MEMY-1805 harvest: vision-fixhub (part 10)

vision-fixhub/court-01/aa2a4094db2c86f0110da6b51c0c29901c844d7847798c50540f44b2a5e48e0b.md

@@ -0,0 +1,75 @@
+Filing # 193147674 E-Filed 03/01/2024 04:41:55 PM
+IN THE CIRCUIT COURT OF THE FIFTEENTH
+JUDICIAL CIRCUIT IN AND FOR PALM
+BEACH COUNTY, FLORIDA
+CASE NO.: 50-2019-CA-0144681-AG
+CA FLORIDA HOLDINGS, LLC
+Publisher of THE PALM BEACH POST,
+Plaintiff
+VS.
+DAVE ARONBERG, as State Attorney
+of Palm Beach, County, Florida; SHARON
+BOCK, as Clerk and Comptroller of
+Palm Beach County, Florida,
+Defendants.
+COPY
+THE MCCLATCHY COMPANY, LLC'S MOTION TO INTERVENE
+The McClatchy Company, LLC ("McClatchy"), publisher of The Miami Herald, moves to
+intervene in this action for the limited purpose of obtaining, pursuant to §905.27, Florida Statutes,
+access to grand jury materials relating to Jeffrey Epstein. The grounds for this motion are:
+1.
+McClatchy
+publishes The Miami Herald.
+The reporting of McClatchy's
+professional journalists, especially Julie
+have been central and instrumental in exposing
+Jeffrey Epstein's sexual abuse and trafficking of minors.
+The Miami Herald's first articles
+regarding Mr. Epstein were published in November 2018.
+Through an initial and amended complaint, and then the prosecution of an appeal,
+Plaintiff has sought to obtain through this action grand jury materials relating to Mr. Epstein.
+By Agreed Order dated February 28, 2024, the Court permitted the Associated
+Press to intervene in this action, writing that "ItJhe Associated Press is hereby permitted to
+*** FILED: PALM BEACH COUNTY, FL
+ABRUZZO, CLERK. 03/01/2024 04:41:55 PM ***
+
+
+intervene in this matter and shall be granted access to any grand jury materials the Court orders to
+be disclosed."
+4.
+Yesterday, on February 29, 2024, this Court entered an order ruling that under the
+law, as it existed on that date, releasing the grand jury materials would not further justice and, on
+that basis, the Court would not order the release of the materials. However, the Court noted that
+the governing law will change on July 1, 2024, and the Court granted the parties leave to file a
+motion for reconsideration once the law changes.
+Through this Motion, McClatchy seeks to intervene in this action for the limited
+purpose of obtaining access to any grand jury materials that, upon motion for reconsideration, the
+Court orders to be disclosed. As the publisher of a newspaper of géneral circulation, McClatchy
+has standing to intervene for the purpose of opposing closure of records and seeking to obtain
+access to records. See, e.g., Barron v. Florida Freedom Newspapers, Inc., 531 So.2d 113, 118
+(Fla. 1988); Miami Herald Publishing Co. v. Lewis, 426 So.2d 1, 4 (Fla. 1983).
+WHEREFORE, McClatchy respectfully requests the entry of an Order permitting it to
+intervene in this action for the limited purpose of obtaining access to the grand jury materials
+related to Mr. Epstein.
+NOT
+Respectfully submitted,
+HOLLAND & KNIGHT LLP
+701 Brickell Avenue, Suite 3300
+Miami, Florida 33131
+(305) 374-8500 (telephone)
+(305) 789-7799 (facsimile)
+By: Is/ Scott D. Ponce
+Scott D. Ponce (FBN 0169528)
+sponce@hklaw.com
+Attorneys for The McClatchy Company, LLC
+2
+#243187610_v1
+
+
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that I filed this document on March 1, 2024 using Florida's e-
+filing portal, which will serve a copy on all counsel of record.
+By: Is/ Scott D. Ponce
+NOT A CERTIFIED COPY
+3
+#243187610_v1

vision-fixhub/court-01/aa2a4094db2c86f0110da6b51c0c29901c844d7847798c50540f44b2a5e48e0b.receipt.json

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vision-fixhub/court-01/aa50a43f537e295bdc6ce73f0a48584495e3ae8a2ccbb4dbbff40fd2f9c3dee1.md

@@ -0,0 +1,26 @@
+Case 1:19-cv-10577-LJL-DCF Document 35 Filed 03/06/20 Page 1 of 1
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+JANE DOE 1000,
+Plaintiff,
+Case No. 1:19-cv-10577 (LJL)
+NOTICE OF APPEARANCE
+VS.
+DARREN I. INDYKE and RICHARD D. KAHN,
+in their capacities as the executors of the ESTATE
+OF JEFFREY EDWARD EPSTEIN,
+Defendants.
+PLEASE TAKE NOTICE that the undersigned attorney, Andrew Villacastin, who
+is a member in good standing of the bar of this Court, hereby appears as counsel for
+Plaintiff Jane Doe 1000 in the above-captioned proceeding.
+Dated: New York, New York
+March 6, 2020
+BOIES SCHILLER FLEXNER LLP
+By:
+Is/ Andrew Villacastin
+Andrew Villacastin
+55 Hudson Yards
+Telephone: (212) 446-2300
+Fax: (212) 446-2350
+avillacastin@bsfllp.com
+Attorney for Plaintiff Jane Doe 1000

vision-fixhub/court-01/aa50a43f537e295bdc6ce73f0a48584495e3ae8a2ccbb4dbbff40fd2f9c3dee1.receipt.json

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vision-fixhub/court-01/aa513ba46d29e289075ffee0aeeade79836cc38c9df33ef7626f1c2c9fb4b55d.md

