Epstein Secrets

Epstein abused them. See Rule 413 Notice, RYbibit E; Deposition of.., Deposition Attachment #4. 15. One of Mr. Epstein's household employees, Mr. Alfredo Rodriguez, saw numerous underage girls coming into Epstein's mansion for purported "massages." See Rodriguez Depo. at 242- 44 (Deposition Attachment #8). Rodr

attorneys pursuing civil sexual assault cases against Epstein as payment for producing the book to the attorneys. See Criminal Complaint at 2, U.S. I. Rodriguez, No. 9:10-CR-80015-KAM (S.D. Fla. 2010) (Exhibit "G"). Rodriguez stated he needed money because the journal was his "property" and that he was afrai

vice in the State of Florida. 3. Prior to assuming his teaching responsibilities, PAUL G. CASSELL clerked first for the U.S. Court of Appeals for the D.C. Circuit (1984-1985) and then from 1985 to 1986 clerked for the United States Supreme Court before serving as an Associate Deputy Attorney EFTA00188845 Ca

istrict Court for the Southern District of Florida, an alleged victim said that Epstein • and girlfriend Ghislaine] Maxwell, Brunel. [house manager Alfredo] Rodriguez. and 'deliberately engaged in a pattern of racketeering that involved luring minor children through MC2, mostly girls under the age of 17. to engag

wels and putting away the sex toys. And she was upset that a photo of Epstein with the pope hung next to one of him with a young girl. Ironically. Rodriguez. who ran the house on El Brillo Way in 2004 and 2005, ended up being sentenced to more jail time than his boss as a result of the complex investigat

e of Law at the University of Utah. Before coming to Utah. he was President of the Stanford Law Review, a law clerk for then-Judge Antonin Scalia on the D.C. Circuit and for Chief Justice Warren Burger of the Supreme Court. an Ass iate Deputy Attorney General with the . Justice Department (1986-88), and an Assi

1) 28 Fla. L. Weekly Fed. C 2701 6 Jennings v. Rodriguez. 538 U.S. -. -. 138 S. Ct. 830. 843-44, 200 L.E

lear and sensible boundary' that is marked by the formal initiation of criminal proceedings and that Chief Judge Srinivasan astutely recognized for the D.C. Circuit in Fokker Services. There is a world of difference between a court insinuating itself into a prosecutor's case before charges are filed and steppin

e incor- rect.’’’) (internal citations omitted). The Court bears in mind that it is bound by Sec- ond Circuit precedent while Judge Robertson applied D.C. Circuit law. Menowitz v. Brown, 991 F.2d 36, 40-41 (2d Cir.1993) (explaining transferee court is to apply its interpretation of federal law, not that of the

e war with the United States). 26. Plaintiffs argue that Judge Robertson held them to an unnecessarily stringent theory of causation and submit that the D.C. Circuit’s subsequent decision in Kilburn v. Socialist People’s Libyan Arab Jamahiriya, 376 F.3d 1123 (D.C.Cir.2004), effectively overrules the holding in Burne

dant. Bank Brussels Lambert v. Fiddler Gonzalez & Rodriguez, 171 F.3d 779, 784 (2d Cir.1999). Because these m

Law Firms *345 Andrew J. Maloney, II, Blanca I. Rodriguez, Brian J. Alexander, *546 David Beekman, David C.

is is another name for the Muslim World League. 5 Plaintiffs bring the Court’s attention to Mwani v. bin Laden, 417 F.3d 1 (D.C.Cir.2005), in which the D.C. Circuit found that Osama bin Laden and al Qaeda were subject to personal jurisdiction under Rule 4(k)(2) because they had “engaged in unabashedly malignant a