Epstein Secrets

Counsel for Plaintiff Jane Doe 6 EFTA00175540 Case 9:08-cv-8uo04-KAM Document Entered ..i FLSD Docket 09115L . J8 Page 7 of 8 SERVICE LIST Doe Epstein, et. al. CASE NO: 08-80804-Civ-MARIUUJOHNSON United States District Court, Southern District of Florida Robert Critton, Esq. Burman, Critton, Lut

natabase - flsd Page 1 of 6 U.S. District Court Southern District of Florida (West Palm Beach) CIVIL DOCKET FOR CASE #: 9:08-cv-80804-KAM Doe v. Epstein et al Assigned to: Judge Kenneth A. Marra Referred to: Magistrate Judge Linnea R. Johnson ' Case in other court: 15th Judicial Circuit, 50 2008 C

stion Plaintiff Jane Doe represented by Spencer Todd Kuvin Ricci Leopold 2925 PGA Boulevard Suite 200 Palm Beach Gardens , FL 33410 Defendant Jeffrey Epstein Fax: 515-2610 Email: LEAD ATTORNEY ATTORNEY TO BE NOTICED Theodore Jon Leopold Leopold—Kuvin, P.A. 2925 PGA Boulevard Suite 200 Palm Beach Garden

SD Do t 3.8/1b,..,08 Page 4 of 21 Iktb4-1 PLEA IN THE CIRCUIT COURT THE FOLLOVVING IS TO REFLECT Al .l TERMS OF THE NEGOTIATED SETTLEMEN*1 Name: Jeffrey E. Epstein Plea: Guilty 1 NP.---_.. SIMI .,lister _Dellloe a D 06CF009454A Felony Solicitation of Prostitution 1 No 3.FEI rocuring Person Under 18 for

nying as moot 2 Motion for Hearing. Signed by Judge Kenneth A. Marra on 8/5/08. (ir) (Entered: 08/06/2008) 08/08/20(8 a r ns KB MOTION Defendant Jeffiwy Epstein's Opposed Motion to Align Response Date by Jeffrey Epstein. (Attachments: # 1 Text of Proposed OrderXTein, Michael) (Entered: 08/08/2008) 08/13/2008

F.3d at 1314. conditions, and sensitive protocols concerning the fact of Epstein's previously disclosed incarceration. See DE 24 in Jane Doe No. 2 I. Epstein, Case No. 9:08-CV-80119-KAM (S.D. Fla. filed Feb. 6, 2Q08) (disclosing fact of Epstein's criminal sentence and incarceration); DE 19 in Jane Doe No

1332: the amount in controversy exceeds $75,000; Defendant Epstein is a citizen of the U.S. Virgin Islands; and Def

Al .l TERMS OF THE NEGOTIATED SETTLEMEN*1 Name: Jeffrey E. Epstein Plea: Guilty 1 NP.---_.. SIMI .,liste

Al .l TERMS OF THE NEGOTIATED SETTLEMEN*1 Name: Jeffrey E. Epstein Plea: Guilty 1 NP.---_.. SIMI .,lister

a/k/a, JANE DOE NO. 1, Plaintiff, vs. IF'.F .EY EPSTEIN , and Defendants. PLAINTIFF'S REPLY TO OPPOSIT

32: the amount in controversy exceeds $75,000; Defendant Epstein is a citizen of the U.S. Virgin Islands; and Defendant is a citizen of New York. (Notice of Removal ¶ 2.) As Plaintiff is a citizen of Florida, complete diversity exists and this Court's jurisdiction is alleged to be proper. As for Defendants cla

have known that Plaintiff had no credentials to provide massage therapy. b. She observed the Plaintiff being brought to the Palm Beach mansion of JEFFREYEPSTEIN, when the Plaintiff was a minor, andsometimes escorted the Plaintiff to a room in that mansion where JEFFREY EPSTEIN was waiting, for the ostensibl

atabase - flsd Page 1 of 5 LSS U.S. District Court Southern District of Florida (West Palm Beach) CIVIL DOCKET FOR CASE #: 9:08-cv-80811-KAM v. Epstein et al Assigned to: Judge Kenneth A. Marra Cause: 28:1332 Diversity Plaintiff V. Defendant Jeffrey Epstein Date Filed: 07/21/2008 Jury Demand:

