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ww.ksmlaw.com Daniel J. Kaiser +1.212.338.9100 x317 +1.646.607.9371 fax [email protected] The history my client, (a), shares with your client, Jeffrey Epstein ("Epstein"), is hands down the worst case of sexual depravity and misconduct I have come across in all my 27 years of representing victims of sexual
el J. Kaiser +1.212.338.9100 x317 +1.646.607.9371 fax [email protected] The history my client, (a), shares with your client, Jeffrey Epstein ("Epstein"), is hands down the worst case of sexual depravity and misconduct I have come across in all my 27 years of representing victims of sexual assault a
94172 Exhibit A EFTA00794173 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK -X Index No. Plaintiff, -against- DRAFT COMPLAINT JEFFREY EDWARD EPSTEIN, Defendant. Plaintiff, en), by her attorneys Kaiser Saurbom & Mair, P.C., as and for her complaint against defendant, alleges as follows: I. P
stein has a residence in New York, New York. 3. Defendant Epstein committed repeated sexual assault and battery upo
L 33139 Dear Mr. Dershowitz: March 19, 2019 v. Jeffrey Epstein Kaiser Saurborn & Mair, P.C. 30 Broad S
s rape; Ms. was forcibly and violently raped by Mr. Epstein. The consequences to Ms. since her experiences w
KAISER SAURBORN st MAIR BY FEDERAL EXPRESS Alan M. Dershowitz, Esq. 1500 Ocean Drive, Unit 805 Miami Beach, FL 33139 Dear Mr. Dershowitz: March 19, 2019 v. Jeffrey Epstein Kaiser Saurborn & Mair, P.C. 30 Broad Street 371° Floor
d experience that code 14 words are often used? 15 A. Correct 16 MR. PIKE: Form 17 BY MI!: EDWARDS: 18 Q. In this particular case regarding Jeffrey 19 Epstein, the words work and massage in your training 20 and experience, are those code words that were used 21 by Jeffrey Epstein and the other people wo
7 TARA A FDDILGAN, ESQUIRE TARA A MINICAR. P A 8 224 Dina Street Suite 900 9 West tide 3340! Mae: 10 1/. Cte tehalfof the Defendant inlay Epstein: 12 MICHAEL PIKE, ESQUIRE BURMAN, ORITTON, LUIT1ER & COLEMAN, U.1) 13 303 Barn Bouienad Suite 4t0 14 West tads. 33401 Phone- 15 16 and 17
17 Q. And from what I understand based on the 18 report, house manager Alfredo Rodriguez, calls the 19 police because of a suspicious vehicle in Jeffrey 20 Epstein's driveway? 21 MR. PIKE: Form. 22 THE WITNESS: Correct. 23 BY MR. EDWARDS: 24 Q. Officer Munyan is the one reporting to the 25
6-b3b7-dcda51494142 EFTA00298296 Page 139 1 (Mr. Epstein returned the deposition 2 mom.) 3 BY MR. KUVI
lready 11 cameras in place? 12 MR. PIKE: Form. 13 THE WITNESS: I do not believe so. 14 BY MR. EDWARDS: 15 Q. All right So when you arrived, Jeffiey 16 Epstein was asking for your assistance in helping 17 set these cameras up? 18 A. I take that back It might have been, the 19 cameras might
een 22 question and answer. So form to that one. 23 BY MR. KUVIN: 24 Q. Did you come to learn what excuse 25 Mr. Epstein gave for being along Ocean Drive -- Page 230 1 (Plaintiffs Exhibit No. 25 was marked for 2 identification.) 3 BY MR. KUVIN: 4 Q. All right. Let me show you what we have S m
Wieder, 19K) reports, "A deadline has passed without opposition from two parties whose depositions in the bitter lawsuit between disgraced financier Jeffrey Epstein's accused co-conspirator, Ghislaine Maxwell, and an Epstein accuser are set to be made public." According to McClatchy, "The two non-parties in the n
two parties whose depositions in the bitter lawsuit between disgraced financier Jeffrey Epstein's accused co-conspirator, Ghislaine Maxwell, and an Epstein accuser are set to be made public." According to McClatchy, "The two non-parties in the now-settled civil dispute between Maxwell and accuser Virgi
s vehicle, argued briefly with a 59-year-old man, Jeffrey Austin, then returned with a rifle and shot him.
