Epstein Secrets

une, 2009. Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards ROTHSTEIN ROSENFELDT ADLER Las Olas City Centre AC14 I OCfl And Paul G. Cassell Pro Hac Vice Ll 19 EFTA00234889 Case 9:08-cv-80119-KAM Document 165 Entered on FLSD Docket 06/19/2009 Page 20 of 41 CASE NO: 08-CV-80119-MA

red on FLSD Docket 06/19/2009 Page 28 of 41 I swear the foregoing to be truthful under the penalty of perjury. FURTHER THE AFFIANT SAYETH NAUGHT. aul G. Cassell EFTA00234898 Case 9:08-cv-80119-KAM Document 165 Entered on FLSD Docket 06/19/2009 Page 29 of 41 UNITED STATES DISTRICT COURT SOUTHERN DISTRI

financial sophistication. See Affidavit of Paul Cassell at ¶ 2 Attachment A to this Pleading. 3. Accord

7 Case 9:08-cv-80119-KAM Document 165 Entered on FLSD Docket 06/19/2009 Page 18 of 41 CASE NO: 08-CV-80119-MARRA/JOHNSON be done." Sterling v. Brevard County, 776 So.2d 281, 284 (Fla. Ct. Apps. 2000). The Court should therefore also exercise its equitable powers to impose the same remedies that Jane Doe

O: 08-CV-80119-MARRA/JOHNSON 6 Cassell, Esq., that Jane Doe initially filed. To the extent that any of the information provided in the Cassell affidavit was hearsay, that problem has now disappeared in view of the Declaration signed by Epstein that Jane Doe is providing to the Court. The

[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 [email protected] Adam D. Horowitz ahorow

e Doe’s argument that “equity will do what ought to be done.” Jane Doe’s Motion to Restrain Fraudulent Transfer of Assets at 17 (citing Sterling v. Brevard County, 776 So.2d 281, 284 (Fla. Ct. Apps. 2000)). The only question then is “what ought to be done?” Case 9:08-cv-80119-KAM Document 217 Entered on

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

Case 9:08-cv-80119-KAM Document 165 Entered on FLSD Docket 06/19/2009 Page 18 of 41 CASE NO: 08-CV-80119-MARRA/JOHNSON be done." Sterling v. Brevard County, 776 So.2d 281, 284 (Fla. Ct. Apps. 2000). The Court should therefore also exercise its equitable powers to impose the same remedies that Jane Doe

nell, 4.66M) had updates on Biden's Cabinet selection process. Biden Reportedly "Leaning Toward" Vilsack For Second Stint At USDA. Politico (12/7, Cassella, Crampton, Pager, 4.29M) reports Biden is "leaning toward picking former Agriculture Secretary Tom Vilsack to return as head of the USDA...turning t

tive, said that in addition to the FBI, the Florida Department of Law Enforcement, the Volusia County Sheriff's Office, Daytona Beach police and the Brevard County Sheriff's Office are assisting with the investigation into the disappearance of Robert Heikka. Heikka, 70, a teacher at Creekside Middle School, fa

nell, 4.66M) had updates on Biden's Cabinet selection process. Biden Reportedly "Leaning Toward" Vilsack For Second Stint At USDA. Politico (12/7, Cassella, Crampton, Pager, 4.29M) reports Biden is "leaning toward picking former Agriculture Secretary Tom Vilsack to return as head of the USDA...turning t

tive, said that in addition to the FBI, the Florida Department of Law Enforcement, the Volusia County Sheriff's Office, Daytona Beach police and the Brevard County Sheriff's Office are assisting with the investigation into the disappearance of Robert Heikka. Heikka, 70, a teacher at Creekside Middle School, fa