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14681-XXXX-MB Div.: AG Plaintiff, v. DAVE ARONBERG, as State Attorney of Palm Beach County, Florida; SHARON R. BOCK, as Clerk and Comptroller of Palm Beach County, Florida, Defendants. FIRST AMENDED COMPLAINT CA Florida Holdings, LLC, publisher of The Palm Beach Post, for its First Amended Complaint against Dav
rosecutors were able to ignore the controversial nonprosecutibn agreement because it contained some significant fine print; said former federal Judge Patil Cassell, who for years has fought to get the agreement thrown.but. It says only that ho charges could be filed.against Epstein in South Florida, he said. Ber
The complaint does not seek forfeiture of Epstein's house in Palm Beach. While heartened that Epstein howfaces serious Criminal charges in New York, Cassell said he would continue to push a West Palm Beach-based federal judge to throw out the nonprosecutibn agreement that Acosta forged with Epstein's star
eclltor~ were able to ,ignore the controversial nOhprosecutibn agreement because it contained some significant.fine print; sa1d former federal Judge Paul Casseil; who for years Jias-foughtto get the agreement thrown.out. It says. only that no charges could be fikdagainsf Epsteinin South Florida, he said, B,
sets so that the plaintiffs in these cases are unable to reach them. 11. Since his guilty plea in state court, he has been incarcerated in the Palm Beach County Detention facility. I have been advised, however, that he has currently been allowed out on a "work release" program, where he works at managing hi
id [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] Robert C. Josefsberg rjosefsbe rg@pod h u rst.com Adam D. Horowitz ahorowit
financial sophistication. See Affidavit of Paul Cassell at ,r 2 Attachment A to this Pleading. 3. Accor
ument 402 Entered on FLSD Docket 11/09/2009 Page 8 of 26 L.M., Plaintiff, V. IN THE COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502008CA028051XXXXMB AB JEFFREY EPSTEIN, Defendant. ____________ ____;/ EPSTEIN'S MOTION FOR PROTECTIVE ORDER TO PROHIBIT INA
law.com Counsel.for Plaintiff, C.MA. Bruce Reinhart, Esq. Bruce E. Reinhaii, P.A. 250 S. AustraHan Avenue Suite 1400 West Palm Beach, FL 33401 Paul G. Cassell, Esq. Pro Hae Vice' 332 South 1400 E, Room 101 Salt Lake City, UT 84112 801-585-5202 801-585-6833 Fax [email protected]. utah. ed u Co-counsel for
e Suite 1400 West Palm Beach, FL 33401 Paul G. Cassell, Esq. Pro Hae Vice' 332 South 1400 E, Room 101
e Thys (DE 114, now DE 207). On June 17, 2009, Plaintiff then filed a subsequent Motion for Protective Order Regarding Treatment Records From Palm Beach County School District, Good Samaritan Hospital, St. Mary's Hospital Dr. Gloria C. Hakkarinen, and Florida Atlantic University (DE 121, now DE 207). While
e 1650 Fort Lauderdale, FL 33301 Phone: 954-522-3456 Fax: 954-527-8663 [email protected] Counsel for Plaintiff in Related Case No. 08-80893 Paul G. Cassell, Esq: Pro Hae Vice 332 South 1400 E, Room 101 Salt Lake City, UT 84112 801-585-5202 801-585-6833 Fax [email protected] Co-counsel for Plai
Plaintiff in Related Case No. 08-80893 Paul G. Cassell, Esq: Pro Hae Vice 332 South 1400 E, Room 101
er of the attorneys. Additionally, the undersigned discussed the foregoing with counsel for Jane Doe this morning at a State Court hearing in Palm Beach County, Florida. Rule 7.1 Certification I hereby certify that counsel for the respective parties communicated by letters (e-mail) in a good faith effort
East Las Olas Boulevard Suite 1650 Fort Lauderdale, FL 33301 Phone: 954-522-3456 Fax: 954-527-8663 [email protected] Counsel for Plaintiff Paul G. Cassell, Esq. Pro Hae Vice 332 South 1400 E, Room 101 Salt Lake City, UT 84112 801-585-5202 801-585-6833 Fax [email protected] Co-counsel for Plai
[email protected] Counsel for Plaintiff Paul G. Cassell, Esq. Pro Hae Vice 332 South 1400 E, Room 101
th offices located at 2751 S. Dixie Highway, West Palm Beach, Florida. 3. Defendant Joseph Abruzzo is the duly elected Clerk and Comptroller of Palm Beach County, Florida. He is sued herein in his official capacity as his office is in possession and/or control of documents that are the subject of this action
osecutors were able to ignore the controversial nonprosecution agreement because it contained some significant fine print, said former federal Judge Paul Cassell, who for years has fought to get the agreement thrown out. It says only that no charges could be filed against Epstein in South Florida, he said.
