8
Shared Docs
8
Same-Page
13 / 8
Mentions
tl. Stare, 407 So. 2d 1007, 1010 (Fla. 5th DCA 1981). And "motive is always relevant in a criminal case, even if it is not an element of the crime." United Stalest. Hill, 643 F.3d 807, 843 (11th Cir. 2011) (internal quotation omitted). When speaking not to the Court but rather to the media, Dershowitz has clearl
agent's ensuing report, Rodriguez "discussed in detail the information contained within the book, and identified important information to the UCE." See United States'. Rodriguez, No. 9:10-cr- 80015-KAM, DE 3 at 5 (S.D. Fla. Dec. 9, 2009). While all of the details of the verbal information explained by Rodriguez to
Senate Judiciary Committee held a hearing regarding child endangerment via the Internet. See H.R. Conf. Rep. No. 104-458, at 193 (1996), quoted in United States ' Searcy, 418 F.3d 1193, 1197 (11th Cir. 2005); see also K. Seto, "Note: How Should Legislation Deal with Children and the Victims and Perpetrators
Whoever, using the mail or any facility or means of interstate or foreign commerce, or within the special maritime and territorial jurisdiction of the United States knowingly persuades, induces, entices or coerces any individual who has not attained the age of 18 years, to engage in prostitution or any sexual
E-mail: [email protected] E-mail: ann.marie.c.villafana@usdojdzov Attorneys for the Government Thomas Scott [email protected] COLE, SCOTT & KISSANE, P.A. Dadeland Centre H 9150 South Dadeland Boulevard, Suite 1400 Miami, Florida 33156 Telephone: (305) 350-5300 Facsimile: (305) 373-2294 -and
Reach, FL 33401 (56!) 82047/! rocssmile: (561)820-8777 September 3, 2008 NOTIFICATION OF IDENTIFIED VICTIM NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED STATES CODE, SECTION 3509(d) AND FLORIDA LAW, THE ATTACHED DOCUMENT IS TO BE TREATED AS CONFIDENTIAL AND SHALL NOT BE DISCLOSED EXCEPT IN CONNECTION WIT
here he could get passports or other travel documents for young girls. He would then bring these young girls (girls ranging in age from 12 to 24) to the United States for sexual purposes and farm them out to his friends, including Epstein. 49. Brunel would offer the girls "modeling" jobs. A lot of the girls came
agent's ensuing report. Rodriguez "discussed in detail the information contained within the book. and identified important information to the UCE." See United States'. Rodriguez, No. 9:1 0-cr- 800I5-KAM. DE 3 at 5 (S.D. Fla. Dec. 9, 2009). While all of the details of the verbal information explained by Rodriguez t
Case 9:08-cv-80736-KAM Document 282 Entered on FLSD Docket 01/05/2015 Page 8 of 10 Respectfully submitted, Thomas Scott Fla. Bar No. 149100 COLE, SCOTT & KISSANE, P.A. -and- /s/ Kendall Coffey Kendall Coffey, Fla. Bar No. 259681 Benjamin H. Brodsky, Fla. Bar No. 73748 Counsel for Prof Alan Al. Dershowiiz
ards first falsely accused Dershowitz of sexually abusing (' as a minor in a publicly filed pleading (the "Joinder Motion") in Jane Doe #1, et at v. United States, Case 1 EFTA00613391 No. 08-cv-80736 (S.D. Fla.) (the "Federal Action"). The attorneys then alerted the press to the false and defamatory pleadi
etion for the Court to deny Dershowitz's request. 15 EFTA00613405 Respectfully submitted, s/ Thomas E. Scott Steven R. Safra, FBN 057028 COLE, SCOTT & KISSANE, P.A. Richard A. Simpson (pro hac vice) Ma E. Bo 'a ro hac vice) Ashle E. Filer ro hac vice) Nicole Audet Richardson (pro hac vice) Counsel for