raids in Corpus Christi. Agents raided the headquarters of Fulton Construction in the downtown area and they also searched an upscale home just off Ocean Drive. At this point no one has been accused of any wrongdoing, but already Longoria is facing calls from the local head of the American Federation of Tea
Wieder, 19K) reports, "A deadline has passed without opposition from two parties whose depositions in the bitter lawsuit between disgraced financier Jeffrey Epstein's accused co-conspirator, Ghislaine Maxwell, and an Epstein accuser are set to be made public." EFTA01658793 According to McClatchy, "The two non-p
two parties whose depositions in the bitter lawsuit between disgraced financier Jeffrey Epstein's accused co-conspirator, Ghislaine Maxwell, and an Epstein accuser are set to be made public." EFTA01658793 According to McClatchy, "The two non-parties in the now-settled civil dispute between Maxwell an
s vehicle, argued briefly with a 59-year-old man, Jeffrey Austin, then returned with a rifle and shot him.
raids in Corpus Christi. Agents raided the headquarters of Fulton Construction in the downtown area and they also searched an upscale home just off Ocean Drive. At this point no one has been accused of any wrongdoing, but already Longoria is facing calls from the local head of the American Federation of Tea
From: Mark L. Epstein Sent: Monday, December 28, 2015 1:37 PM To: Jeffrey E. Subject: PB I was driving around Palm Beach yesterday, showing my =riend who had never been here the usual sights; The Breakers, =orth Ave., the ho
From: Mark L. Epstein Sent: Monday, December 28, 2015 1:37 PM To: J
n Sent: Monday, December 28, 2015 1:37 PM To: Jeffrey E. Subject: PB I was driving around Palm Beach
PB I was driving around Palm Beach yesterday, showing my =riend who had never been here the usual sights; The Breakers, =orth Ave., the homes along Ocean Drive, registered =ffenders' homes, etc. I was surprised that your gate =as open. Told your guy there to say hi. Heading to =iami to the boat. A comic s
From: "Mark L. Epstein" To: mjeffrey E.'" <[email protected]> Subject: PB Date: Mon, 28 Dec 2015 13:37:02 +0000 I was driving around Palm Beach yesterday, showing my friend who had ne
From: "Mark L. Epstein" To: mjeffrey E.'" <[email protected]> Subj
00 I was driving around Palm Beach yesterday, showing my friend who had never been here the usual sights; The Breakers, Worth Ave., the homes along Ocean Drive, registered offenders' homes, etc. I was surprised that your gate was open. Told your guy there to say hi. Heading to Miami to the boat. A comic s
ounsel For The United Stales: Lawrence LaVecchio. Jeffrey Kaplan. and Paul Schwartz Coun Reporter: Tammy
ndant RP24," includes all buildings, improvements, fixtures, attachments and easements found therein or thereon more particularly described as 1116 Ocean Drive, Miami Beach, FL Folio Number 02-3234-008-0310; B. Vehicles and Vessels ("VV"): (VV1) 1990 Red Ferrari F40 Coupe, VIN: ZFFMN34A5L0087066; -5- EFT
To: mail.conteevacationellgmail.com]; Jeffrey Epsteinjeevacation@gmaii corn] From: Sent Wed
th only one leg direct flight (other leg has connection) and double room will be 5850.00 per person http://www.breakwatersouthbeach.comi Located on Ocean Drive Also no swimming pool at the moment. EFTA_R1_00480135 EFTA01988323
Entities connected to both Jeffrey Epstein and Ocean Drive
Leon Black
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
T-Mobile
ORGANIZATION
John F. Kennedy
PERSON
Eric Trump
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
Donald Trump
PERSON
United States
LOCATION
Newark
LOCATION
Stephen Hawking
PERSONJack Goldberger
PERSON
Joe Biden
PERSON
Prince Charles
PERSON
Michael Cohen
PERSON
Steve Bannon
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSON
Julie K. Brown
PERSON