Epstein Secrets

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 t

ion For Time Certain Based On Parallel Civil And Criminal Proceedings With Incorporated Memorandum Of Law Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN") by and through his undersigned attorneys, hereby moves this Court for the entry of an order staying or continuing this action for a time certain

13 In the instant case, the privilege applies as Defendant EPSTEIN "has reasonable cause to apprehend danger from a

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

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

attorney for JEFFREY EPSTEIN. 3. I represented Mr. EPSTEIN in the negotiation of and entering into a Non-Pr

t Palm Beach, FL 33401-5012 561-659-8300 Fax: 561-835-8691 jaqesqObellsouth.net Co-Counsel for Defendant Jeffrey Epstein Respectfully sub By: ROBERT D CRITTON, JR., ESQ. Florida Ba No. 224162 rcritabcl aw.com MICHAEL J. PIKE, ESQ. Florida Bar #617296 mpikeabciclaw.com BURMAN, CRITI-ON, LUTTIER & COLEMAN

rth is in the hundreds of millions of dollars - if not, indeed, a billion dollars. See, e.g., New York Time, July 1, 2008, at A2 ("Over the weekend Jeffrey E. Epstein, who after years of advising billionaires became a billionaire himself, left his estate on Little St. James Island, with its staff of 70 and its fl

ant PLAINTIFF, JANE DOE'S MOTION FOR INJUNCTION RESTRAINING FRAUDULENT TRANSFER OF ASSETS, APPOINTMENT OF A RECEIVER TO TAKE CHARGE OF PROPERTY OF EPSTEIN, AND TO POST A $15 MILLION BOND, TO SECURE POTENTIAL JUDGMENT COMES NOW Plaintiff Jane Doe, by and through undersigned counsel, and hereby files t

IS ASSETS. As noted in the material facts above, defendant Epstein is currently making fraudulent transfers of his

ork Time, July 1, 2008, at A2 ("Over the weekend Jeffrey E. Epstein, who after years of advising billionair

ork Time, July 1, 2008, at A2 ("Over the weekend Jeffrey E. Epstein, who after years of advising billionaire

#23. 14. Epstein has blocked all discovery, in this and other related cases, regarding his assets. Affidavit of Paul Cassell at ¶¶ 7, 8. ARGUMENT I. EPSTEIN IS FRAUDULENTLY TRANSFERRING HIS ASSETS. As noted in the material facts above, defendant Epstein is currently making fraudulent transfers of his as

Palm Beach, FL 33401-5012 561-659-8300 561-835-8691 Fax jaoesoebellsouth.net Co-Counsel for Defendant Jeffrey Epstein Respectfully sub , By: ROBERT D CRITTON, JR., ESQ. Florida B. No. 224162 [email protected] BURMAN, CRITTON, LUTTIER & COLEMAN 515 N. Flagler Drive, Suite 400 West Palm Beach, FL 33401 561/

2/2009 Page 1 of 9 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2 Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION TO COMPEL PLAINTIFF, JANE DOE NO. 2, To ANSWER DEFENDANT'S FIRST SET OF INTERROGATORIES AND TO OVERRULE OB

ICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2 Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION TO COMPEL PLAINTIFF, JANE DOE NO. 2, To ANSWER DEFENDANT'S FIRST SET OF INTERROGATORIES AND TO OVERRULE OBJECTIONS, AND FOR AN AWARD OF D

2 Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION TO COMPEL PLAINTIFF, JANE DOE NO. 2, To

19-MARRA-JOHNSON JANE DOE NO. 2 Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION

resses and phone numbers of all males, excluding Mr. Epstein, with whom you have had sexual activity since age

eiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 Co-Counsel for Defendant Jeffrey Epstein Respectfully sub By: ROBERT D CRITTON, JR., ESQ. Florida Ba No. 224162 J. E, SQ. Florida Bar #617296 BURMAN, CRITTON, LUTTIER & COLEMAN 515 N. Flagler Drive, Suite 400 West Palm Beach,

se - flsd Page 1 of 17 U.S. District Court Southern District of Florida (West Palm Beach) CIVIL DOCKET FOR CASE #: 9:08-cv-80380-KAM Doe No. 4'. Epstein Assigned to: Judge Kenneth A. Marra Referred to: Magistrate Judge Linnea R. Johnson Lead case: 9:08-ev-80111-.KAM Member case• (View Member Case)

ON Plaintiffs Jane Doe No. 101 and Jane Doe 102's Motion for No- Contact Order Plaintiffs Jane Doe No. 101 and Jane Doe No. 102's Reply to Defendant Jeffrey Epstein's Response to Plaintiffs Jane Doe No. 101 and Jane Doe No. 102's Motion for a No-Contact Order filed by Jane Doe No. 101, Jane Doe No. 102. Associate

