Epstein Secrets

MEMORANDUM TO RDC FROM JMB RE Epstein — Punitive Damages DATE April 8, 2009 Bob: You requested that I put together a general overview/outline of issues which will present themselves

neral overview/outline of issues which will present themselves to us in connection with Plaintiffs' claims for punitive damages against our client, Jeffrey Epstein. The following is not intended to be exhaustive and I am sure specific issues will present themselves, which will require additional research and b

claims for punitive damages against our client, Jeffrey Epstein. The following is not intended to be exha

mages brought in State and Federal Court against Mr. Epstein. I. STATE State claims for punitive damages ar

With regard to the amount of damages, the greater weight of the evidence — burden of proof applies. C. DISCOVERY/FINANCIAL NET WORTH In Florida, the Rules of Civil Procedure shall be liberally construed so as to allow the claimant discovery of evidence which appears reasonably calculated to lead to admissible evidence o

E OF CONTENTS INTRODUCTION 1 BACKGROUND 3 LEGAL AUTHORITY 5 I. PLAINTIFF'S LACK OF DILIGENCE 6 6 B. Ross Gow 9 C. Jean Luc Brunel 10 D. Jeffrey Epstein 12 E. and 14 II. FIFTH AMENDMENT BY EPSTEIN, OR NOT ADMISSIBLE IN THIS CASE AGAINST MS. MAXWELL 15 III. PLAINTIFF'S BAD FAITH DISCOVER

5 I. PLAINTIFF'S LACK OF DILIGENCE 6 6 B. Ross Gow 9 C. Jean Luc Brunel 10 D. Jeffrey Epstein 12 E. and 14 II. FIFTH AMENDMENT BY EPSTEIN, OR NOT ADMISSIBLE IN THIS CASE AGAINST MS. MAXWELL 15 III. PLAINTIFF'S BAD FAITH DISCOVERY TACTICS SHOULD NOT BE REWARDED WITH EXTRA TIME 18

ONS FOR VIOLATION OF RULE 45 Laura A. Menninger Jeffrey S. Pagliuca HADDON. MORGAN, AND FOREMAN, P.C. E

hat deposition in the Virgin Islands. Last week, Mr. Epstein's counsel filed a Motion to Quash his deposition

"did not commence in this matter until" February 8. What she means is that she neglected to seek any non-witness depositions until then; nothing in the Rules of Civil Procedure, this Court's Orders, or the law prevented Plaintiff from doing so at any point after October 23, 2015.7 Plaintiff has had over eight months to subp

Jane Doe No. 1 and Jane Doe No. 2 became familiar enough with the non-prosecution agreement to both invoke its provisions in their lawsuits against Jeffrey Epstein under 18 U.S.C. § 2255.1 United States' Reply in Support of Its Motion to Dismiss for Lack of Subject matter Jurisdiction, D.E. 205-6, Exhibits A -

wsuit was that the government failed to consult with them prior to what they believed would be the disposition of the federal investigation against Epstein. D.E. I II 3,4. They knew, at the time their petition was filed, that Epstein had "recently been prosecuted and pleaded guilty, on June 30, 2008, i

h invoke its provisions in their lawsuits against Jeffrey Epstein under 18 U.S.C. § 2255.1 United States'

ies to an ongoing proceeding would be governed under the Federal Rules of Civil Procedure by Fed.R.Civ.P. 15, not by Fed.R.Civ.P. 21. Even applying the Rules of Civil Procedure, moreover, the motions should be denied because they are untimely. As to the motion to add Jane Doe No. 3 and Jane Doe No. 4, petitioners still mai

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff(s), vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually Defendant(s). REQUEST FOR ADMISSION

ionaire sometime within the past 5 years. 7. Admit that you have been a billionaire sometime within the past 10 years. EFTA00792321 Edwards adv. Epstein Case No.: 502009CA040800)OOOCMBAG Request for Admissions to Jeffrey Epstein 8. Admit that you have a reputation as being a billionaire. 9. Admi

OUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff(s), vs. SCOTT ROTHSTEIN, in

e never spent even one day in a state or federal prison facility (as opposed to a county jail) as punishment for any sex-related crime. Pursuant to the Rules of Civil Procedure, each fact on which admission is requested shall be deemed admitted if not denied or if no reply is received on or before March 28, 2013. 2 EFTA00