@@ -0,0 +1,46 @@
+Case 1:19-cv-08673-KPF-DCF Document 58 kl
+Filed 03/23/20 Page 1 of 1
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+JANE DOE
+Case No. 1:19-cv-08673-KPF-DCF
+Plaintiff,
+-against-
+DARREN I. INDYKE and RICHARD D. KAHN,
+in their capacities as executors of the ESTATE
+OF JEFFREY E. EPSTEIN
+Defendant.
+NOTICE OF CHANGE OF ADDRESS
+TO:
+ATTORNEY SERVICES CLERK AND ALL OTHER PARTIES
+I have cases pending
+I have no cases pending
+Pursuant to Local Rule 1.3 of this Court, please take notice of the following attorney information change (s) for:
+Mary "Molly" S. DiRago
+FILL IN ATTORNEY NAME
+_ My State Bar Number is _6282757
+My SDNY Bar Number is:
+1am,
+•
+An attorney
+A Government Agency attorney
+A Pro Hac Vice attorney
+FIRM INFORMATION (Include full name of firm (OLD AND NEW), address, telephone number and fax number):
+OLD FIRM:
+FIRM NAME: TROUTMAN SANDERS LLP
+FIRM ADDRESS: One North Wacker Drive, Suite 2905 Chicago, IL 60606
+FIRM TELEPHONE NUMBER: 13121759-1928
+FIRM FAX NUMBER: 1712759-1939
+NEW FIRM:
+FIRM NAME: TROUTMAN SANDERS LLP
+FIRM ADDRESS: 227 W. Monroe Street, Suite 3900, Chicago, IL 60606.
+FIRM TELEPHONE NUMBER: 13121759-1928
+FIRM FAX NUMBER: 312759-1939
+I will continue to be counsel of record on the above-entitled case at my new firm/agency.
+•
+I am no longer counsel of record on the above-entitled case. An order withdrawing my appearance
+was entered on
+by Judge
+Dated: 03/20/2020
+Is/ Mary "Molly" S. DiRago
+ATTORNEY'S SIGNATURE

vision-fixhub/court-01/aa513ba46d29e289075ffee0aeeade79836cc38c9df33ef7626f1c2c9fb4b55d.receipt.json

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vision-fixhub/court-01/aa64e5146004d1e945dfd4256551eb7c77ed75f36d7d97dd0471a0872202be0b.md

@@ -0,0 +1,79 @@
+Case 9:08-cv-80119-KAM Document 68-2 Entered on FLSD Docket 04/02/2009 Page 1 of 2
+34
+IN THE COURT OF THE FIFTEENTH
+JUDICIAL CIRCUIT, IN AND FOR PALM
+BEACH COUNTY, FLORIDA
+CASE NO. 502008CA025129XXXXMB AI
+A.C.,
+V.
+Plaintift,
+JEFFREY E. EPSTEIN, and
+Defendants.
+ORDER ON DEFENDANT EPSTEIN'S MOTION TO COMPEL RESPONSES TO
+FIRST REQUEST TO PRODUCE TO PLAINTIFF AND TO OVERRULE
+PLAINTIFF'S OBJECTIONS, & FOR DEFENDANT'S EXPENSES,
+INCLUDING ATTORNEYS' FEES
+THIS CAUSE came before the Court on Defendant Epstein's Motion To
+Compel Responses To First Request To Produce To Plaintiff And To Overrule
+Plaintiff's Objections, & For Defendant's Expenses, Including Attorneys' Fees
+and the Court having heard argument of counsel and being fully advised in these
+premises, it is hereby
+ORDERED and ADJUDGED that Defendant's Motion is hereby granted/
+deniedas
+to
+# 17 + 7/18
+→ and denced
+as to #22 as phrased.
+Responses to
+be fter semed w/in 10 dap.
+DONE AND ORDERED at Palm Beach County Courthouse, West Palm
+Beach, Florida, this 23 day of _
+FUB
+< 2008
+Edward A.
+Garrison
+Circuit Judge
+Copies furnished:
+ROBERT D. CRITTON, JR., ESQ., and MICHAEL J. PIKE, ESO., 515 North Flagler Drive, Suite 400, West Palm Beach,
+FL 33401; JACK SCAROLA, ESQ., AND JACK P.
+Shipley, P.A., 2139 Palm Beach Lakes Blvd.,
+ESQ., Searcy Denney Scarola Barnhart &
+West Palm Beach, FL 33409, and JACK A.
+Austrian ReSus a Fis, PA, One Clearake Centre, Suite 1400, 250%,
+Australian Avenue South, West Palm Beach, FL 33401
+EXHIBIT" B
+COVENARI
+
+
+Case 9:08-cv-80119-KAM Document 68-2 Entered on FLSD Docket 04/02/2009 Page 2 of 2
+35
+A.C.,
+IN THE COURT OF THE FIFTEENTH
+JUDICIAL CIRCUIT, IN AND FOR PALM
+BEACH COUNTY, FLORIDA
+CASE NO. 502008CA025129XXXXMB Al
+Plaintiff
+V.
+JEFFREY E. EPSTEIN, and
+Defendants.
+ORDER ON DEFENDANT EPSTEIN'S MOTION TO COMPEL ANSWERS TO
+INTERROGATORIES AND TO OVERRULE PLAINTIFF'S OBJECTIONS, & FOR
+DEFENDANT'S EXPENSES, INCLUDING ATTORNEYS' FEES
+THIS CAUSE came before the Court on Defendant Epstein's Motion To
+Compel Answers To Interrogatories And To Overrule Plaintiff's Objections, & For
+Defendant's Expenses, Including Attorneys' Fees, and the Court having heard
+argument of counsel and being fully advised in these premises, it is hereby
+ORDERED and ADJUDGED that Defendant's Motion is hereby granted/
+denled
+as to #5, 12$18, denied as
+to #2.
+Responses to be soned whin
+10 dap.
+DONE AND ORDERED at Palm Beach County Courthouse, West Palm
+Beach, Florida, this 23 day of .
+Edward A. Garrison
+Circuit Judge
+Copies furnished:
+ROBERT D. CRITTON, JR., ESQ., and MICHAEL J. PIKE, ESO. 515 North Flagler Drive, Suite 400, West Palm Beach,
+, ESQ., Searcy Denney Scarola Barnhart &
+TENG, DE

vision-fixhub/court-01/aa64e5146004d1e945dfd4256551eb7c77ed75f36d7d97dd0471a0872202be0b.receipt.json

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vision-fixhub/court-01/aab0673f361474330755b66d67bf69bd5bb3317f77d4629c0485e90fe328449b.md

