Epstein Secrets

Y EPSTEIN RALD LEFCO r RT ESQ. COUNSEL TO JEFFR Y EPSTEIN LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR JEFFREY EP

in the woe position as they would have been had Mr. Epstein been convicted al trial. No more; no less. From

hearing shall be limited to the issue of whether Defendant Epstein's defense of the civil actions filed against him

of Breach USAO No. 2006R0 181 June 9, 2009 To Jeffrey H. Sloman Acting United States Attorney Robert

TATES ATTORNEY Dated: By: Dated: Dated: Dated: A. MARIE VILLAFARA ASSISTANT U.S. ATTORNEY JEFFREY EPSTEIN RALD LEFCO r RT ESQ. COUNSEL TO JEFFR Y EPSTEIN LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR JEFFREY EPSTEIN Case No. 08-80736-CV-MARRA P-011815 EFTA00192861 By signing this Addendum, Epstein assert

tted a crime, and because Plaintiff surely would have charged that Defendant actually committed a crime if she had a good-faith basis for doing so, Counts IV and, must be dismissed with prejudice. VII. COUNT SIX MUST BE DISMISSED BECAUSE 18 U.S.C. § 2252A(g) WAS NOT ENACTED UNTIL 2006. Count VI of the F

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

CONTAINED WITHIN THAT FEDERAL STATUTE 77. Plaintiff,. adopts and realleges paragraphs I through 60 above. 78. The allegations contained herein in Counts IV through XXIII are separate and distinct legal remedies. I6 EFTA00729623 Case 9:10-cv-81111-X)OO( Document 1 Entered on FLSD Docket 09/17/2010 Pa

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

ONTAINED WITHIN THAT FEDERAL STATUTE 77. Plaintiff, MJ, adopts and realleges paragraphs I through 60 above. 78. The allegations contained herein in Counts IV through XXIII are separate and distinct legal remedies. 16 EFTA00616162 Case 9:10-cv-81111-WPD Document 1 Entered on FLSD Docket 09/17/2010 Pag

DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE No. 101, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED COMPLAINT OR, IN THE ALTERNATIVE, FOR A MORE DEFINITE STATEMENT Defendant JEFFREY EPSTEIN, by and through his u

ed on FLSD Docket 05/26/2009 Page 27 of 36 Defendant's mansion in or about the spring of 2003," FAC ¶ 18, and that she later was "lured ... to the Epstein mansion on at least one and perhaps two other occasions in the spring and/or summer of 2003." Id. ¶ 19. Since these vague allegations leave open the

01, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S

tted a crime, and because Plaintiff surely would have charged that Defendant actually committed a crime if she had a good-faith basis for doing so, Counts IV and V must be dismissed with prejudice. VII. COUNT SIX MUST BE DISMISSED BECAUSE 18 U.S.C. § 2252A(g) WAS NOT ENACTED UNTIL 2006. Count VI of the

DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE No. 101, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED COMPLAINT OR, IN THE ALTERNATIVE, FOR A MORE DEFINITE STATEMENT Defendant JEFFREY EPSTEIN, by and through his u

ed on FLSD Docket 05/26/2009 Page 27 of 36 Defendant's mansion in or about the spring of 2003," FAC ¶ 18, and that she later was "lured ... to the Epstein mansion on at least one and perhaps two other occasions in the spring and/or summer of 2003." Id. ¶ 19. Since these vague allegations leave open the

01, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S

tted a crime, and because Plaintiff surely would have charged that Defendant actually committed a crime if she had a good-faith basis for doing so, Counts IV and V must be dismissed with prejudice. VII. COUNT SIX MUST BE DISMISSED BECAUSE 18 U.S.C. § 2252A(g) WAS NOT ENACTED UNTIL 2006. Count VI of the

DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE No. 101, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED COMPLAINT OR, IN THE ALTERNATIVE, FOR A MORE DEFINITE STATEMENT Defendant JEFFREY EPSTEIN, by and through his u

ed on FLSD Docket 05/26/2009 Page 27 of 36 Defendant's mansion in or about the spring of 2003," FAC ¶ 18, and that she later was "lured ... to the Epstein mansion on at least one and perhaps two other occasions in the spring and/or summer of 2003." Id. ¶ 19. Since these vague allegations leave open the

01, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S

tted a crime, and because Plaintiff surely would have charged that Defendant actually committed a crime if she had a good-faith basis for doing so, Counts IV and V must be dismissed with prejudice. VII. COUNT SIX MUST BE DISMISSED BECAUSE 18 U.S.C. § 2252A(g) WAS NOT ENACTED UNTIL 2006. Count VI of the

DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE No. 101, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED COMPLAINT OR, IN THE ALTERNATIVE, FOR A MORE DEFINITE STATEMENT Defendant JEFFREY EPSTEIN, by and through his u

ed on FLSD Docket 05/26/2009 Page 27 of 36 Defendant's mansion in or about the spring of 2003," FAC ¶ 18, and that she later was "lured ... to the Epstein mansion on at least one and perhaps two other occasions in the spring and/or summer of 2003." Id. ¶ 19. Since these vague allegations leave open the

01, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S

tted a crime, and because Plaintiff surely would have charged that Defendant actually committed a crime if she had a good-faith basis for doing so, Counts IV and V must be dismissed with prejudice. VII. COUNT SIX MUST BE DISMISSED BECAUSE 18 U.S.C. § 2252A(g) WAS NOT ENACTED UNTIL 2006. Count VI of the

DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE No. 101, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS THE FIRST AMENDED COMPLAINT OR, IN THE ALTERNATIVE, FOR A MORE DEFINITE STATEMENT Defendant JEFFREY EPSTEIN, by and through his u

ed on FLSD Docket 05/26/2009 Page 27 of 36 Defendant's mansion in or about the spring of 2003," FAC ¶ 18, and that she later was "lured ... to the Epstein mansion on at least one and perhaps two other occasions in the spring and/or summer of 2003." Id. ¶ 19. Since these vague allegations leave open the

01, Case No.: 9:09-CV-80591-KAM Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT JEFFREY EPSTEIN'S

tted a crime, and because Plaintiff surely would have charged that Defendant actually committed a crime if she had a good-faith basis for doing so, Counts IV and V must be dismissed with prejudice. VII. COUNT SIX MUST BE DISMISSED BECAUSE 18 U.S.C. § 2252A(g) WAS NOT ENACTED UNTIL 2006. Count VI of the