Epstein Secrets

n, Palm Beach County Circuit Court Case No: 502008CA028051AXXXMB, counsel for Plaintiff, Jane Doe, intends to utilize this deposition in Jane Doe's Federal Court action. Further, counsel for Plaintiffs, Jane Does 2-8 have filed a Cross-Notice of Taking Depositions as to NADIA MARCINKOV A. Case 9:08-cv-80

n February 3, 2010, counsel for Plaintiff, Jane Doe, filed a Notice of Taking the Deposition of Third-Party Witness, NADIA MARCINKOV A, in a related State Court action filed against Mr. Epstein. While the Notice is filed in L.M. v. Jeffrey Epstein, Palm Beach County Circuit Court Case No: 502008CA028051AXXX

due diligence in a class action on behalf of a group of plaintiff investors seeking damages from the service providers to the fund. (South Florida, Federal Court, trial set for June, 2011) Providing expert testimony on behalf of a hedge fund being sued by a former employee for wrongful termination. Plaintiff

lf of a hedge fund being sued by a former employee for wrongful termination. Plaintiff alsoalleges improper accounting treatment of incentive fees. (State Court, Denver, CO, hearing set for January 2011; no trial date set) Past matters Provided litigation support and expert testimony in a divorce proceedin

art governmental prornses by discouraging citizens from giving the government information), I represented four victims of Epstein's sex offenses in Federal Court — Jane Doe No. 1, Jane Doe No. 2, and a victim I will refer to as "S.R." and "M.J.", and other victims of Jeffrey Epstein's abuse as well. If furth

t several of the young girls that were victimized and abused by Jeffrey Epstein. While we are aware of his recent guilty plea and conviction in his State Court case, the sentence imposed in that case is grossly inadequate for a sexual predator of this magnitude. The information and evidence that has come to

h apparently he has, which is that the 21 $50,000 or $150,000 floor under 2255 also would be a cap. That 22 if they were to proceed to file suit in Federal Court to get 23 fair damages under 2255, Mr. Epstein would admit liability, but 24 he, of course, could fight the damages portion, which means 25 that,

arties to this litigation Box #2 P-008299 Thru P-008363 File folder entitled "FINAL AGREEMENTS" containing subfolder entitled "Agrmts Filed in State Court" (P-008300-P-008327 [not being withheld as privileged — have been produced to opposing counsel]); signed Non-Prosecution Agreement, Addendum, and

/2009 Page 5 of 12 agreed that the subpoenas filed with the clerk would be redacted. Several attorneys agreed to this procedure in those cases. In Federal Court, subpoenas are not filed with the clerk. Thus, In this matter, the undersigned offered to serve the third-party subpoenas with plaintiff's full nam

), the District Court dismissed a purely state law claim for equitable subrogation because there had been an earlier claim for declaratory relief in State Court; the Eleventh Circuit reversed, concluding ...that no exceptional circumstances require dismissal of this case in deference to the pending state c