se cases involving Epstein); b. Reached agreements to share attorneys fees with non-lawyers; c. Used investor money to pay plaintiffs (i.e., L.M., E.W. and Jane Doe) "up front" money such that plaintiffs would refuse to settle the Civil Actions; d. Conducted searches, wiretaps or intercepted conver

ed she worked at eleven (11) separate strip clubs, including Cheetah which RRA represented and in which ROTHSTEIN may have owned an interest; and E.W. also worked at Platinum Showgirls in Boynton Beach, which was the subject of a recent police raid where dancers were allegedly selling prescriptio

hereto in the sealed envelope, E.W. discusses page-by-page the sealed document, the Non-Prosecution Agreement. Public disclosure of this portion of E.W.'s response would violate this Court's order staying disclosure of the NPA. For this reason, E.W. moves to file the attached under seal. Copies of

8 CF 9381 JEFFREY EPSTEIN, Petitioner, STATE OF FLORIDA, et. al, Respondents. E.W.'S MOTION TO FILE PORTION OF RESPONSE UNDER SEAL Respondent, E.W., moves to file under seal a portion of her response (dealing with this Court's lack of jurisdiction) to the petition for writ of certiorari, on the

: Cassell is C-a-s-s-e-I-1. 5 THE COURT: And who are you representing in 6 this matter? 7 MR. CASSELL: I represent putative 8 intervenors L.M., E.W. and Jane Doc, who have a pending 9 motion for leave to intervene. 10 THE COURT: All right. Let me ask, is there 11 any opposition to the motion

present in the courtroom? 14 MR. EDWARDS: Your Honor, I was informed 15 that Mr. Paul Cassell was to call into this hearing on 16 behalf of L.M., E.W. and S.R. 17 THE COURT: I don't --- 18 MR. EDWARDS: I don't know what arrangements 19 he made. 20 THE COURT: No such arrangements were made. 21

ve the anxiety and emotional distress he has suffered every single day over the last eight years is by bringing his three clients into Court — L.M., E.W. and Jane Doe — to testify about their claims against Epstein, which they settled more than seven years ago. The three individuals have no interest

clear that the CVRA proceeding is going to be a focal point of this case, Epstein is filing a Response to Edwards' Motion with a request to reopen E.W.'s deposition as well. Epstein incorporates those arguments herein. CONCLUSION For the reasons stated above and in Epstein's Response to Edwards' Mo

oquialism, discussion, conversation or agreement. C. "Plaintiff means =. (MI. v. Jeffrey Epstein, Palm Beach County Case #502008CA0280S1XXXXMB), E.W. (E.W. v. Jeffrey Epstein, Palm Beach County Case #502008CA0280S8XXXXIVIB), Jane Doe (Jane Doe v. Jeffrey Epstein, United States District Court Case

stina ICitterman k. Dean Kretschmar 1. Michael Legamaro 16. All documents related to or referencing potential deponents in the Jane Doe, M. or E.W., cases used in connection with Investor meetings and/or general Investor solicitation into the Rothstein Ponzi Scheme. 17. Any employment agreemen

order compelling disclosure of a confidential federal non-prosecution agreement and addendum, pursuant to motions to unseal, filed by non-parties, E.W., B.B. and Palm Beach Newspapers d/b/a The Palm Beach Post ("the Post"),I The confidential federal non-prosecution agreement and addendum between th

ith notice to the United States, the other party to the Agreement. (A-6). Rather than seeking relief from Judge Marra in federal court, non- party E.W., a victim of Mr. Epstein, filed a motion in the state criminal action on May 12, 2009, seeking to intervene and unseal the non-prosecution agreemen

se cases involving Epstein); b. Reached agreements to share attorneys fees with non-lawyers; c. Used investor money to pay plaintiffs (i.e., L.M., E.W. and Jane Doe) "up front" money such that plaintiffs would refuse to settle the Civil Actions; d. Conducted searches, wiretaps or intercepted conver

