Epstein Secrets

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

SD Docket 07/23/2009 Page 16 of 26 CASE NO: 08-CV-80119-MARRA/JOHNSON 14 198 at 18] (citing In re Leneve, 341 B.R. 53, 56 (Bkrtcy S.D. Fla. 2006).3 However, Epstein does not grapple with the fact that Jane Doe has properly proven each of these four poi

eavily on the affidavit Jane Doe's own counsel. See Affidavit of Paul Cassell, Esq., attached as Exhibit A to the Injunction Motion (DE #165). Mr. Cassell's affidavit is riddled with hearsay, speculation, conjecture and unsupported assumptions and does not contain one material "fact" based on his pers

est Palm Beach, FL 33409 561-686-6300 Fax: 561-383-9424 [email protected] [email protected] Counsel for Plaintiff, C.M.A. Bruce Reinhart, Esq. Paul G. Cassell, Esq. ProHac Vice 332 South 1400 E, Room 101 Salt Lake City, UT 84112 801-585-5202 801-585-6833 Fax [email protected] Co-counsel for Plain

ccurred within certain statutory time periods; and (4) the debtor made the transfer with the intent to hinder, delay or defraud creditors. See In re Leneve, 341 B.R. 53, 56 (S.D. Fla. 2006). Courts typically resort to the "badges of fraud," to determine fraudulent intent. Id. at 61. The Eleventh Circui

sel for Plaintiff in Related Case No. 08-80893 ounse or amttj s In related Cases Nos. 08-80069, 08-80119, 08-80232, 08-80380, 08-80381, 08-80993, Paul G. Cassell, Esq. 08-80994 Richard Horace Willits, Esq. Richard H. Willits, P.A. Counsel for Plaintiff in Related Case No. 08-80811 Jack Scarola, Esq. Jac

eavily on the affidavit Jane Doe's own counsel. ate Affidavit of Paul Cassell, Esq., attached as Exhibit A to the Injunction Motion (DE #165). Mr. Cassell's affidavit is riddled with hearsay, speculation, conjecture and unsupported assumptions and does not contain one material "fact" based on his pers

ccurred within certain statutory time periods; and (4) the debtor made the transfer with the intent to hinder, delay or defraud creditors. See In re Leneve, 341 B.R. 53, 56 (S.D. Fla. 2006). Courts typically resort to the "badges of fraud," to determine fraudulent intent. Id. at 61. The Eleventh Circui