Epstein Secrets

Counsel for Plaintiff Jane Doe 6 EFTA00175540 Case 9:08-cv-8uo04-KAM Document Entered ..i FLSD Docket 09115L . J8 Page 7 of 8 SERVICE LIST Doe Epstein, et. al. CASE NO: 08-80804-Civ-MARIUUJOHNSON United States District Court, Southern District of Florida Robert Critton, Esq. Burman, Critton, Lut

natabase - flsd Page 1 of 6 U.S. District Court Southern District of Florida (West Palm Beach) CIVIL DOCKET FOR CASE #: 9:08-cv-80804-KAM Doe v. Epstein et al Assigned to: Judge Kenneth A. Marra Referred to: Magistrate Judge Linnea R. Johnson ' Case in other court: 15th Judicial Circuit, 50 2008 C

stion Plaintiff Jane Doe represented by Spencer Todd Kuvin Ricci Leopold 2925 PGA Boulevard Suite 200 Palm Beach Gardens , FL 33410 Defendant Jeffrey Epstein Fax: 515-2610 Email: LEAD ATTORNEY ATTORNEY TO BE NOTICED Theodore Jon Leopold Leopold—Kuvin, P.A. 2925 PGA Boulevard Suite 200 Palm Beach Garden

SD Do t 3.8/1b,..,08 Page 4 of 21 Iktb4-1 PLEA IN THE CIRCUIT COURT THE FOLLOVVING IS TO REFLECT Al .l TERMS OF THE NEGOTIATED SETTLEMEN*1 Name: Jeffrey E. Epstein Plea: Guilty 1 NP.---_.. SIMI .,lister _Dellloe a D 06CF009454A Felony Solicitation of Prostitution 1 No 3.FEI rocuring Person Under 18 for

nying as moot 2 Motion for Hearing. Signed by Judge Kenneth A. Marra on 8/5/08. (ir) (Entered: 08/06/2008) 08/08/20(8 a r ns KB MOTION Defendant Jeffiwy Epstein's Opposed Motion to Align Response Date by Jeffrey Epstein. (Attachments: # 1 Text of Proposed OrderXTein, Michael) (Entered: 08/08/2008) 08/13/2008

F.3d at 1314. conditions, and sensitive protocols concerning the fact of Epstein's previously disclosed incarceration. See DE 24 in Jane Doe No. 2 I. Epstein, Case No. 9:08-CV-80119-KAM (S.D. Fla. filed Feb. 6, 2Q08) (disclosing fact of Epstein's criminal sentence and incarceration); DE 19 in Jane Doe No

1332: the amount in controversy exceeds $75,000; Defendant Epstein is a citizen of the U.S. Virgin Islands; and Def

Al .l TERMS OF THE NEGOTIATED SETTLEMEN*1 Name: Jeffrey E. Epstein Plea: Guilty 1 NP.---_.. SIMI .,liste

Al .l TERMS OF THE NEGOTIATED SETTLEMEN*1 Name: Jeffrey E. Epstein Plea: Guilty 1 NP.---_.. SIMI .,lister

a/k/a, JANE DOE NO. 1, Plaintiff, vs. IF'.F .EY EPSTEIN , and Defendants. PLAINTIFF'S REPLY TO OPPOSIT

DE 1, pp. 307-308). It is for harm suffered as a result of these predicate acts that Plaintiff seeks damages for in Count IV of her complaint. Cf. Palmas Y Bambu, E.I. Dupont De Nemours & Co., Inc., 881 So. 2d 565, 570 (Fla. 3d DCA 2004) (holding plaintiff has standing to sue for civil RICO when her injurie

driguez advised he had very limited contact with Mr. Epstein. If Rodriguez needed to relay a message to Mr. E

d Six, to-wit The Grand Jurors of the State of Florida, inquiring in end for the body of said County of Palm Beach, upon their oaths do present that JEFFREY E. EPSTEIN in the County of Palm Beach aforesaid. in the Circuit and State aforesaid. COUNT ONE FELONY SOLICITATION OF PROSTITUTION on or about or between th

esses and register himself as an agent. I also observed Epstein has his El Zorro Ranch Corporation, New York Strategy Group, Ghislaine Corporation, J Epstein and Company and the Financial Strategy Group registered to this same address. Finally, a third call is received by at 12:02 pm from the same corp

y of Palm Beach, upon their oaths do present that JEFFREY E. EPSTEIN in the County of Palm Beach aforesaid.

