Epstein Secrets

rth is in the hundreds of millions of dollars - if not, indeed, a billion dollars. See, e.g., New York Time, July 1, 2008, at A2 ("Over the weekend Jeffrey E. Epstein, who after years of advising billionaires became a billionaire himself, left his estate on Little St. James Island, with its staff of 70 and its fl

ant PLAINTIFF, JANE DOE'S MOTION FOR INJUNCTION RESTRAINING FRAUDULENT TRANSFER OF ASSETS, APPOINTMENT OF A RECEIVER TO TAKE CHARGE OF PROPERTY OF EPSTEIN, AND TO POST A $15 MILLION BOND, TO SECURE POTENTIAL JUDGMENT COMES NOW Plaintiff Jane Doe, by and through undersigned counsel, and hereby files t

IS ASSETS. As noted in the material facts above, defendant Epstein is currently making fraudulent transfers of his

ork Time, July 1, 2008, at A2 ("Over the weekend Jeffrey E. Epstein, who after years of advising billionair

ork Time, July 1, 2008, at A2 ("Over the weekend Jeffrey E. Epstein, who after years of advising billionaire

#23. 14. Epstein has blocked all discovery, in this and other related cases, regarding his assets. Affidavit of Paul Cassell at ¶¶ 7, 8. ARGUMENT I. EPSTEIN IS FRAUDULENTLY TRANSFERRING HIS ASSETS. As noted in the material facts above, defendant Epstein is currently making fraudulent transfers of his as

vailable state law pre-judgment remedies to respond to these fraudulent transfers. Florida has adopted the Florida Uniform Fraudulent Transfer Act (FUFTA), Fla. Stat. Ann. § 726.101 et seq., which gives the Court power to appoint a receiver to take charge of assets that are being fraudulently transfe

d by Epstein's top assistant, Defendant 27. Defendant in furtherance of the scheme to exploit Plaintiff, escorted Plaintiff upstairs to Defendant Jeffrey Epstein's large bathroom, where Defendant set up the 7 EFTA00729614 Case 9:10-cv-81111-XXXX Document 1 Entered on FLSD Docket 09/17/2010 Page 8 of 29 mas

legal acts against her. FACTUAL ALLEGATIONS 9. At all times material, Defendant, Jeffrey Epstein, was an adult male, over 50 years old. Defendant Epstein is known as a billionaire, yet even those closest to him, including family members, long time employees and those that he considers his closest frie

ouse before taking her upstairs to be alone with Mr. Epstein. Upon information and belief, Defendant remains

y Epstein, was an adult male, over 50 years old. Defendant Epstein is known as a billionaire, yet even those closest

P mg, Civil Action No. CASE NO.: 9:10-cv-81111 JEFFREY EPSTEIN and WM Defendant (If the action is pend

in excess of $50,000,000. Therefore, he is facing judgments in excess of $50,000,000 from her. Epstein is thus a debtor of M.J., as defined in the FUFTA. 109. Defendant Jeffrey Epstein has numerous overseas contacts and sophistication in international business transactions. He previously served as a

y Epstein, was an adult male, over 50 years old. Defendant Epstein is known as a billionaire, yet even those closest

CT OF FLORIDA CASE NO.: M.J., Plaintiff, vs. JEFFREY EPSTEIN and SARAH KELLEN, Defendants. COMPLAIN

ssistant, Defendant Sarah Kellen. 27. Defendant Kellen, in furtherance of the scheme to exploit Plaintiff, escorted Plaintiff upstairs to Defendant Jeffrey Epstein's large bathroom, where Defendant Kellen set up the 7 EFTA00616153 Case 9:10-cv-81111-WPD Document 1 Entered on FLSD Docket 09/17/2010 Page 8 of 2

legal acts against her. FACTUAL ALLEGATIONS 9. At all times material, Defendant, Jeffrey Epstein, was an adult male, over 50 years old. Defendant Epstein is known as a billionaire, yet even those closest to him, including family members, long time employees and those that he considers his closest frie

ouse before taking her upstairs to be alone with Mr. Epstein. Upon information and belief, Defendant Kellen r

in excess of $50,000,000. Therefore, he is facing judgments in excess of $50,000,000 from her. Epstein is thus a debtor of M.J., as defined in the FUFTA. 109. Defendant Jeffrey Epstein has numerous overseas contacts and sophistication in international business transactions. He previously served as a

NSON  JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. Related cases: 08-80232, 08-80380,

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

09 Page 1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CIV-80119-MARRA/JOHNSON  JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. Related cases: 08-80232, 08-80380, 08-80993,08-80811, 09-80591, 09-80656, 08-80381, 08-80994, 08-80893, 09-80469, 09-80802, 09-81

at 'Fraudulent transfer claims under Florida law arise under the Florida Uniform Fraudulent Transfers Act ("FUFTA"), Fla. Stat. § 726.101, et seq.. FUFTA, as set forth in Florida Statute § 726.105, provides the substantive requirements that must be pled to state a valid fraudulent transfer claim. Nat