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

ively by the Federal Rules of Criminal Procedure, the USAO would not be entitled to compel pm-trial production of any of this information. See Fed. R. Cr. P. 16(bX1)(A), (C), and 16(bX2); United States v. Argomaniz, 925 F.2d 1349, 1355-56 (11th Cir. 1991) (explaining act-of-production privilege). Th

21 LRJ, MEDREQ, REF_DISCOV U.S. District Court Southern District of Florida (West Palm Beach) CIVIL DOCKET FOR CASE #: 9:08-cv-80119-1CAM Doe v. Epstein Assigned to: Judge Kenneth A. Marra Referred to: Magistrate Judge Linnea R. Johnson Member case: (View Member Case) Case: 9:09-cv-80802-KAM Caus

ON Plaintiffs Jane Doe No. 101 and Jane Doe 102's Motion for No- Contact Order Plaintiffs Jane Doe No. 101 and Jane Doe No. 102's Reply to Defendant Jeffrey Epstein's Response to Plaintiffi Jane Doe No. 101 and Jane Doe No. 102's Motion for a No-Contact Order filed by Jane Doe No. 101, Jane Doe No. 102. Associate

red: 02/08/2008) 05/22/2008 4 AFFIDAVIT of Service for Summons and Complaint served on Jeffrey Epstein on May 7, 2008, filed by Jane Doe. (Herman, Jeffrey) (Entered: 05/22/2008) 05/22/2008 5 SUMMONS Returned Executed by Jane Doe. Jeffrey Epstein served on 5/7/2008, Answer due 5/27/2008. (Ik) (Entere

FTA00175604 CM/ECF - Live Database - flsd Page 17 of 21 05/20/2009 Ma NOTICE be. of Filing Withdrawal of Previously Raise Lions to Defendant. Jetey Epstein's Motion to Ag And/Or IdentifyMf. in the Style of This Case and Motion to Identi . in Third-Party Subpoenas for Purposes of Discovery, Or, Alternati

. 2 I JEFFREY EPSTEIN, Plaintiff, Defendant. DEFENDANT EPSTEIN'S ANSWER & AFFIRMATIVE DEFENSES TO PLAINTIFF'S S

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

ively by the Federal Rules of Criminal Procedure, the USA° would not be entitled to compel pm-trial production of any of this information. See Fed. R. Cr. P. 16(bX1XA), J), and 16(bX2); United Stales Argomaniz, 925 F.2d 1349, 1355-56 (11th Cir. 1991) (explaining act-of-production privilege ). Thus,

9-KAM Document 38 Entered on FLSD Docket 08/12/2008 Page 1 of 13 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, vs. JEFFREY EPSTEIN. JANE DOE NO. 3, VS. JEFFREY EPSTEIN. / JANE DOE NO. 4, vs. JEFFREY EPSTEIN. JANE DOE NO. 5, vs. JEFFREY EPSTEIN. CASE NO.: 08-80119-CIV-K

VEN CLERK M LAD U -EL-r-EyeAgr CASE NO.: 08-80232-CIV- -KAM-L CASE NO.: 08-80380-CIV-KAM-LRJ CASE NO.: 08-80381-CIV-KAM-LRJ FILED UNDER SEAL. EPSTEIN'S REPLY IN SUPPORT OF MOTION TO STAY This motion is filed under seal because the deferred-prosecution agreement between the United States Attorney's

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

OUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, vs. JEFFREY EPSTEIN. JANE DOE NO. 3, VS. JEFFREY EPSTEIN.

between the United States Attorney's Office and Mr. Epstein. discussed herein, contains a confidentiality cla

ively by the Federal Rules of Criminal Procedure, the USAO would not be entitled to compel pm-trial production of any of this information. See Fed. R. Cr. P. 16(bX1)(A), (C), and 16(bX2); United States v. Argomaniz, 925 F.2d 1349, 1355-56 (11th Cir. 1991) (explaining act-of-production privilege). Th

9-KAM Document 38 Entered on FLSD Docket 08/12/2008 Page 1 of 13 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, vs. JEFFREY EPSTEIN. JANE DOE NO. 3, VS. JEFFREY EPSTEIN. / JANE DOE NO. 4, vs. JEFFREY EPSTEIN. JANE DOE NO. 5, vs. JEFFREY EPSTEIN. CASE NO.: 08-80119-CIV-K