@@ -0,0 +1,327 @@
+Case 1:20-cv-00484-JGK-DCF Document 56-1 Filed 07/16/20 Page 1 of 8
+From:
+Sent:
+To:
+Cc:
+Subject:
+Moskowitz, Bennet J.
+Wednesday, July 15, 2020 5:24 PM
+Laura Menninger
+Nathan Werksman; Claudia Lomeli; Robert Glassman;
+daniel.weiner@hugheshubbard.com; Metcalfe, Mary
+Re: Jane Doe (1:20-cv-00484-JGK-DCF)
+: Keilah Betts; Kevin Boyle
+Ms. Menninger:
+Thanks for confirming our understanding. As we previously advised Robert, the parties also need to get on the same
+page about a confidentiality agreement before we start productions; that was clear from our written discovery
+responses to him. We thought that would be discussed on Friday as well. We are still available to meet and confer as
+discussed, and will take up Robert's premature, erroneous letter with Judge Freeman unless he immediately withdraws
+it.
+Best,
+Bennet
+On Jul 15, 2020, at 5:17 PM, Laura Menninger <Imenninger@hmflaw.com> wrote:
+EXTERNAL SENDER
+That is correct. I understand that we were having a call tomorrow to discuss a number of scheduling issues, including
+scheduling depositions. I said that I needed to see the discovery and disclosures produced to date, prior to that call. I
+have yet to receive any discovery produced by either side.
+I now have other meetings scheduled at 10 am, 1 pm and 4:30 pm on Friday (all MST). Let me know if you all still want
+to have a discussion or not, given Mr. Glassman's very premature letter to the court. If so, please send me whatever
+docs have been produced to date.
+I believe that we need to compile a deposition schedule for all witnesses that the parties intend to depose at one time,
+so Mr. Glassman I assume you will be providing dates for your client's deposition.
+Laura A. Menninger Partner
+Haddon,
+•. P.C.
+150 E. 10th Avenue | Denver, CO 80203
++1 303 831 7364 (Office)
+Imenninger@hmflaw.com
+From: Moskowitz, Bennet J. <Bennet.Moskowitz@troutman.com>
+Sent: Wednesday, July 15, 2020 3:14 PM
+To: Laura Menninger <Imenninger@hmflaw.com>
+Cc: Nathan Werksman <werksman@psblaw.com>; Claudia Lomeli < lomeli@psblaw.com>; Robert Glassman
+<glassman@psblaw.com>; daniel.weiner@hugheshubbard.com; Metcalfe, Mary
+<MaryGrace.Metcalfe@troutman.com>; Keilah Betts <betts@psblaw.com>; Kevin Boyle <Boyle@psblaw.com>
+Subject: Re: Jane Doe (1:20-cv-00484-JGK-DCF)
+1
+
+
+Case 1:20-cv-00484-JGK-DCF Document 56-1 Filed 07/16/20 Page 2 of 8
+Hi Laura,
+You may have seen that Robert just filed a letter to Judge Freeman claiming, among other things, that we unilaterally
+canceled Mr. Indyke's deposition to be obstructionist. Our understanding is that you requested we speak to, among
+other things, set new dates for that and all other discovery dates and deadlines which were set before you appeared in
+this action. Indeed, that is why we are supposed to speak on Friday. Is my understanding correct?
+Thank you,
+Bennet
+Bennet J. Moskowitz*
+Partner
+troutman pepper
+Direct: 212.704.6087
+bennet.moskowitz@troutman.com
+*Licensed to practice law in New York and Connecticut
+On Jul 15, 2020, at 2:34 AM, Robert Glassman <glassman@psblaw.com> wrote:
+EXTERNAL SENDER
+Friday works for us too. I am still waiting on a response from Ms. Menninger concerning the depositions | emailed her
+about on July 8. I would also like to add to the agenda for Friday scheduling the deposition of Ms. Maxwell.
+Robert Glassman, Esq.
+Panish Shea & Boyle LLP
+11111 Santa Monica Boulevard, Suite 700
+Los Angeles, CA 90025
+Tel: (310) 477-1700
+Fax: (310) 477-1699
+Email: glassman@psblaw.com
+Web: www.psblaw.com
+CONFIDENTIALITY NOTICE:
+This e-mail may contain confidential and privileged material for the sole use of the intended recipients). Any review, use,
+distribution or disclosure by others is strictly prohibited. If you are not the intended recipient (or authorized to receive for the
+recipient), please contact the sender by reply e-mail or telephone, and delete all copies of this message.
+If you are a potential client, the information you disclose to us by email will be kept in strict confidence and will be protected to the
+full extent of the law. Please be advised, however, that Panish Shea & Boyle LLP and its lawyers do not represent you until you have
+signed a retainer agreement with the firm. Until that time, you are responsible for any statutes of limitations or other deadlines for
+your case or potential case.
+From: Moskowitz, Bennet J. [mailto:Bennet.Moskowitz@troutman.com]
+Sent: Tuesday, July 14, 2020 1:56 PM
+To: Laura Menninger <Imenninger@hmflaw.com>
+Cc: Robert Glassman <glassman@psblaw.com>; Nathan Werksman <werksman@psblaw.com>; Claudia Lomeli
+2
+
+
+Case 1:20-cv-00484-JGK-DCF Document 56-1 Filed 07/16/20 Page 3 of 8
+<lomeli@psblaw.com>; daniel.weiner@hugheshubbard.com; Metcalfe, Mary L
+<MaryGrace.Metcalfe@troutman.com>; Keilah Betts <betts@psblaw.com>
+Subject: Re: Jane Doe (1:20-cv-00484-JGK-DCF)
+Friday works for us to speak. We sent our discovery materials yesterday. In the meantime, we Will mark Mr. Indyke's
+deposition off the calendar subject to whatever new schedule we all reach.
+Bennet J. Moskowitz*
+Partner
+troutman pepper
+Direct: 212.704.6087
+bennet.moskowitz@troutman.com
+*Licensed to practice law in New York and Connecticut
+On Jul 13, 2020, at 12:19 PM, Laura Menninger <Imenninger@hmflaw.com> wrote:
+EXTERNAL SENDER
+I am free Wednesday afternoon and all day Friday, presuming I have received the current discovery and disclosures by
+then.
+Laura A. Menninger Partner
+Haddon,
+, P.C.
+150 E. 10th Avenue | Denver, CO 80203
++1 303 831 7364 (Office)