I wrote that, but I didn't write what you 13 said. 14 4. 15 16 you write that? 17 18 19 20 21 22 about what happened when you went to Jeff Epstein's house You wrote in this exhibit, "I got some stupid court s-h-i-t on the 20th. Bull s-h-i-t." Didn't A. Yes. Q. Referring to this deposition, d

his associates. ) (describing character of party defendant Epstein as a "sexual predator" (a term defined by Florida

y of Palm Beach, upon their oaths do present that JEFFREY E. EPSTEIN in the County of Palm Beach aforesaid. i

sages from other people (see, e.g., Am. Compl. ¶¶ 9, 11, 12, 32), those activities are not alleged in any way to have impacted Jane Doe. Cf., e.g., Palmas Y Bambu, S.A. v. E.I. Dupont De Nemours & Co., Inc., 881 E. 2d 565, 570 (Fla. 3d DCA 2004) (holding that "'indirect injuries, that is injuries sustained no

ket 07)21:2008 Page 16 of 100 1. The plaintiff seeks damages in connection with her own illegal conduct. The plaintiff concedes that she went to Jeffrey Epstein's house "to give Epstein a massage for monetary compensation." (Am. Compl. ¶ 13.) The plaintiff also concedes, in the guise of an allegation, that "

respectfully state as follows: Introduction Six months ago, this plaintiff filed virtually the identical lawsuit in this Court. See Jane Doe #1 v. Epstein, Case No. 08-cv-80069-KAM (S.D. Fla. filed Doe v. Epstein et at, Case No. 50 2008 CA 006596 XXXX MB (Fla. 15th Cir. Ct. filed Mar. 6, 2008). Lewis

A. Yes. Q. Didn't you tell that to the police? A. Yes. And I will continue. I have never had sex with him. Q. Did what happened upstairs at Jeff Epstein's house take you completely by surprise,. A. Yes. Q. Now the civil complaint that you filed against Mr. Epstein for fifty million dollars alleged

in's house you had 17 never told Jeff that you were under 18, right? 18 A. No. 19 Q. Before you got to Epstein's house had you 20 ever told Jeffrey that you were under 18? 21 A. No. I never spoke to the man before that. 22 Q. And you only went to Jeff Epstein's house 23 that one time thre

his associates. ) (describing character of party defendant Epstein as a "sexual predator" (a term defined by Florida

the instant case, adding two nominal defendants Mr. Epstein's personal secretary, and MB one of Jane Doe #1'

sages from other people (see, e.g., Am. Compl. TV 9, 11, 12, 32), those activities are not alleged in any way to have impacted Jane Doe. Cf., e.g., Palmas Y Bambu, S.A. v. F..I. Dupont De Nemours & Co., Inc., 881 So. 2d 565, 570 (Fla. 3d DCA 2004) (holding that "'indirect injuries, that is injuries sustained

011 Pages w/cover: 4 Fax #: Direct #: Please see the attached letter, in response to your letter to Martin Weinberg of July 27, 2011, concerning Jeffrey Epstein. Thank you. Documena EFTA00180294 07/29/2011 13: 12 FAX a 002/004 Jay P. LeatowItz. P.C. To ilaiactly: jay.lefkowitzekirklend.cOm KIRKLAND &

oncerning the request by the New York District Attorney for copies of the Non-Prosecution Agreement ("NPA") and the "victim list" in regards to Mr. Epstein. We continue for the reasons stated herein to believe that any such disclosure would violate the confidentiality agreement between your Office and

