3
Shared Docs
3
Same-Page
9 / 3
Mentions
as alleged that Epstein has international contacts, having travelled overseas with such famous persons as President Bill Clinton, Prince Andrew, and Donald Trump. Is Epstein contesting that he has these international travels? Here again, it is impossible to tell because Epstein has not explained whether he
ons as President Bill Clinton, Prince Andrew, and Donald Trump. Is Epstein contesting that he has these
President Bill Clinton, Prince Andrew, and Donald Trump. Is Epstein contesting that he has these intern
SD Docket 07/23/2009 Page 16 of 26 CASE NO: 08-CV-80119-MARRA/JOHNSON 14 198 at 18] (citing In re Leneve, 341 B.R. 53, 56 (Bkrtcy S.D. Fla. 2006).3 However, Epstein does not grapple with the fact that Jane Doe has properly proven each of these four poi
t include: (1) Epstein may own a Boeing 727 with a trading room (See Affidavit of Paul Cassell '1[7); (2) Epstein has travelled internationally with Donald Trump and is Case 9:08-cv-80119-KAM Document 198 Entered on FLSD Docket 07/13/2009 Page 8 of 24 Jane Doe v. Epstein Case No. 08-CV-80893-Marra/Jo
); (2) Epstein has travelled internationally with Donald Trump and is Case 9:08-cv-80119-KAM Document
Epstein has travelled internationally with Donald Trump and is Case 9:08-cv-80119-KAM Document 198
ccurred within certain statutory time periods; and (4) the debtor made the transfer with the intent to hinder, delay or defraud creditors. See In re Leneve, 341 B.R. 53, 56 (S.D. Fla. 2006). Courts typically resort to the "badges of fraud," to determine fraudulent intent. Id. at 61. The Eleventh Circui
vit include: (1) Epstein may own a Boeing 727 with a trading room (Sec Affidavit of Paul Cassell 17); (2) Epstein has travelled internationally with Donald Trump and is EFTA00221935 Case 9:08-cv-80119-KAM Document 198 Entered on FLSD Docket 07/13/2009 Page 8 of 24 Jane Doe v. Epstein Case No. 08-CV-808
Epstein has travelled internationally with Donald Trump and is EFTA00221935 Case 9:08-cv-80119-KAM Do
); (2) Epstein has travelled internationally with Donald Trump and is EFTA00221935 Case 9:08-cv-80119-K
ccurred within certain statutory time periods; and (4) the debtor made the transfer with the intent to hinder, delay or defraud creditors. See In re Leneve, 341 B.R. 53, 56 (S.D. Fla. 2006). Courts typically resort to the "badges of fraud," to determine fraudulent intent. Id. at 61. The Eleventh Circui
Entities connected to both Donald Trump and Leneve

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
George W. Bush
PERSON
Bradley Edwards
PERSON
Scarlett Johansson
PERSONJack Goldberger
PERSONJane Doe
PERSON
Harvey Weinstein
PERSON
Kenneth Marra
PERSON
Vicky Ward
PERSON
Martha Stewart
PERSON
James Baker
PERSONScott Rothstein
PERSON
Paul Cassell
PERSON
Bear Stearns
ORGANIZATIONJack Scarola
PERSON
Sarah Kellen
PERSON
Steven Hoffenberg
PERSONRobert D. Critton
PERSONSpencer Kuvin
PERSON