+Imenninger@hmflaw.com
+From: Moskowitz, Bennet J. <Bennet.Moskowitz@troutman.com>
+Sent: Monday, July 13, 2020 10:18 AM
+To: Laura Menninger <Imenninger@hmflaw.com>; Robert Glassman < glassman@psblaw.com>
+Cc: Nathan Werksman <werksman@psblaw.com>; Claudia Lomeli <lomeli@psblaw.com>;
+daniel.weiner@hugheshubbard.com; Metcalfe, Mary L
+<MaryGrace.Metcalfe@troutman.com>; Keilah Betts
+<betts@psblaw.com>
+Subject: Re: Jane Doe (1:20-cv-00484-JGK-DCF)
+Today we will send you discovery served by or to the Co-Executors and responses thereto. When can we all speak?
+Thanks,
+Bennet
+Bennet J. Moskowitz*
+3
+
+
+Case 1:20-cv-00484-JGK-DCF Document 56-1 Filed 07/16/20 Page 4 of 8
+Partner
+troutman pepper
+Direct: 212.704.6087
+bennet.moskowitz@troutman.com
+*Licensed to practice law in New York and Connecticut
+On Jul 13, 2020, at 12:07 PM, Laura Menninger <Imenninger@hmflaw.com> wrote:
+EXTERNAL SENDER
+I did not yet receive the disclosures or discovery. When can I expect those?
+Thank you,
+Laura
+Laura A. Menninger | Partner
+Haddon,
+. P.C.
+150 E. 10th Avenue | Denver, CO 80203
++1 303 831 7364 (Office)
+Imenninger@hmflaw.com
+From: Robert Glassman <glassman@psblaw.com>
+Sent: Friday, July 10, 2020 10:03 AM
+To: Laura Menninger <Imenninger@hmflaw.com>; 'Moskowitz, Bennet J.' <Bennet.Moskowitz@troutman.com>
+Cc: Nathan Werksman <werksman@psblaw.com>; Claudia Lomeli <lomeli@psblaw.com>;
+'daniel.weiner@hugheshubbard.com' <daniel.weiner@hugheshubbard.com>; Metcalfe, Mary
+<MaryGrace.Metcalfe@troutman.com>; Keilah Betts <betts@psblaw.com>
+Subject: RE: Jane Doe (1:20-cv-00484-JGK-DCF)
+Bennet, yes, the depositions that were scheduled yesterday are, as previously advised, being continued, and the doc
+requests that went along with them are withdrawn for now.
+Laura, we will get you the disclosures and discovery both propounded and answered thus far. Free to discuss the
+scheduling order next week.
+Thanks.
+Robert Glassman, Esq.
+Panish Shea & Boyle LLP
+11111 Santa Monica Boulevard, Suite 700
+Los Angeles, CA 90025
+Tel: (310) 477-1700
+
+
+Case 1:20-cv-00484-JGK-DCF Document 56-1 Filed 07/16/20 Page 5 of 8
+Fax: (310) 477-1699
+Email: glassman@psblaw.com
+Web: www.psblaw.com
+CONFIDENTIALITY NOTICE:
+This e-mail may contain confidential and privileged material for the sole use of the intended recipients). Any review, use,
+distribution or disclosure by others is strictly prohibited. If you are not the intended recipient (or authorized to receive for the
+recipient), please contact the sender by reply e-mail or telephone, and delete all copies of this message.
+If you are a potential client, the information you disclose to us by email will be kept in strict confidence and will be protected to the
+full extent of the law. Please be advised, however, that Panish Shea & Boyle LLP and its lawyers do not represent you until you have
+signed a retainer agreement with the firm. Until that time, you are responsible for any statutes of limitations or other deadlines for
+your case or potential case.
+From: Laura Menninger [mailto:Imenninger@hmflaw.com]
+Sent: Friday, July 10, 2020 8:53 AM
+To: 'Moskowitz, Bennet J.' <Bennet.Moskowitz@troutman.com>; Robert Glassman <glassman@psblaw.com>
+Cc: Nathan Werksman <werksman@psblaw.com>; Claudia Lomeli <lomeli@psblaw.com>;
+'daniel. weiner@hugheshubbard.com' <daniel. weiner@hugheshubbard.com>; Metcalfe, Mary
+<MaryGrace.Metcalfe@troutman.com>; Keilah Betts <betts@psblaw.com>
+Subject: RE: Jane Doe (1:20-cv-00484-JGK-DCF)
+Counsel -
+Given my appearance in the case, please provide me with your R. 26 disclosures, any discovery requests that have been
+propounded in the matter, and any responses thereto.
+I will need to confer with you next week about my anticipated request for relief from the scheduling order to the extent
+it contemplated deadlines that passed or are soon approaching, all scheduled prior to my client's service in this case.
+Thank you,
+Laura
+Laura A. Menninger Partner
+Haddon,
+1. P.C.
+150 E. 10th Avenue | Denver, CO 80203
++1 303 831 7364 (Office)
+Imenninger@hmflaw.com
+From: Moskowitz, Bennet J. <Bennet.Moskowitz@troutman.com>
+Sent: Friday, July 10, 2020 7:31 AM
+To: Robert Glassman <glassman@psblaw.com>
+Cc: Nathan Werksman <werksman@psblaw.com>; Claudia Lomeli <lomeli@psblaw.com>;
+'daniel.weiner@hugheshubbard.com' <daniel.weiner@hugheshubbard.com>; Metcalfe, Mary
+<MaryGrace.Metcalfe@troutman.com>; Keilah Betts <betts@psblaw.com>; Laura Menninger
+<lmenninger@hmflaw.com>
+Subject: RE: Jane Doe (1:20-cv-00484-JGK-DCF)
+Robert,
+5
+
+
+Case 1:20-cv-00484-JGK-DCF Document 56-1
+Filed 07/16/20 Page 6 of 8
+Again, please confirm you are withdrawing the document requests in the deposition notices. We do not want
+to have to burden Judge Freeman with this issue.
+I have added Laura Menninger to this email chain given her appearance in this action.
+Thank you,
+Bennet
+Bennet J. Moskowitz*
+Partner
+troutman pepper
+Direct: 212.704.6087
+bennet.moskowitz@troutman.com
+*Licensed to practice law in New York and Connecticut
+From: Moskowitz, Bennet J.
+Sent: Wednesday, July 8, 2020 3:00 PM
+To: 'Robert Glassman' <glassman@psblaw.com>
+Cc: Nathan Werksman <werksman@psblaw.com>; Claudia Lomeli <lomeli@psblaw.com>;
+'daniel. weiner@hugheshubbard.com' < daniel. weiner@hugheshubbard.com>; Metcalfe, Mary
+<MaryGrace.Metcalfe@troutman.com>; Keilah Betts <betts@psblaw.com>
+Subject: RE: Jane Doe (1:20-cv-00484-JGK-DCF)
+We did not receive anything. Also, please confirm you are withdrawing the document requests in the deposition
+notices.
+Bennet J. Moskowitz*
