Epstein Secrets

tiff C.M.A. Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss P.A. West Palm Beach, FL 33401-5012 ounse or a en an s Jeffrey Epstein and Sarah Kellen Jack Scarola, Esq. Jack P. Hill, Esq. Bruce Reinhart, Esq. Searcy Denney Scarola Barnhart & Bruce E. Reinhart. P.A. Shiolev, P A West Palm

ounse or a en an s Jeffrey Epstein and Sarah Kellen Jack Scarola, Esq. Jack P. Hill, Esq. Bruce Re

the "predicate acts" specifically identified in §2255. "18 U.S.C. §2255 gives victims of sexual conduct who are minors a private right of action." Martinez v. White, 492 EFTA00201194 Case 9:08-cv-80811-KAM Document 47 Entered on FLSD Docket 03/12/2009 Page 6 of 21 C.M.A. v. Epstein, et al. Page 6

rther evidenced by Count XXXI — "Sexual Battery" where Plaintiff reincorporates each of the 30 counts and seeks the identical "actual damages." In Martinez v. White, supra, the defendants sought to dismiss plaintiffs' 18 U.S.C. §2255 action based on forum non conveniens. The Northern District of Califor

13 Entered on FLSD Docket 05/06/2009 Page 2 of 29 Jane Doe II v. Epstein. et al. Page 2 50 2008CA020614 MBAF, Jane Doe II v. Jeffrey Epstein, and Sarah Kellen, (hereinafter "state action"). In attempting to allege a claim under 18 U.S.C. §2255, Plaintiff improperly relies on the §2255, as amended, effect

ENDNOTES: 1 In paragraph 11 of her Complaint, Jane Doe II alleges that — "From about June, 2003 until about February, 2005, Defendants, EPSTEIN and KELLEN persuaded, induced, or EFTA00222839 Case 9:09-cv-80469-KAM Document 13 Entered on FLSD Docket 05/06/2009 Page 28 of 29 Jane Doe II v. Epstein,

ion." EFTA00222830 Case 9:09-cv-80469-KAM Document 13 Entered on FLSD Docket 05/06/2009 Page 19 of 29 Jane Doe II v. Epstein, et al. Page 19 Martinez v. White 492 F.Supp.2d 1186, 1188 (N.D. Cal. 2007), (emphasis added). 18 U.S.C.A. §2255 "merely provides a cause of action for damages in 'any appro

ecoverable on a "per violation" or "per incident" basis. The Plaintiff's position on §2255 puts a strained interpretation with an absurd result. In Martinez v. White, supra, the defendants sought to dismiss plaintiffs' 18 U.S.C. §2255 action based on forum non conveniens. The Northern District of Califor

r of Epstein, including but not limited to Sarah Kellen, Adrian Ross, Lesley Groff, or Nadia Marcinkova.

victims, the NPA granted federal immunity not only to Epstein, but also to "any potential co-conspirator of Epstein, including but not limited to Sarah Kellen, Adrian Ross, Lesley Groff, or Nadia Marcinkova." It is only because the victims filed this lawsuit, and the District Court ordered the NPA be pro

"encompass the entire criminal investigatory process," but rather "at the very least requires the initiation of legal proceedings." P M()Chavez it Martinez, 538 U.S. 760, 766, 123 S.Ct. 1994, 155 L.Ed.2d 984 (2003). Notably, in so holding, the Court drew on longstanding tradition, citing its now nearl

n legal parlance the judicial-case connotation is undoubtedly primary." Maj. Op. at 1207. As to the term "case," even the Majority cites Chavez v. Martinez, 538 U.S. 760, 766, 123 S. Ct. 1994, 2000-01, 155 L.Ed.2d 984 (2003), which supports my conclusion that the CVRA's conferral right attaches pre- cha

d States also agrees that it will not institute any criminal charges against any potential co-conspirators of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova. NPA at 5; Def. Mot. I at 20-21. Aside from the reference to "United States" which, as noted abov

s of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova

004) 56, 57 Madanes v. Madanes, 186 F.R.D. 279 (S.D.N.Y. 1999) 141 Martindell v. Intl Tel. and Tel Coup., 594 F.2d 291 (2d Cir. 1979) passim Martinez v. McAleenan, 385 F. Stipp. 3d 349 (S.D.N.Y. 2019) 150, 151 Michigan v. Tucker, 417 U.S. 433 (1974) 137 vii EFTA00099948 Miller v. Pate,

