Epstein Secrets

2'2009 Page 1 of 26 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE, CASE NO.: 08-CIV- 80893 - MARRA/JOHNSON Plaintiff, v. JEFFREY EPSTEIN, Defendants. Defendant's, Epstein. Motion To Dismiss, For More Definite Statement & To Strike Directed To Plaintiff Jane Doe's Amended Complaint,

Plaintiff. . .was called on the telephone by. . .Epstein and other employees. . ., and transported to. . .

Florida Civil Rico action is, at this time, only defendant Epstein. . . ." However, the RICO enterprise must be dis

.: 08-CIV- 80893 - MARRA/JOHNSON Plaintiff, v. JEFFREY EPSTEIN, Defendants. Defendant's, Epstein. Moti

AJ, 2008 WL 476220,'3 (M.D.Fla. Feb.19, 2008) (dismissing RICO claim because the alleged enterprise and the defendant person were one in the same); Lockheed Martin Corp. v. Boeing co.. 314 F. Supp.2d 1198, 1216-1217 (M.D. Fla. 2004Xfor purpose of liability under Racketeer Influenced and Corrupt Organizations Act (RIC

kground 2 I. DBZ's Investment Strategy 3 2. Mr. Zwirn's Role at DBZ 3 3. Mr. Dubin's Involvement with DBZ 4 4. DBZ's Lock-Ups 4 C. Mr. Epstein's Relationship with Mr. Dubin 6 D. FTC's Investments in the Fund 7 E. Accounting Improprieties at DBZ 8 F. DBZ's Discovery of Accounting Imp

Third-Party Claimants Financial Trust Company, Inc. and Jeepers, Inc. (together, "FTC"). Preliminary Statement At no time did Daniel Zwim promise Jeffrey Epstein that FTC could immediately withdraw $80 million of its investments in DBZ's Fund. Mr. Epstein's claim that Mr. Zwim made such a promise is a newly

ary Statement At no time did Daniel Zwim promise Jeffrey Epstein that FTC could immediately withdraw $80

volvement with DBZ 4 4. DBZ's Lock-Ups 4 C. Mr. Epstein's Relationship with Mr. Dubin 6 D. FTC's Inves

Nov. 26, 2002) 29 Anglo Amen Sec. Fund, L.P. v. S.R. Global Int'! Fund, L.P., 2006 WL 1494360 (Del. Ch. May 24, 2006) 20 BAE Sys. N. Am. Inc. v. Lockheed Martin Corp., 2004 WL 1739522 (Del. Ch. Aug. 3, 2004) 23 Bay Center Apartments Owner, LLC v. Einery Bay PKI, LLC, 2009 WL 1124451 (Del. Ch. Apr. 20, 2009) 27

IN THE DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA, FOURTH DISTRICT JEFFREY EPSTEIN, Petitioner, v. STATE OF FLORIDA, Respondent. CASE NO. 4D09-2554 PALM BEACH COUNTY L.T. CASE NO. 2008 CF 009381A REPLY TO RESPONSES TO EMERGE

Judge Colbath defer to the federal court, which has twice denied disclosure of the confidential non- prosecution between the U.S. government and Mr. Epstein to third parties. Just 1 09/12/2019 Agency to Agency Requet: 19-411 CONFPI535ENTIAL SDNY_GM_00331783 EFTA 00204509 EFTA02729494 last week, J

APPEAL OF THE STATE OF FLORIDA, FOURTH DISTRICT JEFFREY EPSTEIN, Petitioner, v. STATE OF FLORIDA, Res

non- prosecution between the U.S. government and Mr. Epstein to third parties. Just 1 09/12/2019 Agency to

er target") (Post Resp. at 22; B.B. Resp. at 14) are wrong (see sealed NPA). The cases the Post and B.B. cite recognize these policy concerns. See Lockheed Martin Corp. v. Boeing Co., 393 F. Supp. 2d 1276, 1279 (M.D. Fla, 2005); In re Grand Jury Investigation of Ven-Fuel, 441 F. Supp. 1299, 1302-03 (M.D. Fla. 1977)