+Partner
+troutman pepper
+Direct: 212.704.6087
+bennet.moskowitz@troutman.com
+*Licensed to practice law in New York and Connecticut
+From: Robert Glassman <glassman@psblaw.com>
+Sent: Wednesday, July 8, 2020 2:57 PM
+To: Metcalfe, Mary
+<MaryGrace.Metcalfe@troutman.com>; Keilah Betts <betts@psblaw.com>;
+'daniel.weiner@hugheshubbard.com' <daniel.weiner@hugheshubbard.com>; Moskowitz, Bennet J.
+<Bennet.Moskowitz@troutman.com>
+Cc: Nathan Werksman <werksman@psblaw.com>; Claudia Lomeli <lomeli@psblaw.com>
+Subject: RE: Jane Doe (1:20-cv-00484-JGK-DCF)
+EXTERNAL SENDER
+Mary
+, supplemental responses were served on you and Bennet yesterday by email per our agreement. Looks like
+they were sent at 5:05 PST. Let us know if you need us to re-send them to you.
+
+
+Case 1:20-cv-00484-JGK-DCF Document 56-1 Filed 07/16/20 Page 7 of 8
+As we discussed on our call, the depositions set for tomorrow were taken off calendar and are being rescheduled at a
+later date.
+Robert Glassman, Esq.
+Panish Shea & Boyle LLP
+11111 Santa Monica Boulevard, Suite 700
+Los Angeles, CA 90025
+Tel: (310) 477-1700
+Fax: (310) 477-1699
+Email: glassman@psblaw.com
+Web: www.psblaw.com
+CONFIDENTIALITY NOTICE:
+This e-mail may contain confidential and privileged material for the sole use of the intended recipient(s). Any review, use,
+distribution or disclosure by others is strictly prohibited. If you are not the intended recipient (or authorized to receive for the
+recipient), please contact the sender by reply e-mail or telephone, and delete all copies of this message.
+If you are a potential client, the information you disclose to us by email will be kept in strict confidence and will be protected to the
+full extent of the law. Please be advised, however, that Panish Shea & Boyle LLP and its lawyers do not represent you until you have
+signed a retainer agreement with the firm. Until that time, you are responsible for any statutes of limitations or other deadlines for
+your case or potential case.
+From: Metcalfe, Mary
+[mailto:MaryGrace.Metcalfe@troutman.com]
+Sent: Wednesday, July 08, 2020 11:31 AM
+To: Keilah Betts <betts@psblaw.com>; 'daniel. weiner@hugheshubbard.com' <daniel.weiner@hugheshubbard.com>;
+Moskowitz, Bennet J. <Bennet.Moskowitz@troutman.com>
+Cc: Robert Glassman <glassman@psblaw.com>; Nathan Werksman <werksman@psblaw.com>; Claudia Lomeli
+<lomeli@psblaw.com>
+Subject: RE: Jane Doe (1:20-cv-00484-JGK-DCF)
+Robert,
+We have reviewed the subpoena below. It is accompanied a notice of deposition, similar to those issued alongside the
+subpoenas you sent us in April. As we noted then, such notices of deposition are improper. Please let us know if you
+will withdraw this one as you did its predecessors.
+Furthermore, you have included document requests without specifying a response date. Please clarify that point.
+Finally, you indicated last week that we could expect to receive supplemental discovery responses addressing the
+concerns we raised in our letter last month. We have yet to receive these responses. Please send them immediately.
+Thank you,
+Mary
+W. Metcalfe
+Associate
+troutman pepper
+Direct: 212.704.6029 | Mobile: 425.984.4165
+marygrace.metcalfe@troutman.com
+7
+
+
+Case 1:20-cv-00484-JGK-DCF Document 56-1 Filed 07/16/20 Page 8 of 8
+From: Keilah Betts <betts@psblaw.com>
+Sent: Monday, June 15, 2020 4:40 PM
+To:'daniel.weiner@hugheshubbard.com' <daniel.weiner@hugheshubbard.com>; Moskowitz, Bennet J.
+<Bennet.Moskowitz@troutman.com>
+Cc: Robert Glassman <glassman@psblaw.com>; Nathan Werksman <werksman@psblaw.com>; Claudia Lomeli
+<lomeli@psblaw.com>
+Subject: Jane Doe (1:20-cv-00484-JGK-DCF)
+Importance: High
+EXTERNAL SENDER
+Counsel - Attached please find the Deposition Notice and Subpoena for Darren Indyke.
+Mr. Weiner - Per a previous conversation with Attorney Werksman, you are willing to accept service of the subpoena on
+behalf of your client, Mr. Darren Indyke. Please acknowledge receipt of this e-mail. Thank you
+Keilah Betts
+Panish Shea & Boyle LLP
+11111 Santa Monica Boulevard, Suite 700
+Los Angeles, CA 90025
+Tel: (310) 477-1700
+Fax: (310) 477-1699
+Email: betts@psblaw.com
+Web: www.psblaw.com
+CONFIDENTIALITY NOTICE:
+This e-mail may contain confidential and privileged material for the sole use of the intended recipients). Any review, use,
+distribution or disclosure by others is strictly prohibited. If you are not the intended recipient (or authorized to receive for the
+recipient), please contact the sender by reply e-mail or telephone, and delete all copies of this message.
+If you are a potential client, the information you disclose to us by email will be kept in strict confidence and will be protected to the
+full extent of the law. Please be advised, however, that Panish Shea & Boyle LLP and its lawyers do not represent you until you have
+signed a retainer agreement with the firm. Until that time, you are responsible for any statutes of limitations or other deadlines for
+your case or potential case.
+This e-mail (and any attachments) from a law firm may contain legally privileged and confidential information
+solely for the intended recipient. If you received this message in error, please notify the sender and delete it.
+Any unauthorized reading, distribution, copying, or other use of this e-mail (and attachments) is strictly
+prohibited. We have taken precautions to minimize the risk of transmitting computer viruses, but you should
+scan attachments for viruses and other malicious threats; we are not liable for any loss or damage caused by
+viruses.
+8

