Epstein Secrets

-80591,09-80656,09-80802,09-81092 ------------------'/ MOTION FOR PROTECTIVE ORDER AS TO THE DEPOSITION OF NADIA MARCINKOV A Third-Party Witness, NADIA MARCINKOV A, by and through her undersigned attorney, Jack A. Goldberger, and pursuant to Fed. R. Civ. P. 26(c), moves for a Protective Order to rescheduled he

, via email and telephone on February 24 and February 25, 2010 detailing the circumstances surrounding the need to reschedule the deposition of Ms. Marcinkova, providing additional available dates wherein both the undersigned and Ms. Marcinkova will be available. Case 9:08-cv-80119-KAM Document 475

0, to another date to be agreed upon by all interested parties. Isl Jack A. Goldberger Jack A. Goldberger, Esq. Attorney for Third-Party Witness, Nadia Marc ink ova Certificate of Service I HEREBY CERTIFY that the foregoing document is being served this day on all counsel of record identified on th

n February 3, 2010, counsel for Plaintiff, Jane Doe, filed a Notice of Taking the Deposition of Third-Party Witness, NADIA MARCINKOV A, in a related State Court action filed against Mr. Epstein. While the Notice is filed in L.M. v. Jeffrey Epstein, Palm Beach County Circuit Court Case No: 502008CA028051AXXX

efcourt Letter that he cannot accept service for Eric Gany 8O8O007 A. Marie Villafatia Nathan Z. Dershowitz Left messages with Sarah Kellen and Nadia Marcinkova to request if he can accept service on their behalf 8/30/2007 Jeff Sloman, Andrew Lourie, Drew Oosterbaan, John McMillan, Karen Atkinson Mar

howitz Left messages with Sarah Kellen and Nadia Marcinkova to request if he can accept service on their beh

Dershowitz Left messages with Sarah Kellen and Nadia Marcinkova to request if he can accept service o

, and #38 B-70 7/21/2008 Valhalla; cc: Senior Sloman Email response to Villafafia's 7/21/08 email regarding Motion for Return of Property in State Court 7/22/2008 Valhalla Kuyrkendall Email chain regarding victim addresses 7/22/2008 Emails between A. M. Villafana, A. Acosta, J. Sloman, R. Senior

criminal. Amended Complaint at 143. According to the Amended Complaint and the Rico Statement, the enterprise consisted of Epstein, Sarah Kellen and Nadia Marcinkova. Id. However, as set forth in more detail below, Plaintiff does not and cannot establish the "distinctiveness" requirement of the enterprise eleme

rise consisted of Epstein, Sarah Kellen and Nadia Marcinkova. Id. However, as set forth in more detail below

enterprise consisted of Epstein, Sarah Kellen and Nadia Marcinkova. Id. However, as set forth in more d

witness, (0 destroying or concealing evidence and (g) maintaining a place for purposes of lewdness and prostitution. In O'Malley, appellants sued in State Court under Florida RICO alleging they were terminated because they refused to participate in alleged RICO violations. O'Malley v. St.. Thomas Univ.. Inc

s ofthis agreement, the United States also agrees that it will not institute any • tellifilif Indira of Epstein, including but not limited to or Nadia Marcinkova. Further, upon execution of this agreement and a plea agreement with the State Attorney's Office, the federal Grand Jury investigation will be susp

f Epstein, including but not limited to or Nadia Marcinkova. Further, upon execution of this agreement and a

dira of Epstein, including but not limited to or Nadia Marcinkova. Further, upon execution of this agre

t several of the young girls that were victimized and abused by Jeffrey Epstein. While we are aware of his recent guilty plea and conviction in his State Court case, the sentence imposed in that case is grossly inadequate for a sexual predator of this magnitude. The information and evidence that has come to

y information for a number of victim/witnesses, Nadia Marcinkova, and Adriana Mucinska Work product 6

03545 Indictment preparation binder containing meta- analysis charts of telephone/flight/grand jury information for a number of victim/witnesses, Nadia Marcinkova, and Adriana Mucinska Work product 6(e) Contains information and documents subject to investigative privilege. Also contains information and d

ormation for a number of victim/witnesses, Nadia Marcinkova, and Adriana Mucinska Work product 6(e) Contai

arties to this litigation Box #2 P-008299 Thru P-008363 File folder entitled "FINAL AGREEMENTS" containing subfolder entitled "Agrmts Filed in State Court" (P-008300-P-008327 [not being withheld as privileged — have been produced to opposing counsel]); signed Non-Prosecution Agreement, Addendum, and