e complaint does not seek forfeiture of Epstein's house in Palm Beach. While heartened that Epstein now faces serious criminal charges in New York, Cassell said he would continue to push a West Palm Beach-based federal judge to throw out the nonprosecution agreement that Acosta forged with Epstein's st
AND ADJUDGED that Petitioners' Motion to Unseal Non-Prosecution Agreement (DE 28) is DENIED. DONE and ORDERED in Chambers, in West Palm Beach, Pain Beach County, Florida, this lr day of February, 2008. Copies furnished to: all counsel of record 09/12/2019 KENNETH A. MARRA UNITED STATES DISTRICT JUDGE 2
quet: 19-011 SDNY_GM_00332025 EFTA_0020475 1 EFTA02729735 Case 9:08-cv-80736-KAM Document 28 Entered on FLSD Docket 09/25/2008 Page 7 of 8 1 Paul G. Cassell Attorney for Petitioners Pro Hac Vice 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: 801-585-5202 Facsimile: 801-585-6833 E Mail: casse
SDNY_GM_00332040 I 1 r EFTA 00204766 EFTA02729750 Case 9:08-cv-80736-KAM Document 30 Entered on FLSD Docket 10/16/2008 Page 5 of 6 Paul 0. Cassell Attorney for Petitioners Pro Hac Vice 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: 801-585-5202 Facsimile: 801-585-6833 E-Mail: casse
is correct. 3 THE COURT: All address -- I assume 4 all of this, to and from work and any other 5 approved activities restricts him to Palm 6 Beach County, is that correct? 7 PROBATION OFFICER: That is correct, 8 Your Honor. 9 THE COURT: II let's be clear, 10 everything, from the day he walks ou
lorida 33020 Telephone: Facsimile: E-Mail: 6 EFTA00231196 Case 9:08-cv-80736-KAM Document 28 Entered on FLSD Docket 09/25/2008 Page 7 of 8 Paul G. Cassell Attorney for Petitioners Pro Hac Vice 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: Facsimile: E-Mail: Jay C. Howell, Esquire Attorney
d on FLSD Docket 09/25/2008 Page 7 of 8 Paul G. Cassell Attorney for Petitioners Pro Hac Vice 332 S. 1
is correct. 3 THE COURT: All address -- I assume 4 all of this, to and from work and any other 5 approved activities restricts him to Palm 6 Beach County, is that correct? 7 PROBATION OFFICER: That is correct, 8 Your Honor. 9 THE COURT: So let's be clear, 10 everything, from the day he walks ou
eet - Suite 202 Hollywood, Telephone: E-Mail: EFTA00232331 Case 9:08-cv-80736-KAM Document 30 Entered on FLED Docket 10/16/2008 Page 5 of 6 Paul G. Cassell Attorney for Petitioners Pro Hac Vice 332 S. 1400 E. Salt Lake City 4 Telephone: Facsimile: E-Mail: Jay C. Howell, Esquire Attorney for Pet
ntered on FLSD Docket 09/25/2008 Page 7 of 8 G. Cassell Attorney for Petitioners Pro Hac Vice 332 S. 1
d =moncy manager, who spends most of his time on his estate Little Saint James in the territory, served 13 months of an 18-month sentence in the Palm Beach County Stockade. He was allowed to leave cach day to go to work. Hoping to persuade U.S. District Judge Kenneth Marra to throw out the lawsuit that accuses
Page: HOUSE_OVERSIGHT_024270 →the investigation and in- formed the victims of that by letter in January 2008. In their lawsuit, the victims’ at- torneys, Bradley Edwards and Paul Cassell, say the letter is evidence of their claim that prosecutors lied to the victims. They also claim that prosecutors never told Epstein’s victims about
Page: HOUSE_OVERSIGHT_024270 →Entities connected to both Beach County and Paul Cassell

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJane Doe
PERSON
Kenneth Marra
PERSONJack Goldberger
PERSON
Alan Dershowitz
PERSON
Salt Lake City
LOCATIONMaria Farmer
PERSONRobert D. Critton
PERSONMichael J. Pike
PERSONSouthern District
LOCATION
Adam D. Horowitz
PERSONLeon Black
PERSON
United States
LOCATIONRichard Horace Willits
PERSONJack Patrick Hill
PERSON
Scarlett Johansson
PERSONIsidro Manuel Garcia
PERSONKatherine W. Ezell
PERSONJack Scarola
PERSON