Epstein Secrets

ANDERSON,ALBIN GRUBMAN,CLAY HICKS,CAROLYN R KEMBLE,WM T JR BOBST,ELMER H

QUINN,OLIVER H LOCKER,NANCY OWEN,JANE D CUSHMAN & WAKEFIELD KELLER,MICHAEL

(p. 8 - FBI). Yet at her September, 2009 deposition now represented by EDWARDS and RRA,■. told a very different story: Q: My question was what did Carolyn tell you to tell Mr. Epstein about your age? A: She said it didn't matter. Q: That's your recollection about what she said? A: Yes, she said — I

.D. Tenn. 2008). 5. Annexed hereto as Exhibit C is the Supplementary Affidavit of George Rush in this proceeding, sworn to on April 30, 2010. 6. Jane Doe's brief in opposition to Jeffrey Epstein's motion for summary judgment dismissing the federal claims in this action ("Si °pp.') may be found on PACER,

17 18 19 20 21 22 23 24 25 Q Okay. So let's talk about Jane Doe Number Two. Who is she? A Jane Doe Number Two is a white feinale named Carolyn. She was born in January of 1987. She lived in Palm Beach County, Florida, at the time she had contact with Mr. Epstein. Q And how -- has she bee

9 20 21 22 23 24 25 attended Palm Beach Central High School. I should state that all of these high schools are located in Palm Beach County. Jane Doe Number Seven attended William T. Dwyer High School in Palm Beach County. Jane Doe Numbers Nine, 14, 15, 16, 17, 18, and 19 attended Royal Palm Bea

8 - FBI). Yet at her September, 2009 deposition now represented by EDWARDS and RRA, L.M. told a very different story: Q: My question was what did Carolyn tell you to tell Mr. Epstein about your age? A: She said it didn't matter. Q: That's your recollection about what she said? A: Yes, she said — I

OTHSTEIN, EDWARDS (who either know or should have known) and, at times, L.M. in her Civil Action against EPSTEIN: a) Included claims for damages in Jane Doe's federal action in excess of $50,000,000.00 rather than simply alleging the jurisdictional limits. b) Organized a Jane Doe TV media interview witho

8 - FBI). Yet at her September, 2009 deposition now represented by EDWARDS and RRA, L.M. told a very different story: Q: My question was what did Carolyn tell you to tell Mr. Epstein about your age? A: She said it didn't matter. Q: That's your recollection about what she said? A: Yes, she said — I

OTHSTEIN, EDWARDS (who either know or should have known) and, at times, L.M. in her Civil Action against EPSTEIN: a) Included claims for damages in Jane Doe's federal action in excess of $50,000,000.00 rather than simply alleging the jurisdictional limits. b) Organized a Jane Doe TV media interview witho

t reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05440-05441 04/01/2009 Bradley Edwards Carolyn (Legal Asst. to Jay Howell, Co- Counsel) CW Personal information Work product; attorney/client privilege; irrelevant and not reasonably

to lead to the discovery of the admissible evidence; protected by privacy rights 05541 07/31/2009 Carolyn Edwards Bradley Edwards All depos in Jane doe's case Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; pr

t reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05440-05441 04/01/2009 Bradley Edwards Carolyn (Legal Asst. to Jay Howell, Co- Counsel) CW Personal information Work product; attorney/client privilege; irrelevant and not reasonably

to lead to the discovery of the admissible evidence; protected by privacy rights 05541 07/31/2O09 Carolyn Edwards Bradley Edwards All depos in jane doe's case Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; pr

ified that they would counsel their friends to lie about their ages as well. Ms. Miller stated the following: "I would tell my girlfriends just like Carolyn approached me. Make sure you tell hint you're. 18. Well, these girls that I brought, i know that they were 18 or 19 or 20. And the girls that !didn

.S.C. § 1591(c)(1): Count Date(s) Minor Involved Defendant(s) 2 2001 - 2004 Jane Doe #2 JEFFREY EPSTEIN 3 January 2004 through July 2004 Jane Doe F JEFFREY EPSTEIN SARAH KELLEN 4 July 2004 through December 29, Jane Doe #9 JEFFREY EPSTEIN SARAH KELLEN 38 EFTA00225746 New Jersey to Palm