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

ir. 2004), cited in Fla. Stat. 772.102, annotated, (analysis applied to claims under the Federal Rico Act is equally applicable to claims under the Florida Rico statute). 2. Moore v. Potter, 142 Fed. Appx. WL 1600194 (11Th Cir. 2005). 3. Pilkington v. United Airlines 112 F.3d 1532, 1536 (11th Cir,1997)

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

ir. 2004), cited in Fla. Stat. 772.102, annotated, (analysis applied to claims under the Federal Rico Act is equally applicable to claims under the Florida Rico statute). 2. Moore v. Potter, 142 Fed. Appx. WL 1600194 (11Th Cir. 2005). 3. Pilkington v. United Airlines 112 F.3d 1532, 1536 (11th Cir,1997)

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

simple - personal injury damages are not cognizable under FCRCP. To hold otherwise would fly in the face of the several RICO decisions interpreting Florida Rico and its application, and would open the flood gates for every personal injury claim to be transformed into a Rico claim. In line with the cases cit

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

simple - personal injury damages are not cognizable under FCRCP. To hold otherwise would fly in the face of the several RICO decisions interpreting Florida Rico and its application, and would open the flood gates for every personal injury claim to be transformed into a Rico claim. In line with the cases cit