Jack 2:114:5 jackpot 32:9 jail 41:7 Jane 1:4,15,18,22 2:3,7 3:5,5,7,11 5:17 6:8,9,16 11:12 21:4 29:14 29:22 33:5 35:13 42:22 Jay 2:20 4:18 Jeffrey 1/ 37:12 jeopardize 9:15 Jeopardy 15:17 join 26:11,15 Josefsberg 2:1,2,5 3:18,20,21,23 19:7 19:7,1021:25 23:1 24:5 25:25 26:7,11 26:12,16 27:

ourt. I was• later 20 informed that it was a deposition. 21 Q. I'm going to ask you some questions now 22 about what happened when you went to Jeff Epstein's house 23 three years ago. Okay? 24 A. Oh-huh. 25 Q. When the police interviewed you one month Ph. 561.682.0905 - Fax. 561.682.1771 1655 Pal

. § 1446, this notice of removal is timely. Only defendant Epstein has been served with process. Defendants 21 Lew

ment ("NPA") and the "victim list" in regards to Mr. Epstein. We continue for the reasons stated herein to be

sages from other people (see, e.g., Am. Compl. ¶¶ 9, I I, 12, 32), those activities are not alleged in any way to have impacted Jane Doe. CI, e.g., Palmas Y Bambu, S.A. v. E.I. Dupont De Nemours & Ca, Inc., 881 So. 2d 565, 570 (Fla. 3d DCA 2004) (holding that "'indirect injuries, that is injuries sustained no

e meeting? 2 A. No. They -- yeah. No. They have it. I'm 3 guessing. I don't have it. 4 Q. How much money are you hoping to get out of 5 Mr. Epstein? 6 MR. LEOPOLD: Objection to the form of the 7 question. Attorney/client privilege. 8 BY MR. TEIN: 9 Q. How much money are you hoping to get

ket 07/21/2008 Page 16 of 100 1. The plaintiff seeks damages in connection with her own illegal conduct. The plaintiff concedes that she went to Jeffrey Epstein's house "to give Epstein a massage for monetary compensation." (Am. Compl. ¶ 13.) The plaintiff also concedes, in the guise of an allegation, that "

court. I was later 20 informed that it was a deposition. 21 Q. I'm going to ask you some questions now 22 about what happened when you went to Jeff Epstein's house 23 three years ago. Okay? 24 A. Uh-huh. 25 Q. When the police interviewed you one month You wrote in this exhibit, "I got some Ph. 56

you got to Epstein's house you had never told Jeff that you were under 18, right? A. No. Q. Before you got to Epstein's house had you ever told Jeffrey that you were under 18? A. No. I never spoke to the man before that. Q. And you only went to Jeff Epstein's house that one time three years ago,

his associates. ) (describing character of party defendant Epstein as a "sexual predator" (a term defined by Florida

How much money are you hoping to get out of 5 Mr. Epstein? 6 MR. LEOPOLD: Objection to the form of the 7

ages from other people (see, e.g., Am. Compl. ti 9, I I, 12, 32), those activities are not alleged in any way to have impacted Jane Doe. Cf., e.g., Palmas Y Bambu, S.A. v. E.I. Dupont De Nemours & Co., Inc., 881 So. 2d 565, 570 (Ha. 3d DCA 2004) (holding that "'indirect injuries, that is injuries sustained no

SD Do ;,A8/18/2008 Page 4 of 21 ktIVA4 . PLEA IN THE CIRCUIT COURT THE FOLLOWING IS TO REFLECT ALI. TERMS OF THE NEGOTIATED SI TTLFMEN I Name: Jeffrey E. Epstein Plea: Guilty A 6e4 /9—,—..... . _charge Cpynt Lessei _Dee' ep &b 06CF00945 Felony Solicitation of Prostitution 1 No 3 FUT rocuring Pers

told detectives, 'I'm like a Heidi Fleiss.'"). EFTA00234424 Case 9:08-cv-80804-KAM Document 11 Entered on FLSD Docket 08)18:2008 Page 2 of 11 Epstein," (Notice of Removal, DE 1, p. 3) and that Plaintiff fraudulently joined her in this action to prevent complete diversity.2 3. As demonstrated in Pl

