n letter to me. This was the first written communication I had received from the FBI. The letter was attached as Exhibit 1 to my earlier statement." D.E. 310- 1, 1 34. Exhibit 1 to her earlier statement of January 19, 2015 (D.E. 291-1), is the notification letter from the United States Attorney's Offi

on June 30, 2008, in the Circuit Court for Palm Beach County to various similar state offenses including solicitation of minors for prostitution." D.E. 1,1 2. Once they received the non-prosecution Jane Doe No. 3, who seeks to be added as a party, also wasted little time in utilizing the non- prosec

proof of service from Mr. Marsigliano attesting that he left M.J.'s complaint with the caretaker at Epstein's residence or usual place of abode." (D.E. 15 at p. II). This assertion is false. Defendant has never admitted that the proof of service states that Mr. Marsigliano left the Summons and Com

copy of her complaint and other documents with someone at the home", which is all that Plaintiff alleges, or whether Mr. Epstein had actual notice (D.E. 15 at 12), but, rather, whether the suit papers were left with "someone of suitable age and discretion who resides" at 9 East 71s' Street, New York.

ant to this Court's September 11, 2020, order directing the parties to respond to the Government's amicus letter brief filed on September 16, 2020. D.E. 113.1 Ms. Giuffre agrees with the Government's position and opposes Defendant's motion to consolidate this appeal (the "civil appeal") with her app

criminal appeals bearing no relation to one another. First, the issues presented in the criminal appeal have no bearing on the civil Citations to "D.E." refer to this Court's docket. Ghislaine Maxwell's Appendix is cited as "App." Virginia Giuffre's Supplemental Appendix is cited as "SA." EFTA00095

he arguments raised in Plaintiffs Response In Opposition to Defendant's Motion to Stay Complaint in Jane Doe No.1 v. Epstein (Case No. 08-CV-80893, D.E. 31)(Attached hereto as Exhibit "1") and Plaintiffs Memorandum in Opposition to Motion to Stay and or Continue Action in Jane Doe No. 2 v. Epstein (

On July 7, 2008, plaintiff Jane Doe filed her "Emergency Victim's Petition for Enforcement of Crime Victim's Rights Act, 18 U.S.C. Section 3771." (D.E. I). On the same day, this Court issued an Order directing the United States Attorney to file a response to the petition by 5:00 p.m., Wednesday, Jul

On July 7, 2008, plaintiff Jane Doe filed her "Emergency Victim's Petition for Enforcement of Crime Victim's Rights Act, 18 U.S.C. Section 3771." (D.E. I). On the same day, this Court issued an Order directing the United States Attorney to file a response to the petition by 5:00 p.m., Wednesday, Jul

2010 the United States District Court entered a Final Order in the above-captioned case dismissing the action with prejudice and closing the case. (D.E. #211). In said Order, Judge Marra stated "[t]he Court shall retain jurisdiction to enforce the terms of the parties' settlement and the joint stipu

retrial motions by the parties is March 5, 2010. This action is currently set for trial on the two week calendar commencing Monday, July 16, 2010. [D.E. 119]. Thus, in order to comply with the Court's order, Defendant is filing the subject motion now. As stated above, Defendant requests and reserves

note from a review of the docket sheet in Doe v. U.S., that Judge Marra administratively closed the cases for non-prosecution on September 9, 2010 [D.E. 39]. Please recall the undersigned pointed out in Epstein's initial motion that this case has been languishing in excess -6- FOWLER WHITE BURNETT.

n letter to me. This was the first written communication I had received from the FBI. The letter was attached as Exhibit 1 to my earlier statement." D.E. 310- 1, ¶ 34. Exhibit 1 to her earlier statement of January 19, 2015 (D.E. 291-1), is the notification letter from the United States Attorney's Offi

FBI's investigation of Jeffrey Epstein. She told S/A Slater that she did not want to be bothered about the Epstein matter again. D.E. 304-1, ¶ 7 and D.E. 290-3 at 17-18. In their motion, petitioners claim that the facts surrounding this exchange are highly disputed, when they are not. D.E. 311 at 16

ates: I. PETITIONERS' MOTION TO ADD TWO ADDITIONAL PARTIES SHOULD BE DENIED AS UNTIMELY This action was commenced by Jane Doe #1 on July 7, 2008 (D.E. I). The Court ordered the Government to file a response by July 9, 2008, which was done. On July 11, 2008, the Court held a hearing on the emergenc

2010 the United States District Court entered a Final Order in the above-captioned case dismissing the action with prejudice and closing the case. (D.E. #211). In said Order, Judge Marra stated "[t]he Court shall retain jurisdiction to enforce the terms of the parties' settlement and the joint stipu

extended. In light of Plaintiff's filing of her Conditional Notice of Intent to Exclusively Rely on Statutory Damages Provided by 18 U.S.C. §2255 (D.E. 113) on June 5, 2009, Plaintiff agrees to a modification of the pretrial schedule as outlined in Defendant EPSTEIN's Motion to Strike (D.E. 104); to

2010 the United States District Court entered a Final Order in the above-captioned case dismissing the action with prejudice and closing the case. (D.E. #211). In said Order, Judge Marra stated "[t]he Court shall retain jurisdiction to enforce the terms of the parties' settlement and the joint stipu

led a motion to compel the Clerk of Court to enter default against Mr. Epstein, or in the alternative, for an enlargement of time to serve process [D.E. 9].3 Overview of Rules for Service of Process The Federal Rules of Civil Procedure authorize three distinct methods of service in a diversity actio

other inquiries related to the same subject matter in this case, the related cases and those matters outlined in Epstein's in camera submissions at D.E. #s 282 and 283. Given the allegations raised in the various Complaints and the elements 5 EFTA00222432 Case 9:08-cv-80119-KAM Document 462 Enter

. A. www.hermanlaw.com - 1 - EFTA00222609 Case 9:08-cv-80119-KAM Document 9 Entered on FLSD Docket 06)11:2008 Page 2 of 7 improper service. (D.E. 8).1 5. The Affidavit of Service filed in this case, states that the process server made five separate attempts at service at the Defendant's New Y

On July 7, 2008, plaintiff Jane Doe filed her "Emergency Victim's Petition for Enforcement of Crime Victim's Rights Act, 18 U.S.C. Section 3771." (D.E. I). On the same day, this Court issued an Order directing the United States Attorney to file a response to the petition by 5:00 p.m., Wednesday, Jul

EPSTEIN upon her, Plaintiff intends to rely exclusively on the statutory damages, rather than those damages which are available at common law. (See D.E. 113). If however, the Court rules that the statutory floor applies only one time, regardless of the number of times EPSTEIN committed an enumerated