Epstein Secrets

, Suite 900 West Palm Beach, FL 33401 561-832-7732 561-832-7137 F isid [email protected] Counsel for Plaintiff in Related Case No. Searcy Denney Scarola Shipley, P.A. Barnhart & 08-80469 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 561-686-6300 Fax: 561-383-9424 jsx@searc

T. S.D. OF FLA. - W.P.B. DEFENDANT EPSTEIN'S EMERGENCY MOTION FOR ORDER FOR THE PRESERVATION OF EVIDENCE, & INCORPORATED MEMORANDUM OF LAW (AS TO JANE DOE v. EPSTEIN, Case No. 08-CIV-80893 Marra/Johnson) Defendant, Jeffrey Epstein, (hereinafter "Epstein"), by and through his undersigned attorneys, pur

o work at a law firm for Searcy & Denney — Q. Okay. A. -- Scarola, Barnhart & Shipley. Q. I'm sorry. I missed that last part. A. Oh, it's Searcy, Denney, Scarola, Barnhart & Shipley. That's the law firm. It's all the names. Q. Gotcha. I'm not familiar with that firm. Is that down here? A. It's in

. Do not fill it in. Do not mark 6 outside the circles. Pick the two most troubling 7 concerns for you. 8 A. Okay. Q. Your marital status, Ms. Jane Doe No. 5, what do you consider your race ethnicity, background? A. Me? Q. Right. A. I'm white. Q. Okay. A. limitation. Q. Italian. Okay. (The t

0 a copy of the foregoing has been served via U.S. Mail and email transmittal to all those on the attached service list. By: Jack Scarola Searcy, Denney, Scarola, Barnhart & Shipley 2139 Palm Beach Lakes Blvd West Palm Beach, FL 33409 (561) 68 561 fax OL Flori No.: 169440 37 EFTA00726035 S

buse. Epstein also made perform oral sex on him and was to perform sex acts on (Epstein's live- in sex slave) in Epstein's presence. See Plaintiff Jane Doe's Notice Regarding Evidence of Similar Acts of Sexual Assault, filed in Jane Doe v. Epstein, No. 08-cv-80893 (S.D. Fla. 2010), as DE 197, (hereinafte

3:22,25 134:6 defense's 97:6 defined 167:22 defraud 148:13 degree 6:24,24 7:1 33:11 84:5 92:18 delegated 127:17 Delray 12:14,15 demise 23:10 Denney 2:15 35:22 36:20 deny 147:4 depending 18:4 Depends 94:8 105:24 DEPONENT 170:5 depose 38:20 deposition 1:13 3:3 3:17 4:4,8,24 5:11 5:13,22 6

riod and say, You 25 know, I should have realized there was something that were being prosecuted on behalf of throe young 1 woman: M., B.N. and Jane Doe. And w➢ will refer to them when I talk to you about them in that ➢ame way, 4 referring to sham by those initial➢ and that 5 pseudonym. 4 Desc

0 a copy of the foregoing has been served via U.S. Mail and email transmittal to all those on the attached service list. By: Jack Scarola Searcy, Denney, Scarola, Barnhart & Shipley 2139 Palm Beach Lakes Blvd West Palm Beach, FL 33409 (561) 68 (561 (fax) OL Flon No.: 169440 37 EFTA00081218

made E.W. perform oral sex on him and was to perform sex acts on Nadia Marcinkova (Epstein's live- in sex slave) in Epstein's presence. See Plaintiff Jane Doe's Notice Regarding Evidence of Similar Acts of Sexual Assault, filed in Jane Doe v. Epstein, No. 08-cv-80893 (S.D. Fla. 2010), as DE 197, (hereinafte

i,2010 a copy of the foregoing has been served via U.S. Mail and email transmittal to all those on the attached service list. Jack Scarola Searcy, Denney, Scarola, Bamhart & Shipley By: 37 OL No.: 169440 EFTA00188902 Case 9:08-cv-80736-KAM ,current 291-15 Entered on FLSD L_ Ket 01/21/2015 Page

es by another underage victim. Epstein engaged in one or more of the following acts with each of the then-minor girls at his mansion: See Plaintiff Jane Doe's Notice Regarding Evidence of Similar Acts of Sexual Assault, filed in Jane Doe I. Epstein, No. 08-cv-80893 (S.D. Fla. 2010), as DE 197, (hereinafte

rds filed a civil suit against Jeffrey Epstein to recover damages for his sexual assault of L.M. See Complaint, L.M. v. Epstein, (Exhibit “V”’). 47. Jane Doe’s federal complaint indicated that she sought damages of more than $50,000,000. Listing the amount of damages sought in the complaint was in accord wit

on November U , 2010 a copy of the foregoing has been served via Fax and U.S. Mail to all those on the attached service list. Jack Scarola Searcy, Denney, Scarola, Barnhart & Shipley 2139 Palm Beach Lakes Blvd West Palm Beach, FL 33409 By: 42 HOUSE_OVERSIGHT_010607 --- PAGE BREAK --- SERVICE LIST

ards filed a civil sot against Jeffrey Epstein to recover damages for his sexual assault of L.M. See Complaint, LM. v. Epstein, (Exhibit “V”). 3 47. Jane Doe’s federal complaint indicated that she sought damages of more than $50,000,000. Listing the amount of damages sought in the complaint was in accord wit

on November U , 2010 a copy of the foregoing has been served via Fax and U.S. Mail to all those on the attached service list. Jack Scarola Searcy, Denney, Scarola, Barnhart & Shipley 2139 Palm Beach Lakes Blvd West Palm Beach, FL 33409 By: 42 HOUSE_OVERSIGHT_013360 --- PAGE BREAK --- SERVICE LIST