Epstein Secrets

"an express confidentiality provision." In opposing the Motion to Unseal the NPA that was filed by Jane Doe, you stated that you had informed Judge Marra of the confidentiality provision during an earlier telephonic status conference occurring on August 14, 2008 which "the United States was obligated

E DOE, et al., 6 Plaintiffs, vs. JUNE 12, 2009 7 8 JEFFREY EPSTEIN, 9 Defendant. 10 11 TRANSCRIPT OF MOTION HEARING BEFORE THE HONORABLE KENNETH A. MARRA, 12 UNITED STATES DISTRICT JUDGE APPEARANCES: 13 14 FOR THE PLAINTIFFS: ADAM D. HOROWITZ, ESQ. Mermelstein & Horowitz 15 18205 Biscayne Bou

ed by Jane Doe, you stated that you had informed Judge Marra of the confidentiality provision during an earlie

oregoing, the plaintiff cannot blame someone else (= ) for the consequences of her own criminal conduct. Cf. Feld & Sons, Inc. v. Pechner, Dorfman, Wolfe, Rounick and Cabot, 458 A.2d 545, 552 (Pa. Super. Ct, 1983) (holding that law-firm clients could not recover damages flowing from their own crimina

7NG SERVICE, INC. . - 7 S11,17i-i995 1431Sel'OnlileicliRep—mtinie.ac EFTA00617921 8 9 10 11 12 13 14 15 16 case is pending before Judge Marra. And one of the threshold issues in that case was whether victims rights attach prior to the filing of a federal indictment. And Judge Marra ruled

0 11 12 13 14 15 16 case is pending before Judge Marra. And one of the threshold issues in that case wa

stion. This case is still on appeal. And I know that your Honor recognitions the significance of the appellate issue that is presented because the Wolfe decision upon which your Honor's summary judgment was based is in fact the only decision in the country that 17 18 19 20 21 22 23 24 25 a

Mr. Epstein to post a multi-million-dollar bond. Judge Marra threw that out, stating that there was no basis

was shown to the investors, and there is testimony to that fact. Then Mr. Edwards filed a motion. It was a motion asking that the court -- Judge Marra -- federal district court -- to enter a bond -- enter an order requiring Mr. Epstein to post a multi-million-dollar bond. Judge Marra threw that o

with the transcript can be understood for not remembering. But Epstein moved for summary judgment on three grounds: litigation privilege that the Wolfe case compelled with, and also that we were unable to prove two elements of the malicious prosecution claim. One of them was lack of probable caus

s in LM v. Jeffrey Epstein, 502008CA028051XXXXMB AB; EW v. Jeffrey Epstein, 502008CA028058XXXXMB AB; and Jane Doe v. Jeffrey Epstein, 08-80893- CIV Marra/Johnson; deposition of Jeffrey Epstein, p. 23, line 4; p. 38, line 22. R. 809-10, citing amended complaint in Razorback Funding, LLC, et al. v. Scot

use of process claims filed against Epstein by the appellant, Bradley J. Edwards. The trial judge relied in part upon the then binding precedent of Wolfe v. Foreman, 128 So. 3d 67 (Fla. 3d DCA 2013) (holding that the litigation privilege applies to causes of action for malicious prosecution and abuse

B; and Jane Doe v. Jeffrey Epstein, 08-80893-CIV Marra/Johnson. Rothstein returned to South Florida in

s written order granting summary judgment in favor of Epstein upon application of the litigation privilege based upon the then binding precedent of Wolfe v. Foreman, 128 So. 3d 67 (Fla. 3d DCA 2013). Final judgment was thereafter entered in favor of Epstein. Edwards appealed the judgment as it pertai

COURT SOUTHERN DISTRICT OF FLORIDA 08-80804-Civ-MARRA/JOHNSON CASE NO.: JANE DOE, a/k/a JANE DOE #1,

n the foregoing, the plaintiff cannot blame someone els for the consequences of her own criminal conduct. CI Fe/d & Sons, Inc. v. Pechner, Dorfman, Wolfe, Rounick and Cabot, 458 A.2d 545, 552 (Pa. Super. Ct. 1983) (holding that law-firm clients could not recover damages flowing from their own crimina

B; and Jane Doe v. Jeffrey Epstein, 08-80893- CIV Marra/Johnson. Rothstein returned to South Florida in

lege. 11 EFTA00583962 summary judgment in favor of Epstein upon application of the litigation privilege based upon the then binding precedent of Wolfe v. Foreman, 128 So. 3d 67 (Fla. 3d DCA 2013). Final judgment was thereafter entered in favor of Epstein. Edwards appealed the judgment as it pertai

COURT SOUTHERN DISTRICT OF FLORIDA 08-80804-Civ-MARRA/JOHNSON CASE NO.: JANE DOE, a/k/a JANE DOE #1,

e foregoing, the plaintiff cannot blame someone else (= for the consequences of her own criminal conduct. CI Feld & Sons, Inc. v. Pechner, Dorfman, Wolfe, Rounick and Cabot, 458 A.2d 545, 552 (Pa. Super. Ct. 1983) (holding that law-firm clients could not recover damages flowing from their own crimina

ctions taken by him occurred during the litigation of his abuse of process claim against Edwards. For support, he relies primarily on the decision of Wolfe v. Foreman, 2013 WL 3724763 (Fla. 3d DCA July 17, 2013), wherein the Third District found that the litigation privilege barred both an abuse of proc

ous prosecution is not barred by the litigation privilege — an implicit recognition acknowledged by the Third District itself — Epstein’s reliance on Wolfe is misplaced. Wo/fe is also factually distinguishable from Edwards’ claims against Epstein. Wolfe involved a malicious prosecution action against att

lved and depended upon his plane travel. Although Judge Marra dismissed the RICO claim at some point in the fed

litigation. The RICO claim alleged that Epstein ran an expansive criminal entirpitge that involved and depended upon his plane travel. Although Judge Marra dismissed the RICO claim at some point in the federal litigation, the legal team representing ever clients intended to pursue an appeal of that dismi