lawyers, but I have concerns about whether there would be an inherent tension because they may feel that THEY mig