Epstein Secrets

hat bears on, or that reasonably could lead to another matter that could bear on any issue that is or may be in the case." Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340, 352 (1978). Discovery is not limited to the issues raised by the pleadings because 'discovery itself is designed to help define and

ida, has MI intent to stay in Palm Beach County after his incarceration and is otherwise suijuris. 4. Defendant, Mil is a citizen and resident of the State of New York and otherwise sui juris. EFTA00723266 5. This is an action for damages in excess of Fifteen Thousand Dollars (815,000), exclusive of interest a

ly 9, 2012 Stephen G. Rinehart, Esq. Troutman & Sanders, LLP The Chyrsler Building 405 Lexington Avenue

17 18 19 20 21 22 23 24 25 26 27 28 JEFFREY EPSTEIN ("Epstein") is, and at all times relevant hereto was, a citizen of and residing in the State of New York. 3. Epstein has engaged in the necessary minimal contacts with the State of California for this Court to entertain personal jurisdiction, includin

consistent with this Agreement or the Related Documents. LENDER'S EXPENDfTURES. If any action a proceeding is OYMOVICOO that would materially effect Landers interest in the Collateral or if Grantor fors to comply with any provision of this Agreement or any Relined Documents, including but not limited to

s all of the Assignor's rights, interests, duties, obligations and liabilities thereunder. 3. Governing Law. This Assignment is being delivered in the State of New York. This Assignment shall in all respects be governed by, and construed in accordance with, the internal substantive laws of the State of New York, in

Austration Ave. Suite 400 West Palm Beach, FL 3340] (561) §20-871] Angust 31, 2007 DELIVERY BY FACSIMILE Ms. In care of Bruce Lyons, Esq. Lyons and Sanders 600 Northeast 3rd Avenue Fort Landerdale,; FL 33304 Re: Grand Jury investigation—Confidential Dea i This letter is an invitation for you to testif

buse upon a HERMAN & MERMELSTEIN, P. A. www.hermaniaw.com HOUSE_OVERSIGHT_012637 minor, 5. Defendant Jeffrey Epstein is a citizen and resident of the State of New York. 6. This is an action for damages in excess of $50 million. 7. ‘This Court has jurisdiction of this action and the claims set forth herein pursuant t

learned that another of its high value clients, Bernie Madoff, was running the largest Ponzi- scheme in

Adult Survivor's Act, N.Y. CPLR § 214-j. II. PARTIES 7. Jane Doe 1 is a U.S. citizen and was at all relevant times a resident of and domiciled in the State of New York. 8. Plaintiff Jane Doe 1 is using a pseudonym to protect her identity because of the sensitive and highly personal nature of this matter, which in