ALI. TERMS OF THE NEGOTIATED SI TTLFMEN I Name: Jeffrey E. Epstein Plea: Guilty A 6e4 /9—,—..... . _char

ut, however, that there is a question of whether Defendant Epstein is actually a citizen of Florida because he is n

ALI. TERMS OF THE NEGOTIATED SI TTLFMEN I Name: Jeffrey E. Epstein Plea: Guilty A 6e4 /9—,—..... . _charg

m of Defendants' scheme, was directly harmed by the scheme and it is damages for this harm that she seeks in Count IV of the amended complaint. Cf. Palmas Y Bambu, Dupont De Nemours & Co., Inc., 881 So. 2d 565, 570 (Fla. 3d DCA 2004) (holding plaintiff has standing to sue for civil RICO when her injuries flow

Docket 03/03;2010 Page 1 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80893-CIV-MARRA JANE DOE, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ORDER THIS CAUSE is before the Court upon Defendant Jeffrey Epstein ("Defendant")'s Motion to Dismiss, for More Definite Statement &

stein. A list of more than 30 such minor females has previously been provided by the U.S. Attorney's Office for the Southern District of Florida to Epstein (but not to Jane Doe). See DE 38-2 at ¶ 4. Finally, Defendant argues, and Plaintiff concedes, that punitive damages are not available under 18 U.S

ICO statement that the "enterprise" consisted of Defendant Epstein, and his paid employees and . See Am. Comp. ¶

. 08-80893-CIV-MARRA JANE DOE, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ORDER THIS CAUSE is before

the similarities between Florida and federal RICO acts, Florida looks to federal authority regarding the interpretation and application of its act. Palmas Y Bambu, S.A. v. E.I. Dupont De Nemours & Co., Inc., 881 So.2d 565, 570 n.1 (3s DCA 2004); see also RLS Business Ventures, Inc. v. Second Chance Wholesale,

The names of all of the victims are unknown to the plaintiff at this time. However, they include Jane Doe herself as well as the victim in E.W. v. Jeffrey Epstein and L.M. v. Jeffrey Epstein. A list of more than 30 such minor females has previously been provided by the U.S. Attorney's Office for the Southern

stein. A list of more than 30 such minor females has previously been provided by the U.S. Attorney's Office for the Southern District of Florida to Epstein (but not to Jane Doe). See DE 38-2 at ¶ 4. Finally, Defendant argues, and Plaintiff concedes, that punitive damages are not available under 18 U.S

ICO statement that the "enterprise" consisted of Defendant Epstein, and his paid employees Sarah Kellen and Nadia Ma

. 08-80893-CIV-MARRA JANE DOE, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ORDER THIS CAUSE is before

the similarities between Florida and federal RICO acts, Florida looks to federal authority regarding the interpretation and application of its act. Palmas Y Bambu, S.A. v. E.I. Dupont De Nemours & Co., Inc., 881 So.2d 565, 570 n.1 (3rd DCA 2004); see also RLS Business Ventures, Inc. v. Second Chance Wholesale

The names of all of the victims are unknown to the plaintiff at this time. However, they include Jane Doe herself as well as the victim in E.W. v. Jeffrey Epstein and L.M. v. Jeffrey Epstein. A list of more than 30 such minor females has previously been provided by the U.S. Attorney's Office for the Southern

stein. A list of more than 30 such minor females has previously been provided by the U.S. Attorney's Office for the Southern District of Florida to Epstein (but not to Jane Doe). See DE 38-2 at ¶ 4. Finally, Defendant argues, and Plaintiff concedes, that punitive damages are not available under 18 U.S

ICO statement that the "enterprise" consisted of Defendant Epstein, and his paid employees and Sec Am. Comp. 1 43

. 08-80893-CIV-MARRA JANE DOE, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ORDER THIS CAUSE is before

the similarities between Florida and federal RICO acts, Florida looks to federal authority regarding the interpretation and application of its act. Palmas Y Bambu, S.A. v. E.I. Dupont De Nemours & Co., Inc., 881 So.2d 565, 570 n.1 (3rd DCA 2004); see also RLS Business Ventures, Inc. v. Second Chance Wholesale