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

o a Non-Prosecution Agreement with the United States Attorney General's Office for the Federal Southem District of Florida and the State Attorney's Office for Palm Beach County. Under the terms of the Non-Prosecution Agreement, any criminal prosecution against Epstein is deferred as long as he abides by the certain terms a

, which has been consolidated for purposes of discovery, Plaintiffs are former under-age girls who allege they were sexually assaulted by Defendant, Jeffrey Epstein ("Epstein"), at his Palm Beach mansion home. The scheme is alleged to have taken place over the course of several years in or around 2004-2005, when

nsolidated for purposes of discovery, Plaintiffs are former under-age girls who allege they were sexually assaulted by Defendant, Jeffrey Epstein ("Epstein"), at his Palm Beach mansion home. The scheme is alleged to have taken place over the course of several years in or around 2004-2005, when the girls

requests for production that were propounded on Defendant Epstein. Defendant has responded by asserting several obj

-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. Related cases: 08-80232, 0

a Non-Prosecution Agreement with the United States Attorney General's Office for the Federal Southern District of Florida and the State Attorney's Office for Palm Beach County. Under the terms of the Non-Prosecution Agreement, any criminal prosecution against Epstein is deferred as long as he abides by the certain terms a

, which has been consolidated for purposes of discovery, Plaintiffs are former under-age girls who allege they were sexually assaulted by Defendant, Jeffrey Epstein ("Epstein"), at his Palm Beach mansion home. The scheme is alleged to have taken place over the course of several years in or around 2004-2005, when

nsolidated for purposes of discovery, Plaintiffs are former under-age girls who allege they were sexually assaulted by Defendant, Jeffrey Epstein ("Epstein"), at his Palm Beach mansion home. The scheme is alleged to have taken place over the course of several years in or around 2004-2005, when the girls

requests for production that were propounded on Defendant Epstein. Defendant has responded by asserting several obj

-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. Related cases: 08-80232, 0

a Non-Prosecution Agreement with the United States Attorney General's Office for the Federal Southern District of Florida and the State Attorney's Office for Palm Beach County. Under the terms of the Non-Prosecution Agreement, any criminal prosecution against Epstein is deferred as long as he abides by the certain terms a

PERSONS WITH KNOWLEDGE REGARDING THE NEGOTIATION OF THE NON-PROSECUTION AGREEMENT 1. U.S. Attorney's Office 2. Counsel for Jeffrey Epstein Kenneth Starr Jay Lefkowitz Roy Black Gerald Lefcourt Lilly Ann Sanchez Guy Lewis Michael Tein Jack Goldberger Alan Dershowitz Martin Weinb

1. U.S. Attorney's Office 2. Counsel for Jeffrey Epstein Kenneth Starr Jay Lefkowitz Roy Black Gerald

EEMENT 1. U.S. Attorney's Office 2. Counsel for Jeffrey Epstein Kenneth Starr Jay Lefkowitz Roy Black

owitz Roy Black Gerald Lefcourt Lilly Ann Sanchez Guy Lewis Michael Tein Jack Goldberger Alan Dershowitz Martin Weinberg 3. State Attorney's Office for Palm Beach County Barry Krisher Lanna Behlolahvek EFTA00205681

Entered on FLSD Docket 08/04/2009 Page 2 of 22 JEFFREY EPSTEIN, Defendant. JANE DOE NO. 6, CASE NO.:

, which has been consolidated for purposes of discovery, Plaintiffs are former under-age girls who allege they were sexually assaulted by Defendant, Jeffrey Epstein ("Epstein"), at his Palm Beach mansion home. The scheme is alleged to have taken place over the course of several years in or around 2004-2005, when

nsolidated for purposes of discovery, Plaintiffs are former under-age girls who allege they were sexually assaulted by Defendant, Jeffrey Epstein ("Epstein"), at his Palm Beach mansion home. The scheme is alleged to have taken place over the course of several years in or around 2004-2005, when the girls

a Non-Prosecution Agreement with the United States Attorney General's Office for the Federal Southern District of Florida and the State Attorney's Office for Palm Beach County. Under the terms of the Non-Prosecution Agreement, any criminal prosecution against Epstein is deferred as long as he abides by the certain terms a

, which has been consolidated for purposes of discovery, Plaintiffs are former under-age girls who allege they were sexually assaulted by Defendant, Jeffrey Epstein ("Epstein"), at his Palm Beach mansion home. The scheme is alleged to have taken place over the course of several years in or around 2004-2005, when

nsolidated for purposes of discovery, Plaintiffs are former under-age girls who allege they were sexually assaulted by Defendant, Jeffrey Epstein ("Epstein"), at his Palm Beach mansion home. The scheme is alleged to have taken place over the course of several years in or around 2004-2005, when the girls

-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. Related cases: 08-80232, 0

a Non-Prosecution Agreement with the United States Attorney General's Office for the Federal Southern District of Florida and the State Attorney's Office for Palm Beach County. Under the terms of the Non-Prosecution Agreement, any criminal prosecution against Epstein is deferred as long as he abides by the certain terms a

ll, LEAD ATTORNEY, Podhurst Orseck Josefsberg et al, Miami, FL USA; Robert C. Josefsberg, LEAD ATTORNEY, Podhurst Orseck, P.A., Miami, FL USA. For Jeffrey Epstein, Defendant (9:09-cv-80591-KAM): Michael James Pike, LEAD ATTORNEY, Pike & Lustig, LLP, West Palm Beach, FL; Robert Deweese Critton, Jr., LEAD ATTOR

nsolidated for purposes of discovery, Plaintiffs are former under-age girls who allege they were sexually assaulted by Defendant, Jeffrey Epstein ("Epstein"), at his Palm Beach mansion home. The scheme is alleged to have taken place over the course of several years in or around 2004-2005, when the girls

ORNEY, Podhurst Orseck, P.A., Miami, FL USA. For Jeffrey Epstein, Defendant (9:09-cv-80591-KAM): Michael J

a Non-Prosecution Agreement with the United States Attorney General's Office for the Federal Southern District of Florida and the State Attorney's Office for Palm Beach County. Under the terms of the Non-Prosecution Agreement, any criminal prosecution against Epstein is deferred as long as he abides by the certain terms a

ll, LEAD ATTORNEY, Podhurst Orseck Josefsberg et al, Miami, FL USA; Robert C. Josefsberg, LEAD ATTORNEY, Podhurst Orseck, P.A., Miami, FL USA. For Jeffrey Epstein, Defendant (9:09-cv-80591-KAM): Michael James Pike, LEAD ATTORNEY, Pike & Lustig, LLP, West Palm Beach, FL; Robert Deweese Critton, Jr., LEAD ATTOR

nsolidated for purposes of discovery, Plaintiffs are former under-age girls who allege they were sexually assaulted by Defendant, Jeffrey Epstein ("Epstein"), at his Palm Beach mansion home. The scheme is alleged to have taken place over the course of several years in or around 2004-2005, when the girls

ORNEY, Podhurst Orseck, P.A., Miami, FL USA. For Jeffrey Epstein, Defendant (9:09-cv-80591-KAM): Michael J

a Non-Prosecution Agreement with the United States Attorney General's Office for the Federal Southern District of Florida and the State Attorney's Office for Palm Beach County. Under the terms of the Non-Prosecution Agreement, any criminal prosecution against Epstein is deferred as long as he abides by the certain terms a