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EY EPSTEIN, Defendant. CASE NO.: 09-80469-CIV-MARRA-JOHNSON CASE NO.: 09-80591-CIV-MARRA-JOHNSON CASE NO.: 09-80656-CIV-MARRA/JOHNSON DEFENDANT, JEFFREY EPSTEIN'S REPLY TO JANE DOE NO. 101 AND JANE DOE NO. 102'S RESPONSE IN OPPOSITION TO MOTION TO COMPEL AND IDENTIFY JANE DOE NUMBERS 101 AND 102 IN THIRD PART
CASE NO.: 08-CV-8038I-MARRA/JOHNSON EFTA00182748 Case 9:08-cv-80119-KAM Document 152 Entered on FLSD Docket 06/10/2009 Page 2 of 8 Doe 101 v. Epstein Page 2 JANE DOE NO. 6, Plaintiff, JEFFREY EPSTEIN, Defendant. CASE NO.: 08-80994-CIV-MARRA/JOHNSON CASE NO.: 08-80993-CIV-MARRA/JOHNSON JANE
OHNSON Plaintiff, JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S RESPONSE TO PLAINTIFFS JANE DOE NOS. 101 AND 10
v. Epstein Page 4 Defendant, Jeffrey Epstein, ("Mr. Epstein"), by and through his undersigned attorneys, her
ICT OF FLORIDA JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN Defendant. JANE DOE NO. 3, Plaintiff,
, was in bankruptcy, Lowy obeyed Hoffenberg's instructions to destroy the company's books and records. In 1992, when Towers was in litigation with Dunn & Bradstreet, Hughes followed Hoffenberg's and Rosoffs instruc- tions to perjure himself in deposition testimony and affidavits. •1274 Hughes testified that Ho
ction for the captioned KYC for accounts The 2007 Jeffrey E. Epstein Insurance Trust #3, The Haze Trust, NES
f business from the customer page of NES LLC which states "NES, Elk' was formed to take care of the expenses associated with running one of .Jeffrey Epstein's homes" and the purpose of the account that you had provided states "This is a simple checking account for pay for costs associated for Jeffrey Eps
ction for the captioned KYC for accounts The 2007 Jeffrey E. Epstein Insurance Trust #3, The Haze Trust, NES, LLC, Pl
ction for the captioned KYC for accounts The 2007 Jeffrey E. Epstein Insurance Trust #3, The Haze Trust, NES,
e access to NetX. 11. Plan D LLC: b. Nature of business: Please confirm. Equipment rental/leasing is listed as the industry for this entity on the Dunn & Bradstreet report (within the due diligence searches). If this is accurate, the KYC should reflect this information. — We need your assistance on the accuracy
ction for the captioned KYC for accounts The 2007 Jeffrey E. Epstein Insurance Trust #3, The Haze Trust, NES
ction for the captioned KYC for accounts The 2007 Jeffrey E. Epstein Insurance Trust #3, The Haze Trust, NES, LLC, Pl
he captioned KYC for accounts The 2007 Jeffrey E. Epstein Insurance Trust #3, The Haze Trust, NES, LLC, Pl
ction for the captioned KYC for accounts The 2007 Jeffrey E. Epstein Insurance Trust #3, The Haze Trust, NES,
ing Authorization 11. Plan D LLC: b. Nature of business: Please confirm. Equipment rental/leasing is listed as the industry for this entity on the Dunn & Bradstreet report (within the due diligence searches). If this is accurate, the KYC should reflect this information. — We need your assistance on the accuracy
associated with running one of Jeffrey Epstein's homes" and the purpose of the account that you had provided states "This is a simple checking account for pay for costs associated for Jeffrey Epste
associated with running one of Jeffrey Epstein's homes" and the purpose of the account that you
associated with running one of Jeffrey Epstein's homes" and the purpose of the account t
d information and documentation (including research). — Kindly provide this as we do not have access to NetX. Sec attached account resolutions: • Jeffrey Epstein & Damn Indykerfnistees -Trust Authorization and Trust Agreement • Harty Beller & Jean Anne Widaracht — POAs • Paul Barrett - Limited Trading Author
ing Authorization 11. Plan D LLC: b. Nature of business: Please confirm. Equipment rental/leasing is listed as the industry for this entity on the Dunn & Bradstreet report (within the due diligence searches). If this is accurate, the KYC should reflect this information. — We need your assistance on the accuracy
• Jeffrey Epstein & Darren Inclyke/Tnistees - Trust Audiori2,ation and Trust Agreement • Harry Beller A: Jean Anne Wiebraeht — POAs • Paul Barrett - Limited Trading
— We need your assistance on the accuracy on Customer page of Plan D LLC mentions "LLC created to hold funds to pay for costs associated with one of Jeffrey Epstein's planes" and search states "Equipment rental/leasing" in the SIC codes (research is attached for your quick reference) An airplane is equipment. Per
