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By signing this agreement, Epstein asserts and certifies that the above has been read and explained to him. Epstein hereby states that he understands the conditions of this Non- Prosec
ts and information referring or relating to the transfer of fund to or from any account owned by NES, LLC to or from any account owned by JEGE, Inc., Jeffrey E. Epstein, Hyperion Air, Inc., Financial Trust Co., New York Strategy Group, Inc., J. Epstein Virgin Islands Foundations, Inc., and/or Epstein Interests. For
ASSISTANT U.S. ATTORNEY Dated: JEFFREY EPSTEIN Dated: GERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN Dated: F-4Y- 09- ANN Z, ESQ. ATTORNEY FOR JEFFREY EPSTEIN Page 7 of 7 HOUSE_OVERSIGHT_012597 TAB 22 HOUSE_OVERSIGHT_012598 08/31/2007 13:03 PAX 5618021787 USAD WEB FL i oo2 U.S. Department of Justice United
, LLC to or from any account owned by JEGE, Inc., Jeffrey E. Epstein, Hyperion Air, Inc., Financial Trust Co.
ase No. 3:04CR00003 (D. Alaska 2004). The federal prosecutors here rejected this idea, and they insisted that an attorney representative, paid for by Mr, Epstein, be appointed. Yet, there was ho suggestion at the time that the attomey representative’s duties included litigating claims on behalf of the identifi
nancial Trust Co., New York Strategy Group, Inc., J. Epstein Virgin Islands Foundations, Inc., and/or Epstein
, LLC to or from any account owned by JEGE, Inc., Jeffrey E. Epstein, Hyperion Air, Inc., Financial Trust Co.,
omas and Palm Beach, FL. The allegations herein concern Epstein’s conduct while at his lavish estate in Palm Beach. 10. Upon information and belief, Epstem has a sexual preference and obsession for underage minor girls. He engaged in a plan and scheme in which he gained access to primarily economically d
d that we use retired llth Circuit Judge Joseph Hatchett instead of Judge Davis because of Judge Davis's heaith problems. (No one has contacted Judge Hatchett yet, but one of the District Judges in Miami mentioned him as a good choice.) I am available for a conference call between 9:00 and 10:00, and betwe
rth is in the hundreds of millions of dollars - if not, indeed, a billion dollars. See, e.g., New York Time, July 1, 2008, at A2 ("Over the weekend Jeffrey E. Epstein, who after years of advising billionaires became a billionaire himself, left his estate on Little St. James Island, with its staff of 70 and its fl
ant PLAINTIFF, JANE DOE'S MOTION FOR INJUNCTION RESTRAINING FRAUDULENT TRANSFER OF ASSETS, APPOINTMENT OF A RECEIVER TO TAKE CHARGE OF PROPERTY OF EPSTEIN, AND TO POST A $15 MILLION BOND, TO SECURE POTENTIAL JUDGMENT COMES NOW Plaintiff Jane Doe, by and through undersigned counsel, and hereby files t
IS ASSETS. As noted in the material facts above, defendant Epstein is currently making fraudulent transfers of his
ork Time, July 1, 2008, at A2 ("Over the weekend Jeffrey E. Epstein, who after years of advising billionair
ork Time, July 1, 2008, at A2 ("Over the weekend Jeffrey E. Epstein, who after years of advising billionaire
#23. 14. Epstein has blocked all discovery, in this and other related cases, regarding his assets. Affidavit of Paul Cassell at ¶¶ 7, 8. ARGUMENT I. EPSTEIN IS FRAUDULENTLY TRANSFERRING HIS ASSETS. As noted in the material facts above, defendant Epstein is currently making fraudulent transfers of his as
n direct evidence, and, in some cases is even more reliable.'" United States v. Ranum, 96 F.3d 1020, 1026 (7th Cir. 1996) (quoting United States v. Hatchett, 31 F.3d 1411, 1421 (7th Cir. 1994)). For all these reasons, the Court should conclude that Epstein is fraudulently transferring assets. 11 EFTA
BURMAN CRITTON LUTTIER UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CIV- 80893 - MARRA/JOHNSON JANE DOE, Plaintiff, V. JEFFREY EPSTEIN, Defendant. ____________ ___;/ DEFENDANT EPSTEIN'S RESPONSE TO PLAINTIFF JANE DOE'S FIRST REQUEST FOR ADMISSIONS (dated 03/23/09) 14] 023/031 D
unsel, and hereby files this Motion for Injunction, pursuant to Federal Rule of Civil Procedure 64, for appointment of a receiver to take charge of Epstein's property, and to post a $15 million bond to secure any potential judgment in this case, for the reasons explained in the accompanying supporting
ork Time, July 1, 2008, at A2 ("Over the weekend Jeffrey E. Epstein, who after years of advising billionair
