Epstein Secrets

cument 36 Entered on FLSD Docket 06/12/2009 Page 1 of 19 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE II Plaintiff, VS. JEFFREY EPSTEIN, and Defendants. ) CASE NO.: 09-80469-CIV-MARRA ) ) ) ) ) ) ) ) ) PLAINTIFF'S AMENDED' MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANT EP

IN, and Defendants. ) CASE NO.: 09-80469-CIV-MARRA ) ) ) ) ) ) ) ) ) PLAINTIFF'S AMENDED' MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANT EPSTEIN'S MOTION TO DISMISS Plaintiff, JANE DOE II, through counsel, opposes Defendant's RICHARD EPSTEIN's Motion to Dismiss. Defendant's argument for a di

FF'S AMENDED' MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANT EPSTEIN'S MOTION TO DISMISS Plaintiff, JANE DOE II, thro

ISTRICT OF FLORIDA JANE DOE II Plaintiff, VS. JEFFREY EPSTEIN, and Defendants. ) CASE NO.: 09-80469

upheld intervening procedural changes even if application of the new rule operated to a defendant's disadvantage in the particular case. See e. g., Dobbert v. Florida, 432 U.S. 282, 293-294, 53 L. Ed. 2d 344, 97 S. Ct. 2290 (1977); see also Collins v. Youngblood, 497 U.S. 37, 111 L. Ed. 2d 30, 110 S. C

HE INDICTMENT On April , 2008, a Grand Jury sitting in the Southern District of Florida returned a twenty-nine-count indictment charging defendant Jeffrey Epstein' with one count of conspiracy to use a means of interstate commerce to persuade, induce, or entice nineteen minors to engage in prostitution, in vio

under 18 years of age, in violation of 18 U.S.C. § 2423(b). Jane Does #1 through #19 were all minors at the time of their involvement with defendant Epstein. Jane Doe #11 was a resident of New York; the remaining Jane Does were all residents of Palm Beach County, Florida, at the time of their involvemen

all minors at the time of their involvement with defendant Epstein. Jane Doe #11 was a resident of New York; the re

FLORIDA Case No. UNITED STATES OF AMERICA vs. JEFFREY EPSTEIN, Defendant. Notice of Appeal From Magis

al is not an ex post facto law. Even though it may work to the disadvant- age p f of a defendant, a procedural clinge is not ex ostacto ',"citing Dobbert Flor- ida, 432 U.S. 282, 293, 97 S.Ct. 2290, 2298, 53 L.Ed.2d 344 (1977); g e e.g., United States ex rel Massarella Elrod, 682 F.2d 688, 689

om the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN's bedroom at 358 El Brillo Way. (113) In or around the last half of 2004, Defendantr FREY EPSTEIN asked Jane Doe #14 to provide her telephone number. 22 EFTA00191745 (114) In or around the last half of 2004, Defendant JEFFREY EPSTEIN instruc

nd the New York residence so that JEFFREY EPSTEIN could, in exchange for money, engage in lewd conduct with those minor females in order to satisfy JEFFREY EPSTEIN's prurient interests. 6 EFTA00191729 Manner and Means 29. The manner and means by which the Defendants and other participants sought to accompli

t 358 El Brillo Way, Palm Beach, Florida, in the Southern District of Florida (hereinafter referred to as "358 El Brillo Way"). 5. DefendRJEFFREY EPSTEIN owned a property located at 9 East 71st Street, New York, New York (hereinafter referred to as "the New York residence"). 6. Defendant JEFFREY EPS

JEFFREY EPSTEIN asked Jane Doe #3 to recruit additional females to come to 358 El Brillo Way. (29) On or about November 8, 2004, one of Defendant JEFFREY EIN's employees prepared a written telephone message for Defendant JEFFREY EPSTEIN's review regarding a telephone call received from Jane Doe #3 t

(quoting Hop . Utah, 110 U.S. 574, 590, 4 S.Ct. 202, 21 , 28 L.Ed. 262 (1884) (brackets added to conform to origll quotation in Hopt )); see also Dobbert ■ Florida, 432 U.S. 282, 293, 97 S.Ct. 22 , 2298, 53 L.Ed.2d 344 (1977) ("Even though it may work to the uri disadvantage of a defendant, a proced