Epstein Secrets

2008 13 08/21/2008 08/22/2008 14 Proceeding Text NOTICE OF REMOVAL Filing fee $350.00 Receipt#: 724495, filed by Sarah Kellen. Jeffrey Epstein, Haley Robson. (Attachments: # 1 exhibits. # 2 exhibits)(jgn) (Entered: 07/21/2008) MOTION for Hearing Defendants Jeffrey Epstein and Sarah Kellen's Request for O

ey to be Noticed Email: [email protected] Haley Robson Defendant Doualas Malcolm McIntosh Lead Attorn

. (ir) (Entered: 05/17/2010) 05/18/2010 22 STIPULATION of Dismissal With Prejudice by JANE DOE No. 103 (Attachments: # 1 Text of Proposed Order) (Ezell, Katherine) (Entered: 05/18/2010) 05/19/2010 23 ORDER DISMISSING CASE WITH PREJUDICE. Any pending motions are denied as moot. This case is CLOSED

Defendant Class Code: CLOSED Closed: Yes Statute: 28:1391 Jury Demand: Plaintiff Demand Amount: $0 NOS Description: Personal Injury Attorneys Katherine Warthen Ezell [COR LD NTC] Podhurst Orseck Josefsberg Et Al City National Bank Building 25 W Flagter Street Suite 800 Miami , FL 33130-1780 USA 305-358-280

Time to File Response to Defendant Epstein's Amended Motion to Dismiss Count VI and for More Definite Statement and to Strike by JANE DOE No. 103. (Ezell, Katherine) (Entered: 05/13/2010) 05/17/2010 21 ENDORSED ORDER granting nunc pro tunc 20 Motion for Extension of Time to File Response/Reply re 14

Entered on FLSD Docket 08/11/2009 Page 5 of 15 discussed Jeffrey Epstein with her in a public forum, l.e., Jane Doe 7 discussed her lawsuit with Haley Robson in public, with others. See Exhibit "A". Even so, an elementary review of the alleged questioning by the investigators as set forth in Jane Doe 7'

t. (Declaration, DE 251-2, 15). Moreover, Haley Robson's affidavit tells a different story; that is, Ja

FL 33401 561-832-7732 561-832-7137 F [email protected] Counsel for Plaintiff in Related Case No. 08-80469 Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 14 Case 9:08-cv-80119-KAM Document 262 Entered on FLSD Docke

, 48, 52, 56, 61, 65, and 69, Comp., DE I. Jane Doe 101 and 102 came to Defendant's home on a number of occasions. Jane Doe 101 brought her friend, Haley Robson (referenced by name in a number of actions) to experience this same "trauma" - it does not make sense. Jane Doe 101 had issues associated with law e

ccasions. Jane Doe 101 brought her friend, Haley Robson (referenced by name in a number of actions) to ex

FL 33401 561-832-7732 561-832-7137 F [email protected] Counsel for Plaintiff in Related Case No. 08- 80469 Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 305 358-2800 Fax: 305 358-2382 Case 9:08-cv-80119-KAM Documen

limited without violating Epstein's constitutional due process rights to defend himself. 15. Next, Jane Doe #7 claims that investigators mentioned Haley Robson, but fails to state what references were made relative to Haley Robson. Is it Jane Doe #7's contention that investigators cannot ask others whether

ussed Jeffrey Epstein with her in a public forum, i.e., Jane Doe #7 discussed her lawsuit with Haley Robson in public, with others. See Exhibit "I", Robson Affidavit. Even so, an elementary review of the alleged questioning by the investigators as set forth in Jane Doe #7' s declaration shows that same

FL 33401 561-832-7732 561-832-7137 F [email protected] Counsel for Plaintiff in Related Case No. 08-80469 Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 305 358-2800 Fax: 305 358-2382 [email protected] kezell@p

ith inaccuracies and misstatements. For example, Haley Robson has not been asked to gather any information rela

case styled, Jane Doe v. Jeffrey Epstein, Haley Robson and Sarah Kellen, Case No. 502008CA006596XXXXMB A

or Plaintiff, C.M.A. Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Str

the Plaintiffs/victims were threatened and harassed. 3. As with other Plaintiffs, Jane Does 4 and 7 were first introduced to Defendant Epstein by Bayley Robson, who was a high school friend.' 4. Robson had had contact with these Plaintiffs on several occasions in which she represented to Plaintiffs Jane D

d. 3. As with other Plaintiffs, Jane Does 4 and 7 were first introduced to Defendant Epstein by Bayley Robson, who was a high school friend.' 4. Robson had had contact with these Plaintiffs on several occasions in which she represented to Plaintiffs Jane Doe 4 and 7 that she is cooperating with Defe

[email protected] Bradley James Edwards [email protected] Isidro Manuel Garcia [email protected] Jack Patrick Hill [email protected] Katherine Warthen Ezell [email protected] Michael James Pike [email protected] Paul G. Cassell [email protected] Richard Horace Willits [email protected]

o have it recopied to have an original in evidence and a working copy with the file. Upon researching the file, it was discovered that the suspect, Haley Robson's cellular calls wer sub oenaed incorrectly. The suspect telephone number was and the original request was for . I requeste t e information through

lalliehinitially denied anything had happened, only admitting to going with Haley (later identif ed as Haley Robson) to Palm Beach to pick up money Robson was owed. identified Haley Robson as the cousin of her former boyfriend She ultimately admitted to knowing that Robson worked for a wealthy man an

s trial by jury on all issues triable as of right by a jury. Date: May I, 2009 fickla-A4 krs....-4-1,4,-,6 Robert C. Josefsb'erg, Bar No. 04085 Katherine W. Ezell, Bar No. 114771 Podhurst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, Florida 33130 (305) 358-2800 (305) 358-2382 (fax) rjosefsbergApo

on as part of any claim or defense. § 90.503(4); Roberson, 884 So.2d at 980; State v. Famiglietti, 817 So.

d Case No. 08- 80469 Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25 West Flagler Str

Florida asks that you provide the following amended notice to your client, HIOR Some of the information contained in the July 10, 2008 letter to Ms. Robson was inaccurate, so please advise her of the following changes. As you were previously advised, on June 30, 2008, Jeffrey Epstein (hereinafter refe

him or his partner, Katherine Ezell, directly at 305 358-2800. Please note that, even if you decide not to pursue a claim against Mr. Epstein, Ms. Ezell has put together a team of counselors who can assist you with any counseling or other services that you might need. You also can continue to 08-807

Florida asks that you provide the following amended notice to your client, HIOR Some of the information contained in the July 10, 2008 letter to Ms. Robson was inaccurate, so please advise her of the following changes. As you were previously advised, on June 30, 2008, Jeffrey Epstein (hereinafter refe

him or his partner, Katherine Ezell, directly at 305 358-2800. Please note that, even if you decide not to pursue a claim against Mr. Epstein, Ms. Ezell has put together a team of counselors who can assist you with any counseling or other services that you might need. You also can continue to 08-807