03545 Indictment preparation binder containing meta- analysis charts of telephone/flight/grand jury information for a number of victim/witnesses, Nadia Marcinkova, and Adriana Mucinska Work product 6(e) Contains information and documents subject to investigative privilege. Also contains information and d

ral sex and vaginal sex. Epstein sometimes brought his assistant/girlfriend, Nadia Marcinkova, into the sexual activity. One of the girls described Marcinkova as Epstein's "sex slave". On October 18, 2005, PBPD obtained a search warrant with the assistance of the Palm Beach County State Attorney's Office

y information for a number of victim/witnesses, Nadia Marcinkova, and Adriana Mucinska Work product 6

arties to this litigation Box #2 P-008299 Thru P-008363 File folder entitled "FINAL AGREEMENTS" containing subfolder entitled "Agrmts Filed in State Court" (P-008300-P-008327 [not being withheld as privileged — have been produced to opposing counsel]); signed Non-Prosecution Agreement, Addendum, and

August 19, 2005, Defendant a/k/a "MIEM" placed a telephone call to a telephone used by Jane Doe #16. (169) On or about August 21, 2005, Defendant NADIA placed a telephone call to a b4hone used by Jane Doe #16. (170) On or about September 3, 2005, Defendant aAc/a " placed a telephone call to a tel

ach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. On or about February 3, 2005, Defendants JEFFREY EPSTEIN, SARAH KELLEN, and NADIA MARCINICOVA traveled from Columbus, Ohio, to Palm Beach County, Florida, aboard the Boeing 727 aircraft owned by JEGE, MC. (213) On or about February 10, 2005,

t 19, 2004, Defendants JEFFREY EPSTEIN and NADIA MARCINKOVA tra ed from Van Nuys, California to Palm Beach C

ers of Mr. Epstein's defense team, prior published reports of a pending State case against Mr. Epstein and public information available through the State Court system. Weinstein refused to answer the first question. As to the second question, Weinstein told him that any matter arising out of conduct in Pal

ute any criminal charges against any potential co-conspirators of Epstein, including but not limited to Sarah Kellen, Adrian Ross, Lesley Groff, or Nadia Marcinkova. Further, upon execution of this agreement and a plea agreement with the State Attorney's Office, the federal Grand Jury investigation will be susp

arah Kellen, Adrian Ross, Lesley Groff, or Nadia Marcinkova. Further, upon execution of this agreement and a

d to Sarah Kellen, Adrian Ross, Lesley Groff, or Nadia Marcinkova. Further, upon execution of this agre

ment available to the victims, the United States sought to confirm that counsel for Mr. Epstein had filed the complete Agreement under seal with the State Court at the time of the entry of his guilty plea to the State charges, to insure that an exact copy of that Agreement would be provided in this case, sh

elephone/flight/grand jury information for Contains information and Anticipation of Litigation; Improper P-003545 a number of victim/witnesses, Nadia documents subject to Invocation; Overriding Need; Claims Against Marcinkova, and Adriana Mucinska investigative privilege. Public Prosecutor, At

ipation of Litigation; Improper P-003545 a number of victim/witnesses, Nadia documents subject to Invocation; Overriding Need; Claims Against Marcinkova, and Adriana Mucinska investigative privilege. Public Prosecutor, Attorney Conduct at Issue; Also contains information and documents subject to

Asserted Victims' Objections Box #2 File folder entitled "FINAL P-008299 Thru AGREEMENTS" containing subfolder entitled "Agrmts Filed in State Court" (P- N/A P-008363 008300-P-008327 [not being withheld as privileged — have been produced to opposing counsel]); signed Non- Prosecution Agree

irls to his mansion. Epstein's key "lieutenant" in the organization was MI who served as both his scheduler and a recruiter/procurer of the girls. Marcinkova also served as a recruiter and helped Epstein satisfy his criminal sexual desires by, on occasion, directly participating in sexual abuse and prost

), the District Court dismissed a purely state law claim for equitable subrogation because there had been an earlier claim for declaratory relief in State Court; the Eleventh Circuit reversed, concluding ...that no exceptional circumstances require dismissal of this case in deference to the pending state c