Epstein Secrets

Case 9:08-cv-80119-KAM Document 16-2 Entered on FLSD Docket 07/01/2008 Page 2 of 4 : tiP • ' CASE PIO ±-122OO.1.:IFO-51/4 541sXXX CF V. JEFFREY E. EPSTEIN Z41 'FP ^i ria4 Y tr..mr.y..PRzia"rtnivz•zrt : . • . 7 'Crt. Rep. lun,L__ Date : • -17 vcri J „Asir )----=-- • / PD e--P:9fot Pres, D

events or omissions giving rise to the claim occurred in this District. Factual Allegations 7. At all relevant times, Defendant Jeffrey Epstein ("Epstein") was an adult male, 52 years old. Epstein is a financier and money manager with a secret clientele limited exclusively to billionaires. He is hims

, represented by Assistant United States , and Mr. Epstein, entered into a deferred- prosecution agreement (

' CASE PIO ±-122OO.1.:IFO-51/4 541sXXX CF V. JEFFREY E. EPSTEIN Z41 'FP ^i ria4 Y tr..mr.y..PRzia"r

ach, Florida 33401 Tel. 561 659 8300 Fax. 561 835 8691 By: Jack A. Goldberger Fla. Bar No. 262013 jgoldberger®agwpa.com Attorneys for Defendant Jay Epstein CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 711.A.3 While defense counsel admittedly did not confer with plaintiffs' counsel prior to filing the moti

l distress based on the same factual allegations. Defendant Epstein has moved to dismiss only Count I of the Complai

' CASE PIO ±-122OO.1.:IFO-51/4 541sXXX CF V. JEFFREY E. EPSTEIN Z41 'FP ^i ria4 Y tr..mr.y..PRzia"rt

when, on the basis of a dispositive issue of law, no construction of the factual allegations will support a cause of action." Marshall County Bd. of Ethic. v. Marshal County Gas Dist., 992 F.2d 1171, 1174 (11th Cir. 1993). "[T]o survive a 2 EFTA00222724 Case 9:08-cv-80119-KAM Document 40 Entered

he say? 4 A. She, she said she doesn't really know. I 5 guess she doesn't remember. She says that she was asked 6 if she knew about my going to Jeffrey Epstein's house, 7 and she told them that she gave me a ride there before. 8 Q. And was that true? 9 A. Yes. 10 1Okay. On how many times did your sist

the same conduct or what I would say lack of professionalism to do something like that. MR. EDWARDS: Well, but, obviously, the difference is Mr. Epstein's anonymity has not been protected in this case, and these victims have. So... MR. CRITTON: So it's okay to humiliate and embarrass someone and t

e; true? 4 A. No. 5 Q. You so if I ask you is it your testimony, 6 as you sit here today, that since the time you filed the 7 lawsuit against MrStein, you have never discussed 8 your lawsuit withM.? 9 A. No. 10 Q. That's not true — that's not correct? 11 A. What is not correct? 12 Q. All

-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, -vs- JEFFREY EPSTEIN, Defendant. VOLUME I Related cases: 0

EDWARDS: Well, but, obviously, the difference is Mr. Epstein's anonymity has not been protected in this case,

s at the time you were living with het? Page 56 1 Q. A few months? 2 A. Yes. 3 Q. What does a few months mean you to? Tine or 4 four, five, Ethic? S A. About three. 6 Q. Did you — and was she -. was she living at 7 the same place in =En 8 A. No. 9 Q. Where was she living at that time?

008 Page 1 of 8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-80119-CIV-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN Defendant. MOTION TO DISMISS Defendant Jeffrey Epstein, pursuant to Rule 12(b) of the Federal Rules of Civil Procedure and Rule 7.1(A) of the Loc

COMPLAINT This action arises out of the alleged assault of the plaintiff. According to the allegations in her complaint, the plaintiff went to Mr. Epstein's house to give him "a massage for monetary compensation" (Compl. ¶ 12), where Mr. Epstein allegedly assaulted her "in violation of Chapter 800 of

-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN Defendant. MOTION TO DISMISS Defendant

legations in her complaint, the plaintiff went to Mr. Epstein's house to give him "a massage for monetary comp

when, on the basis of a dispositive issue of law, no construction of the factual allegations will support a cause of action." Marshall County Bd. of Ethic. v. Marshal County Gas Dist., 992 F.2d 1171, 1174 (11th Cir. 1993). "[T]o survive a 2 EFTA00221978 Case 9:08-cv-80119-KAM Document 40 Entered

