Epstein Secrets

to Palm Beach County, Florida, aboard the Boeing 727 aircraft owned by JEGE, INC. (215) On or about February 24, 2005, Defendants JEFFREY EPSTEIN, SARAH ICELLEN, and traveled from Teterboro, New Jersey to Palm Beach County, Florida, aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (216) On or ab

Section 853. If the property described above as being subject to forfeiture, as a result of any act or omission of the defendants, JEFFREY EPSTEIN, SARAH a/k/a "Adriana Mucinska," and (1) cannot be located upon the exercise of due diligence; (2) has been transferred or sold to, or deposited with a

exchange for posing for nude photographs. (13) In or around 2003, Defendant SARAH KELLEN told Jane Doe #2 that Defendant JEFFREY EPSTEIN had asked KELLEN to take nude photographs of Jane Doe #2. (14) In or around 2003, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane,Doe #2, who was th

to protect persons charged with criminal conduct from the burdens associated with multiple prosecutions and punishments for substantially the same act(s) or transaction(s)." Id. To that end, Petite "establishes guidelines for the exercise of discretion by appropriate officers of the Department of Jus

of 25 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80811-MARRAIJOHNSON C.M. A., Plaintiff, v. JEFFREY EPSTEIN and SARAH KELLEN, Defendants, DEFENDANT EPSTEIN'S REPLY TO PLAINTIFF'S MEMORANDUM IN RESPONSE TO DEFENDANT, JEFFREY EPSTEIN'S, MOTION TO DISMISS FIRST AMEDNED COM

. A., Plaintiff, v. JEFFREY EPSTEIN and SARAH KELLEN, Defendants, DEFENDANT EPSTEIN'S REPLY TO PLAIN

ally identified in subsection (a) of the statute. Plaintiff in her response, p. 10, agrees that she has failed to sufficiently allege the predicate act(s) required by §2255. Defendant has no objection to Plaintiff attempting to amend, but Plaintiff should be required to plead a single cause of action

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

2255 claim to go forward without specifying the statutory predicate act and factual allegations pertaining to a violation of the requisite predicate act(s). Accordingly, under EFTA00201199 Case 9:08-cv-80811-KAM Document 47 Entered on FLSD Docket 03/12/2009 Page 11 of 21 C.M.A. v. Epstein, et al.