• Jeffrey Epstein & Darren Inclyke/Tnistees - Trust Audiori2,ation
• Jeffrey Epstein & Darren Inclyke/Tnistees - Trust Audiori
ing Authorization 11. Plan D LLC: b. Nature of business: Please confirm. Equipment rental/leasing is listed as the industry for this entity on the Dunn & Bradstreet report (within the due diligence searches). If this is accurate, the KYC should reflect this information. — We need your assistance on the accuracy
— We need your assistance on the accuracy on Customer page of Plan D LLC mentions "LLC created to hold funds to pay for costs associated with one of Jeffrey Epstein's planes" and search states "Equipment rental/leasing" in the SIC codes (research is attached for your quick reference) An airplane is equipment. Per
to pay for costs associated with one of Jeffrey Epstein's planes" and search states "Equipment rental/lea
ld funds to pay for costs associated with one of Jeffrey Epstein's planes" and search states "Equipment re
ing Authorization 11. Plan D LLC: b. Nature of business: Please confirm. Equipment rental/leasing is listed as the industry for this entity on the Dunn & Bradstreet report (within the due diligence searches). If this is accurate, the KYC should reflect this information. — We need your assistance on the accuracy
from the customer page of NES LLC which states "NES., LLC was formed to take care of the expenses associated with running one of Jeffrey Epstein's homes" and the purpose of the account that you had provided states "This is a simple checking account for pay for costs associated for Jeffrey Epst
expenses associated with running one of Jeffrey Epstein's homes" and the purpose of the account that you
e of the expenses associated with running one of Jeffrey Epstein's homes" and the purpose of the account
e access to NetX. 11. Plan D LLC: b. Nature of business: Please confirm. Equipment rental/leasing is listed as the industry for this entity on the Dunn & Bradstreet report (within the due diligence searches). If this is accurate, the KYC should reflect this information. — We need your assistance on the accuracy
case. a. 5. The nature of business narrative for NES LLC states the entity was formed to take care of the expenses associated with running one of Jeffrey's homes. However, the KYC states the purpose of its DDA account is to pay for costs associated with Jeffrey's airplanes. Please review and ensure th
nature of business from the customer page of NES LLC which states "NES, LLC was formed to take care of the expenses associated with running one of Jeffrey Epstein's homes" and the purpose of the account that you had provided states "This is a simple checking account for pay for costs associated for Jeffrey Epste
expenses associated with running one of Jeffrey Epstein's homes" and the purpose of the account that you
e access to NetX. 11. Plan D LLC: b. Nature of business: Please confirm. Equipment rental/leasing is listed as the industry for this entity on the Dunn & Bradstreet report (within the due diligence searches). If this is accurate, the KYC should reflect this information. — We need your assistance on the accuracy
states "This is a simple checking account for pay for costs associated for Jeffrey Epstein's airplanes". Please assist us as this seems to be inconsistent by the checker. Correction - NES, LLC was fanned to take cam of the expenses associat
account for pay for costs associated for Jeffrey Epstein's airplanes". Please assist us as this seems to
checking account for pay for costs associated for Jeffrey Epstein's airplanes". Please assist us as this s
ing Authorization 11. Plan D LLC: b. Nature of business: Please confirm. Equipment rental/leasing is listed as the industry for this entity on the Dunn & Bradstreet report (within the due diligence searches). If this is accurate, the KYC should reflect this information. — We need your assistance on the accuracy
Entities connected to both Jeffrey Epstein and Dunn & Bradstreet
Darren Indyke
PERSONLarry Visoski
PERSON
Prince Andrew
PERSON
Lawrence Krauss
PERSON
Al Gore
PERSONNES LLC
ORGANIZATION
Mumbai
LOCATIONNirlon Knowledge Park
LOCATIONGoregaon East
LOCATIONAlka Babu
PERSONJeffrey E. Epstein Insurance Trust
PERSONThe Haze Trust
ORGANIZATIONPaul Barrett - Limited Trading Authorization
PERSONAndrew Gallivan's
PERSONCorrection - NES
ORGANIZATIONThe Operating Agreement
ORGANIZATION