Epstein Secrets

nd Jane Doe) and other similar lawsuits (111 54-58); "blocking" of discovery by various witnesses (9191 59-66); Epstein's purported association with Jean Luc Brunel, who allegedly ran a modeling agency and sexually assaulted underage models who "presumably live(d) as underage prostitutes in condos owned by Epst

6); Epstein's purported association with Jean Luc Brunel, who allegedly ran a modeling agency and sexuall

59-66); Epstein's purported association with Jean Luc Brunel, who allegedly ran a modeling agency and sexuall

puted "facts" is egregious. It is well settled that mere allegations do not constitute "facts" for purposes of summary judgment. See, e.g., Metro. Dade County v. Wilkey, 414 So. 2d 269, 271 (FIa. 3d DCA. 1982) ("[P]leadings are not admissible in evidence to prove or disprove a fact in issue.") (citing Hine

o be known to your reporter but omitted from her articles; 2. Mr. Epstein did not, as your articles claim, see eg 7-22-10 bullet point 4, give Mr Brunel $1,000,000 to start his modeling agency; molesting three 12 year olds as alleged by Ms. in her articles, sec cg q-2-1-1-0-ner-kas-this-allegatien-b

icles claim, see eg 7-22-10 bullet point 4, give Mr Brunel $1,000,000 to start his modeling agency; molesti

2, see eg 7-22-10 article, bulletpoint 5. Her name is . She plead guilty to grand theft in the first degree in the 11th Judicial Circuit Court for Dade County, Florida, on December 3, 2007 and was sentenced to 1 year of community control and 19 years of probation as a result of her embezzling $148,000 fr

s available to your reporter but omitted from her articles; 2. Mr. Epstein did not, as your articles claim, see eg 7-22-10 bullet point 4, give Mr Brunel $1,000,000 to start his modeling agency; 3. Despite both a state and federal investigation, Mr. Epstein has never been charged — and never particip

icles claim, see eg 7-22-10 bullet point 4, give Mr Brunel $1,000,000 to start his modeling agency; 3. Desp

, see eg 7-22-10 article, bulletpoint 5. Her name is . She plead guilty to grand theft in the first degree in the 11th Judicial Circuit Court for Dade County, Florida, on December 3, 2007 and was sentenced to 1 year of community control and 19 years of probation as a result of her embezzling $148,000 fr

s available to your reporter but omitted from her articles; 2. Mr. Epstein did not, as your articles claim, see eg 7-22-10 bullet point 4, give Mr Brunel $1,000,000 to start his modeling agency; 3. Despite both a state and federal investigation, Mr. Epstein has never been charged — and never particip

icles claim, see eg 7-22-10 bullet point 4, give Mr Brunel $1,000,000 to start his modeling agency; 3. Desp

2, see eg 7-22-10 article, bulletpoint 5. Her name is . She plead guilty to grand theft in the first degree in the 11th Judicial Circuit Court for Dade County, Florida, on December 3, 2007 and was sentenced to 1 year of community control and 19 years of probation as a result of her embezzling $148,000 fr

to be known to your reporter but omitted from her articles; 2. Mr. Epstein did not, as your articles claim, see eg 7-22-10 bullet point 4, give Mr Brunel $1,000,000 to start his modelin a enc 3. who is uoted b , 4. Mr. Epstein never "committed" nor even considered much less agreed) to a 10 year fe

icles claim, see eg 7-22-10 bullet point 4, give Mr Brunel $1,000,000 to start his modelin a enc 3. who is

2, see eg 7-22-10 article, bulletpoint 5. Her name is . She plead guilty to grand theft in the first degree in the 11th Judicial Circuit Court for Dade County, Florida, on December 3, 2007 and was sentenced to 1 year of community control and 19 years of probation as a result of her embezzlin $148 000 from

losing her criminal conviction and bias in the articles; 2. Mr. Epstein did not, as your articles claim, see e.g. 7-22-10 bullet point 4, give Mr. Brunel $1,000,000 to start his modeling agency; 3. Ms. =, who is quoted by Ms. in her 7-21-10 article as saying that Mr. Epstein told her the "younger

ELLIS LLP Ms. Tina September 23, 2010 Page 2 name is She plead guilty to grand theft in the first degree in the 11th Judicial Circuit Court for Dade County, Florida, on December 3, 2007 and was sentenced to 1 year of community control and 19 years of probation as a result of her embezzling $148,000 from