VEN CLERK M LAD U -EL-r-EyeAgr CASE NO.: 08-80232-CIV- -KAM-L CASE NO.: 08-80380-CIV-KAM-LRJ CASE NO.: 08-80381-CIV-KAM-LRJ FILED UNDER SEAL. EPSTEIN'S REPLY IN SUPPORT OF MOTION TO STAY This motion is filed under seal because the deferred-prosecution agreement between the United States Attorney's

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

OUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, vs. JEFFREY EPSTEIN. JANE DOE NO. 3, VS. JEFFREY EPSTEIN.

between the United States Attorney's Office and Mr. Epstein. discussed herein, contains a confidentiality cla

ively by the Federal Rules of Criminal Procedure, the USAO would not be entitled to compel pm-trial production of any of this information. See Fed. R. Cr. P. 16(bX1)(A), (C), and 16(bX2); United States v. Argomaniz, 925 F.2d 1349, 1355-56 (11th Cir. 1991) (explaining act-of-production privilege). Th

9-KAM Document 38 Entered on FLSD Docket 08/12/2008 Page 1 of 13 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, vs. JEFFREY EPSTEIN. JANE DOE NO. 3, VS. JEFFREY EPSTEIN. / JANE DOE NO. 4, vs. JEFFREY EPSTEIN. JANE DOE NO. 5, vs. JEFFREY EPSTEIN. CASE NO.: 08-80119-CIV-K

VEN CLERK M LAD U -EL-r-EyeAgr CASE NO.: 08-80232-CIV- -KAM-L CASE NO.: 08-80380-CIV-KAM-LRJ CASE NO.: 08-80381-CIV-KAM-LRJ FILED UNDER SEAL. EPSTEIN'S REPLY IN SUPPORT OF MOTION TO STAY This motion is filed under seal because the deferred-prosecution agreement between the United States Attorney's

ach, Florida 33401 Tel. 561 659 8300 Fax. 561 835 8691 By: Jack A. Goldberger Fla. Bar No. 262013 [email protected] 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

OUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, vs. JEFFREY EPSTEIN. JANE DOE NO. 3, VS. JEFFREY EPSTEIN.

between the United States Attorney's Office and Mr. Epstein. discussed herein, contains a confidentiality cla

ively by the Federal Rules of Criminal Procedure, the USAO would not be entitled to compel pm-trial production of any of this information. See Fed. R. Cr. P. 16(bX1)(A), (C), and 16(bX2); United States v. Argomaniz, 925 F.2d 1349, 1355-56 (11th Cir. 1991) (explaining act-of-production privilege). Th

e v. FBI, 17 Civ. 3956 (PGG). The FBI in New York released to Radar Online some 1,232 pages "relating to the FBI's investigation and prosecution of Jeffrey Edward Epstein." Id. at Dkt. 25, p. 1. According to a letter signed by your office, 181 pages were released in full and 1,051 were released with partial redactions

SDNY, FBI-New York Office, and FBI Florida Office, regarding any other FOIA requests that have produced documents pertaining to any investigation of Jeffrey Epstein or Ghislaine Maxwell and produce to us the documents made public through the FOIA requests, the dates the documents were produced and the identity

investigation and prosecution of Jeffrey Edward Epstein." Id. at Dkt. 25, p. 1. According to a letter sig

ng to the FBI's investigation and prosecution of Jeffrey Edward Epstein." Id. at Dkt. 25, p. 1. According

ine Maxwell, 20 Cr. 330 (AJN) Discovery request pertaining to FOIA productions Dear Counsel: I write to request certain discovery pursuant to Fed. R. Cr. P. 16. Haddon, Morgan and Foreman, r c Laura A. Menninger N Under Rule 16(a)(1)(E), I ask that you provide to us the documents produced by the F

e v. FBI, 17 Civ. 3956 (PGG). The FBI in New York released to Radar Online some 1,232 pages "relating to the FBI's investigation and prosecution of Jeffrey Edward Epstein." Id. at Dkt. 25, p. 1. According to a letter signed by your office, 181 pages were released in full and 1,051 were released with partial redactions

