Epstein Secrets

mi, FL 33132 BLACK SREBNICK KORNSPAN STUMPF - P.A. March 29, 2010 Assistant United States Attorney 99 N.E. 4th Street Miami, FL 33132 RE: Jeffrey Epstein Dear Counsel: JESSICA FONSECA-NADER KATifunrii P. PHILUPS AARON AMMON MARCOS BEATON, JR. MATTHEW P. O'BRIEN JENIPER J. SOUUKIAS NOAH Fox Ass

ponse. We firmly believe that the issues raised in the draft motion that is appended to this letter do not conflict with, nor, if filed, breach Mr. Epstein's obligations under the NPA. Please advise if any of the issues in the draft motion authored by his civil counsel Robert Critton are, from your per

, Plaintiff, vs. JEFFERY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION TO DISMISS, & FOR MORE DEFINITE STATEME

torney 99 N.E. 4th Street Miami, FL 33132 RE: Jeffrey Epstein Dear Counsel: JESSICA FONSECA-NADER KA

tter do not conflict with, nor, if filed, breach Mr. Epstein's obligations under the NPA. Please advise if an

ment Act of 1998;" House Report No. 105-557, 11, 1998 U.S.C.A.N. 678, 679 (1998). Quoting from the "Background and Need For Legislation" portion of the House Report No. 105-557, 11-16, H.R. 3494, of which 18 U.S.C. §2255 is included, is described as "the most comprehensive package of new crimes and increased penalt

W P. Oilmen JENIPER J. SOUUKIAS NOAH Fox E-Mail March 29, 2010 Esq. Assistant United States Attorney 99 N.E. 4th Street Miami, FL 33132 RE: Jeffrey Epstein Dear Counsel: Esq. Assistant United States Attorney 500 South Australian Avenue West Palm Beach, FL 33401-6223 Jeffrey Epstein has an April 5,

ponse. We firmly believe that the issues raised in the draft motion that is appended to this letter do not conflict with, nor, if filed, breach Mr. Epstein's obligations under the NPA. Please advise if any of the issues in the draft motion authored by his civil counsel Robert Critton are, from your per

, Plaintiff, vs. JEFFERY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION TO DISMISS, & FOR MORE DEFINITE STATEME

torney 99 N.E. 4th Street Miami, FL 33132 RE: Jeffrey Epstein Dear Counsel: Esq. Assistant United St

tter do not conflict with, nor, if filed, breach Mr. Epstein's obligations under the NPA. Please advise if an

ment Act of 1998;" House Report No. 105-557, 11, 1998 U.S.C.A.N. 678, 679 (1998). Quoting from the "Background and Need For Legislation" portion of the House Report No. 105-557, 11-16, H.R. 3494, of which 18 U.S.C. §2255 is included, is described as "the most comprehensive package of new crimes and increased penalt

uly 10, 2008, in the in the Fifteenth Judicial Circuit In and For Palm Beach County, State of Florida, Case No. 50 2008CA020614 MBAF, Jane Doe II v. Jeffrey Epstein. and Sarah Kellen, based on the same factual allegations that she asserts in the instant case. Attached here to as Exhibit A is Plaintiff's First Am

T COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 09-CIV- 80469 - MARRA/JOHNSON JANE DOE II, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION TO DISMISS PLAINTIFF'S COMPLAINT, AND SUPPORTING MEMORANDUM OF LAW Defendant, Jeffrey Epstein, (hereinafter "Epstein"), by and through his

et, Defendant gives notice to the Court that issues pertaining to 18 U.S.C. §2255 in this motion to dismiss are also raised in the case of C.M.A. v. Jeffrey Epstein Case No. 08-CV-80811-MARRA/JOHNSON, in Defendant's Motion to Dismiss directed to Plaintiff C.M.A.'s Amended Complaint, Plaintiff C.M.A.'s Response, and

I, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION TO DISMISS PLAINTIFF'S COMPLAINT, AND S

69 - MARRA/JOHNSON JANE DOE II, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION

ment Act of 1998;" House Report No. 105-557, 11, 1998 U.S.C.A.N. 678, 679 (1998). Quoting from the "Background and Need For Legislation" portion of the House Report No. 105-557, 11-16, H.R. 3494, of which 18 U.S.C. §2255 is included, is described as "the most comprehensive package of new crimes and increased penal

sts the legitimate concern that the agreement could be so used and the reality that any concern about such use significantly and unfairly burdens Mr Epstein's right to resort to the courts to resolve outstanding legal Issues regarding the criteria for payment and the amount of payment owed. I hope this

Jane Doe No. 103 1 0 - 80 (b) County of Residency of First Listed Plaintiff West Palm Beach (EXCEPT IN U.S. PLAINTIPP CASES) S int. NTS 0 it Fey stein (c) Attorney's (Tina Nam, Address. nod Telephone Hornbill) Robert C..losefsbag, Esq./Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 W. Flag' e

