Epstein Secrets

-80119-MARRA-JOHNSON JANE DOE NO. 2. Plaintiff JEFFREY E. EPSTEIN, Defendant. Related Cases: 08-80232,

09/17/2009 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2. Plaintiff JEFFREY E. EPSTEIN, Defendant. Related Cases: 08-80232, 08-80380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 0940469, 09-80581, 09-80656, 0940802, 09-81092.

d as Exhibit 1. 5. Some 13 days later, counsel for Jane Doe No. 4 flied a motion for protective order on September 9, 2009 attempting to prohibit MrEpstein's presence at the deposition. The Defendant immediately filed a response (an Emergency Motion) on September II, 2009 requesting that the coon enter

been justified, however, under these circumstances, it was grandstanding and improper. In that the Plaintiff has stated that she voluntary went to JE's home 50 plus times without trauma until she filed a lawsuit, this brief visual encounter from a distance should not have resulted in the unilater

Entered on FLSD Docket 09/11/2009 Page 4 of 33 Page 4 the plaintiffs either directly or indirectly. However, there is no prohibition against Mr. F.pstein's attendance at a deposition where, as is reflected in the order, the communication wilt be made to the plaintiff solely through defense counsel wi

LORIDA COUNTY OF PALM BEACFI hereby Se that. On. day, hefoie me, an ACC* &if itithoiiiid to oaths and take ac/cnowledgmener, personally appeared Jeffrey E. Bpetein known to me to be the person described in and who executed the foregoing Affidavit, who wrimowledged before me that he/she executed the same, that

09-00419, 0940581, 0940656, 09-80802, 0941092. Defendant Epstein's Emergency Motion To Strike Plaintiff's Motion F

s the intent of the Court to give the Defendant, Mr. Epstein, and his attorney an opportunity to have this Co

-80119-MARRA-JOHNSON JANE DOE NO. 2. Plaintiff JEFFREY E. EPSTEIN, Defendant. Related Cases: 08-80232, 0

.; Stuart Memcbtein; Ashlie Stoker-Badng; Connie Zagulrre Subject Jane Does v. Epstein From reviewing the transcripts, it seems Dr. Kliman utilized Questionnaire's with all of your clients. I need them. Please advise of your position. I'm sure you will produce since they are EXHIBIT 3 9/15/2009 09/12/2019

17/2009 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOB NO. 2, Plaintiff I JEFFREY B. EPSTEIN, Defendant. Related Cases: 08-80232, 08-80380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80581, 09-80656, 09-80802, 09-8109

deo deposition creates logistical problems. 4. On August 27, 2009, the undersigned wrote a letter to counsel for the Plaintiff indicating that Mr. Epstein would be present at the deposition. A copy of that letter is attached as Exhibit 1. 5. Some 13 days later, counsel for Jane Doe No. 4 filed a moti

been justified, however, under these circumstances, it was grandstanding and improper. In that the Plaintiff has stated that she voluntary went to JE's home 50 plus times without trauma until she filed a lawsuit, this brief visual encounter from a distance should not have resulted in the unilater

ths and take acknowledgments, personally appeared Jeffrey E. Epstein known to me to be the person described

d to me and I agree by them. ep/07-02-08 Defendant aeir 7-D-3- 6 7 reitS* al +k 6-5 taINS Page 7 of 8 Form Revised 03-18-08 EFTA00182102 :TREY EPSTEIN CASEN502008CF009381AXXXMB COURT ORDERED PAYMENTS CHECK ALL THAT ARE ORDERED: FINES K K K S Total of fines assessed in sentence, pursuant to

t fib. Critton, Jr. Mic 1J. Pike Attorneys for Defendant Epstein Certificate of Service I HEREBY CERTIFY that a

ths and take acknowledgments, personally appeared Jeffrey E. Epstein known to me to be the person described i

ter to counsel for the Plaintiff indicating that Mr. Epstein would be present at the deposition. A copy of tha

Stuart Mermeistein; Ashlie Stoken-Baring; Connie Zaguirre Subject Jane Does v. Epstein From reviewing the transcripts, it seems Dr. Kliman utilized Questionnaire's with all of your clients. I need them. Please advise of your position. I'm sure you will produce since they are EXHIBIT 3 If 9/15/2009 EFTA001

been justified, however, under these circumstances, it was grandstanding and improper. In that the Plaintiff has stated that she voluntary went to JE's home 50 plus times without trauma until she filed a lawsuit, this brief visual encounter from a distance should not have resulted in the unilater