vision-fixhub/court-01/aab0673f361474330755b66d67bf69bd5bb3317f77d4629c0485e90fe328449b.receipt.json

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+}

vision-fixhub/court-01/aabbbe156df390eef8c7a2ee0eb0b7caae41ea6a9e52acee16c8c3c07ea3d2a0.md

@@ -0,0 +1,341 @@
+Case 9:08-cv-80119-KAM Document 233 Entered on FLSD Docket 07/30/2009 Page 1 of 9
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+JANE DOE NO.2,
+Plaintiff,
+CASE NO.; 08-CV-80119-MARRAJ
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO.3,
+Plaintiff,
+CASE NO.; 08-CV-80232-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO.4,
+Plaintiff,
+CASE NO.; 08-CV-80380-MARRA/JOHNSON
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 5,
+Plaintiff,
+CASE NO.; 08-CV-80381-MARRA/|
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+
+
+Case 9:08-cv-80119-KAM Document 233 Entered on FLSD Docket 07/30/2009 Page 2 of 9
+Page 2
+JANE DOE NO. 6,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 7,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+C.M.A.,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN, et al.,
+Defendants.
+DOE II,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN, et al,
+CASE NO.; 08-CV-80994-MARRA/JOHNSON
+CASE NO.; 08-CV-80993-MARRA/
+CASE NO.; 08-CV-80811-MARRA/JOHNSON
+CASE NO.; 08-CV-80893-MARRA/
+CASE NO.; 08-CV-80469-MARRA/JOHNSON
+2
+
+
+Case 9:08-cv-80119-KAM Document 233 Entered on FLSD Docket 07/30/2009 Page 3 of 9
+Page 3
+Defendants.
+JANE DOE NO. 101,
+Plaintiff,
+CASE NO.; 08-CV-80591-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 102,
+Plaintiff,
+CASE NO.; 08-CV-80656-MARRA1
+vS.
+JEFFREY EPSTEIN,
+Defendant.
+Defendant, Jeffrey Epstein's Response in Opposition to Jane Doe Numbers 2-7 Notice Of
+Joinder In Plaintiffs' Jane Does 101 and 102's Motion for No-Contact Order, with
+Incorporated Memorandum of Law
+Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN") by and through his
+undersigned attorneys, hereby files his Response in Opposition to Jane Doe Numbers 2-7 Notice
+of Joinder In Plaintiffs' Jane Does 101 and 102's Motion for No-Contact Order, with
+Incorporated Memorandum of Law. In support, EPSTEIN states:
+I.
+Introduction
+1. Jane Doe 101 and 102 filed their Motion for No-Contact Order on May 22, 2009. (DE
+113).
+3
+
+
+Case 9:08-cv-80119-KAM Document 233 Entered on FLSD Docket 07/30/2009 Page 4 of 9
+Page 4
+2. Epstein filed his Response In Opposition to the Motion for No Contact Order on May 29,
+2009. (DE 127). The arguments set forth in the Response In Opposition to the Motion for No-
+Contact Order are incorporated herein by reference as if same were outlined herein.
+3. Jane Doe 101 and 102 filed their Reply to Epstein's Response to their Motion for No-
+Contact Order on June 4, 2009. (DE 136).
+4. On June 8, 2009, Jane Doe Numbers 2-7 filed their Notice of Joinder in Plaintiffs' Jane
+Does 101 and 102's Motion for No-Contact Order. (DE 45)(the "Notice of Joinder").
+Il. Response
+5. The Notice of Joinder is unwarranted and simply a waste of attorney time and judicial
+resources. However, it does once again telegraph for this court Plaintiffs' collective efforts to
+stall this case by any means possible.
+6. The Notice of Joinder is riddled with inaccuracies and misstatements. For example,
+has not been asked to gather any information relative to Jane Doe 4 and Jane Doe
+7. See Affidavit of
+, Exhibit "A". Moreover,
+only spoke to Jane
+Doe 7 when approached by her and her boyfriend at a local West Palm Beach bar. Id. At that
+time,
+told Jane Doe 7 that she "I] could not believe she was bringing a lawsuit
+against Jeffrey Epstein, as
+knew] she has taken money from a number of older
+men and even traveled to Chicago with one of them." Id.
+also told Jane Doe 7
+that she intended to tell the truth about everything she knew about Jane Doe 7 and her escapades
+with other men. Id. As such, any contact was initiated by Jane Doe 7 in a public forum.
+7. It is clear from the attached Affidavit that at least Jane Does 4 and 7 have made
+misstatements in order to stall this case. As to Jane Doe numbers 2, 3, 5, and 6, no supporting
+4
+
+
+Case 9:08-cv-80119-KAM Document 233 Entered on FLSD Docket 07/30/2009 Page 5 of 9
+Page 5
+allegations exist to substantiate the entry of any such order. Plaintiffs simply make much to do
+about nothing.
+8. For the reasons set forth herein and in Epstein's Response Motion (DE 127), Epstein asks
+that this Court deny Plaintiff's Notice/Motion for No-Contact Order.
+Wherefore, Defendant, Jeffrey Epstein, requests that this court deny the Notice/Motion for
+No-Contact Order, and for such other and further reliefs this Court deems just and proper.
+By c
+MICHAEL J.PIKE, ESQ.
+Florida Bar #617296
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
+need this day on all ouce of record da tre on he following service lit in the
+manner specified by CM/ECF on this 30 day of
+Respectfully submitted,
+By:
+ROBERTID. CRITTON, JR., ESQ
+Florida Bar No. 224162