d States also agrees that it will not institute any criminal charges against any potential co-conspirators of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova. NPA at 5; Def. Mot. 1 at 20-21. Aside from the reference to "United States" which, as noted abov

s of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova

004) 56, 57 Madanes v. Madanes, 186 F.R.D. 279 (S.D.N.Y. 1999) 141 Martindell v. Intl Tel. and Tel. Corp., 594 F.2d 291 (2d Cir. 1979) passim Martinez v. McAleenan, 385 F. Supp. 3d 349 (S.D.N.Y. 2019) 150, 151 Michigan v. Tucker, 417 U.S. 433 (1974) 137 vii EFTA00077613 Miller v. Pate, 386

d States also agrees that it will not institute any criminal charges against any potential co-conspirators of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova. NPA at 5; Def. Mot. 1 at 20-21. Aside from the reference to "United States" which, as noted abov

s of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova

004) 56, 57 Madanes v. Madanes, 186 F.R.D. 279 (S.D.N.Y. 1999) 141 Martindell v. Intl Tel. and Tel. Corp., 594 F.2d 291 (2d Cir. 1979) passim Martinez v. McAleenan, 385 F. Supp. 3d 349 (S.D.N.Y. 2019) 150, 151 Michigan v. Tucker, 417 U.S. 433 (1974) 137 vii EFTA00039428 Miller v. Pate, 386

d States also agrees that it will not institute any criminal charges against any potential co-conspirators of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova. NPA at 5; Def. Mot. 1 at 20-21. Aside from the reference to "United States" which, as noted abov

s of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova

186 F.R.D. 279 (S.D.N.Y. 1999) 98 Martindell v. Intl Tel. and Tel. Corp., 594 F.2d 291 (2d Cir. 1979) 59, 63, 77, 102 Martindell, 594 F.3d 79 Martinez v. McAleenan, 385 F. Supp. 3d 349 (S.D.N.Y. 2019) 104 Michigan v. Tucker, 417 U.S. 433 (1974) 96 Miller v. Pate, 386 U.S. 1 (1967) 108, 117,

olved the exact same crimes and same evidence being reviewed by the U.S. Attorney's office when he was employed there. Specifically, he represented Sarah Kellen (Epstcin's number one co-conspirator who was actually named as such in the NPA), his housekeeper (Louella Ruboyo), his pilots Larry Morrison, Larry

ployed there. Specifically, he represented Sarah Kellen (Epstcin's number one co-conspirator who was actu

rc "merely a statement of assertion or concession made for some independent purpose," and may be controverted or explained by the party who made it. Martinez I Bally's Louisiana, Inc., 244 F.3d 474, 476-77 (51° Cir. 2001), citing McNamara v. Miller, 269 F.2d 511, 515 (D.C. Cir. 1959). In contrast, a judi

not use non-public Government information for any purpose. 14. After opening my private practice on January 2, 2008, I was retained to represent Sarah Kellen for purposes of civil depositions in causes of action to which the United States was not a party. At a later time, I was retained to represent seve

nuary 2, 2008, I was retained to represent Sarah Kellen for purposes of civil depositions in causes of ac

re "merely a statement of assertion or concession made for some independent purpose," and may be controverted or explained by the party who made it. Martinez I. Bally's Louisiana, Inc., 244 F.3d 474, 476-77 (V' Cir. 2001), citing McNamara'. Miller, 269 F.2d 511, 515 (D.C. Cir. 1959). In contrast, a judic

Nathan Z. Dershowitz Left messages with Sarah Kellen and to request if he can accept service on thei

faiia Gerald Lefcourt Letter that he cannot accept service for Eric Gany 8/28/2007 A. Marie Villafaiia Nathan Z. Dershowitz Left messages with Sarah Kellen and to request if he can accept service on their behalf 8/30/2007 Jeff Sloman, Andrew Laurie, Drew Oosterbaan, John McMillan, Karen Atkinson

e Dalton School (return date 9/29/09) 9/26/2006 Acosta, Mulvihill, Sloman, Noto, Waters, L°urie' Stefin, Atkinson, Garcia, Brown, Boscovich, Martinez Villafaila Memo regarding changes to Child Explotation Statutes in Tide 18 16 10/19/2006 Subpoena to Individual #28 (return date 10/27/06) 10/2