— worked at eleven (11) separate strip clubs, including Cheetah (7°) which RRA represented and in which ROTHSTEIN may have owned an interest; and E.W. also worked at Platinum Showgirls in Boynton Beach, which was the subject of a recent police raid where dancers were allegedly selling prescriptio

at simply says that the motion for 16 protective order is denied for the reasons 17 stated on the record and the amended protective 18 order in E.W.'s case is denied for reasons 19 stated on the record, that will be fine. 20 MR. BERGER: Judge, I've just drafted - I 21 know Mr. Critton wants

nt here is I haven't 10 asked one question to anybody yet in terms of 11 the deposition. What I did was, is I set 12 E.W. -- 13 THE COURT: And E.W. is the same lady who 14 the transcript -- 15 MR. CRITTON: Transcript has 16 and are the same person, §§§. is the same 17 person, and Jane Doe

R. CASSELL: Cassell is C-a-s-s-e-1-1. THE COURT: And who are you representing in this matter? MR. CASSELL: I represent putative intervenors L.M., E.W. and Jane Doe, who have a pending motion for leave to intervene. THE COURT: All right. Let me ask, is there any opposition to the motion to interve

r Shapiro present in the courtroom? MR. EDWARDS: Your Honor, I was informed that Mr. Paul Cassell was to call into this hearing on behalf of L.M., E.W. and S.R. THE COURT: I don't MR. EDWARDS: I don't know what arrangements he made. THE COURT: No such arrangements were made. So, we'll just -- on

reet, Fort Lauderdale, FL 3330I• 954.467.1223 EFTA00799405 lines 20-21. Q: During that time that you have been involved in this case on behalf of E.W., has Mr. Howell participated in the case; that is, has he done work on the case? Id. at page 90; lines 20-23. A: Yes. Id. at page 90; line 24. Q:

AROLA: I am going to object. That calls for attorney-client privilege. Id. at page 98; line 24-25. Q: All right. At the time you began representing E.W. or at any time prior to the filing of the lawsuit against the United States Government in July of '08, did you learn whether she was listed as a, o

an provide explanation. See Epstein Deposition, February 17, 2010, at 11-12, 30-31 (Deposition Attachment # 7). 9. Epstein also sexually assaulted E.W., beginning when she was 14 years old and did so on numerous occasions. See E.W. Depo., Attachment #4 at 215-216. 10. Another of the minor girls Ep

did not notify E.W. and L.M. that a plea agreement had already been reached that would block federal prosecution of Epstein. Nor did the FBI notify E.W. and L.M. of any of the parts of the plea agreement. Nor did the FBI or other federal authorities confer with E.W. and L.M. about the plea. See id.

accurate misdescription. Nowhere in his complaint in the Ponzi Scheme Action does Epstein allege that the sex abuse suits brought by Jane Doe,. and E.W. were fabricated. Instead, what the complaint actually alleges is that Rothstein used 9 DWI 1584534543 3970112.000042 EFTA00596463 these three le

minors); id. at 7 ("the evidence of Epstein's crimes is now clear"). Among the many other evidentiary sources listed by Edwards: • Jane Doe,.. and E.W. have all provided graphic eyewitness testimony that they were sexually abused by Epstein when minors. See SUF ¶ 2 ("Deposition of Jane Doe, Septemb

Attorney-Client and work-product privileges. Id. at page 89; lines 20-21. Q: During that time that you have been involved in this case on behalf of E.W., 3 It is significant to note that other jurisdictions have sanctioned counsel for just this behavior during deposition. See e.g. Van Pilsum v. Iow

AROLA: I am going to object. That calls for attorney-client privilege. Id. at page 98; line 24-25. Q: All right. At the time you began representing E.W. or at any time prior to the filing of the lawsuit against the United States Government in July of '08, did you learn whether she was listed as a, o

