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

rendered prior to October 1, 1981. On February 20, 2008, the plaintiff was deposed in State of Florida'. Jeffrey Epstein, 502006CF009454 (Fla. 15th Cir. Ct. filed July 19, 2006). During that deposition, she made numerous admissions that completely undermined the allegations in her complaint. Two days l

driguez advised he had very limited contact with Mr. Epstein. If Rodriguez needed to relay a message to Mr. E

d Six, to-wit The Grand Jurors of the State of Florida, inquiring in end for the body of said County of Palm Beach, upon their oaths do present that JEFFREY E. EPSTEIN in the County of Palm Beach aforesaid. in the Circuit and State aforesaid. COUNT ONE FELONY SOLICITATION OF PROSTITUTION on or about or between th

esses and register himself as an agent. I also observed Epstein has his El Zorro Ranch Corporation, New York Strategy Group, Ghislaine Corporation, J Epstein and Company and the Financial Strategy Group registered to this same address. Finally, a third call is received by at 12:02 pm from the same corp

y of Palm Beach, upon their oaths do present that JEFFREY E. EPSTEIN in the County of Palm Beach aforesaid.

I wrote that, but I didn't write what you 13 said. 14 4. 15 16 you write that? 17 18 19 20 21 22 about what happened when you went to Jeff Epstein's house You wrote in this exhibit, "I got some stupid court s-h-i-t on the 20th. Bull s-h-i-t." Didn't A. Yes. Q. Referring to this deposition, d

his associates. ) (describing character of party defendant Epstein as a "sexual predator" (a term defined by Florida

y of Palm Beach, upon their oaths do present that JEFFREY E. EPSTEIN in the County of Palm Beach aforesaid. i

. 2008) (same). On February 20, amid these filings, Jane Doe 41 was deposed in State of Florida v. Jeffrey Epstein, 502006CF009454AXXXMB (Fla. 15th Cir. Ct., filed Jul. 19, 2006), a parallel state-court criminal action. During that deposition, she made numerous admissions that completely undermined the

esses and register himself as an agent. I also observed Epstein has his El Zorro Ranch Corporation, New York Strategy Group, Ghislaine Corporation, J Epstein and Company and the Financial Strategy Group registered to this same address. Finally, a third call is received by at 12:02 pm from the same corp

d Six, to-wit The Grand Jurors of the State of Florida, inquiring in and for the body of said County of Palm Beach, upon their oaths do present that JEFFREY E. EPSTEIN in the County of Palm Beach aforesaid. in the Circuit and State aforesaid. COUNT ONE FELONY SOLICITATION OF PROSTITUTION on or about or between th

ourt. I was• later 20 informed that it was a deposition. 21 Q. I'm going to ask you some questions now 22 about what happened when you went to Jeff Epstein's house — 2S-- three-Yearragerr— Gkeig 24 A. Uh -huh. 25 Q. When the police interviewed you one month Ph. - Fax. 1655 Palm Beach Lakes Blvd.,

y of Palm Beach, upon their oaths do present that JEFFREY E. EPSTEIN in the County of Palm Beach aforesaid.

his associates. ) (describing character of party defendant Epstein as a "sexual predator" (a term defined by Florida

y of Palm Beach, upon their oaths do present that JEFFREY E. EPSTEIN in the County of Palm Beach aforesaid. i

ery well and did not want to speak with me about Mr. Epstein. She was very fond of Epstein and did not want t

. 2008) (same). On February 20, amid these filings, Jane Doe #1 was deposed in State of Florida v. Jeffrey Epstein, 502006CF009454AXXXMB (Fla. 15th Cir. Ct., filed Jul. 19, 2006), a parallel state-court criminal action. During that deposition, she made numerous admissions that completely undermined the

ket 07)21:2008 Page 16 of 100 1. The plaintiff seeks damages in connection with her own illegal conduct. The plaintiff concedes that she went to Jeffrey Epstein's house "to give Epstein a massage for monetary compensation." (Am. Compl. ¶ 13.) The plaintiff also concedes, in the guise of an allegation, that "

respectfully state as follows: Introduction Six months ago, this plaintiff filed virtually the identical lawsuit in this Court. See Jane Doe #1 v. Epstein, Case No. 08-cv-80069-KAM (S.D. Fla. filed Doe v. Epstein et at, Case No. 50 2008 CA 006596 XXXX MB (Fla. 15th Cir. Ct. filed Mar. 6, 2008). Lewis