e Plaintiff, when the Plaintiff was a minor, which depicted fhe Plaintiff in the nude. She told the Plaintiff that the pictures were at the request ofJEFFREY EPSTEIN, and paid the Plainlifffor posing for the photographs. 12. As a icsult, the Plaintiff sufferedmental anguish, mental pain and suffeaing, psychic

on which alleges sexual abuse of a female minor by the defendant JEFFREY EPSTEIN. 4. It has come to the attention of the undersigned that Defendant JEFFREY EPSTEIN filed a Motion with the Florida State Court to return the evidence seized at his home in conjunction with his criminal prosecution. With re

instant claim, but for other suits filed against Defendant EPSTEIN, including but not limited to the Florida RICO c

e 4 of 40 (b) While the Complaint suggests that Mr. Epstein might be a citizen of New York or Florida, he is

ly where it was filed within 30 days after the last defendant was served). Second, in accordance with section 1446(d), defendants have served this Notice of Removal on July 21, 2008, Third, in accordance with section 1446(6), all of the defendants join this Petition and consent to removal. District courts may

EPSTEIN BOX INVENTORY Box A: Redwell with different files for each Jane Doe I. Epstein case Cd's with Documents on 2nd Supplemental Privilege Log (2) and

uments that are not Privileged; printout of brief regardin Westlaw printouts Redwell with emails from 2007-2008 Box K: FBI Palm Beach County RA, Jeffrey E. Epstein, 31E-MM White binder with PBPD Reports Palm Beach Police/SAO Records Redwell with post it that says "This whole stack is for opposing counsel" — in

ith 6/23/08 letter from (DAG) to and =; 11/2/2010 Privileged Communication letter re Litigation Hold; clipped Non-Prosecution Agreement Doe (..) I. Epstein, 08-80893-CV-KAM (red file folder) Box II: (labeled GJ Presentation Materials) Federal Criminal Code and Rules 2006 Edition with multiple post-its

ral Analysis File folder: FBI E. Log File folder no name — includes September 17, 2009 letter to M= from File folder: Responses to Arguments from JE counsel File folder: Overt Act Lists File folder: Breach Memo File folder: 6/12/09 Victim Notif Log File folder: 6/9/09 Signed Indictment Pkg Bi

from 2007-2008 Box K: FBI Palm Beach County RA, Jeffrey E. Epstein, 31E-MM White binder with PBPD Reports

from 2007-2008 Box K: FBI Palm Beach County RA, Jeffrey E. Epstein, 31E-MM White binder with PBPD Reports P

er) 6/12/09 Breach Ltr file folder) — post it says Epstein Defense 3 (Kelly) 7/29/11 Letter to from regarding NPA being a confidential document Notice of Removal (DEtf1) in 08-CV-8084-KAM Jane Doe case Redwell with Epstein's Motion to Seal Non-Pros Agreement Epstein New York Case (Redwell) 12/10/10, 3/1/11,

Palm Beach County, Florida. Plaintiff is a female who is presently twenty-one years old. 3. The Plaintiff is unsure of the residency of defendant JEFFREY ES PSTEIN, because he has residences in New York, Florida, New Mexico, and also outside of the continental United States. a 4. The defendant, was n reside

strict Court for the Southern District of Florida. See 28 U.S.C. § 1332(a)(1) (establishing that federal district courts have original I C.M.A. v. Epstein et aL, Case No. 50 2008 CA 005240 XXXX MB (Fla. 15th Cir. Ct. filed Feb. 21, 2008). Lewis.tein n. 3059 Gray MINUE, Sum 340, COCONUT GROVE, FLORIDA

28 U.S.C. § 1446(6), this Notice is timely. Only defendant Epstein has been served with process. Defendant has not

.M.A., 08-80811-Civ-ZLOCH/SNOW Plaintiff, vs. JEFFREY EPSTEIN and Defendants. NOTICE OF REMOVAL July

e 4 of 40 (b) While the Complaint suggests that Mr. Epstein might be a citizen of New York or Florida, he is

and suffering, psychic trauma, and a loss of the capacity for the enjoyment of life. WHEREFORE, THE PLAINTIFF DEMANDS JUDGMENT FOR DAMAGES AGAINST JEFFREY EPSTEI N, IN AN AMOUNT IN EXCESS OF FIFTEEN THOUSAND DOLLARS, EXCLUSIVE OF COSTS AND INTEREST, AND FUR'FII ER DEMANDS TRIAL BY JURY. COV.NT n 10. Plaintif

ly where it was filed within 30 days after the last defendant was served). Second, in accordance with section 1446(d), defendants have served this Notice of Removal on July 21, 2008. Third, in accordance with section 1446(b), all of the defendants join this Petition and consent to removal. 4 District courts m

