Epstein Secrets

August 4, 2009 VIA ELECTRONIC MAIL Spencer T. Kuvin, Esq. Leopold—Kuvin, P.A. 2925 PGA Boulevard Suite 200 Palm Beach Gardens, FL 33410 Re: Jeffrey Epstein/B.B. — Requested Disclosure of Non-Prosecution Agreement Dear Mr. Kuvin: Thank you for your letter regarding the disclosure of the Non-Prosecution Agree

ter giving notice of breach. I respectfully submit that the Motion to Dismiss that is referenced therein did not constitute a willful breach of Mr. Epstein's obligations under the non-prosecution agreement. Mr. Epstein's counsel unanimously determined that the filing of this Motion to Dismiss was not a

's Office Southern District of Florida 500 South Australian Avenue, Suite 400 West Palm Beach, Florida 33401 voswidrkland.com June 15, 2009 Re: Jay Epstein Dear a I am attaching a letter authored by my co-counsel, Robert Critton, on today's date. It represents our agreement with a proposal that Kathy Ez

Atkinson, Esq. EFTA00183762 J. WHAM. BURMAN, PA., GREGORY W.CCU:NAN. PA. ROBERT D. CRITTON. IR., PA., BERNARD LEBEDBKER MARK T. I II/STIER, PA. JEFFREY PEPIN MIOIAEL PIKE HEATHER McNAMARA RUDA I R.ORIDA WARD anima CIVIL TRIAL LAWYER BURMAN, CRITTON, LUTTIER & COLEMAN LLP A LIMITED LIABILITY PARTNER

8 1. JEFFREY EPSTEIN, Plaintiff, Defendant. DEFENDANT EPSTEIN'S MOTION TO DISMISS PLAINTIFF'S COMPLAINT Defend

, Suite 400 West Palm Beach, Florida 33401 Re: Jeffrey Epstein Dear Ms. www.kirklend.com June 12, 200

d therein did not constitute a willful breach of Mr. Epstein's obligations under the non-prosecution agreement

statute of limitations. As to Count I, which is plead pursuant to state law, it is well settled that this Court is to apply Florida law. Erie R.Co. I. Tompkins, 58 S.Ct. 817 (1938). Pursuant to Florida law, the statute of limitations for assault and battery is four years, §95.11(3)(o)., Fla. Stat. §95.11(3

August 4, 2009 VIA ELECTRONIC MAIL Spencer T. Kuvin, Esq. Leopold—Kuvin, P.A. 2925 PGA Boulevard Suite 200 Palm Beach Gardens, FL 33410 Re: Jeffrey Epstein/B.B. — Requested Disclosure of Non-Prosecution Agreement Dear Mr. Kuvin: Thank you for your letter regarding the disclosure of the Non-Prosecution Agree

ter giving notice of breach. I respectfully submit that the Motion to Dismiss that is referenced therein did not constitute a willful breach of Mr. Epstein's obligations under the non-prosecution agreement. Mr. Epstein's counsel unanimously determined that the filing of this Motion to Dismiss was not a

tatement [DE 29] dated May 26, 2009. Counsel for Defendant EPSTEIN Certificate of Service I HEREBY CERTIFY that a

, Suite 400 West Palm Beach, Florida 33401 Re: Jeffrey Epstein Dear Ms. Villafana, M www.kirkland.com

d therein did not constitute a willful breach of Mr. Epstein's obligations under the non-prosecution agreement

tion against Jeffrey Epstein styled B.B.I. Jeffi-ey Epstein, case no.: 502008CA037319 MB AB. We are hereby r

statute of limitations. As to Count I, which is plead pursuant to state law, it is well settled that this Court is to apply Florida law. Erie R.Co. I. Tompkins, 58 S.Ct. 817 (1938). Pursuant to Florida law, the statute of limitations for assault and battery is four years, §95.11(3)(o)., Fla. Stat. §95.11(3

21 LRJ, MEDREQ, REF_DISCOV U.S. District Court Southern District of Florida (West Palm Beach) CIVIL DOCKET FOR CASE #: 9:08-cv-80119-1CAM Doe v. Epstein Assigned to: Judge Kenneth A. Marra Referred to: Magistrate Judge Linnea R. Johnson Member case: (View Member Case) Case: 9:09-cv-80802-KAM Caus

ON Plaintiffs Jane Doe No. 101 and Jane Doe 102's Motion for No- Contact Order Plaintiffs Jane Doe No. 101 and Jane Doe No. 102's Reply to Defendant Jeffrey Epstein's Response to Plaintiffi Jane Doe No. 101 and Jane Doe No. 102's Motion for a No-Contact Order filed by Jane Doe No. 101, Jane Doe No. 102. Associate

red: 02/08/2008) 05/22/2008 4 AFFIDAVIT of Service for Summons and Complaint served on Jeffrey Epstein on May 7, 2008, filed by Jane Doe. (Herman, Jeffrey) (Entered: 05/22/2008) 05/22/2008 5 SUMMONS Returned Executed by Jane Doe. Jeffrey Epstein served on 5/7/2008, Answer due 5/27/2008. (Ik) (Entere