A. Yes. Q. Didn't you tell that to the police? A. Yes. And I will continue. I have never had sex with him. Q. Did what happened upstairs at Jeff Epstein's house take you completely by surprise,. A. Yes. Q. Now the civil complaint that you filed against Mr. Epstein for fifty million dollars alleged

in's house you had 17 never told Jeff that you were under 18, right? 18 A. No. 19 Q. Before you got to Epstein's house had you 20 ever told Jeffrey that you were under 18? 21 A. No. I never spoke to the man before that. 22 Q. And you only went to Jeff Epstein's house 23 that one time thre

his associates. ) (describing character of party defendant Epstein as a "sexual predator" (a term defined by Florida

the instant case, adding two nominal defendants Mr. Epstein's personal secretary, and MB one of Jane Doe #1'

. 2008) (same). On February 20, amid these filings, Jane Doe #1 was deposed in State of Florida v. Jeffrey Epstein, 502006CF009454AXXXMB (Fla. 15th Cir. Ct., filed Jul. 19, 2006), a parallel state-court criminal action. During that deposition, she made numerous admissions that completely undermined the

011 Pages w/cover: 4 Fax #: Direct #: Please see the attached letter, in response to your letter to Martin Weinberg of July 27, 2011, concerning Jeffrey Epstein. Thank you. Documena EFTA00180294 07/29/2011 13: 12 FAX a 002/004 Jay P. LeatowItz. P.C. To ilaiactly: jay.lefkowitzekirklend.cOm KIRKLAND &

oncerning the request by the New York District Attorney for copies of the Non-Prosecution Agreement ("NPA") and the "victim list" in regards to Mr. Epstein. We continue for the reasons stated herein to believe that any such disclosure would violate the confidentiality agreement between your Office and

Jack 2:114:5 jackpot 32:9 jail 41:7 Jane 1:4,15,18,22 2:3,7 3:5,5,7,11 5:17 6:8,9,16 11:12 21:4 29:14 29:22 33:5 35:13 42:22 Jay 2:20 4:18 Jeffrey 1/ 37:12 jeopardize 9:15 Jeopardy 15:17 join 26:11,15 Josefsberg 2:1,2,5 3:18,20,21,23 19:7 19:7,1021:25 23:1 24:5 25:25 26:7,11 26:12,16 27:

ourt. I was• later 20 informed that it was a deposition. 21 Q. I'm going to ask you some questions now 22 about what happened when you went to Jeff Epstein's house 23 three years ago. Okay? 24 A. Oh-huh. 25 Q. When the police interviewed you one month Ph. 561.682.0905 - Fax. 561.682.1771 1655 Pal

. § 1446, this notice of removal is timely. Only defendant Epstein has been served with process. Defendants 21 Lew

ment ("NPA") and the "victim list" in regards to Mr. Epstein. We continue for the reasons stated herein to be

this Court. See Jane Doe #1 v. Epstein, Case No. 08-cv-80069-KAM (S.D. FM. filed Doe v. Epstein et at, Case No. 50 2008 CA 006596 XXXX MB (FM. 15th Cir. Ct. filed Mar. 6, 2008). Lewis 'reins. 30$96amailonsuL Sum 340,CoColtui Gaon, Foram 33133 1 01311 EFTA00180357 Case 9:08-cv-80804-KAM Document 1

e meeting? 2 A. No. They -- yeah. No. They have it. I'm 3 guessing. I don't have it. 4 Q. How much money are you hoping to get out of 5 Mr. Epstein? 6 MR. LEOPOLD: Objection to the form of the 7 question. Attorney/client privilege. 8 BY MR. TEIN: 9 Q. How much money are you hoping to get

ket 07/21/2008 Page 16 of 100 1. The plaintiff seeks damages in connection with her own illegal conduct. The plaintiff concedes that she went to Jeffrey Epstein's house "to give Epstein a massage for monetary compensation." (Am. Compl. ¶ 13.) The plaintiff also concedes, in the guise of an allegation, that "

court. I was later 20 informed that it was a deposition. 21 Q. I'm going to ask you some questions now 22 about what happened when you went to Jeff Epstein's house 23 three years ago. Okay? 24 A. Uh-huh. 25 Q. When the police interviewed you one month You wrote in this exhibit, "I got some Ph. 56

you got to Epstein's house you had never told Jeff that you were under 18, right? A. No. Q. Before you got to Epstein's house had you ever told Jeffrey that you were under 18? A. No. I never spoke to the man before that. Q. And you only went to Jeff Epstein's house that one time three years ago,

his associates. ) (describing character of party defendant Epstein as a "sexual predator" (a term defined by Florida

How much money are you hoping to get out of 5 Mr. Epstein? 6 MR. LEOPOLD: Objection to the form of the 7