Inc. d/b/a The Palm Beach Post ("the Post") its attorneys' fees and costs in responding to this petition. JURISDICTION The Post adopts Respondent E.W.'s statement concerning jurisdiction. Insofar as this Court finds jurisdiction, the Post requests that this Court expedite its consideration of this

fact, the U.S. Attorney's Office has taken no position on this matter throughout the lower court proceedings and specifically informed counsel for E.W. that it had no position (A-18 at p. 7,11. 10-14.) At that hearing, the Court found that the proper procedures to initially seal the records were not

se cases involving Epstein); b. Reached agreements to share attorneys fees with non-lawyers; c. Used investor money to pay plaintiffs (i.e., L.M., E.W. and Jane Doe) "up front" money such that plaintiffs would refuse to settle the Civil Actions; d. Conducted searches, wiretaps or intercepted conver

ed she worked at eleven (11) separate strip clubs, including Cheetah which RRA represented and in which ROTHSTEIN may have owned an interest; and E.W. also worked at Platinum Showgirls in Boynton Beach, which was the subject of a recent police raid where dancers were allegedly selling prescriptio

ts on behalf of clients in Palm Beach County, Florida. (RRA is currently a debtor in bankruptcy. RRA is not named as a Defendant). 17. Defendant, E.W. ("E.W."), is an individual residing in County, Florida. At all times relevant hereto, E.W. was represented by RRA, ROTHSTEIN and the Litigation

bs, including Cheetah (7°) which RRA represented and ROTHSTEIN may have owned an interest; EFTA00725339 j) Epstein v. RRA, et al. Page 22 and E.W. also worked at Platinum Showgirls in Boynton Beach, which was the subject of a recent police raid where dancers were selling prescription painkill

have to be the Jane Doe; Jane Doe? 5 A. Yes. 6 Q. Are you aware of any individuals that Miss - 7 Mr. Edwards represents, other than you, a and E.W.? 8 A. No. 9 Q. All right. Then it goes down — again, 1 10 take you back where it says: "Jane Doe was identified 11. via the FBI's investigati

25 Federal, local, that you had been to Mr. Er:stain's home; Page 136 Q. Okay. would be -- 2 A. Yes. 3 Q. — you would assume. C.W. would be E.W., and 4 you would have to be the Jane Doe; Jane Doe? 5 A. Yes. 6 Q. Are you aware of any individuals that Miss - 7 Mr. Edwards represents, oth

aintiff, v. JEFFREY EPSTEIN, Defendant. PLAINTIFF E.W.'S RESPONSE TO DEFENDANT'S MOTION FOR LEAVE TO FILE ADDITIONAL INTERROGATORIES Plaintiff, E.W., hereby files this response to Defendant Epstein's Motion for Leave to File Additional Interrogatories. In support of this response, Plaintiff state

ount of discovery, including that of the most sensitive and personal nature, from information about past sexual partners to abortion records, which E.W. has been made to hand over to the convicted sex offender who molested her. Epstein has questioned Plaintiffs friends, family, neighbors, set many o

ow Ghislaine Maxwell? 18 A Fifth. 18 A Fifth. 19 Q in addition to your sexual interactions 19 Q Is that somebody who helped Jeffrey 20 with E.W., isn't it true that you have used 20 Epstein to devise the scheme to allow him access 21 strap-on dildos and vibrators on other underage 21 to

23 females? 24 MR. YAREMA: Object to the form. 25 A Fifth. 11 1 A I take the Fifth. 2 Q I represent a lady named, a young female 3 named E.W.; you know who that is, right? 4 Ma. YAREMA: Object to the form. S A The Fifth. 6 Q Jeffrey Epstein made you have sex with 7 E.W., didn't he?

'S MOTION TO DISIMISS PETITION FOR LACK OF JURISDICTION Petitioner, JEFFREY EPSTEIN, replies to the three separate responses filed by respondents, E.W., B.B., and the Post, and responds to E.W.'s Request to Dismiss Petition for Lack of Jurisdiction as follows: The non-prosecution agreement and adde

agreement and addendum is confidential by its terms. Mr. Epstein directs this Court to review paragraph 13 of the sealed non-prosecution agreement. E.W.'s argument is also disingenuous. EW has had the non-prosecution agreement for months, yet never advanced this position in federal or state court un