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mmediate family that I send drafts to is Jeffrey" The Talented Mr. Epstein, By Vicky Ward on January, 2005 in Published Wor
ed to you in the public media express a willingness, indeed a strong desire, to submit to questioning under oath regarding your alleged knowledge of Jeffrey Epstein's extensive abuse of underage females as well as your alleged personal participation in those activities. As I am sure you will recall, our efforts to
you have already selected other counsel to represent you, or if you do so in the future, and you decide to file a claim against Jeffrey Epstein, Mr. Epstein's attorney, Jack Goldberger as s th t u h at Atterbury Gonberger and Weiss, , (561) 659-8300. In addition, there has been litigation between th
here is overwhelming proof that the number of underage girls molested by Epstein through his scheme was in the hundreds. See Complaint, Jane Doe 102 J Epstein, (hereinafter Jane Doe 102 complaint) (Exhibit "B"); see also Deposition of Jeffrey Epstein, April 14, 2010, at 442, 443, and 444 (Epstein invoking
nt. began speaking with the agents then excused herself to go upstairs to check on her sleeping child. While upstairs, NE telephoned the defendant, Jeffrey Epii informed him that the FBI agents were at her home. Mr. Epstein instructed not to speak with the agents and IN lmanded her for allowing them into h
lot of fun to be with. It is even said that he likes beautiful women as much as I do, and many of them are on the younger side. No doubt about it — Jeffrey enjoys his social life." Jeffrey Epstein: International Moneyman of Mystery; He's pals with a passel of Nobel Prize—winning scientists, CEOs like L
ies."). Sexual Abuse of Children By Epstein 1. Defendant Epstein has a sexual preference for young children. Depos
young you are. You have a tight butt like a baby". See Jeff Epstein Sued for "Repeated Sexual Assaults" on Teen, New York Post, October 17, 2007, by Dareh Gregorian, link at: http://www.mmost.com/pinews/reirionaliitem 44zlWvLUFH7R1OUtICYGPbP;isessionid=6CA3EBF1 BEF68F5DEI4BFB2CAA5C37E0. See Article attached he
tein's victims. As a consequence, the victims were not told about the NPA. 46. On July 7, 2008, a young woman identified as Jane Doe No. 1, one of Jeffrey Epstein's victims (other than Plaintiff), filed a petition to enforce her rights under the Crime Victims' Rights Act ("CVRA"), 18 U.S.C. § 3771, alleging that
ng 2000-2002, beginning when Plaintiff was 16, Plaintiff was the victim of sex trafficking and abuse by convicted sex offender Jeffrey Epstein. 3. Epstein's trafficking scheme involved recruiting young girls, often by claiming they would be paid $200 for simply providing a massage to a wealthy billiona
r. Epstein" for many years. In 2003, Defendant said "I'm on my 20th book... The only person outside of my immediate family that I send drafts to is Jeffrey." Vicky Ward, The Talented Mr. Epstein, VANITY FAIR (Jun. 27, 2003), https://bit.ly/2S9MzQU. Defendant also described Epstein as his friend. "I woul
ntiff 34. Defendant has been "a close friend of Mr. Epstein" for many years. In 2003, Defendant said "I'm on
y that I send drafts to is Jeffrey." Vicky Ward, The Talented Mr. Epstein, VANITY FAIR (Jun. 27, 2003), https://bit.ly/2S9
as." Ray Gustini, Vanity Fair Reminds Us When Jef•ey Epstein Wasn't a Creep, THE ATLANTIC (June 21, 2011), ht
0. Defendant also lied by saying that he "never" got a massage from anybody: "I never got a massage from anybody. It's made up out of whole cloth." Dareh Gregorian, Alleged 'sex slave' says she didn't have sex with former President Bill Clinton, but in explosive court filing, details I I-person orgy with Prin
egan speaking with the agents and then excused herself to go upstairs to check on her sleeping child. While upstairs, Ms. telephoned the defendant, Jeffrey Epsteiriand informed him that the FBI agents were at her home. Mr. Epstein instructed Ms= not to speak with the agents and reprimanded her for allowing them i
ing specific facts as the undisputed material facts in this case. Each of the following facts is numbered separately and individually to facilitate Epstein's required compliance with Fla. R. Civ. P. 1.510(c) ("The adverse party shall identify . . . any summary judgment evidence on which the adverse part
. P. 1.510(c) ("The adverse party shall identify . . . any summary judgment evidence on which the adverse party relies."). Sexual Abuse of Children Dv Epstein 1. Defendant Epstein has a sexual preference for young children. Deposition of Jeffrey Epstein, Mar. 17, 2010, at 110 (hereinafter "Epstein Depo."