, Plaintiff, vs. JEFFERY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION TO DISMISS, & FOR MORE DEFINITE STATEME

Biscayne Blvd, Suite 1300 Miami, FL 33131 Re: Jeffrey Epstein Dear Mr. Black: Thank you for meeting w

it a breach of the Non- Prosecution Agreement for Mr. Epstein to file suit against the victim's attorney-repres

ment Act of 1998;" House Report No. 105-557, 11, 1998 U.S.C.A.N. 678, 679 (1998). Quoting from the "Background and Need For Legislation" portion of the House Report No. 105-557, 11-16, N.R. 3494, of which 18 U.S.C. §2255 is included, is described as "the most comprehensive package of new crimes and increased penalt

742, 754 (M.D. Pa. 2007); and the recent cases in front of this court on Defendant's Motions to Dismiss and For More Definite Statement — Doe No. 2 I. Epstein, 2009 WL 383332 (S.D. Fla. Feb. 12, 2009); Doe No. 3'. Epstein 2009 WL 383330 (S.D. Fla. Feb. 12, 2009); Doe No. 4'. Epstein 2009 WL 383286 (S.D. Fl

sts the legitimate concern that the agreement could be so used and the reality that any concern about such use significantly and unfairly burdens Mr Epstein's right to resort to the courts to resolve outstanding legal issues regarding the criteria for payment and the amount of payment owed. I hope this

, Plaintiff, vs. JEFFERY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION TO DISMISS. & FOR MORE DEFINITE STATEME

Biscayne Blvd, Suite 1300 Miami, FL 33131 Re: Jeffrey Epstein Dear Mr. Black: Thank you for meeting w

it a breach of the Non- Prosecution Agreement for Mr. Epstein to file suit against the victim's attorney-repres

ator Punishment Act of 1998;" House Report No. 105-557, 11, 1998 678, 679 (1998). Quoting from the "Background and Need For Legislation" portion of the House Report No. 105-557, 11-16, H.R. 3494, of which 18 §2255 is included, is described as "the most comprehensive package of new crimes and increased penalties e

Defendant, JEFFREY EPSTEIN, ("EPSTEIN"), by and through his undersigned counsel, files his reply to Plaintiff's Memorandum in Response to Defendant, JEFFREY EPSTEIN's, Motion to Dismiss First Amended Complaint For Failure to State A Cause of Action; And Motion for More Definite Statement; Motion to Strike, And Sup

UTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80811-MARRAIJOHNSON C.M. A., Plaintiff, v. JEFFREY EPSTEIN and SARAH KELLEN, Defendants, DEFENDANT EPSTEIN'S REPLY TO PLAINTIFF'S MEMORANDUM IN RESPONSE TO DEFENDANT, JEFFREY EPSTEIN'S, MOTION TO DISMISS FIRST AMEDNED COMPLAINT FOR FAIURE TO STATE A CAUS

JEFFREY EPSTEIN and SARAH KELLEN, Defendants, DEFENDANT EPSTEIN'S REPLY TO PLAINTIFF'S MEMORANDUM IN RESPONSE TO

CV-80811-MARRAIJOHNSON C.M. A., Plaintiff, v. JEFFREY EPSTEIN and SARAH KELLEN, Defendants, DEFENDAN

ment Act of 1998;" House Report No. 105-557, 11, 1998 U.S.C.A.N. 678, 679 (1998). Quoting from the "Background and Need For Legislation" portion of the House Report No. 105-557, 11-16, H.R. 3494, of which 18 U.S.C. §2255 is included, is described as "the most comprehensive package of new crimes and increased penal

FLSD Docket 03/05/2010 Page 1 of 36 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80893-MARRA-JOHNSON Plaintiff; v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION FOR SUMMARY JUDGMENT, INCLUDING SUPPORTING MEMORANDUM OF LAW Defendant, JEFFREY EPSTEIN, ("EPSTEIN"), by a

TED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80893-MARRA-JOHNSON Plaintiff; v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION FOR SUMMARY JUDGMENT, INCLUDING SUPPORTING MEMORANDUM OF LAW Defendant, JEFFREY EPSTEIN, ("EPSTEIN"), by and through his undersigned coun

ON Plaintiff; v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION FOR SUMMARY JUDGMENT, INCLUDING SUPPORT

E NO.: 08-CV-80893-MARRA-JOHNSON Plaintiff; v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION

ment Act of 1998;" House Report No. 105-557, 11, 1998 U.S.C.A.N. 678, 679 (1998). Quoting from the "Background and Need For Legislation" portion of the House Report No. 105-557, 11-16, H.R. 3494, of which 18 U.S-C. §2255 is included, is described as "the most comprehensive package of new crimes and increased penalt