ork Time, July 1, 2008, at A2 ("Over the weekend Jeffrey E. Epstein, who after years of advising billionaire
IS ASSETS. As noted in the material facts above, defendant Epstein is currently making fraudulent transfers of his
n direct evidence, and, in some cases is even more reliable."' United States v. Ranum, 96 F.3d 1020, 1026 (7th Cir. 1996) (quoting United States v. Hatchett, 31 F.3d 1411, 1421 (7th Cir. 1994 )). For all these reasons, the Court should conclude that Epstein is fraudulently transferring assets. 11 C
R TO THE SPECIAL MASTER Re: special Master: Privileged and Confidential Dear Sir: The undersigned, as counsel for the United States of America and Jeffrey Epstein, jointly write to you to provide information relevant to your service as a Special Master in the selection of an attorney to represent several youn
to your service as a Special Master in the selection of an attorney to represent several young women who may have civil damages claims against Mr. Epstein. The U.S. Attorney's Office and the Federal Bureau of Investigation (jointly referred to as the "United States") have conducted an investigation of
, as counsel for the United States of America and Jeffrey Epstein, jointly write to you to provide informa
women who may have civil damages claims against Mr. Epstein. The U.S. Attorney's Office and the Federal Bure
hat we use retired 11th Circuit Judge Joseph Hatchett instead of Judge Davis because of Judge Davis's health problems. (No one has contacted Judge Hatchett yet, but one of the District Judges in Miami mentioned him as a good choice.) I am available for a conference call between 9:00 and 10:00, and be
15th Judicial Circuit in and for Palm Beach County (hereinafter, the "State Attorney's Office") have conducted an investigation into the conduct of Jeffrey Epstein (hereinafter "Epstein"); IT APPEARING that the State Attorney's Office has charged Epstein by indictment with solicitation of prostitution, in viol
sked AUSA Villafada to simply quote the terms of the Agreement directly into the Notification Letter. We also have no objection to referring to Mr. Epstein n a "sexual offender" rather titan a "predator." We have no objection to using the conjonedon "wid/or" in rofmabm to the particular offame(s) of whic
ov> Sent: Sun Sep 23 12:22:46 2007 Subject: Re: Jeffrey Epstein - confidential Can we do a conf call? S
onth windowin case we discover a violation after Mr. Epstein is released. Ido not care if you want to call th
hat we use retired 11th circuit Judge Joseph Hatchett instead of Judge Davis because of Judge Davis's health problems. (No one has contacted Judge Hatchett yet, but one of the District Judges in Miami mentioned him as a good choice.) I am available for a conference call between 9:00 and 10:00, and be
SAFLS) Subject: Re: Proposed Letter to Special Master U- - I, too, am interested in speed. But I really need to go over this and then discuss with Jeffrey. So please do not send this to any Special Master before we discuss the next steps. Thanks -- Jay 10/03/2007 04:24 PM To "Jay Lefkowitz" < cc
that we use retired 11th Circuit Judge Joseph Hatchett instead of Judge Davis because of Judge Davis's health problems. (No one has contacted Judge Hatchett yet, but one of the District Judges in Miami mentioned him as a good choice.) I am available for a conference call between 9:00 and 10:00, and bet
land.comi Subject: Re: Proposed Letter to Special Master - I, too, am interested in speed. But I really need to go over this and then discuss with Jeffrey. So please do not send this to any Special Master before we discuss the next steps. Thanks -- Jay 111111111111 To "Jay Lefkowitz" <JLefkowitz@ki
that we use retired 12th Circuit Judge Joseph Hatchett instead of Judge Davis because of Judge Davis's health problems. (No one has contacted Judge Hatchett yet, but one of the District Judges in Miami mentioned him as a good choice.) I am available for a conference call between 9:00 and 10:00, and betw
LS) Subject: Re: Proposed Letter tc Special Master Marie - I, too, am interested in speed. But I really need to go over this and then discuss with Jeffrey. So please do not send this to any Special Master before we discuss the next steps. Thanks -- Jay "Villafana, Ann Marie C. (USAFLS)" <Ann.Marie.C.