. 2008) (same). On February 20, amid these filings, Jane Doe #1 was deposed in State of Florida v. Jeffrey Epstein, 502006CF009454AXXXMB (Fla. 15th Cir. Ct., filed Jul. 19, 2006), a parallel state-court criminal action. During that deposition, she made numerous admissions that completely undermined the

ulver Smith Ill ceu 561.301.3800 ENGAGEMENT MEMORANDUM BY ELECTRONIC MAIL ONLY To: Gunster, Yoakley & Stewart P.A. do David R. Atkinson < RE: Epstein v. Rothstein, No. 502009CA040800XXXXMB (Fla. 15th Cir. Ct.) DATE: November 2, 2017 Thank you for engaging me on behalf of Mr. Epstein, Jeffrey Epst

RE: Epstein v. Rothstein, No. 502009CA040800XXXXMB (Fla. 15th Cir. Ct.) DATE: November 2, 2017 Thank you for engaging me on behalf of Mr. Epstein, Jeffrey Epstein, to serve as an expert witness in regard to the above-referenced matter. The purposes of this letter are to confirm the engagement and to ensure th

ank you for engaging me on behalf of Mr. Epstein, Jeffrey Epstein, to serve as an expert witness in regard

r 2, 2017 Thank you for engaging me on behalf of Mr. Epstein, Jeffrey Epstein, to serve as an expert witness

BY ELECTRONIC MAIL ONLY To: Gunster, Yoakley & Stewart P.A. do David R. Atkinson < RE: Epstein v. Rothstein, No. 502009CA040800XXXXMB (Fla. 15th Cir. Ct.) DATE: November 2, 2017 Thank you for engaging me on behalf of Mr. Epstein, Jeffrey Epstein, to serve as an expert witness in regard to the above

01 www.culversmithlaw.com D. Culver Smith Ill Cell 561.301.3800 ENGAGEMENT MEMORANDUM BY ELECTRONIC MAIL ONLY To: Link & Rockenbach P.A. RE: Epstein v. Rothstein, No. 50-2009-CA-040800-XXXX-MB (Fla. 15th Cir. Ct.) DATE: December 12, 2017 Thank you for engaging me on behalf of your client, Jeffre

pstein v. Rothstein, No. 50-2009-CA-040800-XXXX-MB (Fla. 15th Cir. Ct.) DATE: December 12, 2017 Thank you for engaging me on behalf of your client, Jeffrey Epstein, to serve as an expert witness regarding the above-referenced matter. The purposes of this memorandum are to confirm the engagement and to ensure t

ank you for engaging me on behalf of your client, Jeffrey Epstein, to serve as an expert witness regarding

o confirm the engagement and to ensure that you, Mr. Epstein, and I understand and agree upon the scope of my

800 ENGAGEMENT MEMORANDUM BY ELECTRONIC MAIL ONLY To: Link & Rockenbach P.A. RE: Epstein v. Rothstein, No. 50-2009-CA-040800-XXXX-MB (Fla. 15th Cir. Ct.) DATE: December 12, 2017 Thank you for engaging me on behalf of your client, Jeffrey Epstein, to serve as an expert witness regarding the above-r

l. www.culversmithlaw.com D. Culver Smith Ill Cell 561.301.3800 ENGAGEMENT MEMORANDUM BY ELECTRONIC MAIL ONLY To: Link & Rockenbach P.A. RE: Epstein v. Rothstein, No. 50-2009-CA-040800-XXXX-MB (Fla. 15th Cir. Ct.) DATE: December 7, 2017 Thank you for engaging me on behalf of your client, Jeffrey

Epstein v. Rothstein, No. 50-2009-CA-040800-XXXX-MB (Fla. 15th Cir. Ct.) DATE: December 7, 2017 Thank you for engaging me on behalf of your client, Jeffrey Epstein, to serve as an expert witness regarding the above-referenced matter. The purposes of this memorandum are to confirm the engagement and to ensure t

ank you for engaging me on behalf of your client, Jeffrey Epstein, to serve as an expert witness regarding

o confirm the engagement and to ensure that you, Mr. Epstein, and I understand and agree upon the scope of my

800 ENGAGEMENT MEMORANDUM BY ELECTRONIC MAIL ONLY To: Link & Rockenbach P.A. RE: Epstein v. Rothstein, No. 50-2009-CA-040800-XXXX-MB (Fla. 15th Cir. Ct.) DATE: December 7, 2017 Thank you for engaging me on behalf of your client, Jeffrey Epstein, to serve as an expert witness regarding the above-re