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

t her entire amended complaint, the plaintiff uses the term "scheme" as though it were a password for gaining access to RICO standing. Cf. Newton'. Tyson Foods, Inc., 207 F.3d 444, 447 (8th Cir. 2000) (observing in the context of indirect and attenuated RICO allegations that "[t]he mere recitation of the chain o

rmation in the civil case, after extended litigation the Court ordered Epstein to produce all correspondence between the U.S. Attorney's Office and Jeffrey Epstein's legal counsel. Because of the delay 2 EFTA00614066 Case 9:08-cv-80736-KAM Document 96 Entered on FLSD Docket 09/16/2011 Page 3 of 21 caused by

24(a) and Fed. R. Civ. P. 24(b) (DE 93). The motion for "limited" intervention should be denied for three separate and independent reasons. First, Epstein's motion is not timely. The victims very specifically advised Epstein more than one year ago that they would be filing U.S. Attorney correspondence

RESPONSE TO MOTION FOR "LIMITED" INTERVENTION OF JEFFREY EPSTEIN COME NOW Jane Doe #1 and Jane Doe #2 (al

CVRA case: "At this point there is no reason for Mr. Epstein to become involved in the case where [Jane Doe #1

issues -- Jeffrey Epstein filed his untimely "Motion for Limited Intervention" (DE #93). This document was also signed by attorney Roy Black, Esq. I. EPSTEIN MOTION FOR LIMITED INTERVENTION IS UNTIMELY. The Court should deny Epstein's motion for invention because it is simply untimely. As Epstein concede

required to make the same initial disclosures that are part and parcel of civil suits. He would also presumably be subject to deposition. See Fox v. Tyson Foods, Inc., 519 F.3d 1298, 1305 (11th Cir. 2008) (affirming denial of motion to intervene because of delay that would be involved in deposing the intervenors)

rmation in the civil case, after extended litigation the Court ordered Epstein to produce all correspondence between the U.S. Attorney's Office and Jeffrey Epstein's legal counsel. Because of the delay 2 EFTA00614087 Case 9:08-cv-80736-KAM Document 96 Entered on FLSD Docket 09/16/2011 Page 3 of 21 caused by

24(a) and Fed. R. Civ. P. 24(b) (DE 93). The motion for "limited" intervention should be denied for three separate and independent reasons. First, Epstein's motion is not timely. The victims very specifically advised Epstein more than one year ago that they would be filing U.S. Attorney correspondence

RESPONSE TO MOTION FOR "LIMITED" INTERVENTION OF JEFFREY EPSTEIN COME NOW Jane Doe #1 and Jane Doe #2 (al

CVRA case: "At this point there is no reason for Mr. Epstein to become involved in the case where (Jane Doe #1

issues -- Jeffrey Epstein filed his untimely "Motion for Limited Intervention" (DE #93). This document was also signed by attorney Roy Black, Esq. I. EPSTEIN MOTION FOR LIMITED INTERVENTION IS UNTIMELY. The Court should deny Epstein's motion for invention because it is simply untimely. As Epstein concede

required to make the same initial disclosures that are part and parcel of civil suits. He would also presumably be subject to deposition. See Fox v. Tyson Foods, Inc., 519 F.3d 1298, 1305 (11th Cir. 2008) (affirming denial of motion to intervene because of delay that would be involved in deposing the intervenors)

PEL NON-PRIVILEGED DOCUMENTS Laura A. Menninger Jeffrey S. Pagliuca HADDON, MORGAN, AND FOREMAN. P.C. E

ions of the agreement were prepared in anticipation of litigation and therefore fall within the definition of attorney work product."); Oklahoma v. Tyson Foods, Inc., No. 05-CV-329, 2007 WL 3128422, at • (N.D. Okla. Oct. 24, 2007). 10 EFTA00618143 Case 1:15-cv-07433-RWS Document 191 Filed 06/06/16 Page 13 of 1