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

Defendants claim that who has described herself as Heidi Fleiss (the Hollywood madam),' has "nothing to do with the plaintiff's case against Mr. ' See New York Post Oct. 12007 (reporting "Some of the girls, legal documents indicate, were recruited by now 21, who described herself as `like Heidi Fleiss,' the no

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'

Doe is a citizen of Florida. (Am. Compl. ¶ 1.) 6 Jane Doe may, in fact, be a citizen of Georgia. not Florida, as she pled in her Amended Complaint. See New York Post, Jul. 1, 2008 (reporting that "On his way into court [for his state-court guilty plea on June 30], Epstein was served with a copy of a lawsuit by D

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

Doe is a citizen of Florida. (Am. Compl. ¶ 1.) 6 Jane Doc may, in fact, be a citizen of Georgia, not Florida, as she pled in her Amended Complaint. See New York Post, Jul. I, 2008 (reporting that "On his way into court [for his state-court guilty plea on June 30], Epstein was served with a copy of a lawsuit by D

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

Doe is a citizen of Florida. (Am, Compl. ¶ 1.) 6 'Jane Doe may, in fact, be a citizen of Georgia, not Florida, as she pled in her Amended Complaint. See New York Post, Jul. 1, 2008 (reporting that "On his way into court [for his state-court guilty plea on June 30], Epstein was served with a copy of a lawsuit by D

SD Do ;,A8/18/2008 Page 4 of 21 ktIVA4 . PLEA IN THE CIRCUIT COURT THE FOLLOWING IS TO REFLECT ALI. TERMS OF THE NEGOTIATED SI TTLFMEN I Name: Jeffrey E. Epstein Plea: Guilty A 6e4 /9—,—..... . _charge Cpynt Lessei _Dee' ep &b 06CF00945 Felony Solicitation of Prostitution 1 No 3 FUT rocuring Pers

told detectives, 'I'm like a Heidi Fleiss.'"). EFTA00234424 Case 9:08-cv-80804-KAM Document 11 Entered on FLSD Docket 08)18:2008 Page 2 of 11 Epstein," (Notice of Removal, DE 1, p. 3) and that Plaintiff fraudulently joined her in this action to prevent complete diversity.2 3. As demonstrated in Pl

ALI. TERMS OF THE NEGOTIATED SI TTLFMEN I Name: Jeffrey E. Epstein Plea: Guilty A 6e4 /9—,—..... . _char

ut, however, that there is a question of whether Defendant Epstein is actually a citizen of Florida because he is n

ALI. TERMS OF THE NEGOTIATED SI TTLFMEN I Name: Jeffrey E. Epstein Plea: Guilty A 6e4 /9—,—..... . _charg

fendants claim that , who has described herself as Heidi Fleiss (the Hollywood madam),' has "nothing to do with the plaintiff's case against Mr. I See New York Post, Oct. 1, 2007 (reporting "Some of the girls, legal documents indicate, were recruited by I now 21, who described herself as `like Heidi Fleiss,' th