4/21/2008) 05/22/2008 6 AFFIDAVIT of Service for Summons and Complaint served on Jeffrey Epstein on May 7, 2008, filed by Jane Doe No. 4. (Herman, Jeffrey) (Entered: 05/22/2008) 05/29/2008 7. Plaintiffs MOTION for Entry of Default by Clerk Against Defendant by Jane Doe No. 4. (Attachments: # 1 Exhib

. 4 1. Plaintiff, JEFFREY EPSTEIN Defendant. DEFENDANT EPSTEIN'S MOTION TO DISMISS AND MOTION FOR MORE DEFINITE

, Esq. Lewis Tein, P.L. 3059 Grand Avenue, Suite 340 Coconut Grove, FL 33133 rax: Counse or e endant Jeffrey Epstein Respectfully submitt By: ROBERT D CRITTON, JR., ESQ. Florida Ba No. 224162 , ESQ. Florida Bar #617296 BURMAN, CRITTON, LUTTIER & COLEMAN 515 N. Flagler Drive, Suite 400 West ach, FL 33401

2009 Page 1 of 12 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO.2, Plaintiff, CASE NO.; 08-CV-80119-MARRA/JOHNSON vs. JEYPREY EPSTEIN, Defendant. JANE DOE NO.3, CASE NO.; 08-CV-80232-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO.4, CASE NO.; 08-CV-803

vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 102, CASE NO.; 08-CV-80656-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. Defendant, Jeffrey Epstein's, Reply to Plaintiff, Carolyn Margaret Andriano'st Opposition to Epstein's Motion To Strike Cases From Current Trial Docket And Motion to Continue Ca

cket And Motion to Continue Case And/Or Alternative Motion to Modify Trial and Scheduling Order Deadlines Defendant, JEFFREY EPSTEIN (hereinafter "EPSTEIN"), by and through his undersigned attorneys, hereby files his Reply to Plaintiff, (hereinafter "CMA"), Opposition to Motion To Strike Cases From Cu

NO.; 08-CV-80232-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO.4, CASE NO.; 0

itional 3 months as to all deadlines, including the trial date; and d. for such other and further relief as this couryldeems just and proper. By: ROBERT D CRITTON, JR., ESQ. Florida Bar o. 224162 MICHAEL J. PIKE, ESQ. Florida Bar #617296 Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing

/2009 Page 1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT's MOTION FOR EXTENSION OF TIME IN WHICH TO RESPOND TO PLAINTIFF'S SECOND AMENDED COMPLAINT Defendant, Jeffrey Epstein, (her

nt. DEFENDANT's MOTION FOR EXTENSION OF TIME IN WHICH TO RESPOND TO PLAINTIFF'S SECOND AMENDED COMPLAINT Defendant, Jeffrey Epstein, (hereinafter "Epstein") by and through his undersigned attorneys, respectfully moves this Court for an extension of time in which to respond to Plaintiffs Second Amended

Complaint. Robert D. •ritton, Jr. Attorney f r Defendant Epstein Certificate of Se ce I HEREBY CERTIFY that a t

9-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT's MOTION FOR EXTE

South Suite 1400 West Palm Beach, FL 33401-5012 561-659-8300 Fax: 561-835-8691 Co-Counsel for Defendant Jeffrey Epstein Respectfully sub By: ROBERT D CRITTON, JR., ESQ. Florida Bar No. 224162 rcritebcIclaw.com MICHAEL J. PIKE, ESQ. Florida Bar #617296 BURMAN, CRITTON, LUTTIER & COLEMAN 515 N. Flagler Driv

ntiff, JANE DOE 3, by and through their undersigned counsel, and pursuant to Federal Rules of Civil Procedure Rule 33, hereby responds to Defendant, JEFFREY EPSTEIN'S First Set of Interrogatories to Plaintiff as follows: General Oblections 1. Plaintiff objects to Defendant's Interrogatories to the extent that th

CT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S RESPONSE TO PLAINTIFF'S MOTION FOR PROTECTIVE ORDER AND TO QUASH SUBPOENA FOR DEPOSITION OF JANE DOE NO.3. MOTION TO CONSOLIDATE CASES FOR PURPO

2, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S RESPONSE TO PLAINTIFF'S MOTION FOR PROTECTIVE

9-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S RESPONS

Court deny the Motion, enter an order allowing for the relief requested herein and for such other relief as this court deems just and proper. By: ROBERT D CRITTON, JR., ESQ. Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of the Court using CM/ECF.

