4
Shared Docs
4
Same-Page
4 / 4
Mentions
er women, were any devices or sex toys used as part of the sexual activity? A. No. Q. Were you ever involved in sexual activities in Mr. Epstein's Palm Beach house that included the use of sex toys or any kind of mechanical or other device? MR. PAGLIUCA: Objection to form and foundation. A. No. Q. Were
043 I, at *2 (S.D.N.Y. Apr. 3, 2007), aff'd, 348 F. App'x 636, 638 (2d Cir. 2009) (first alteration in original) (quoting Werner, 620 F2d at 927). Joinder is also proper for "distinct criminal acts where they originated from a common scheme." United States v. Ying Lin, No. 15 Cr. 601 (DLI), 2018 WL 511
er women, were any devices or sex toys used as part of the sexual activity? A. No. Q. Were you ever involved in sexual activities in Mr. Epstein's Palm Beach house that included the use of sex toys or any kind of mechanical or other device? MR. PAGLIUCA: Objection to form and foundation. A. No. Q. Were
80431, at *2 (S.D.N.Y. Apr. 3, 2007), aff'd, 348 F. App'x 636, 638 (2d Cir. 2009) (first alteration in original) (quoting Werner, 620 F2d at 927). Joinder is also proper for "distinct criminal acts where they originated from a common scheme." United States v. Ying Lin, No. 15 Cr. 601 (DLI), 2018 WL 511
er women, were any devices or sex toys used as part of the sexual activity? A. No. Q. Were you ever involved in sexual activities in Mr. Epstein's Palm Beach house that included the use of sex toys or any kind of mechanical or other device? MR. PAGLIUCA: Objection to form and foundation. A. No. Q. Were
80431, at *2 (S.D.N.Y. Apr. 3, 2007), aff'd, 348 F. App'x 636, 638 (2d Cir. 2009) (first alteration in original) (quoting Werner, 620 F2d at 927). Joinder is also proper for "distinct criminal acts where they originated from a common scheme." United States v. Ying Lin, No. 15 Cr. 601 (DLI), 2018 WL 511
, more important, fails to say. The Court will notice that Dcrshowitz devotes only a single sentence in his affidavit to his activities at Epstein's Palm Beach and New York mansions. See DE 282-I at 3 ("As to Mr. Epstein's homes in New York City and Palm Beach, I categorically state that I never had any sex
witz"), a nonparty to this litigation, is the victim of scurrilous allegations made in Jane Doe #3 and Jane Doe #4's Motion Pursuant to Rule 21 for Joinder in the Action (the "Joinder Motion"), filed as of record at DE 279. Having no remedy in this proceeding for the harm to his reputational interest, P
Entities connected to both Palm Beach and Joinder

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
George W. Bush
PERSONLeon Black
PERSON
United States
LOCATION
Alan Dershowitz
PERSONJack Goldberger
PERSON
Marc Rich
PERSON
New York
LOCATION
Eric Holder
PERSONJane Doe
PERSON
Donald Trump
PERSON
Palm Beach County
LOCATION
Bradley Edwards
PERSON
U.S. Virgin Islands
LOCATIONthe Southern District
LOCATION
Bill Clinton
PERSON
Kenneth Marra
PERSON
Prince Andrew
PERSON
Department of Justice
ORGANIZATION