008 Page 1 of 8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-80119-CIV-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN Defendant. MOTION TO DISMISS Defendant Jeffrey Epstein, pursuant to Rule 12(b) of the Federal Rules of Civil Procedure and Rule 7.1(A) of the Loc

COMPLAINT This action arises out of the alleged assault of the plaintiff. According to the allegations in her complaint, the plaintiff went to Mr. Epstein's house to give him "a massage for monetary compensation" (Compl. ¶ 12), where Mr. Epstein allegedly assaulted her "in violation of Chapter 800 of

-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN Defendant. MOTION TO DISMISS Defendant

legations in her complaint, the plaintiff went to Mr. Epstein's house to give him "a massage for monetary comp

when, on the basis of a dispositive issue of law, no construction of the factual allegations will support a cause of action." Marshall County Bd. of Ethic. v. Marshal County Gas Dist., 992 F.2d 1171, 1174 (11th Cir. 1993). "[T]o survive a 2 EFTA00222421 Case 9:08-cv-80119-KAM Document 40 Entered

legal relief that Petitioners have sought pursuant to the CVRA is the setting aside of the Non-Prosecution Agreement that was entered into between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida ("USAO-SDFL"). See, e.g., DE 99 at 6 (recognizing that the relief Petitioners se

oners seek "is to invalidate the non-prosecution agreement"). But even assuming arguendo that Petitioners' rights under the CVRA were violated when Epstein and the USAO-SDFL entered into the Non- Prosecution Agreement, constitutional due process guarantees do not allow either the Non- Prosecution Agreeme

secution Agreement that was entered into between Jeffrey Epstein and the U.S. Attorney's Office for the So

pstein) who has not been made a party to the proceedings before the Court. See, e.g., School Dist. of City of Pontiac v. Secretary of U.S. Dept. of Ethic., 584 F.3d 253, 303 (6th Cir. 2009) ("It is hombook law that all parties to a contract are necessary in an action challenging its validity ...."); D

legal relief that Petitioners have sought pursuant to the CVRA is the setting aside of the Non-Prosecution Agreement that was entered into between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida ("USAO-SDFL"). See, e.g., DE 99 at 6 (recognizing that the relief Petitioners se

oners seek "is to invalidate the non-prosecution agreement"). But even assuming arguendo that Petitioners' rights under the CVRA were violated when Epstein and the USAO-SDFL entered into the Non- Prosecution Agreement, constitutional due process guarantees do not allow either the Non- Prosecution Agreeme

secution Agreement that was entered into between Jeffrey Epstein and the U.S. Attorney's Office for the So

pstein) who has not been made a party to the proceedings before the Court. See, e.g., School Dist. of City of Pontiac v. Secretary of U.S. Dept. of Ethic., 584 F.3d 253, 303 (6th Cir. 2009) ("It is hombook law that all parties to a contract are necessary in an action challenging its validity ...."); D

legal relief that Petitioners have sought pursuant to the CVRA is the setting aside of the Non-Prosecution Agreement that was entered into between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida ("USAO-SDFL"). See, e.g., DE 99 at 6 (recognizing that the relief Petitioners se

oners seek "is to invalidate the non-prosecution agreement"). But even assuming arguendo that Petitioners' rights under the CVRA were violated when Epstein and the USAO-SDFL entered into the Non- Prosecution Agreement, constitutional due process guarantees do not allow either the Non- Prosecution Agreeme

secution Agreement that was entered into between Jeffrey Epstein and the U.S. Attorney's Office for the So

pstein) who has not been made a party to the proceedings before the Court. See, e.g., School Dist. of City of Pontiac v. Secretary of U.S. Dept. of Ethic., 584 F.3d 253, 303 (6th Cir. 2009) ("It is hombook law that all parties to a contract are necessary in an action challenging its validity ...."); D

Source Document(s) 1 Source Document(s) IN RE: JEFFREY J. PROSSER, Debtor. NORTH SHORE REAL ESTATE CORP

* issue for trial." Id. In making this determination, this Court draws all reasonable riff] inferences in favor of the non-moving party. See Bd. of Ethic. v. Earls, 536 U.S. 822, 850, 122 S. Ct. 2559, 153 L. Ed. 2d 735 (2002); see also Armbruster v. Unisys Corp 32 F.3d 768, 777 (3d Cir. 1994). In Ca