Epstein Secrets

ed States, 359 F.Supp.2d 981, 984 (E.D. Cal. 2005). An evidentiary hearing is the proper vehicle for resolving this particular factual dispute. See Blair v. City of Worcester, 522 F.3d 105, 115 (1st Cir. 2008) (reversing district court for refusing to hold an evidentiary hearing where factual issues s

legal counsel filed a motion to "quash" service of process, alleging that process was not properly made. Attached to the Motion was an Affidavit of Richard Barnett, which swore that an "unmarked and unpostmarked envelope was discovered in the mailbox at Mr. Epstein's vacation home in New York at 9 East 7111 St

nothing short of an intentional fraud being committed on the court. The circumstances surrounding the making of this statement strongly suggest that Barnett swore to this false statement deliberately, for the purpose of obstructing proper proceedings in this case. Defendant Epstein's history of obstruct

not state who made the discovery. The affidavit does not state whether Bamett has personal knowledge of the facts contained in his affidavit. 13. Barnett subsequently filed a second affidavit, this time to merely announce that nobody named "Mark` was at the house on October 8, 2010. While this may be

re in personam jurisdiction over the person of a defendant is permitted by the Federal Rules of Civil Procedure, specifically Rule 26”). See also Blair v. City of Worcester, 522 F.3d 105, 111 (1st Cir. 2008); Monteiro v. San Nicolas, S.A., 254 F.2d 514, 516-17 (2d Cir. 1958) (holding that discovery

P. A. www.hermanlaw.com - 2 - response as Exhibit “A” the Affidavit of Richard Barnett, who claims to have received the copies of the Summons and Complaint on May 7, 2008 at Defendant Epstein’s residence. In this Affidavit, Mr. Barne

rnett, who claims to have received the copies of the Summons and Complaint on May 7, 2008 at Defendant Epstein’s residence. In this Affidavit, Mr. Barnett states very little. He asserts that he does not now, nor has he ever, resided at 9 E. 71st Street, New York, New York (Mr. Epstein’s residence). H

tiff did not dispute—and thereby confessed—that this statement is not actionable. Accordingly, we assume this statement is not in issue at trial. 2 Blair v. Inside Ed. Prods., 7 F. Supp. 3d 348, 358 & n.6 (S.D.N.Y. 2014) (citing DiBella v. Hopkins, 403 F.3d 102, 111 (2d Cir. 2005)). 8 EFTA00792763

South Africa 4. Philip Barden (live) Devonshires Solicitors LLP 30 Finsbury Circus London, United Kingdom EC2M 7DT DX: 33856 Finsbury Square 5. Richard Barnett (live) 14 Oakland Ave Port Washington, NY 11050 6. Custodian of Records (live) The Mar-a-Lago Club, Inc. 725 Fifth Avenue New York, NY 10022 7

tiff did not dispute—and thereby confessed—that this statement is not actionable. Accordingly, we assume this statement is not in issue at trial. 2 Blair v. Inside Ed. Prods., 7 F. Supp. 3d 348, 358 & n.6 (S.D.N.Y. 2014) (citing DiBella v. Hopkins, 403 F.3d 102, 111 (2d Cir. 2005)). 8 EFTA00617403

iles (live) 4. Philip Barden (live) Devonshires Solicitors LLP 30 Finsbury Circus London, United Kingdom EC2M 7DT DX: 33856 Finsbury Square 5. Richard Barnett (live) 6. Custodian of Records (live) The Mar-a-Lago Club, Inc. 725 Fifth Avenue New York, NY 10022 7. 8. 9. Dershowitz (live) do Richard A.

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I n 859 155 ill Wedge (I) 631 4 7 17 8319 260 ston (yin 17 7 0 1 o 631 9 5*I 954 648 1281 Coat) 011 39 335 56 5933 (boat) JEFFREY 71ST, Barnett, Richard 14 Oakland Ave Pon rti ton. 516 88 4411( ) NY 11050 116-44 Emad: rb [email protected] (Hm}1800 skyPage 917940 6157 (py lea Blachon, Mag