998) ("the courts have uniformly concluded that habeas corpus proceedings — and their cousins, section 2255 proceedings — are not 'civil actions"); United States'. Soueiti, 154 F.3d 1018, 1019 (9th Cir.) (finding deportation proceeding conducted as part of a criminal sentencing not a "civil action" because "o
on February 6, 2015, on the following using the Court's CM/ECF system: Attorneys for the Government Thomas Scott [email protected] COLE, SCOTT & KISSANE, P.A. Dadeland Centre II Kendall Coffey Gabriel Groisman Groisman Benjamin H. Brodsky COFFEY BURLINGTON, P.L. Attorneys for Alan Dershowitz /
did not apply to Jane Doe #1 and Jane Doe #2 because no federal charges had ever been filed against Jeffrey Epstein. The Court has firmly rejected the United States' position. In a detailed ruling, the Court concluded that the CVRA extended rights to Jane Doe #1 and Jane Doe #2 even though federal charges were n
500 S. Australian Ave., Suite 400 West Palm Beach, FL 33401 (561) 820-8711 Fax: 561 820-8777 Attorneys for the Government Thomas Scott ar COLE. SCOTT & KISSANE, P.A. -and- Kendall Coffey Gabriel Groisman Benjamin H. Brodsk n om COFFEY BURLINGTON. P.L. Attorneys for Alan Dershowit: /s/ Bradley J. Edward
t page? Q. Page 19. You were asked: "I'm wondering, have you spoken to Jeffrey Epstein about this since these allegations came out in this suit in the United States? Have conversations happened there?" Oo On KH MP WN BP PRR PP Pe RH to OW HU PWN REO communication with Jeffrey Epstein, correct? A. I disclosed
EY, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33402-3626 BY: JACK SCAROLA, ESQ. [email protected] On behalf of Defendant: COLE, SCOTT & KISSANE, P.A. Dadeland Centre H - Suite 1400 9150 South Dadeland Boulevard Miami, Florida 33156 BY: THOMAS EMERSON SCOTT, JR., ESQ. [email protected]
e names of prominent people, including Prince Andrew. That the allegations were improper and irresponsible is not merely an assertion by Dershowitz; United States District Judge Marra has expressly held that the "lurid" allegations were "unnecessary," "immaterial," and "impertinent" to the federal lawsuit. See
ated: May 2015 Respectfully Submitted, s/ Thomas E. Scott Thomas E. Scott Florida Bar No. 149100 Steven R. Safra Florida Bar No. 057028 COLE, SCOTT & KISSANE, Dadeland Centre II, 14th Floor 9150 South Dadeland Boulevard Miami, Florida 33156 Phone: (305) 350-5300 Fax: (305) 373-2294 Richard A. Simpson
e names of prominent people, including Prince Andrew. That the allegations were improper and irresponsible is not merely an assertion by Dershowitz; United States District Judge Marra has expressly held that the "lurid" allegations were "unnecessary," "immaterial," and "impertinent" to the federal lawsuit. See
ated: May 2015 Respectfully Submitted, s/ Thomas E. Scott Thomas E. Scott Florida Bar No. 149100 Steven R. Safra Florida Bar No. 057028 COLE, SCOTT & KISSANE, Dadeland Centre II, 14th Floor 9150 South Dadeland Boulevard Miami, Florida 33156 Phone: (305) 350-5300 Fax: (305) 373-2294 Richard A. Simpson
Entities connected to both United States and SCOTT & KISSANE

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Ghislaine Maxwell
PERSON
Department of Justice
ORGANIZATIONthe Southern District
LOCATIONLeon Black
PERSON
Prince Andrew
PERSON
Alan Dershowitz
PERSON
John F. Kennedy
PERSON
Alexander Acosta
PERSONJane Doe
PERSONFBI
ORGANIZATION
Kenneth Marra
PERSON
Bradley Edwards
PERSON
Prince Charles
PERSON
New York
LOCATION
Marc Rich
PERSON
Donald Trump
PERSON
Bill Clinton
PERSON
Scarlett Johansson
PERSON