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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
ction to prevent “transfer[ring] assets abroad” and distinguishing De Beers). In one final attempt to obscure this Court’s power, Epstein cites Lawhon v. Mason, 611 So.2d 1367, 1368 (Fla. Ct. App. 1993), as rejecting plaintiff’s motion to prohibit a defendant from transferring assets. Mem. in Opp.
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
er, in her First Amended Complaint (DE #38), Jane Doe does not seek an injunction nor does she assert a claim under Fla. Stat. §726.101 et seq. See Lawhon v. Mason, 611 So. 2d 1367, 1368 (Fla. 2d DCA 1993) (holding that a party must ''file suit under the Uniform Fraudulent Transfer Act" to enjoin frau
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
leges the defendant may be dissipating assets; a judgment for money damages is adequate and injunctive relief is improper) (citations omitted). The Lawhon court also noted that the order was similar to a pit-judgment writ of attachment. 611 So. 2d at 1368. "A writ of attachment cannot issue unless the
Entities connected to both Donald Trump and Lawhon

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