Epstein Secrets

e No. 2, by and through her undersigned counsel, submits this Memorandum of Law in Response to Motion for Stay, as follows: INTRODUCTION Defendant Jeffrey Epstein's Motion to Stay this action is based on the incorrect premise that there are criminal actions pending against him in Palm Beach Circuit Court, State

deral action pending. This Notice discloses a confidential Agreement between the U.S. Attorney and Defendant, the terms of which were triggered when Epstein began serving his state imposed criminal sentence. Under the Agreement, according to the Notice, the U.S. Attorney "agreed to suspend its grand jur

pears at this point to be specious. Nonetheless, Defendant Epstein represents to this Court in his "Notice Concernin

-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. PLAINTIFF'S MEMORANDUM OF L

he right to reactivate the grand jury and indict Mr. Epstein should he breach any part of the Agreement during

stay under 28 U.S.C. §3509(k) is mandated because there is a "pending" federal criminal action. 18 U.S.C. §3509(k) DOES NOT AUTHORIZE A STAY OF A CIVIL LAWSUIT FILED BY AN ADULT PLAINTIFF Even if there were a criminal case pending, which there is not, 18 U.S.C. §3509(k) would not apply to the claim

ACTICE IN FLORIDA AND COLORADO Sent by E-Mail and U.S. Mail William Riley Riley Kiraly 5645 Coral Ridge Drive #391 Coral Springs, FL 33076 Re: Epstein Matter Dear Bill: November 20, 2009 AcilLevi J. BENAYENTE mmucm/wwsricATOR JESSICA CADWELL BOBBIE M. MCKENNA ASHLIE STOKEN•BOUNG BETTY STOKES

R.. P.A. I BERNARD A. !Amcor MARK T. LUTTIER.. JEFFREY C PENN MICHAEL J. PIKE HEATHER MCNAMAM RUDA DA

rsation, I asked whether the materials taken from Mr. Epstein's house in Palm Beach were ever inventoried and

TON. JR.. P.A. I BERNARD A. !Amcor MARK T. LUTTIER.. JEFFREY C PENN MICHAEL J. PIKE HEATHER MCNAMAM RUDA DAVID A. YAREMA 'FLORIDA BOARD MINIM, CIVIL TRIAL LAWYER ' ADMITTED TO PRACTICE IN FLORIDA AND COLORADO Sent by E-Mail and U.S. Mail William Riley Riley Kiraly 5645 Coral Ridge Drive #391

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV -MARRA/JOHNSON JANE DOE, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. / NOTICE OF TAKING VIDEO DEPOSITION PLEASE TAKE NOTICE that the Plaintiff, JANE DOE, will take the deposition of Leslie Wexler on Fr

ARRA/JOHNSON JANE DOE, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. / NOTICE OF TAKING VIDEO DEPOSITIO

8-CIV -MARRA/JOHNSON JANE DOE, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. / NOTICE OF TAKING VIDEO D

80893CIV-MARRA/JOHNSO (If the action is pending in another district, state where: SUBPOENA TO TESTIFY AT A DEPOSITION OR TO PRODUCE DOCUMENTS IN A CIVIL, ACTION To: GHISLANE NOELLE MAXWELL, 116 E. 65 LLC, NEW YORK I Testimony: YOU ARE COMMANDED to appear at the time, date, and place set forth below