FTA00175604 CM/ECF - Live Database - flsd Page 17 of 21 05/20/2009 Ma NOTICE be. of Filing Withdrawal of Previously Raise Lions to Defendant. Jetey Epstein's Motion to Ag And/Or IdentifyMf. in the Style of This Case and Motion to Identi . in Third-Party Subpoenas for Purposes of Discovery, Or, Alternati

. 2 I JEFFREY EPSTEIN, Plaintiff, Defendant. DEFENDANT EPSTEIN'S ANSWER & AFFIRMATIVE DEFENSES TO PLAINTIFF'S S

legations in her complaint, the plaintiff went to Mr. Epstein's house to give him "a massage for monetary comp

o state a claim upon which relief can be granted. It is well settled that this Court is to apply Florida substantive law in this action. Erie R.Co. I. Tompkins, 58 S.Ct. 817 (1938). Pursuant to Florida law, although the term "assault and battery" is most commonly referred to as if it were a legal unit, or a

se - flsd Page 1 of 17 U.S. District Court Southern District of Florida (West Palm Beach) CIVIL DOCKET FOR CASE #: 9:08-cv-80380-KAM Doe No. 4'. Epstein Assigned to: Judge Kenneth A. Marra Referred to: Magistrate Judge Linnea R. Johnson Lead case: 9:08-ev-80111-.KAM Member case• (View Member Case)

ON Plaintiffs Jane Doe No. 101 and Jane Doe 102's Motion for No- Contact Order Plaintiffs Jane Doe No. 101 and Jane Doe No. 102's Reply to Defendant Jeffrey Epstein's Response to Plaintiffs Jane Doe No. 101 and Jane Doe No. 102's Motion for a No-Contact Order filed by Jane Doe No. 101, Jane Doe No. 102. Associate

4/21/2008) 05/22/2008 6 AFFIDAVIT of Service for Summons and Complaint served on Jeffrey Epstein on May 7, 2008, filed by Jane Doe No. 4. (Herman, Jeffrey) (Entered: 05/22/2008) 05/29/2008 7. Plaintiffs MOTION for Entry of Default by Clerk Against Defendant by Jane Doe No. 4. (Attachments: # 1 Exhib

. 4 1. Plaintiff, JEFFREY EPSTEIN Defendant. DEFENDANT EPSTEIN'S MOTION TO DISMISS AND MOTION FOR MORE DEFINITE

o state a claim upon which relief can be granted. It is well settled that this Court is to apply Florida substantive law in this action. Erie R.Co. I. Tompkins, 58 S.Ct. 817 (1938). Pursuant to Florida law, although the term "assault and battery" is most commonly referred to as if it were a legal unit, or a

- flsd ( Page 1 of 14 U.S. District Court Southern District of Florida (West Palm Beach) CIVIL DOCKET FOR CASE #: 9:08-cv-80381-KAM Doe No. 5'. Epstein Assigned to: Judge Kenneth A. Marra Lead case: 9:08-cv-80119-KAM Member case: (View Member Case] Case: 9:09-cv-80802-KAM Cause: 28:1332 Diversit

eth A. Marra on 5/20/2009. (1c3) (Entered: 05/20/2009) 05/20/2009 9B NOTICE by of Filing Withdrawal of Previously RaisedObjections to Defendant, Jeffrey Epstein's Motion to ConaitAnd/Or Identify . in the Style of This Case and Motion to IdentlfrM. in Third-Party Subpoenas for Purposes of Discovery, Or, Alter

4/17/2008) 05/22/2008 4 AFFIDAVIT of Service for Summons and Complaint served on Jeffrey Epstein on May 7, 2008, filed by Jane Doe No. 5. (Herman, Jeffrey) (Entered: 05/22/2008) 05/29/2008 5 Plaintiffs MOTION for Entry of Default by Clerk Against Defendant by Jane Doe No. 5. (Attachments: # I Exhibi

5 1. JEFFREY EPSTEIN, Plaintiff, Defendant. DEFENDANT EPSTEIN'S ANSWER & AFFIRMATIVE DEFENSES TO PLAINTIFF'S S

o state a claim upon which relief can be granted. It is well settled that this Court is to apply Florida substantive law in this action. Erie R.Co. I. Tompkins, 58 S.Ct. 817 (1938). Pursuant to Florida law, although the term "assault and battery" is most commonly referred to as if it were a legal unit, or a

cument 20 Entered on FLSD Docket 05/22/2009 Page 1 of 20 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 MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANT EPSTEIN'S M

REY EPSTEIN, and Defendants. ) CASE NO.: 09-80469-CIV-MARRA ) ) ) ) ) ) ) ) ) PLAINTIFF'S 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

PLAINTIFF'S 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

e not present a federal court should hesitate to exercise jurisdiction over state claims, even though bound to apply state law to them, Erie R. Co. I. Tompkins, 304 U.S. 64.Needless decisions of state law [by a federal court] should be avoided both as a matter of comity and to promote justice between the p