lot of fun to be with. It is even said that he likes beautiful women as much as I do, and many of them are on the younger side. No doubt about it -- Jeffrey enjoys his social life." Jeffrey Epstein: International Moneyman of Mystery; He's pals with a passel of Nobel Prize—winning scientists, CEOs like
ies."). Sexual Abuse of Children Dv Epstein 1. Defendant Epstein has a sexual preference for young children. Depos
unediate family that I send drafts to is Jeffrey" The Talented Mr. Epstein, By Vicky Ward on January, 2005 in Published Wor
young you are. You have a tight butt like a baby". See Jeff Epstein Sued for "Repeated Sexual Assaults" on Teen, New York Post, October 17, 2007, by Dareh Gregorian, link at: http://www.nypost.com/n/news/regionallitem 44z1WvLUFH7RIOUtKYGPbP:isessionid=6CA3EBF1 BEF68F5DE14BFB2CAA5C37E0. See Article attached her
of 40 EXHIBIT 16 EFTA00081180 Case 9:08-cv-807m091349pept Z91-15 _EriterM ocp WERocisstifolf/E15 Page 2 of roio-< uoc 16q0,3 e 0 EXHIBIT C Epstein vs. Edwards Undisputed Statement of Facts EFTA00081181 Case 9:08-cv-807ailaVs kigsyffigt 28415-c1p6Arger phri N 7NRocieatgfe)10/§815 Page 3 of I
02 was initially approached at Trump's Maralago by Ghislaine Maxwell and recruited to be Maxwell and Epstein's underage sex slave; (e) Mark Epstein (Jeffrrey Epstein's brother) testified that Trump flew on Jeffrey Epstein's plane with him (the same plane that Jane Doe 102 alleged was used to have sex with underage
lot of fun to be with. It is even said that he likes beautiful women as much as I do, and many of them are on the younger side. No doubt about it — Jeffrey enjoys his social life." Jeffrey Epstein: International Moneyman of Mystery; He's pals with a passel of Nobel Prize—winning scientists, CEOs like L
ies."). Sexual Abuse of Children By Epstein 1. Defendant Epstein has a sexual preference for young children. Depos
mmediate family that I send drafts to is Jeffrey" The Talented Mr. Epstein, By Vicky Ward on January, 2005 in Published Wor
young you are. You have a tight butt like a baby". See Jeff Epstein Sued for "Repeated Sexual Assaults" on Teen, New York Post, October 17, 2007, by Dareh Gregorian, link at: http://www.nvoost.com/p/newskegionaUitem 44z1WyLUFH7R1 OUtKYGPbP sessionid=6CA3EBF1 BEF68F5DE14BFB2CAA5C37E0. See Article attached heret
A00599889 Jeffrey Epstein's Level 3 sex offender status upheld by NY appeals court By Dareh Gregorian November 18, 2011 5:00am Multimillionaire pery Jeffrey Epstein may not consider his Florida conviction for soliciting a minor a big deal, but New York does. A state appeals court yesterday upheld the financier'
office in Dade County. The causes of action and damages against Defendant Jeffrey Epstein accrued in Dade County, Florida, due to specific acts by Epstein there, and accordingly, venue is appropriate there. Florida Statute 47.011. 2. Florida Statute 48.193(1)(a)(I) ("long-arm") authorizes service on
. Plaintiffs have been damaged by the conduct of Defendant Epstein, and have accordingly retained undersigned couns
nal Service on a Natural Person VS. DEFENDANT(' JEFFREY EPSTEIN. TYLER MCDONALD. TYLER MCDONALD D/B/A
ot be any pending criminal investigations, given Mr. Epstein's complete fulfillment of all the terms of his no
-3-sex-offender-stat us-upheld-by-ny-appeal- court/ 31 EFTA00599889 Jeffrey Epstein's Level 3 sex offender status upheld by NY appeals court By Dareh Gregorian November 18, 2011 5:00am Multimillionaire pery Jeffrey Epstein may not consider his Florida conviction for soliciting a minor a big deal, but New
n’s private jets. The U.S. Attorney General’s Office in Florida says that it is against policy to confirm or deny the existence of an investigation. Jeffrey Epstein’s lawyer, Jack Goldberger, says he has no knowledge of an ongoing probe, and he told The Daily Beast, "Jeffrey Epstein has fully complied with all stat
an office in Dade County. The causes of action and damages against Defendant Jeffrey Epstein accrued in Dade County, Florida, due to specific acts by Epstein there, and accordingly, venue is appropriate there. Florida Statute 47.011. Ds Florida Statute 48.193(1)(a)(1) (‘long-arm”’) authorizes service on b
4. Plaintiffs have been damaged by the conduct of Defendant Epstein, and have accordingly retained undersigned counse
Natural Person VS. DEFENDANT(S) JEAN-LUC BRUNEL JEFFREY EPSTEIN, TYLER MCDONALD, TYLER MCDONALD D/B/A Y
not be any pending criminal investigations, given Mr. Epstein’s complete fulfillment of all the terms of his no