recommend that w tired 11th Circuit Judge Joseph Hatchett instead of Judge because of Judge illie health problems. :No one has contacted Judge Hatchett yet, but one of the District udges in Miami mentioned him as a good choice.) I am available for a conference call between 9:00 and 10:00, and betwe
FLS) "Object: Re: Proposed Letter to Special Master Marie - I, too, am interested in speed. But I really need to go over this and then discuss with Jeffrey. So please do not send this to any Special Master before we discuss the next steps. Thanks -- Jay 'Villeins, Ann Marl* C. (USAFLS)' cAnn.Marie.C.
that we use retired 11th Circuit Judge Joseph Hatchett instead of Judge Davis because of Judge Davis's health problems. (No one has contacted Judge Hatchett yet, but one of the District Judges in Miami mentioned him as a good choice.) I am available for a conference call between 9:00 and 10:00, and betw
and world leaders are highly relevant and admissible (Motion in Limine 1) .0...... ce ceeeeseeeseeeseeeseeeseeeneeesees 6 2. Meeting Bill Clinton at Jeffrey Epstein’s private island twice (Motion in Limine 2)..... 8 3. FOIA responses and related materials are admissible (Motion in Limine 3).................+ 8 4. L
Page: HOUSE_OVERSIGHT_011464 →her intervening causes of emotional distress and related damages (Motion in Limine 14) 23 15. Plaintiffs lies about her age and the year she met Mr. Epstein must be exposed to the Jury (Motion in Limine 15)... eee eeeceeseesseeseeesseessecseeesceeseecnseesaeeseeceseeaeesseeeeesseesaees 24 16. All of Plai
Page: HOUSE_OVERSIGHT_011465 →laintiffs lies about her age and the year she met Mr. Epstein must be exposed to the Jury (Motion in Limine 15)
Page: HOUSE_OVERSIGHT_011465 →7, 1998)... 25 United States v. Dukes, 727 F.2d 34, 37 (2d Cir. 1984) oo. ceiceeccssseeseceseesseeeseesseeeeecseessaeeseeesneeees 17 United States v. Hatchett, 918 F.2d 631, 641 (6th Cir, 1990) oo. eee ceeeesseeseeeseeeseeeseesseeeseeenaeeees 22 United States v. Lujan, No. 05—CR-924 (RB) (D.N.M. Mar. 25, 20
Page: HOUSE_OVERSIGHT_011467 →Entities connected to both Jeffrey Epstein and Hatchett

Lesley Groff
PERSONLeon Black
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Alan Dershowitz
PERSON
Donald Trump
PERSON
Bradley Edwards
PERSON
United States
LOCATIONJack Goldberger
PERSON
FedEx
ORGANIZATIONJane Doe
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSONMartin Weinberg
PERSON
Kenneth Marra
PERSON
Bill Clinton
PERSON
Alexander Acosta
PERSONthe Southern District
LOCATION
Paul Cassell
PERSON
U.S. Virgin Islands
LOCATION