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, TYLER MCDONALD D/B/A/ YI.ORG Defendants. DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS COMES NOW, the Defendant, Jeffrey Epstein, a resident of the United States Virgin Islands, by and through his undersigned counsel, and files this Motion to Dismiss, and. as good grounds therefore states as follows: 1. On October 5, 2016
RMA 31401.5086 TEUTPHON13 (RS I) 65SAM FAX (561) 8354691 December 2, 2016 Via Email: joetitone708(geomcastnet Joe Titone, Esq. 621 S.E. 5th St Pompano Beach, FL 33060 Re: Service of Process Dear Joe, December 7, 2016 Via Email: Metitone708acomeastnet Joe Titone, Esq. 621 S.E. 56 Street Pompano Beac
n its order granting Brunel leave to serve Epstein (Defendant's App. E, p.48). Additionally, Brunel did not serve Epstein at his home address in the Virgin Islands, as Epstein lives on his own private island (Little St. James), which is inaccessible to the public (Defendant's App. F, p.62-65). After Epstein's
the Eleventh Judicial Circuit in and for Miami-Dade County, Florida Joe Titone Attorney for Appellant Florida Bar No. 203882 62 1SE 5th Street Pompano Beach, FL 33060 Phone: (954)729-6490 [email protected] 1 EFTA00792289 TABLE OF CONTENTS TABLE OF AUTHORITIES 4 STATEMENT OF THE CASE AND
helicopter? A. Correct. Q. Because you're a trained helicopter pilot? A. That is correct. Q. Where did you stay when you went on the trips to the Virgin Islands? A. Typical hotel, Marriott Resorts that were there. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068703 242 LBUCmax3 - cross 4 5
believe, in the early 2000s, Ghislaine went to school to become a trained helicopter pilot; is that right? A. Yes, she did. Q. That school was in Pompano Beach, Florida? A. That's correct. Q. Pompano Beach is about an hour or so drive south of Palm Beach, right? A. Yeah, give or take traffic. It could be
Entities connected to both U.S. Virgin Islands and Pompano Beach

Jeffrey Epstein
PERSONDarren Indyke
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Richard Kahn
PERSON
Prince Andrew
PERSON
New York
LOCATION
George W. Bush
PERSON
Alan Dershowitz
PERSON
Palm Beach
LOCATION
Bill Clinton
PERSON
Donald Trump
PERSON
Department of Justice
ORGANIZATIONLeon Black
PERSON
Virginia Giuffre
PERSON
Bradley Edwards
PERSON
Marc Rich
PERSONJane Doe
PERSON
Sarah Ferguson
PERSON
New York City
LOCATION