SDNY, FBI-New York Office, and FBI Florida Office, regarding any other FOIA requests that have produced documents pertaining to any investigation of Jeffrey Epstein or Ghislaine Maxwell and produce to us the documents made public through the FOIA requests, the dates the documents were produced and the identity

investigation and prosecution of Jeffrey Edward Epstein." Id. at Dkt. 25, p. 1. According to a letter sig

ng to the FBI's investigation and prosecution of Jeffrey Edward Epstein." Id. at Dkt. 25, p. 1. According

ine Maxwell, 20 Cr. 330 (AJN) Discovery request pertaining to FOIA productions Dear Counsel: I write to request certain discovery pursuant to Fed. R. Cr. P. 16. Haddon, Morgan and Foreman, r.c Laura A. Menninger ISO East 10th Avenue Denver, Colorado 80203 www.hMtlOw.COM Under Rule 16(a)(1)(E), I

9-KAM Document 38 Entered on FLSD Docket 08/12/2008 Page 1 of 13 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, vs. JEFFREY EPSTEIN. JANE DOE NO. 3, VS. JEFFREY EPSTEIN. / JANE DOE NO. 4, vs. JEFFREY EPSTEIN. JANE DOE NO. 5, vs. JEFFREY EPSTEIN. CASE NO.: 08-80119-CIV-K

VEN CLERK M LAD U -EL-r-EyeAgr CASE NO.: 08-80232-CIV- -KAM-L CASE NO.: 08-80380-CIV-KAM-LRJ CASE NO.: 08-80381-CIV-KAM-LRJ FILED UNDER SEAL. EPSTEIN'S REPLY IN SUPPORT OF MOTION TO STAY This motion is filed under seal because the deferred-prosecution agreement between the United States Attorney's

OUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, vs. JEFFREY EPSTEIN. JANE DOE NO. 3, VS. JEFFREY EPSTEIN.

between the United States Attorney's Office and Mr. Epstein. discussed herein, contains a confidentiality cla

ively by the Federal Rules of Criminal Procedure, the USAO would not be entitled to compel pm-trial production of any of this information. See Fed. R. Cr. P. 16(bX1)(A), (C), and 16(bX2); United States v. Argomaniz, 925 F.2d 1349, 1355-56 (11th Cir. 1991) (explaining act-of-production privilege). Th

ich of his clients is the purported victim. Accordingly, I will address facts related to C.W., and S R. All three of those clients were victims of Jeffrey Epstein's while they were minors beginning when they were fifteen years old. =Please note that the dates on the U.S. Attorney's Office letters to C.W. and T.

because the deferred-prosecution agreement between the United States Attorney's Office (by Assistant U.S. Attorney Marie C. Villafana, Esq.) and Mr. Epstein, discussed herein, contains a confidentiality clause. 09/1212019 LewjAIsinn. 3059 Owe Awns. Sum 310, Cccoodur Owns hoes 3303 PT CONFIDE CONFIDEN

ZLOCH/SNOW C.M.A., I I I I Plaintiff, vs. JEFFREY EPSTEIN and SARAH KELLEN, Defendants. $eated

stant U.S. Attorney Marie C. Villafana, Esq.) and Mr. Epstein, discussed herein, contains a confidentiality cl

ively by the Federal Rules of Criminal Procedure, the USAO would not be entitled to compel pre-trial production of any of this information. See Fed. R. Cr. P. 16(b)(1)(A), (C), and 16(bX2); United States v. Argomaniz, 925 F.2d 1349, 1355-56 (11th Cir. 1991) (explaining act-of-production privilege). T

f his clients is the purported victim. Accordingly, I will address facts related to C.W., T.M., and S.R. All three of those clients were victims of Jeffrey Epstein's while they were minors beginning when they were fifteen years old. 'Please note that the dates on the U.S. Attorney's Office letters to C.W. and T.

thern District of Florida asks that you provide the following notice to your client, On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors

401 (561)8204711 Facsimile: (561)8204777 July 9, 2008 VIA FACSIMILE Brad Edwards, Esq. The Law Offices of Brad Edwards & Associates, [.LC Re: Jeffrey 4..stein/QIN...la NOTIFICATION OF IDENTIFIED VICTIM Dear Mr. Edwards: By virtue of this letter, the United States Attorney's Office for the Southe

ceed under Section 2255 as she would have had, if Mr. Epstein EFTA00233829 Case 9:08-cv-80736-KAM Document

ively by the Federal Rules of Criminal Procedure, the USAO would not be entitled to compel pre-trial production of any of this information. See Fed. R. Cr. P. 16(b)(1)(A), (C), and 16(b)(2); United States I Argomaniz, 925 F.2d 1349, 1355-56 (11th Cir. 1991) (explaining act-of-production privilege). T