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

rris, J., held that certiorari was available to quash order permitting discovery that trial court acknowledged was irrelevant Certiorari granted. West Headnotes 11) Pretrial Procedure 307A C=31 307A Pretrial Procedure 307All Depositions and Discovery 307A11(A) Discovery in General 307Ak31 k. Relevancy an

EY EPSTEIN, Defendant. CASE NO.: 09-80469-CIV-MARRA-JOHNSON CASE NO.: 09-80591-CIV-MARRA-JOHNSON CASE NO.: 09-80656-CIV-MARRA/JOHNSON DEFENDANT, JEFFREY EPSTEIN'S REPLY TO JANE DOE NO. 101 AND JANE DOE NO. 102'S RESPONSE IN OPPOSITION TO MOTION TO COMPEL AND IDENTIFY JANE DOE NUMBERS 101 AND 102 IN THIRD PART

CASE NO.: 08-CV-8038I-MARRA/JOHNSON EFTA00182748 Case 9:08-cv-80119-KAM Document 152 Entered on FLSD Docket 06/10/2009 Page 2 of 8 Doe 101 v. Epstein Page 2 JANE DOE NO. 6, Plaintiff, JEFFREY EPSTEIN, Defendant. CASE NO.: 08-80994-CIV-MARRA/JOHNSON CASE NO.: 08-80993-CIV-MARRA/JOHNSON JANE

OHNSON Plaintiff, JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S RESPONSE TO PLAINTIFFS JANE DOE NOS. 101 AND 10

v. Epstein Page 4 Defendant, Jeffrey Epstein, ("Mr. Epstein"), by and through his undersigned attorneys, her

ICT OF FLORIDA JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN Defendant. JANE DOE NO. 3, Plaintiff,

mise not to prosecute defendant, even though defendant was acquitted on drug charges arising out of incident in question. Reversed and remanded. West Headnotes Criminal Law 110 *C=.42.5(3) 110 Criminal Law 11011 Defenses in General I 10k42 Immunity to One Furnishing Inform- ation or Evidence I 1 0k42.5

om the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN's bedroom at 358 El Brillo Way. (113) In or around the last half of 2004, Defendantr FREY EPSTEIN asked Jane Doe #14 to provide her telephone number. 22 EFTA00191745 (114) In or around the last half of 2004, Defendant JEFFREY EPSTEIN instruc

nd the New York residence so that JEFFREY EPSTEIN could, in exchange for money, engage in lewd conduct with those minor females in order to satisfy JEFFREY EPSTEIN's prurient interests. 6 EFTA00191729 Manner and Means 29. The manner and means by which the Defendants and other participants sought to accompli

t 358 El Brillo Way, Palm Beach, Florida, in the Southern District of Florida (hereinafter referred to as "358 El Brillo Way"). 5. DefendRJEFFREY EPSTEIN owned a property located at 9 East 71st Street, New York, New York (hereinafter referred to as "the New York residence"). 6. Defendant JEFFREY EPS

JEFFREY EPSTEIN asked Jane Doe #3 to recruit additional females to come to 358 El Brillo Way. (29) On or about November 8, 2004, one of Defendant JEFFREY EIN's employees prepared a written telephone message for Defendant JEFFREY EPSTEIN's review regarding a telephone call received from Jane Doe #3 t

remanded. McKay, Circuit Judge, dissented and filed opinion, in which Seymour, Circuit Judge, joined, also filing a separate dissenting opinion. West Headnotes Ill Bail 49 C=.44(1) 49 Bail 491I In Criminal Prosecutions 49k41 Right to Release on Bail 49k44 Pending Appeal or Other Proceeding for Review

d as COnsaa Is binding and ow/ not be Menem arter the CorpOratkrn has made a mid election. (Shareholders sign and date belted Otw Signature Date Jeffrey E. Epstein 6100 Red Hook Qugrte Suite B-3 - . ..! 1 --1-' 100 1/1/01 12/3 bin, ThUITIMS I UbV UV* I. 2 ( • t1 under penalties or perjury. I declar

-000101 EFTA00227481 imp-u'stuu0 Oi:b0pe Froe-J Epstein i Coapany, Inc T-150 P.004/005 F-135 CERTIFIC

olders sign and date belted Otw Signature Date Jeffrey E. Epstein 6100 Red Hook Qugrte Suite B-3 - . .

olders sign and date belted Otw Signature Date Jeffrey E. Epstein 6100 Red Hook Qugrte Suite B-3 - . ..

a privilege, but (2) Florida statute imposing secrecy on grand jury does not create evidentiary privilege. Affirmed in pan and dismissed in part. West Headnotes Ill Criminal Law €1023(3) 110k1023(3) Grand jury proceeding is not a 'civil action" for purposes of statute permitting interlocutory appeals in

. See Exhibit A. was interviewed by the FBI on March 17, 2011. During the interview process, the FBI agents informed that they had retrieved from Jeffrey E stein's homes, video to es CDs and DVDs, pictures and documents, that include video tapes of pictures of and documents (including but not limited to e-mai

d from the following residences owned by Jeffrey Epstein. 1) 358 El Brillo Way Palm Beach, Florida 3348

BI agents informed that they had retrieved from Jeffrey E stein's homes, video to es CDs and DVDs, pictures

a privilege, but (2) Florida statute imposing secrecy on grand jury does not create evidentiary privilege. Affirmed in part and dismissed in pan. West Headnotes [1] Criminal Law C=1023(3) 110k1023(3) Grand jury proceeding is not a "civil action" for purposes of statute permitting interlocutory appeals in

defendant-appellant Miguel Plascencia-Alvarado. Jeffrey E. Ellis, Law Offices of Ellis, Holmes & Witchley,

defendant-appellant Miguel Plascencia-Alvarado. Jeffrey E. Ellis, Law Offices of Ellis, Holmes & Witchley,

ngage in sexual activity with a 13-year-old boy, established beyond a reasonable doubt all elements of the charged offenses. Ordered accordingly. West Headnotes Ill Infants C=13 211k13 Most Cited Cases To convict for coercion and enticement, the Government must prove the following elements beyond a reaso