Epstein Secrets

Case 9:08-cv-80119-KAM Document 16-2 Entered on FLSD Docket 07/01/2008 Page 2 of 4 : tiP • ' CASE PIO ±-122OO.1.:IFO-51/4 541sXXX CF V. JEFFREY E. EPSTEIN Z41 'FP ^i ria4 Y tr..mr.y..PRzia"rtnivz•zrt : . • . 7 'Crt. Rep. lun,L__ Date : • -17 vcri J „Asir )----=-- • / PD e--P:9fot Pres, D

events or omissions giving rise to the claim occurred in this District. Factual Allegations 7. At all relevant times, Defendant Jeffrey Epstein ("Epstein") was an adult male, 52 years old. Epstein is a financier and money manager with a secret clientele limited exclusively to billionaires. He is hims

, represented by Assistant United States , and Mr. Epstein, entered into a deferred- prosecution agreement (

' CASE PIO ±-122OO.1.:IFO-51/4 541sXXX CF V. JEFFREY E. EPSTEIN Z41 'FP ^i ria4 Y tr..mr.y..PRzia"r

ach, Florida 33401 Tel. 561 659 8300 Fax. 561 835 8691 By: Jack A. Goldberger Fla. Bar No. 262013 jgoldberger®agwpa.com Attorneys for Defendant Jay Epstein CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 711.A.3 While defense counsel admittedly did not confer with plaintiffs' counsel prior to filing the moti

l distress based on the same factual allegations. Defendant Epstein has moved to dismiss only Count I of the Complai

' CASE PIO ±-122OO.1.:IFO-51/4 541sXXX CF V. JEFFREY E. EPSTEIN Z41 'FP ^i ria4 Y tr..mr.y..PRzia"rt

ed by Fed. R. Civ. P. 26 and S.D. Fla. Local Rule 26.1, Epstein "must" disclose the identities of all the witnesses he would call in his defense to the Federal Criminal Action (Rule 26(aXI XAXi)), copies of "all documents" he "may use to support [his] defenses" (Rule 26(aX1XA)(ii)), as well as the identity of "any" expert witness he "

9-KAM Document 38 Entered on FLSD Docket 08/12/2008 Page 1 of 13 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, vs. JEFFREY EPSTEIN. JANE DOE NO. 3, VS. JEFFREY EPSTEIN. / JANE DOE NO. 4, vs. JEFFREY EPSTEIN. JANE DOE NO. 5, vs. JEFFREY EPSTEIN. CASE NO.: 08-80119-CIV-K

VEN CLERK M LAD U -EL-r-EyeAgr CASE NO.: 08-80232-CIV- -KAM-L CASE NO.: 08-80380-CIV-KAM-LRJ CASE NO.: 08-80381-CIV-KAM-LRJ FILED UNDER SEAL. EPSTEIN'S REPLY IN SUPPORT OF MOTION TO STAY This motion is filed under seal because the deferred-prosecution agreement between the United States Attorney's

ach, Florida 33401 Tel. 561 659 8300 Fax. 561 835 8691 By: Jack A. Goldberger Fla. Bar No. 262013 jgoldberger®agwpa.com Attorneys for Defendant Jay Epstein CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 711.A.3 While defense counsel admittedly did not confer with plaintiffs' counsel prior to filing the moti

OUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, vs. JEFFREY EPSTEIN. JANE DOE NO. 3, VS. JEFFREY EPSTEIN.

between the United States Attorney's Office and Mr. Epstein. discussed herein, contains a confidentiality cla

ed by Fed. R. Civ. P. 26 and S.D. Fla. Local Rule 26.1, Epstein "must" disclose the identities of all the witnesses he would call in his defense to the Federal Criminal Action (Rule 26(aXI XAXi)), copies of "all documents" he "may use to support [his] defenses" (Rule 26(aX1XA)(ii)), as well as the identity of "any" expert witness he "

9-KAM Document 38 Entered on FLSD Docket 08/12/2008 Page 1 of 13 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, vs. JEFFREY EPSTEIN. JANE DOE NO. 3, VS. JEFFREY EPSTEIN. / JANE DOE NO. 4, vs. JEFFREY EPSTEIN. JANE DOE NO. 5, vs. JEFFREY EPSTEIN. CASE NO.: 08-80119-CIV-K

VEN CLERK M LAD U -EL-r-EyeAgr CASE NO.: 08-80232-CIV- -KAM-L CASE NO.: 08-80380-CIV-KAM-LRJ CASE NO.: 08-80381-CIV-KAM-LRJ FILED UNDER SEAL. EPSTEIN'S REPLY IN SUPPORT OF MOTION TO STAY This motion is filed under seal because the deferred-prosecution agreement between the United States Attorney's

ach, Florida 33401 Tel. 561 659 8300 Fax. 561 835 8691 By: Jack A. Goldberger Fla. Bar No. 262013 jgoldberger®agwpa.com Attorneys for Defendant Jay Epstein CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 711.A.3 While defense counsel admittedly did not confer with plaintiffs' counsel prior to filing the moti

OUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, vs. JEFFREY EPSTEIN. JANE DOE NO. 3, VS. JEFFREY EPSTEIN.

between the United States Attorney's Office and Mr. Epstein. discussed herein, contains a confidentiality cla

ed by Fed. R. Civ. P. 26 and S.D. Fla. Local Rule 26.1, Epstein "must" disclose the identities of all the witnesses he would call in his defense to the Federal Criminal Action (Rule 26(aXI XAXi)), copies of "all documents" he "may use to support [his] defenses" (Rule 26(aX1XA)(ii)), as well as the identity of "any" expert witness he "

9-KAM Document 38 Entered on FLSD Docket 08/12/2008 Page 1 of 13 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, vs. JEFFREY EPSTEIN. JANE DOE NO. 3, VS. JEFFREY EPSTEIN. / JANE DOE NO. 4, vs. JEFFREY EPSTEIN. JANE DOE NO. 5, vs. JEFFREY EPSTEIN. CASE NO.: 08-80119-CIV-K

VEN CLERK M LAD U -EL-r-EyeAgr CASE NO.: 08-80232-CIV- -KAM-L CASE NO.: 08-80380-CIV-KAM-LRJ CASE NO.: 08-80381-CIV-KAM-LRJ FILED UNDER SEAL. EPSTEIN'S REPLY IN SUPPORT OF MOTION TO STAY This motion is filed under seal because the deferred-prosecution agreement between the United States Attorney's

ach, Florida 33401 Tel. 561 659 8300 Fax. 561 835 8691 By: Jack A. Goldberger Fla. Bar No. 262013 [email protected] Attorneys for Defendant Jay Epstein CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 711.A.3 While defense counsel admittedly did not confer with plaintiffs' counsel prior to filing the moti

OUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, vs. JEFFREY EPSTEIN. JANE DOE NO. 3, VS. JEFFREY EPSTEIN.

between the United States Attorney's Office and Mr. Epstein. discussed herein, contains a confidentiality cla

ed by Fed. R. Civ. P. 26 and S.D. Fla. Local Rule 26.1, Epstein "must" disclose the identities of all the witnesses he would call in his defense to the Federal Criminal Action (Rule 26(aXI XAXi)), copies of "all documents" he "may use to support [his] defenses" (Rule 26(aX1XA)(ii)), as well as the identity of "any" expert witness he "