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER & COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Counsel for Defendant Jeffrey Epstein)
+5
+
+
+Case 9:08-cv-80119-KAM Document 233 Entered on FLSD Docket 07/30/2009 Page 6 of 9
+Page 6
+Certificate of Service
+Jane Doe No. 2 v. Jeffrey Epstein
+Case No. 08-CV-80119-MARRA/JOHNSON
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Brad
+, Esq.
+Rothstein Rosenfeldt Adler
+Mermelstein & Horowitz, P.A.
+401 East Las Olas Boulevard
+18205 Biscayne Boulevard
+Suite 1650
+Suite 2218
+Fort Lauderdale, FL 33301
+Miami, FL 33160
+Phone: 954-522-3456
+305-931-2200
+Fax: 954-527-8663
+Fax: 305-931-0877
+bedwards@rra-law.com
+ssm@sexabuseattorney.com
+Counsel for Plaintiff in Related Case No.
+ahorowitz@sexabuseattorney.com
+08-80893
+Counsel for Plaintiffs
+In related Cases Nos. 08-80069, 08-
+80119, 08-80232, 08-80380, 08-80381,
+Paul G. Cassell, Esq.
+08-80993, 08-80994
+Pro Hac Vice
+332 South 1400 E, Room 101
+Richard Horace Willits, Esq.
+Salt Lake City, UT 84112
+Richard H. Willits, P.A.
+801-585-5202
+2290 10* Avenue North
+801-585-6833 Fax
+Suite 404
+cassellp@law.utah.edu
+Lake Worth, FL 33461
+Co-counsel for Plaintiff Jane Doe
+561-582-7600
+Fax: 561-588-8819
+Counsel for Plaintiff in Related Case No.
+Isidro. M.
+1, Esq.
+• Law Firm, P.A.
+08-80811
+224 Datura Street, Suite 900
+reelrhw@hotmail.com
+West Palm Beach, FL 33401
+561-832-7732
+561-832-7137 F
+Jack Scarola, Esq.
+isidrogarcia@bellsouth.net
+Jack P.
+1, Esq.
+Counsel for Plaintiff in Related Case No.
+Searcy Denney
+Scarola Barnhart
+& 08-80469
+Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33409
+561-686-6300
+Fax: 561-383-9424
+isx@searcylaw.com
+jph@searcylaw.com
+Counsel for Plaintiff, C.M.A.
+Robert C. Josefsberg, Esq.
+Katherine W. Ezell, Esq.
+Podhurst Orseck, P.A.
+25 West Flagler Street, Suite 800
+Miami, FL 33130
+305 358-2800
+Fax: 305 358-2382
+6
+
+
+Case 9:08-cv-80119-KAM Document 233 Entered on FLSD Docket 07/30/2009 Page 7 of 9
+Page 7
+Bruce Reinhart, Esq.
+Bruce E. Reinhart, P.A.
+250 S. Australian Avenue
+Suite 1400
+West Palm Beach, FL 33401
+561-202-6360
+Fax: 561-828-0983
+ecf@brucereinhartlaw.com
+Counsel for Defendant
+Theodore J. Leopold, Esq.
+Spencer T. Kuvin, Esq.
+Ricci-Leopold, P.A
+2925 PGA Blvd., Suite 200
+Palm Beach Gardens, FL 33410
+561-684-6500
+Fax: 561-515-2610
+Counsel for Plaintiff in Related Case No.
+08-08804
+skuvin@riccilaw.com
+tleopold@riccilaw.com
+rjosefsberg@podhurst.com
+kezell@podhurst.com
+Counsel for Plaintiffs in Related Cases
+Nos. 09-80591 and 09-80656
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Counsel for Defendant Jeffrey Epstein
+7
+
+
+Case 9:08-cV-80119-KAM Document 233 Entered on FLSD Docket 07/30/2009 Page 8 of 9
+IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR
+PALM BEACH COUNTY FLORIDA
+CASE NO. 502008CA006596XXXXMB
+JANE DOE,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+and
+Defendants.
+/
+AFFIDAVIT OF
+STATE OF FLORIDA
+COUNTY OF PALM BEACH
+BEFORE ME, the undersigned authority, personally appeared
+, who after being first duly sworn, deposes and says:
+4.
+5.
+My name is
+I am and have been represented by McIntosh, Sawran, Peltz & Cartaya, P.A.
+I was a Defendant in the case styled, Jane Doe v. Jeffrey Epstein.
+and
+1. Case No. 502008CA006596XXXXMB AB.
+I have read the document entitled " Plaintiffs Jane Does' 2-7 Notice of Joinder
+in Plaintiffs' Jane Does 101 and 102's Motion for No-Contact Order."
+I am writing this affidavit in response to the statements within the motion that
+refer to me.
+I have not had any contact with Jeffrey Epstein since he was arrested.
+I have not been asked by Mr. Epstein or his attorneys to gather information
+about Jane Doe 4 and Jane Doe 7.
+A
+
+
+Case 9:08-cv-80119-KAM Document 233 Entered on FLSD Docket 07/30/2009 Page 9 of 9
+I am not being supported by Mr. Epstein nor did I say that to Jane Doe 4 and
+7.
+Based on the statements within the motion, I can identify Jane Doe 7 and only
+spoke to her when she and her boyfriend approached and confronted me at Dr.
+Feelgood's.
+10.
+When Jane Doe 7 and her boyfriend confronted me, I told her that I could not
+believe she was bringing a lawsuit against Jeffrey Epstein, as I know that she
+has taken money from a number of older men and even traveled to Chicago
+with one of them.
+11.
+I also told Jane Doe 7 and her boyfriend that I intended to tell the truth about
+everything I know about her and what she has done with other men.
+12. I will tell the truth about Mr. Epstein, Jane Doe 4, Jane Doe 7 or anyone else
+that I am asked about. I resent any suggestion that I would lie to assist Mr.
+Epstein.
+FURTHER AFFIANT SAYETH NAUGHT.
+SWORN TO AND SUBSCRIBED before me this and
+day of July
+2009, by Halen Roon
+(name of person), who is personally
+known to me or who has produced fL Drivers License
+(type of
+identification) as identification.
+Cheme Hurles:
+SIGNATURE OF NOTARY
+Netary Poole slale a Fionda
+Cheryl A Hughes
+My Commission DD592524
+Expires 09/06/2010
+PRINTED NAME OF NOTARY