09/17/2009 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOB NO. 2, Plaintiff JEFFREY B. EPSTEIN, Defendant. Related Cases: 08-80232, 08-80380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80581, 09-80656, 09-80802, 09-8109

deo deposition creates logistical problems. 4. On August 27, 2009, the undersigned wrote a letter to counsel for the Plaintiff indicating that Mr. Epstein would be present at the deposition. A copy of that letter is attached as Exhibit 1. 5. Some 13 days later, counsel for Jane Doe No. 4 filed a moti

d to me and I agree by them. ep/07-02-08 Defendant aeir 7-D-3- 6 7 reitS* al +k 6-5 taINS Page 7 of 8 Form Revised 03-18-08 EFTA01625733 :TREY EPSTEIN CASEN502008CF009381AXXXMB COURT ORDERED PAYMENTS CHECK ALL THAT ARE ORDERED: FINES K K K S Total of fines assessed in sentence, pursuant to

t fib. Critton, Jr. Mic 1J. Pike Attorneys for Defendant Epstein Certificate of Service I HEREBY CERTIFY that a

ths and take acknowledgments, personally appeared Jeffrey E. Epstein known to me to be the person described

ths and take acknowledgments, personally appeared Jeffrey E. Epstein known to me to be the person described i

ter to counsel for the Plaintiff indicating that Mr. Epstein would be present at the deposition. A copy of tha

Stuart Mermeisteln; Ashlie Stoken-Baring; Connie Zaguirre Subject Jane Does v. Epstein From reviewing the transcripts, it seems Dr. Kliman utilized Questionnaire's with all of your clients. I need them. Please advise of your position. I'm sure you will produce since they are EXHIBIT 3 If 9/15/2009 EFTA016

Description of the Litigation and the Class This Notice relates to a proposed settlement of claims in a pending class action brought by victims of Jeffrey E. Epstein's ("Epstein") sex trafficking venture, which alleged, among other things, that Defendant violated the Trafficking Victims Protection Act ("TVPA") by p

1, 1998, and through August 10, 2019. This includes, but is not limited to, (1) individuals under the age of 18 who engaged in sexual contact with Epstein and/or a person connected to or otherwise associated with Epstein, and received money or something else of value in exchange for engaging in that s

in a pending class action brought by victims of Jeffrey E. Epstein's ("Epstein") sex trafficking venture, w

in a pending class action brought by victims of Jeffrey E. Epstein's ("Epstein") sex trafficking venture, wh

O CONTACT CLASS COUNSEL IN ORDER TO PARTICIPATE IN DISTRIBUTION OF THE SETTLEMENT FUND? No. If you have received this Notice and timely submit your Questionnaire and Release to the designated address, you need not contact Class Counsel. If your address changes, please contact the Claims Administrator at: Si

AND RELEASE TO BE you (or counsel on your behalf) must submit a Questionnaire and ELIGIBLE TO RECEIVE A Release to the Claims Administrator. The Questionnaire and PAYMENT Release must be postmarked (if mailed) or received (if submitted online) on or before September 5, 2023 at 11:59PM EDT. If the Claims

Description of the Litigation and the Class This Notice relates to a proposed settlement of claims in a pending class action brought by victims of Jeffrey E. Epstein's ("Epstein") sex trafficking venture, which alleged, among other things, that Defendant violated the Trafficking Victims Protection Act ("TVPA") by p

is Case 5. This case grew out of our firms' long representation of the survivors of Jeffrey Epstein's sex trafficking ring. EHL began representing Epstein survivors in 2009. BSF began representing Epstein survivors in the first half of 2014. 6. By 2021, our firms had successfully brought lawsuits aga

s in a pending class action brought by victims of Jeffrey E. Epstein's ("Epstein") sex trafficking venture,

s in a pending class action brought by victims of Jeffrey E. Epstein's ("Epstein") sex trafficking venture, w

5.4 For the avoidance of doubt, should the Claims Administrator have concerns as to the accuracy of a Participating Claimant's claim form answers, Questionnaire answers, allegations, or any other information submitted, the Claims Administrator shall promptly notify Class Counsel in writing of those concerns

their insurers and reinsurers. 4.3 All Class Members who apply for an Allocated Amount will submit an additional release form included within the Questionnaire and Release. 5. Evaluation of Claims, Plan of Allocation, Final Awards, Supervision and Distribution of the Settlement Fund, and Reversion 5.1 T

ing information: the circumstances, severity, type, and extent of the alleged abuse or trafficking, the nature and duration of the relationship with Jeffrey Epstein, and the impact of the alleged conduct on the Participating Claimant. Participating Claimants shall submit under penalty of perjury such other suppo

tional information you which to share with the Claims Administrator including any additional information about the harm you suffered as a result of Epstein's conduct if not already described in your prior answers. 12. Everything that you submit to the Claims Administrator will be kept completely confide

