Epstein Secrets

EY EPSTEIN, Defendant. CASE NO.: 09-80469-CIV-MARRA-JOHNSON CASE NO.: 09-80591-CIV-MARRA-JOHNSON CASE NO.: 09-80656-CIV-MARRA/JOHNSON DEFENDANT, JEFFREY EPSTEIN'S REPLY TO JANE DOE NO. 101 AND JANE DOE NO. 102'S RESPONSE IN OPPOSITION TO MOTION TO COMPEL AND IDENTIFY JANE DOE NUMBERS 101 AND 102 IN THIRD PART

CASE NO.: 08-CV-8038I-MARRA/JOHNSON EFTA00182748 Case 9:08-cv-80119-KAM Document 152 Entered on FLSD Docket 06/10/2009 Page 2 of 8 Doe 101 v. Epstein Page 2 JANE DOE NO. 6, Plaintiff, JEFFREY EPSTEIN, Defendant. CASE NO.: 08-80994-CIV-MARRA/JOHNSON CASE NO.: 08-80993-CIV-MARRA/JOHNSON JANE

OHNSON Plaintiff, JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S RESPONSE TO PLAINTIFFS JANE DOE NOS. 101 AND 10

v. Epstein Page 4 Defendant, Jeffrey Epstein, ("Mr. Epstein"), by and through his undersigned attorneys, her

ICT OF FLORIDA JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN Defendant. JANE DOE NO. 3, Plaintiff,

ntracts in the civil and criminal contexts often focus on the "meticulous standards [which must be] ... met by the prosecutors ...," U.S. v. Mozer, 828 F.Supp. 208, 215-216 (S.D.N.Y.1993) (citations omitted), the differences apply to the defendants as well. The very purpose of a cooperation a

ion"). One does not need to engage in complex analysis to understand what has happened here: the government has sought to substitute our client for Jeffrey Epstein, even if it means stretching—and ultimately exceeding—the bounds of the law. Yet, it is in precisely this setting—involving a defendant who, despit

en short of its obligations here. The indictment must be dismissed. The government's sudden zeal to prosecute Ms. Maxwell for alleged conduct with Epstein in the 1990s—conduct for which the government never even charged Epstein—follows a history that is both highly unusual and deeply troubling. The gov

ohen Christian R. Everdell COHEN & GRESSER LLP Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

d, 867 F.2d 1425 (2d Cir. 1988) 21 United States v. Marquez, 909 F.2d 738 (2d Cir. 1990), cert. denied, 498 U.S. 1084 (1991) 15 United States v. Mozer, 828 F. Supp. 208 (S.D.N.Y. 1993) 12 iii EFTA00065992 United States v. Papa, 533 F.2d 815 (2d Cir. 1975) 29 United States v. Persico, 620 F

ion"). One does not need to engage in complex analysis to understand what has happened here: the government has sought to substitute our client for Jeffrey Epstein, even if it means stretching—and ultimately exceeding—the bounds of the law. Yet, it is in precisely this setting—involving I defendant who, despit

en short of its obligations here. The indictment must be dismissed. The government's sudden zeal to prosecute Ms. Maxwell for alleged conduct with Epstein in the 1990s—conduct for which the government never even charged Epstein—follows I history that is both highly unusual and deeply troubling. The gov

overnment has sought to substitute our client for Jeffrey Epstein, even if it means stretching—and ultimat

d, 867 F.2d 1425 (2d Cir. 1988) 21 United States v. Marquez, 909 F.2d 738 (2d Cir. 1990), cert. denied, 498 U.S. 1084 (1991) 15 United States v. Mozer, 828 F. Supp. 208 (S.D.N.Y. 1993) 12 iii EFTA00099355 United States v. Papa, 533 F.2d 815 (2d Cir. 1975) 29 United States v. Persico, 620 F