Epstein Secrets

-BARING BETTY STOKES PARALEGALS RITA H. BUDNYK OP COUNSEL ED RICCI SPECIAL CONSUMER JUSTICE COUNSEL Dear Judge Hafele: Enclosed, please find Jeffrey Epstein's Response in Opposition to ll's Motion for Inspection and to Compel Discovery, which are set for hearing before Your Honor on December 14, 2009 at 8

E FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502008CA037319XWMB AB Plaintiff, v. JEFFREY EPSTEIN, Defendants. EPSTEIN'S RESPONSE IN OPPOSITION TO MOTION FOR INSPECTION AND TO COMPEL DISCOVERY AND MOTION FOR PROTECTIVE ORDER AND INCORPORATED MEMORANDUM OF LAW Defen

in from disclosing the identity of any person who has knowledge or are in possession of physical evidence (i.e. photographs, EFTA00723281 B,B. v, Eosteiq Case No. 502008CA03 XMB AB Epstein's Objections to Request and Motion for Protective Order Page 10 of 22 videos, written statements, etc.) pert

P. 1.280(c), and states: I. Introduction 1. Mr. Epstein's deposition was set for September 2, 2009, and M

Motion to Compel as to certain requests to which Defendant Epstein was asserting a Fifth Amendment privilege. By th

P.A. BERNARD LESEDEKER. MARK T. LL/TTIER. P.A. JEFFREY C. PEPIN MICHAEL J. PIKE HEATHER. MCNAMARA RUDA

tain a warrant based on probable cause, and the warrant would have to particularly describe the thing to be seized and the place to be searched. See Dalia v. U.S., 441 U.S. 238 (1979). 11. Contrary to the foregoing restrictions imposed on the government, seeks a non-particularized and limitless sear

To: Jeffrey [email protected]] From: COLOM, Olivier Sent: Fri 9/6/2013 3:07:02 PM Subject: RE: Re: FYI: We'll have dinner with Mo Ibrahim on S

We'll have dinner with Mo Ibrahim on Sunday 22. Free anytime on Monday 23 and also on Tuesday 24 (till 3pm). Hope you're having a great time De : Jeffrey Epstein [mailto:[email protected]] Envoyé : mercredi 4 septembre 2013 12:20 : COLOM, Olivier Objet : Re: Re: no , sorry . look forward to seeing you

). Hope you're having a great time De : Jeffrey Epstein [mailto:[email protected]] Envoyé : mercredi

ptembre 2013 12:20 : COLOM, Olivier Objet : Re: Re: no , sorry . look forward to seeing you 20 I 3/9/4 COLOM, Olivier Do you know someone called Dalia GARIH ? She wants to see me in NY. Think it's about the conglomerate built by her father in Turkey (Alorko Holding) De : Jeffrey Epstein [mailto:je

To: COLOM, Olivie From: Jeffrey Epstein Sent: Fri 9/6/2013 3:21:53 PM Subject: Re: Re: great 2013/9/6 COLOM, Olivier FYI: We'll have dinner with Mo Ibrahim on Sunday 22. Free anytim

TA_R1_00434978 EFTA01960587 A : COLOR Olivier Objet : Re: ill check, but will definetly schedule private time 2013/9/3 COLOM, Olivier < ==. Hi Jeffrey Would be nice to meet both. Maybe breakfast with Joshua on Monday 23 for example? About Ehud Barak, what are the options? We will get to NY on Sund

To: COLOM, Olivie From: Jeffrey Epstein Sent: Fri 9/6/2013 3:21:53 PM Subject: Re: Re:

ptembre 2013 12:20 A : COLOM, Olivier Objet : Re: Re: no , sorry . look forward to seeing you 2013/9/4 COLOM, Olivier Do you know someone called Dalia GARIH ? She wants to see me in NY. Think it's about the conglomerate built by her father in Turkey (Alorko Holding) De : Jeffrey Epstein [mailto:ie