the nature and duration of the relationship with Jeffrey Epstein, and the impact of the alleged conduct on

will be rejected, and you will not receive any recovery from the Net Settlement Fund created in connection with the Settlement. You may submit your Questionnaire and Release in your preferred language. The Claims Administrator has English and Russian language versions of this form that can be found by visiti

ed Jane Doe 1 v. JPMorgan Chase Bank, N.A., Case No. 1:22-CV-10019 (JSR) (the "Litigation"), you (or your counsel, on your behalf) must complete the Questionnaire and Release' included in this document and submit it pursuant to the instructions below. You (or your counsel, on your behalf) must mail or upload o

ntors annuity trust. The trust grantor is Jeffrey Epstein the beneficiary is the grantor and the 2013 Butt

the grantors annuity trust. The trust grantor is Jeffrey Epstein the beneficiary is the grantor and the 2

on of the relationship among the Family Members -The entity is a trust for the purpose of retaining the grantors annuity trust. The trust grantor is Jeffrey Epstein the beneficiary is the grantor and the 2013 Butterfly Trust, the trustees are Lesley Goff and Daphne Wallace. O 2017 DautaChe Bank AG. Ail ngnat rf

onnaire." Darren Indyke as contact for The 2017 Caterpillar Trust Signature of Name of Client Representative_ Date O1c1 have completed this Questionnaire and attest that it is accurate to the best of my knowledge based upon the information and documentation provided to me by the banking team.' Signat

, ECF No. 235.1 I. INTRODUCTION This litigation resulted in a historic, globally publicized $290 million settlement agreement for the survivors of Jeffrey Epstein. In its order granting preliminary approval of the Settlement, the Court found the Settlement to be fair, reasonable, and adequate, and authorized N

lan of Allocation, and fee request. HI. THE COURT SHOULD OVERRULE JANE DOE 7'S OBJECTION. On September 15, 2023, an individual purporting to be an Epstein victim and wishing to remain anonymous under the pseudonym Jane Doe 7, filed "Objections to the Proposed Settlement" and an accompanying declaratio

illion settlement agreement for the survivors of Jeffrey Epstein. In its order granting preliminary approv

ust submit a Questionnaire and Release to the Claims Administrator." ECF No. 181-2, at 2. Jane Doe 7 does not claim to have ever submitted either a Questionnaire and Release or an opt-out form to the Class Administrator before filing her Objection. Jane Doe 7 also fails to establish that she is a Class Membe

("GVI") has established a mental health fund (the "Mental Health Fund") to provide a financial resource for mental health services for survivors of Jeffrey Epstein that I will be administering. As a Class Member of both the Epstein DB Fund and the Epstein JPM Fund, you are eligible to apply for approved mental

Simone Lelchuk, Claims Administrator Epstein Survivors' Settlement Fund JPM do Freika PLL Ja

urce for mental health services for survivors of Jeffrey Epstein that I will be administering. As a Class

ted to me from Participating Claimants and this letter ("Determination Notice") constitutes notice of your Allocated Amount. After considering your Questionnaire and Release using the guidelines and evaluation factors enumerated in Section 5.2 of the JPM Stipulation and the totality of the circumstances, I ha

cumentation and only to the person to whom such documentation is actually delivered by the General Partner of Biosys Capital Partners, LP. DRAFT - Jeffery Epstein BIOSYS CAPITAL PARTNERS, LPI Confidential Private Placement Memorandum i Subscription Booklet DAL:0105560100001:2318591v2 EFTA00617709 BIOSYS CA

OT HESITATE TO CONTACT [BORIS NIKOLIC AT (425) 503-9166] BIOSYS CAPITAL PARTNERS, LP I Confidential Private Placement McmorritRIAtriiptionieehab ry Epstein DAL:0105560/00001:2318591v2 EFTA00617710 INVESTOR QUESTIONNAIRE DR(okfT - Ileffpry Epstein BIOSYS CAPITAL PARTNERS, LP I Confidential Private P

r's license? State: Driver's License Number: (kT - Off BIOSYS CAPITAL PARTNERS, LP I Confidential Private Placement MemorandumDR Sufcnption atena se ry Epstein DAL:0105560/00001:2318591v2 EFTA00617719 F. SUPPLEMENTAL QUESTIONS FOR ENTITIES This section should be completed for any Subscriber that is an e

eeded to determine whether the Partnership may accept an investor's investment, it is necessary for the investor (the "Subscriber") to complete this Questionnaire. Please answer all questions. Write "N/A" if not applicable. A. PLEASE PROVIDE THE FOLLOWING INFORMATION. 1. (a) Name of the Subscriber: (b)