Epstein Secrets

ge 2 of 34 Fraud and Deceptive Business Practices Act. 3. This action stems from an enforcement action the Government filed against the Estate of Jeffrey E. Epstein, the Co-Executors of the Estate, and various entities relating to Jeffrey Epstein ("Epstein"), under the Virgin Islands' Criminally Influenced and C

n the Government filed against the Estate of Jeffrey E. Epstein, the Co-Executors of the Estate, and various entities relating to Jeffrey Epstein ("Epstein"), under the Virgin Islands' Criminally Influenced and Corrupt Organizations Act ("CICO Act"), see Government of the U.S. Virgin Islands v. Indyke e

exual activity, and/or attempted to do the same. EFTA00161929 Case 1:22-cv-10904-JSR Document 16-1 Filed 01/10/23 Page 61 of 77 GVI v. Estate of Jeffrey Epstein GV1's Second Amended Complaint Page 60 of 76 338. The Epstein Enterprise kept, maintained, and/or permitted his property at Little St. James to be used

was that, although the Bank properly classified Mr. Epstein as high-risk, the Bank failed to scrutinize the a

ction the Government filed against the Estate of Jeffrey E. Epstein, the Co-Executors of the Estate, and var

ction the Government filed against the Estate of Jeffrey E. Epstein, the Co-Executors of the Estate, and vari

t (July 22, 2010), https://www.thedailybeast.com/jeffrey-epstein-pedophile-billionaire-and-his-sex-den. 10 EFTA0

MAND The Government demands a jury trial on all issues so triable. Dated: January 10, 2023 CAROL THOMAS-JACOBS, ESQ. ACTING ATTORNEY GENERAL Is! David I. Ackerman DAVID I. ACKERMAN (NYS Bar #4110839) Motley Rice LLC 401 9th Street NW, Suite 630 Washington, DC 20004 Tel: (202) 849-4962 [email protected]

s Consumer Fraud and Deceptive Business Practices Act. 3. This action stems from an enforcement action the Government filed against the Estate of Jeffrey E. Epstein, the Co-Executors of the Estate, and various entities relating to Jeffrey Epstein ("Epstein"), under the Virgin Islands' Criminally Influenced and C

n the Government filed against the Estate of Jeffrey E. Epstein, the Co-Executors of the Estate, and various entities relating to Jeffrey Epstein ("Epstein"), under the Virgin Islands' Criminally Influenced and Corrupt Organizations Act ("CICO Act"), see Government of the U.S. Virgin Islands v. Indyke e

ction the Government filed against the Estate of Jeffrey E. Epstein, the Co-Executors of the Estate, and var

ction the Government filed against the Estate of Jeffrey E. Epstein, the Co-Executors of the Estate, and vari

t (July 22, 2010), https://www.thedailybeast.com/jeffrey-epstein-pedophile-billionaire-and-his-sex-den. 10 EFTA0

was that, although the Bank properly classified Mr. Epstein as high-risk, the Bank failed to scrutinize the a

e. Dated: April 3, 2023 CAROL THOMAS-JACOBS, ESQ. ACTING ATTORNEY GENERAL Isl Linda Singer Linda Singer (pro hac vice) Mimi Liu (pro hac vice) David I. Ackerman Paige Boggs (pro hac vice) MOTLEY RICE LLC 401 9th Street NW, Suite 630 Washington. DC 20004 Carol Thomas-Jacobs (pro hac vice) Acting Attorney

), and the authority of the Court to administer proceedings before it, for approval of an agreed- upon protocol authorizing counsel for the Estate of Jeffrey E. Epstein (the "Epstein Estate") to review videorecorded materials and photographs in the possession, custody, or control of the Epstein Estate (the "Epstein

o assume that [there was possible] interstate transmission of child pornography...that could have changed the entire complexion of the case against Epsteinf OPR Report, p. 176. Six computer hard drives were suspiciously missing from Epstein's Florida home just before a police raid--leaving dangling wire

- investigation-into-the-u-s-attorney-s-office-for-the-southern-district-of- florida-s-resolution-of-its-2006-2008-federal-criminal-investigation-of- jeffrey-epstein-and-its-interactions-with-victims-during-the- investigation/db9373e8-22f8-4712-b4a7-be844d162de0/, p. iv. As acknowledged in the OPR Report, law enforce

on protocol authorizing counsel for the Estate of Jeffrey E. Epstein (the "Epstein Estate") to review videor

on protocol authorizing counsel for the Estate of Jeffrey E. Epstein (the "Epstein Estate") to review videore

een agreed to by the parties. Date: March 27, 2023 Respectfully submitted, /s/ Linda Singer Linda Singer (pro hac vice) Mimi Liu (pro hac vice) David I. Ackerman Paige Boggs (pro hac vice) MOTLEY RICE LLC 401 9th Street NW, Suite 630 Washington, DC 20004 Tel: (202) 232-5504 Fax: (202) 232-5513 Isinger@m

), and the authority of the Court to administer proceedings before it, for approval of an agreed- upon protocol authorizing counsel for the Estate of Jeffrey E. Epstein (the "Epstein Estate") to review videorecorded materials and photographs in the possession, custody, or control of the Epstein Estate (the "Epstein

s meant to include Responsive Media that may consist of movies or You Tube videos, for example, but does not extend to Responsive Media relating to Epstein activities or properties that may have been publicly disclosed at any time. 2 In this motion, the parties use the term "child sex abuse imagery" or

on protocol authorizing counsel for the Estate of Jeffrey E. Epstein (the "Epstein Estate") to review videor

on protocol authorizing counsel for the Estate of Jeffrey E. Epstein (the "Epstein Estate") to review videore

een agreed to by the parties. Date: March 27, 2023 Respectfully submitted, /s/ Linda Singer Linda Singer (pro hac vice) Mimi Liu (pro hac vice) David I. Ackerman Paige Boggs (pro hac vice) MOTLEY RICE LLC 401 9th Street NW, Suite 630 Washington, DC 20004 Tel: (202) 232-5504 Fax: (202) 232-5513 Isinger@m