EPSTEIN BOX INVENTORY Box 1: Redwell with different files for each Jane Doe v. Epstein case Cd's with Documents on 2" Supplemental Privilege Log (2) and B

d; printout of brief regarding Alvin F. Aguirre-Gonzalez; Westlaw printouts Redwell with emails from 2007-2008 Box 11: FBI Palm Beach County RA, Jeffrey E. Epstein, 31E-MM White binder with PBPD Reports Palm Beach Police/SAO Records Redwell with post it that says "This whole stack is for opposing counsel" — in

, OLY-53, OLY-54 (red folder) Colonial Bank (green file folder) JEGE & Hyperion from Goldberger OLY-46 & 0LY-47 (file folder) Box 19: Research re JE websites (file folder) Victim Civil Suits (file folder) NY AUSA) - (file folder) Dr. Anna Salter (file folder) Interview (file folder) Research

rom 2007-2008 Box 11: FBI Palm Beach County RA, Jeffrey E. Epstein, 31E-MM White binder with PBPD Reports

rom 2007-2008 Box 11: FBI Palm Beach County RA, Jeffrey E. Epstein, 31E-MM White binder with PBPD Reports P

with NPA 2/18/10 Letter to from Black regarding attorney's fees 3/20/11 Letter from Acosta Transcript of 6/12/09 Motion Hearing in Jane Doe case Notice of Removal (DE#1) in 08-CV-8084-KAM Jane Doe case Redwell with Epstein's Motion to Seal Non-Pros Agreement Epstein New York Case (Redwell) 12/10/10, 3/1/11,

SD Do ;,A8/18/2008 Page 4 of 21 ktIVA4 . PLEA IN THE CIRCUIT COURT THE FOLLOWING IS TO REFLECT ALI. TERMS OF THE NEGOTIATED SI TTLFMEN I Name: Jeffrey E. Epstein Plea: Guilty A 6e4 /9—,—..... . _charge Cpynt Lessei _Dee' ep &b 06CF00945 Felony Solicitation of Prostitution 1 No 3 FUT rocuring Pers

told detectives, 'I'm like a Heidi Fleiss.'"). EFTA00234424 Case 9:08-cv-80804-KAM Document 11 Entered on FLSD Docket 08)18:2008 Page 2 of 11 Epstein," (Notice of Removal, DE 1, p. 3) and that Plaintiff fraudulently joined her in this action to prevent complete diversity.2 3. As demonstrated in Pl

ALI. TERMS OF THE NEGOTIATED SI TTLFMEN I Name: Jeffrey E. Epstein Plea: Guilty A 6e4 /9—,—..... . _char

ut, however, that there is a question of whether Defendant Epstein is actually a citizen of Florida because he is n

ALI. TERMS OF THE NEGOTIATED SI TTLFMEN I Name: Jeffrey E. Epstein Plea: Guilty A 6e4 /9—,—..... . _charg

tion that she is a citizen of Florida, Defendants question whether she might actually be a citizen of Georgia because her mother lives in Georgia. (Notice of Removal, DE I, pp. 7-8, n.6). Defendants fail to point out, however, that there is a question of whether Defendant Epstein is actually a citizen of Florida

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

e case to federal district court, where it was ultimately transferred to the Southern District of Florida. The League filed a Motion to Quash DER's Notice of Removal, which motion was argued before Judge William Hoeveler on July 10, 1991, and was granted on September 10, 1991. The federal court held that there

which of his clients is the purported victim. Accordingly,) will address facts related to , S. 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 III and In

fteenth Judicial Circuit, Palm Beach County, Florida. This charge was based upon the offenses alleged in paragraph 1 of the petition. Second, while Epstein has been under federal investigation, he has not been charged in EFTA00183654 Case 9:08-cv-80736-KAM Document 13 Entered on FLSD Docket 07/15/20

treet, Suite 202 Hollywood, Florida 33020. Re: Jeffrey E eir m/SaVhiii: NOTIFICATION OF IDENTIFIED VICT

ve the federal investigation. al 5. At that time, Mr. Epstein had been charged by the State of Florida with so

e case to federal district court, where it was ultimately transferred to the Southern District of Florida. The League filed a Motion to Quash DER's Notice of Removal, which motion was argued before Judge William Hoeveler on July 10, 1991, and was granted on September 10, 1991. The federal court held that there