Epstein Secrets

e notify the sender immediately by reply e-mail and then delete this message. From: Darren Indyke mallto Sent: Monday, April 03, 2017 1:39 PM To: Jeffrey Epstein Cc: Miller, Michael Subject: Re: Epstein - Update Can we insert in the Section relating to Epstein's and Groff's Statement of the Discovery Plan, just

00 Also, as I am thinking about this, is there anyway to highlight the conflict of interest of her own lawyer who have an outstanding claim against JE in order to introduce the possibility of other motives for this case? DARREN K. INDYKE DARREN K. INDYKE, PLLC 575 Lexington Avenue, 4th Floor New

All rights reserved. On Apr 3, 2017, at 1:12 PM, jeffrey E. < > wrote: why not highlight the fad that unde

nt: Monday, April 03, 2017 1:39 PM To: Jeffrey Epstein Cc: Miller, Michael Subject: Re: Epstein - Update Can we insert in the Section relating to Epstein's and Groff's Statement of the Discovery Plan, just after the clause"and her departure from the United States of her own volition." something the fo

including all attachments. Copyright of Darren K. Indyke, PLLC - C) 2017 Darren K. Indyke, PLLC — All rights reserved. On Apr 3, 2017, at 1:12 PM, jeffrey E. < > wrote: why not highlight the fad that under oath she said she is not seeking money damages. but only wants me in jail On Mon, Apr 3, 2017 at 5:5

ONFIDENTIAL AND PRIVILEGED ATTORNEY WORK PRODUCT Dear Jeffrey and Darren: Further to our March 30, 2017 email

l molestation and abuse cannot proceed anonymously without a sufficient showing of particularized harm to the plaintiff if anonymity is not allowed. Doe v. Smith, 189 FRD 239 (S.D.N.Y. 1998) (anonymous action alleging sexual molestation against psychiatrist not allowed), vacated on reconsideration based on n

ercial sex act. Page 2 of 9 EFTA00182943 CT DATE(S) DEFENDANT(S) VICTIM(S) STATUTES/CHARGE 9 November 2004 - March 2005 --a N EPSTEIN ..NEPSTEIN Jane Doe #14 18 U.S.C. §§ 1591(aX1) and 2 Knowingly, in or affecting interstate or foreign commerce, recruiting, enticing, providing, and obtaini

ravel to 358 El Brillo Way 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. Manner and Means 27. The manner and means by which the Defendants and other participants sought to accomplish the purpose and

ments to be made to, minor females in exchange for engaging in lewd conduct. EPSTEIN, (c) It was further a part of the conspiracy that Defendants JEFFREY a/k/a ," and other participants would ask females to recruit other minor females to engage in lewd conduct with Defendant JEFFREY EPSTEIN. (d)

the public association of their identities with Defendant Epstein and these assaults. 3. Dr. Gilbert Kliman,2 a w

ober 28, 2006 132. Lawrence LE, Viron M, Johnson JE, Hudkins A, Samples G, Kliman G: A school-based m

SISTANT UNITED STATES ATTORNEY 52 EFTA00182941 INDICTMENT SUMMARY CT DATE(S) kEFENDANT(S) VICTIM(S) STATUTES/CHARGE 1 2001 - October 2005 NEPSTEIN Jane Does 1-19 18 U.S.C. §§ 371 and 2 Conspiracy to use a facility or means of interstate commerce to persuade, induce, or entice minors to enga

(4th Cir.I 993); Ill v. New York Blood Center, 213 F.R.D. 108, 110-12 (E.D.N.Y.2003); Javier v. Garcia-Botello, 211 F.R.D. 194, 196 (W.D.N.Y.2002); Doe v. Smith, 105 F.Supp.2d 40, 43-44 (E.D.N.Y.1999); Doe v. United Servs. Life Ins. Co., 123 F.R.D. 437, 439 (S.D.N.Y.1988). Sexual assault victims are a paradi

kept anonymous in the Federal Court criminal case and all documents containing her name were redacted by the United States Government and Defendant, Jeffrey Epstein's attorney. The Defendant, Jeffrey Epstein, will not be prejudiced in any way by this pseudonym pleading, as he has been provided with her name in the

80893-Civ-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. AUGUST 13, 2008 STEVEN M. LARIMORE

OE, 08-80893-Civ-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. AUGUST 13, 2008 STEVEN M.

curity against the public's interest in identification of the litigants and the harm to the defendant stemming from suppression of Plaintiffs name." Doe v. Smith, 105 F.Supp.2d 40, 44 (E.D.N.Y. 1999). The ultimate test for permitting a plaintiff to proceed anonymously is whether the plaintiff has a substanti