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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
entical injuries Jane Doe asserted in the First Federal Action, and are no less serious simply because pled under a state-court caption. Cf., e.g., Woods v. Southwest Airlines, Co., 523 F. Supp. 2d 812, 820 (N.D. III. 2007) (determining, in the context of diversity jurisdiction, that the $75,000 threshold had been satisfied, a
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
entical injuries Jane Doe asserted in the First Federal Action, and are no less serious simply because pled under a state-court caption. Cf., e.g., Woods v. Southwest Airlines, Co., 523 F. Supp. 2d 812, 820 (N.D. III. 2007) (determining, in the context of diversity jurisdiction, that the $75,000 threshold had been satisfied, a
have known that Plaintiff had no credentials to provide massage therapy. b. She observed the Plaintiff being brought to the Palm Beach mansion of JEFFREYEPSTEIN, when the Plaintiff was a minor, andsometimes escorted the Plaintiff to a room in that mansion where JEFFREY EPSTEIN was waiting, for the ostensibl
atabase - flsd Page 1 of 5 LSS U.S. District Court Southern District of Florida (West Palm Beach) CIVIL DOCKET FOR CASE #: 9:08-cv-80811-KAM v. Epstein et al Assigned to: Judge Kenneth A. Marra Cause: 28:1332 Diversity Plaintiff V. Defendant Jeffrey Epstein Date Filed: 07/21/2008 Jury Demand:
e Plaintiff, when the Plaintiff was a minor, which depicted fhe Plaintiff in the nude. She told the Plaintiff that the pictures were at the request ofJEFFREY EPSTEIN, and paid the Plainlifffor posing for the photographs. 12. As a icsult, the Plaintiff sufferedmental anguish, mental pain and suffeaing, psychic
on which alleges sexual abuse of a female minor by the defendant JEFFREY EPSTEIN. 4. It has come to the attention of the undersigned that Defendant JEFFREY EPSTEIN filed a Motion with the Florida State Court to return the evidence seized at his home in conjunction with his criminal prosecution. With re
instant claim, but for other suits filed against Defendant EPSTEIN, including but not limited to the Florida RICO c
e 4 of 40 (b) While the Complaint suggests that Mr. Epstein might be a citizen of New York or Florida, he is
pain and suffering, psychic trauma, and a loss of the capacity for the enjoyment of life." (Compl. ¶ 9.) These are serious allegations. Cf., e.g., Woods v. Southwest Airlines, Co., 523 F. Supp, 2d 812, 820 (N.D. III. 2007) (determining, in the context of diversity jurisdiction, that the $75,000 threshold had been satisfied, a
Palm Beach County, Florida. Plaintiff is a female who is presently twenty-one years old. 3. The Plaintiff is unsure of the residency of defendant JEFFREY ES PSTEIN, because he has residences in New York, Florida, New Mexico, and also outside of the continental United States. a 4. The defendant, was n reside
strict Court for the Southern District of Florida. See 28 U.S.C. § 1332(a)(1) (establishing that federal district courts have original I C.M.A. v. Epstein et aL, Case No. 50 2008 CA 005240 XXXX MB (Fla. 15th Cir. Ct. filed Feb. 21, 2008). Lewis.tein n. 3059 Gray MINUE, Sum 340, COCONUT GROVE, FLORIDA
28 U.S.C. § 1446(6), this Notice is timely. Only defendant Epstein has been served with process. Defendant has not
.M.A., 08-80811-Civ-ZLOCH/SNOW Plaintiff, vs. JEFFREY EPSTEIN and Defendants. NOTICE OF REMOVAL July
e 4 of 40 (b) While the Complaint suggests that Mr. Epstein might be a citizen of New York or Florida, he is
and suffering, psychic trauma, and a loss of the capacity for the enjoyment of life. WHEREFORE, THE PLAINTIFF DEMANDS JUDGMENT FOR DAMAGES AGAINST JEFFREY EPSTEI N, IN AN AMOUNT IN EXCESS OF FIFTEEN THOUSAND DOLLARS, EXCLUSIVE OF COSTS AND INTEREST, AND FUR'FII ER DEMANDS TRIAL BY JURY. COV.NT n 10. Plaintif
pain and suffering, psychic trauma, and a loss of the capacity for the enjoyment of life." (Compl. ¶ 9.) These are serious allegations. Cf., e.g., Woods v. Southwest Airlines, Co., 523 F. Supp, 2d 812, 820 (N.D. III. 2007) (determining, in the context of diversity jurisdiction, that the $75,000 threshold had been satisfied, a
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'
entical injuries Jane Doe asserted in the First Federal Action, and are no less serious simply because pled under a state-court caption. Cf., e.g., Woods v. Southwest Airlines, Co., 523 F. Supp. 2d 812, 820 (N.D. III. 2007) (determining, in the context of diversity jurisdiction, that the $75,000 threshold had been satisfied, a
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
entical injuries Jane Doe asserted in the First Federal Action, and are no less serious simply because pled under a state-court caption. Cf., e.g., Woods v. Southwest Airlines, Co., 523 F. Supp. 2d 812, 820 (N.D. III. 2007) (determining, in the context of diversity jurisdiction, that the $75,000 threshold had been satisfied, a
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