Epstein Secrets

econd amended complaint (the "Fisher counterclaim"), is granted in all respects. The Soffer ejectment motion is granted as against deft Ron Soffer. Defls Jeffrey E. Epstein, Ivan S. Fisher, Ellyn Bank, Debra Elisa Cohen, Dianeataga?/a The Fisher Group, Fisher & Soffer a/k/a Fisher & Sophir, D. Gerzog, Robert Heilbum,

the house to the tenant we have selected should Mr. Epstein decide not to reoccupy the premises under the ne

on of the budding pursuant to the Foreign Missions Act, 22 U.S.C. § 4301 of seq. 0FM leased the building to defen- dant Jeffrey E. Epstein in 1992. Epstein sublet the building to defendant Ivan S. Fish- er in 1996, purportedly without the Govern- ment's consent. Fisher, in turn, sublet a portion of the

n personally liable because Epstein did not sign the con- tract as an agent or as a corporate officer. Epstein signed the contract as follows: /s/ Jeffery Epstein 1AG. Under New York law, a signature in a representative capacity would have been "Jeffrey Epstein for I.A.G." or "I.A.G., by Jeffrey Epstein". 2

atters extrinsic to the complaint. we will treat defendant Epstein's motion to dismiss as a motion for summary judg

RDERED. UNITED STATES of America, Plaintiff, I Jeffrey E. EPSTEIN, Ivan S. Fisher, Ellyn Bank, Debra Elis

RDERED. UNITED STATES of America, Plaintiff, I Jeffrey E. EPSTEIN, Ivan S. Fisher, Ellyn Bank, Debra Elise

ie showing that minimum contacts warranting personal jurisdiction exist.FN3 Mellon Bank (East) PSFS Nat. Ass'n I. Farina, 960 F.2d 1217, 1223 (3d Cir.1992). FN3. The Court notes that although a Plaintiff need only make a prima facie showing of jurisdiction to defeat a motion under Fed.R.Civ.P. 12(bX

2'2009 Page 1 of 26 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE, CASE NO.: 08-CIV- 80893 - MARRA/JOHNSON Plaintiff, v. JEFFREY EPSTEIN, Defendants. Defendant's, Epstein. Motion To Dismiss, For More Definite Statement & To Strike Directed To Plaintiff Jane Doe's Amended Complaint,

Plaintiff. . .was called on the telephone by. . .Epstein and other employees. . ., and transported to. . .

Florida Civil Rico action is, at this time, only defendant Epstein. . . ." However, the RICO enterprise must be dis

.: 08-CIV- 80893 - MARRA/JOHNSON Plaintiff, v. JEFFREY EPSTEIN, Defendants. Defendant's, Epstein. Moti

134 (6th Cir.1994) (finding seventeen month period insufficient to show continuity); Religious Tech. Ctr. v. Wollersheim, 971 F.2d 364, 366-67 (9th Cir.1992)( "We have found no case in which a court [of appeals] has held the [continuity] requirement to be satisfied by a pattern of activity lasting less t

F FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 and JANE DOE 2, Plaintiffs, EXHIBIT A UNITED STATES OF AMERICA, Defendant. INTERVENOR JEFFREY EPSTEIN'S MOTION FOR A PROTECTIVE ORDER AND OPPOSITION TO MOTIONS OF JANE DOE I AND JANE DOE 2 FOR PRODUCTION, USE, AND DISCLOSURE OF PLEA NEGOTIATIONS Purs

DATORY AND DISCRETIONARY INTERVENTION An PROPER Intervention is proper as a matter of right under Federal Rule of Civil Procedure 24(a) because Mr. Epstein has an interest in protecting his privileged and confidential plea negotiations, and "disposing of the action may as a practical matter impair or im

rees without extending its jurisdic- tion. Keith Jeffrey Lambdin, Katzman Gar- finkel Rosenbaum, John Davi

er Federal Rule of Civil Procedure 24(a) because Mr. Epstein has an interest in protecting his privileged and

oduct even more scrupu- lously protected" than fact work' product); National Union Fire Ins. Co. R. Murray Sheet Metal Co., 967 F.2d 980, 984 (4th Cir.1992) (opinion work product "absolutely immune" from discovery); In re Martin Marietta Corp., 856 F.2d 619, 625 (4th Cir.1988); In re John Doe, 662

dar Online submitted a FOIA requests to the FBI collectively seeking "all documents relating to the FBI's investigation and prosecution of financier Jeffrey Epstein, who plead guilty to one count of felony solicitation of prostitution in August 2006. Dkt. No. 12-2, Ex. B; see Declaration of Michael G. Seidel, da

(b)(7)(A). Many of the records sought by the Radar Online fall at the heart of this exemption, and the FBI has withheld them individually, prior to Esptein's arrest, and categorically, after Esptein's arrest. Other FOIA exemptions also justify the FBI's withholding of records in response to the FOIA re

ecords at the core of the criminal prosecution of Jeffrey Epstein, prior to his passing, and the current p

ality can only be waived by the source. Adamowicz v. IRS, 402 Fed. App'x 648, 653 (2d Cir. 2010); see also Ferguson v. FBI, 957 F.2d 1059, 1068 (2d Cir.1992) ("[W]e reject the idea that subsequent disclosures of the identity of a confidential source ... requires full disclosure of information provided by

S. 427, 87 S.Ct. 1 , 18 L. Ed.2d 865 (1967); Buchanan Rhodes. 885 U.S. 3, 87 S.Ct. 83, 17 .Ed.2d 9 (1966); Idlewild Bon Voyage Liquor Corp. v. Epstein, 370 U.S. 713, 82 S.Ct. 1294, 8 L.Ed2d 794 (1962). Since in this case we affirm that refusal, we need not now decide whether or not there is juri

, Gary A. Hughes, J.D, Steven D. Najarian, J.D., Jeffrey A. Schafer, J.D., and Jeffrey J. Shampo, J.D. II

d 20, the district court held a probable cause hear- ing pursuant to United States tz All Assets of Statewide Auto Pads, Inc. 971 F2d 896, 906 (2d Cir.1992) and United States v. Monsanto, 924 F2d 1186, 1203 (2d Cir.1991). On May 30, 1995, the district court vacated the seizure warrant, finding that th

ness through Citibank and other units throughout the world. Indeed. during oral argument on these motions, the defendants presented a letter sent to Epstein concerning the loans, identifying the two as linked together as "Citigroup, private bank" and "The Citigroup Private Bank, Citibank, NA." At least a

he defendant and the forum territory to support in personam jurisdiction, see Mellon Bank (East) PSFS Nat'l Assin v. Farino, 960 F.2d 1217, 1223 (3d Cir.1992), and the court must accept all of the plaintiffs allegations as true and construe disputed facts in favor of the plaintiff, see Carteret Say. Bank

4. A CNN.com - Sandy Berger to plead guilty on documents charge - Apr I, 2005 (http://edition.am.com/2005/LAW/04/01/berger.plea0 15. na b Smith, is Jeffrey, Berger Case Still Roils Archives, Justice Dept., Washington Post, February 21, 2007 (http://www.washingtonpost.cotn/svp-dyn/content/article/2007/02

ase r remanded on other grounds. See United States Palmer, Palmer, F.3d 760, 767 (8th Cir.2002); sited States Montana, 979 F.2d 136, 138 (8th Cir.1992); United States I Fiallo-Jacome, 874 F.2d 1479, 1481-83 (11th Cir.1989). We conclude that Mr. Carter has forfeited his *646 current ex post facto