80656-CIV-MARRA/JOHNSON Plaintiff; JEFFREY EPSTEIN, Defendant. EPSTEIN'S RESPONSE TO JANE DOE'S MOTION TO PROVIDE RECENTLY-OBTAINED AFFIDAVIT OF JEFFREY E. EPSTEIN IN SUPPORT OF MATERIAL FACTS SUPPORTING MOTION FOR APPOINTMENT OF A RECEIVER TO TAKE CHARGE OF PROPERTY OF EPSTEIN Defendant, JEFFREY E. EPSTEIN (

N CASE NO.: 08-CV-80380-MARRA/JOHNSON CASE NO.: 08-CV-80381-M.ARRA/JOHNSON EFTA00729223 Jane Doe v. Epstein Case No. 08-CV-80119-MARRA/JOHNSON Epstein's Response to Jane Doe's Motion to Provide Recently Obtained Affidavit of Epstein Page 2 of 9 JANE DOE NO. 6, Plaintiff, JEFFREY EPSTEIN, Defend

MOTION TO PROVIDE RECENTLY-OBTAINED AFFIDAVIT OF JEFFREY E. EPSTEIN IN SUPPORT OF MATERIAL FACTS SUPPORTING

MOTION TO PROVIDE RECENTLY-OBTAINED AFFIDAVIT OF JEFFREY E. EPSTEIN IN SUPPORT OF MATERIAL FACTS SUPPORTING

n & Horowitz, P.A. 18205 Biscayne Boulevard Suite 2218 Miami, FL 33160 305-931-2200 Fax: 305-931-0877 Counsel for Plaintiffi Respectful! By: ROBERT D CRITTON, JR., ESQ. ri a B o. 224162 submitted, DAVID A. YAREMA, ESQ. Florida Bar No. 12492 IER & COLEMAN 515 N. Flagler Drive, Suite 400 West Palm Beach,

80656-CIV-MARRA/JOHNSON Plaintiff; JEFFREY EPSTEIN, Defendant. EPSTEIN'S RESPONSE TO JANE DOE'S MOTION TO PROVIDE RECENTLY-OBTAINED AFFIDAVIT OF JEFFREY E. EPSTEIN IN SUPPORT OF MATERIAL FACTS SUPPORTING MOTION FOR APPOINTMENT OF A RECEIVER TO TAKE CHARGE OF PROPERTY OF EPSTEIN Defendant, JEFFREY E. EPSTEIN (

N CASE NO.: 08-CV-80380-MARRA/JOHNSON CASE NO.: 08-CV-80381-M.ARRA/JOHNSON EFTA00599334 Jane Doe v. Epstein Case No. 08-CV-80119-MARRA/JOHNSON Epstein's Response to Jane Doe's Motion to Provide Recently Obtained Affidavit of Epstein Page 2 of 9 CASE NO.: 08-80994-C1V-MARRA/JOHNSON JANE DOE NO. 6,

MOTION TO PROVIDE RECENTLY-OBTAINED AFFIDAVIT OF JEFFREY E. EPSTEIN IN SUPPORT OF MATERIAL FACTS SUPPORTING

MOTION TO PROVIDE RECENTLY-OBTAINED AFFIDAVIT OF JEFFREY E. EPSTEIN IN SUPPORT OF MATERIAL FACTS SUPPORTING

unsel of record identified on the following Service List in the manner specified by CM/ECF on this day of August 2009 Respectfully submitted, By: ROBERT D CRITTON, JR., ESQ. Florida No. 224162 rcrit@bc claw.com DAVID A. YAREMA, ESQ. Florida Bar No. 12492 [email protected] BURMAN, CRITTON, LUTTIER & COLEMAN

80656-CIV-MARRA/JOHNSON Plaintiff; JEFFREY EPSTEIN, Defendant. EPSTEIN'S RESPONSE TO JANE DOE'S MOTION TO PROVIDE RECENTLY-OBTAINED AFFIDAVIT OF JEFFREY E. EPSTEIN IN SUPPORT OF MATERIAL FACTS SUPPORTING MOTION FOR APPOINTMENT OF A RECEIVER TO TAKE CHARGE OF PROPERTY OF EPSTEIN Defendant, JEFFREY E. EPSTEIN (

N CASE NO.: 08-CV-80380-MARRA/JOHNSON CASE NO.: 08-CV-80381-M.ARRA/JOHNSON EFTA00599343 Jane Doe v. Epstein Case No. 08-CV-80119-MARRA/JOHNSON Epstein's Response to Jane Doe's Motion to Provide Recently Obtained Affidavit of Epstein Page 2 of 9 CASE NO.: 08-80994-C1V-MARRA/JOHNSON JANE DOE NO. 6,

MOTION TO PROVIDE RECENTLY-OBTAINED AFFIDAVIT OF JEFFREY E. EPSTEIN IN SUPPORT OF MATERIAL FACTS SUPPORTING

MOTION TO PROVIDE RECENTLY-OBTAINED AFFIDAVIT OF JEFFREY E. EPSTEIN IN SUPPORT OF MATERIAL FACTS SUPPORTING

unsel of record identified on the following Service List in the manner specified by CM/ECF on this day of August 2009 Respectfully submitted, By: ROBERT D CRITTON, JR., ESQ. Florida No. 224162 rcrit@bc claw.com DAVID A. YAREMA, ESQ. Florida Bar No. 12492 [email protected] BURMAN, CRITTON, LUTTIER & COLEMAN