Epstein Secrets

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

an action for damages in excess of Fifteen Thousand Dollars ($15,000.00), exclusive of costs and interest. pi 2. At all times material hereto, the Plainti was and is a resident of Palm Beach County, Florida. Plaintiff is a fem ew on presently twenty-one years old. 3. The Plaintiff is misure of the r

• IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Plaintiff, v. cor.50.2929aufactigIVP111, CASE NO. • A Aq SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and .M., individu

OTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and .M., individually, Defendants. COMPL CO Plaintiff, JEFFREY EPSTEIN, (hereinafter "EPSTEIN"), by and through his undersigned attorneys, files this action against Defendants, SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually,

ases and thus by using the deposition sell the cases (or a part of them) to third parties. #4S 37. Because of these facts, ROTHSTEIN claimed that Epste wanted to make certain none of these individuals would be deposed and therefoie he had offered $200,000,000.00 to settle the claims of RRA female

EPSTEIN and like other RRA clients, sought tens of millions of dollars. a. For example, in her sworn statement to the FBI, L.M. was insistent that "Jeffrey is an awesome man." (p. 21 — FBI); At the conclusion of she stated: "I hope Jeffrey, nothing happens to Jeffrey because he's an awesome man and it

hat the evidence is really going to show is that Mr. Epstein — at least dating back as completely irrelevant

vindicate the hardworking and honest lawyers and their K‘ e clients who adversely affected by the misconduct that is the subject of this Complain Plainti reserves the right to add additional defendants — co-conspirators as the facts and evidence is developed. GENERAL ALLEGATONS 1. This is an action

limit, yet her proposed depositions are not calculated to lead to admissible evidence in this case. By way of example, Plaintiff identifies ), and Jeffrey Epstein as alleged "co-conspirators" with each other. She requests the depositions of each. Plaintiff anticipates each will invoke the Fifth Amendment — in

harassing questions Plaintiff posed to her concerning her adult, consensual sexual activities. In other words, depositions of Marcincova, Kellen and Epstein would serve Plaintiff's goal to make a convoluted legal argument, not to actually seek discoverable information. In light of this, the "burden or e

UMPTIVE TEN DEPOSITION LIMIT Laura A. Menninger Jeffrey S. Pagliuca HADDON, MORGAN, AND FOREMAN, P.C. E

and (identified as assistants to Ms. Maxwell or Mr. Epstein). The information Plaintiff claims each of the wi

ry Epstein or the alleged "modus operandi of the Epstein organization." This is a simple case of if Ms. Maxwell's denial of the allegations made by Plainti about Plaintiff's own interactions with Maxwell was defamatory, and if Ms. Maxwell acted with actual malice in issuing the denial. Plaintiff's attem

80656-CIV-MARRA/JOHNSON Plaintiff; JEFFREY EPSTEIN, Defendant. EPSTEIN'S RESPONSE TO JANE DOE'S MOTION TO PROVIDE RECENTLY-OBTAINED AFFIDAVIT OF JEFFREY E. EPSTEIN IN SUPPORT OF MATERIAL FACTS SUPPORTING MOTION FOR APPOINTMENT OF A RECEIVER TO TAKE CHARGE OF PROPERTY OF EPSTEIN Defendant, JEFFREY E. EPSTEIN (

N CASE NO.: 08-CV-80380-MARRA/JOHNSON CASE NO.: 08-CV-80381-M.ARRA/JOHNSON EFTA00599334 Jane Doe v. Epstein Case No. 08-CV-80119-MARRA/JOHNSON Epstein's Response to Jane Doe's Motion to Provide Recently Obtained Affidavit of Epstein Page 2 of 9 CASE NO.: 08-80994-C1V-MARRA/JOHNSON JANE DOE NO. 6,

MOTION TO PROVIDE RECENTLY-OBTAINED AFFIDAVIT OF JEFFREY E. EPSTEIN IN SUPPORT OF MATERIAL FACTS SUPPORTING

MOTION TO PROVIDE RECENTLY-OBTAINED AFFIDAVIT OF JEFFREY E. EPSTEIN IN SUPPORT OF MATERIAL FACTS SUPPORTING

.11, Esq. Pro Hac Vice 332 South 1400 E, Room 101 Salt Lake City, UT 84112 801-585-5202 801-585-6833 Fax [email protected],edu Co-counsel for Plainti ff Jane Doe Isidro M. Garcia, Esq. Garcia Law Finn, P.A. 224 Datura Street, Suite 900 West Palm Beach, FL 33401 561-832-7732 561-832-7137 F is

80656-CIV-MARRA/JOHNSON Plaintiff; JEFFREY EPSTEIN, Defendant. EPSTEIN'S RESPONSE TO JANE DOE'S MOTION TO PROVIDE RECENTLY-OBTAINED AFFIDAVIT OF JEFFREY E. EPSTEIN IN SUPPORT OF MATERIAL FACTS SUPPORTING MOTION FOR APPOINTMENT OF A RECEIVER TO TAKE CHARGE OF PROPERTY OF EPSTEIN Defendant, JEFFREY E. EPSTEIN (

N CASE NO.: 08-CV-80380-MARRA/JOHNSON CASE NO.: 08-CV-80381-M.ARRA/JOHNSON EFTA00599343 Jane Doe v. Epstein Case No. 08-CV-80119-MARRA/JOHNSON Epstein's Response to Jane Doe's Motion to Provide Recently Obtained Affidavit of Epstein Page 2 of 9 CASE NO.: 08-80994-C1V-MARRA/JOHNSON JANE DOE NO. 6,

MOTION TO PROVIDE RECENTLY-OBTAINED AFFIDAVIT OF JEFFREY E. EPSTEIN IN SUPPORT OF MATERIAL FACTS SUPPORTING

MOTION TO PROVIDE RECENTLY-OBTAINED AFFIDAVIT OF JEFFREY E. EPSTEIN IN SUPPORT OF MATERIAL FACTS SUPPORTING

.11, Esq. Pro Hac Vice 332 South 1400 E, Room 101 Salt Lake City, UT 84112 801-585-5202 801-585-6833 Fax [email protected],edu Co-counsel for Plainti ff Jane Doe Isidro M. Garcia, Esq. Garcia Law Finn, P.A. 224 Datura Street, Suite 900 West Palm Beach, FL 33401 561-832-7732 561-832-7137 F is