ffender-status-upheld-by-ny-appeals- court/ 31 HOUSE_OVERSIGHT_011942 Jeffrey Epstein’s Level 3 sex offender status upheld by NY appeals court By Dareh Gregorian November 18, 2011 | 5:00am Multimillionaire perv Jeffrey Epstein may not consider his Florida conviction for soliciting a minor a big deal, but New
175 Epstein’s state guilty plea.250 As U.S. Attorney, Acosta had the authority to resolve the case in this manner, but OPR concludes that in light of all the s
to represent her “because she was unable to get anyone from the [USAO] to tell her what was actually going on with the federal criminal case against Jeffrey Epstein.”347 Villafaña told OPR that Wild did not contact her directly and she was not aware of 344 In
] OPR’s conclusion that deferring prosecution of Jeffrey Epstein to the State Attorney rather than proceed
parents finding out about their involvement with Mr. Epstein. Additionally,
uns for the first tune Feb 19 - Villafada completes third update 10 prosecution memorandum Feb 28 - USAO nmifies DOJ Civli Rights Division that Epstem investigation is ongoing Additional Key Dates Dec 17.2010 - DOJ Office of Legal Counsel issues opinion regarding CVRA Oct 20 I I - DOJ revises
Oct. 14, 2007; “Epstein Eyes Sex-Rap Relief,” New York Post, Oct. 9, 2007; “Sex Case ‘Victims’ Lining Up,” New York Post “Page Six,” Oct. 15, 2007; Dareh Gregorian and Mathew Nestel, “I Was Teen Prey of Pervert Tycoon,” New York Post, Oct. 18, 2007. The following month, the Palm Beach Post reported the end of
onal/longterm /ciaspy/affidavt.htm. 223 When it comes to recruiting moles: Angleton, interviews with author. 224 well experienced with false flags: Epstein, Deception, 22-28. 224 the “Trust” deception: Ibid. Also, Raymond Rocca (the CIA’s former research chief for the counterintelligence staff), intervi
: Mark Memmott, “He Broke the NSA Leaks Story, but Just Who Is Glenn Greenwald?,” NPR, June 11, 2013. For his part owner- ship of the HJ website, see Dareh Gregorian, “Glenn Greenwald, Journalist Who Broke Edward Snowden Story, Was Once Lawyer Sued over Porn Business,” Daily News, June 26, 2013. Also, Jessica Test
ugh his undersigned counsel, hereby submits this Response in Opposition to Plaintiff/Counter-Defendant Jeffrey Epstein’s Motion for Summary Judgment. Epstein seeks Summary Judgment on the claims of abuse of process and malicious prosecution set forth in Brad Edwards’ Fourth Amended Counterclaim. Each of th
Page: HOUSE_OVERSIGHT_013304 →Epstein. Sexual Abuse of Children By Epstein 1. Defendant Epstein has a nexual preference for young children. Depos
Page: HOUSE_OVERSIGHT_013319 →al complaint with obstruction of justice in eanneetinn with trying to obtain $50,000 from civil attorneys pursuing civil sexual assault cases against Rpatein as payment for producing the book to the attorneys. See Criminal Complaint at 4, US. v. Rodriguez, No. 9:10-CR-80015-KAM (S.D. Fla. 2010) (Exhibit “G
Page: HOUSE_OVERSIGHT_013327 →owing specific facts as the undisputed material facts in this case. Each of the following facts is numbered separately and individually to facilitate Epstein’s required compliance with Fla. R. Civ. P. 1.510(c) (“The adverse party shall identify . . . any summary judgment evidence on which the adverse party
Page: HOUSE_OVERSIGHT_010566 →Epstein, Sexual Abuse of Children By Epstein 1. Defendant Epstein has a sexual preference for young children. Depos
Page: HOUSE_OVERSIGHT_010566 →tz (attached hereto as Exhibit “H”), she attached the proposed plea agreement describing Epstein’s witness tampering as follows: "UNITED STATES vs. JEFFREY EPSTEIN PLEA PROFFER” On August 21, 2007, FBI Special Agents E. Nesbitt Kuyrkendall and Jason Richards traveled to the home of Leslie Groff to serve her with a f
Page: HOUSE_OVERSIGHT_010575 →oung you are. You have a tight butt like a baby”. See Jeff Epstein Sued for "Repeated Sexual Assaults" on Teen, New York Post, October —:17, 2007, by Dareh Gregorian, link at: http://www.nypost.com/p/news/regional/item_44z]WyLUFH7R10OUtKY GPbP;jsessionid=6CA3 EBF1BEF68F5DE14BFB2CAA5C37E0. See Article attached here
Page: HOUSE_OVERSIGHT_010585 →Entities connected to both Jeffrey Epstein and Dareh Gregorian

Lesley Groff
PERSON
Marc Rich
PERSONLarry Visoski
PERSONLeon Black
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Eric Trump
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
Donald Trump
PERSON
Bradley Edwards
PERSON
United States
LOCATION
Stephen Hawking
PERSONJack Goldberger
PERSON
Sarah Kellen
PERSON
Joe Biden
PERSON
Prince Charles
PERSONJanusz Banasiak
PERSON
Michael Wolff
PERSONJane Doe
PERSON