vision-fixhub/court-01/aabbbe156df390eef8c7a2ee0eb0b7caae41ea6a9e52acee16c8c3c07ea3d2a0.receipt.json

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+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "fdba108c807cbf544d978f50216dec54662f75056f1a4d8601661f5ec171e27f",
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+}

vision-fixhub/court-01/aabd56d98609cf94f62ad220573f4890de42ff25caac0f98b0db572c0e722f25.md

@@ -0,0 +1,248 @@
+Case 9:08-cv-80736-KAM Document 244 Entered on FLSD Docket 10/28/2013 Page 1 of 9
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No. 08-80736-Civ-Marra/
+JANE DOE #1 and JANE DOE #2
+V.
+UNITED STATES
+JANE DOE #1 AND JANE DOE #2'S REPLY IN SUPPORT OF RENEWED MOTION
+FOR AN ORDER DIRECTING THE U.S. ATTORNEY'S OFFICE
+NOT TO WITHHOLD RELEVANT EVIDENCE
+COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and
+through undersigned counsel, to file this reply in support of their Motion for an Order Directing
+the U.S. Attorney's Office Not to Withhold Relevant Evidence (DE 50, renewed in DE 226), in
+light of the Government's response (DE 230). The Government's response confirms each of the
+victims' arguments in support of their motion, specifically (1) that the Government's privilege
+log is grossly inadequate; (2) the CVRA's requirement that the Government exercise its "best
+efforts" to protect crime victims' rights requires the production of the withheld documents; and
+(3) the CVRA creates a right to access to documents that support their position, just as criminal
+defendants have a right to access such documents. For each of these reasons, the Court should
+grant the victims' motion and provide the materials that it has received in camera to the victims.
+THE GOVERNMENT'S PRIVILEGE LOG IS GROSSLY INADEQUATE.
+In their motion, the victims explained that the Government has substantially violated the
+Court's order to provide an appropriate privilege log in connection with the disputed documents.
+1
+
+
+Case 9:08-cv-80736-KAM Document 244 Entered on FLSD Docket 10/28/2013 Page 2 of 9
+DE 226 at 6-12. The victims gave four specific illustrations of the inadequacies. The
+Government has now responded, but its response only reinforces the fact that it has properly
+invokes privilege in this case.
+As an illustration of the inadequacies, the victims offered the example of the
+Government's failure to identify any documents among the 13,468 pages that it is withholding
+that concern AUSA Bruce Reinhart's internal knowledge about the Epstein prosecution before he
+left the U.S. Attorney's Office and became employed by Epstein. DE 226 at 8-9. The victims
+pointed out that the Government had admitted, in its response to the request for admission (RFA)
+#22, that
+"The Justice Department's Office of Professional Responsibility and/or other
+Government entities have collected information about ... Bruce Reinhart's possible involvement
+in the Epstein matter." The victims wondered where that "collected information" was among the
+thousands of pages, since none of the document descriptions even contains the word "Reinhart."
+In its response, the Government says that the "fallacy" in the victims'
+"reasoning is the assumption that the basis for the government's response to the request for
+admission was a document, rather than a personal observation. If it was based on the latter, there
+would be no document to produce." DE 230 at 3 (emphasis added). So which is it? Was the
+Government's answer based solely on a "personal observation" or not? There is simply no way
+to tell, even after reading the Government's response to the victims' motion. If the Government
+is taking the position that it does not have even a single document in its possession regarding the
+Reinhart issue, they should be required to state that forthrightly. The victims' would note that
+this would be remarkable, since the Reinhart issue was specifically brought to the attention of the
+Justice Department's Office of Professional Responsibility (OPR) - and presumably triggered at
+2
+
+
+Case 9:08-cv-80736-KAM Document 244 Entered on FLSD Docket 10/28/2013 Page 3 of 9
+least some kind of analysis of the issue. Yet, once again, it is impossible to tell where the
+Government is asserting privilege over Reinhart documents or staking out the extraordinary
+position that it does not have even a single document with the word "Reinhart" in it anywhere.
+The victims similarly raised the point about other attorneys apart from Reinhart. The
+victims noted that, in the Government's answers to RFA #22(b), it admitted that "It]he Justice
+Department's Office of Professional Responsibility and/or other Government entities have
+collected information about ... [o]ther government [attorneys'].. • possible improper behavior
+in the Epstein matter." In response, the Government says that the victims have made a
+"fallacious assumption" that such other information about, for example, former AUSA Matt
+Menchel would be contained in a document, because the information "need not have been based
+upon a document." DE 230 at 3-4. Here again, the Government deliberately leaves ambiguous
+whether or not it is saying there are no such documents. And here again, it would be truly
+remarkable if the Government, while "collect|ing] information" about such subjects did not
+produce even a single written document. If so, this might well be the first federal investigation
+in history in which federal investigators did not bother to take any notes!
+The victims also noted that while it appeared that OPR had inquired into the possible
+wrongdoing by government prosecutors, none of the underlying factual information regarding
+those inquiries appears to have been produced. DE 226 at 10. In response, the Government says
+that it has properly invoked privilege over the OPR documents. DE 230 at 4. Here again, the
+Government ducks the issue. The victims contend that they cannot tell which of the thousands of
+pages of documents that the Government is withholding contain the factual information that OPR
+collected regarding improper government behavior. The Government's privilege log shows
+3
+
+
+Case 9:08-cv-80736-KAM Document 244 Entered on FLSD Docket 10/28/2013 Page 4 of 9
+certain correspondence about OPR inquiries; but the log does not reveal any underlying
+substantive information that was "collected" during the OPR investigation. Where in the log is
+the information that was collected?
+The declaration from Robin C. Ashton, Counsel of OPR, only deepens the mysteries
+swirling around the Government's privilege log. For example, Ashton asserts "deliberative
+process" privilege over allegedly internal communications that were designed to "finalize" a
+letter that was to be sent to U.S. Attorney Ferrer. DE 243-1 at 5-6 (arguing that certain
+documents were "part of the internal deliberations to finalize the letter|] to U.S. Attorney
+Ferrer"). Yet this assertion of privilege obviously implies that there was a final letter delivered
+to U.S. Attorney Ferrer - a final letter over which "deliberative" process obviously could not be
+invoked. See DE 225 at 4 (noting that "[a]ny deliberative process privilege would only cover ...
+the processes by which a decision was made, not the final decision itself") (citing NLRB v. Sears
+Roebuck & Co., 421 U.S. 132, 151-52 (1975)). But victims cannot find any description of a final
+letter sent to U.S. Attorney Ferrer anywhere in the privilege log.
+As a fourth and final illustration of the inadequacies of the Government's privilege log,
+the victims pointed out that it appeared that the Government was claiming that there is no a
+single document - no email, no investigative report, no grand jury information, no record of any
+type - existing in the Middle District of Florida after the Southern District of Florida was recused
+from handling certain aspects of this case. DE 226 at 10-11. In response, the Government evades
+the issue, stating that "the USAO-MDFL assumed responsibility for the Epstein case, and
+exercises its own independent judgment and discretion about what action to take, if any." DE
+230 at 6. Is the Government really saying that there not a single responsive document exists in
+4
+
+
+Case 9:08-cv-80736-KAM Document 244 Entered on FLSD Docket 10/28/2013 Page 5 of 9
+the Middle District of Florida. Neither its privilege log nor its response to the victims" motion
+clarifies what the Government's position truly is.
+The victims offered these four illustrations as evidence of pervasive inadequacies in the
+Government's privilege log. In view of these inadequacies, the Court should provide all the
+documents covered by the Government's privilege log to the victims.
+Il.
+THE CVRA'S BEST EFFORTS REQUIREMENT CREATES A FIDUCIARY
+EXCEPTION TO ALL PRIVILEGES.
+The victims have also asked the Court to provide all the withheld documents to them on
+grounds that the CVRA's "best efforts" provision creates a fiduciary exception to any applicable
+privileges. In response, the Government hangs its hat on a single case: United States v. Jicarilla
+Apache Nation, 131 S.Ct. 2313 (2011). There, an Indian tribe argued that it was entitled to
+receive attorney-client privileged information about the handling of certain moneys held in trust
+by the Government because of "common-law trust principles." Id. at 2325. In rejecting the
+tribe's claim, the Supreme Court held that "the Tribe must point to a right conferred by statute..
+• in order to obtain otherwise privilege information from the Government against its wishes."
+Id. (emphasis added). The Supreme Court found that the Tribe could point to no such statutory
+right within the American Indian Trust Fund Management Reform Act of 1994. Id. at 2325-30.
+Here, of course, the victims are not proceeding under an Indian trust fund statute, but
+rather the Crime Victims' Rights Act (CVRA), 18 U.S.C. § 3771. They have very specifically
+pointed to "a right conferred by statute" as the basis for obtaining the information in question.
+The victims have explained that the CVRA obligates government prosecutors to "make their best
+efforts to see that crime victims are ... accorded[] their rights" under the CVRA. 18 U.S.C. §
+5
+
+
+Case 9:08-cv-80736-KAM Document 244 Entered on FLSD Docket 10/28/2013 Page 6 of 9
+3771(c)(1). Throughout their pleadings, at great length, they have explained why this specific
+statutory requirement obligates the Government to produce information that would help ensure
+that they are accorded their rights under the CVRA, including a right to be treated with fairness
+that creates "due process" protections. See DE 226 at 12-17; see also Part III, infra; DE 50 at 3-
+5; DE 76 at 2-6.
+Moreover, even assuming as the Government argues in its brief, that "the Government
+seeks legal advice in a "personal' rather than a fiduciary capacity," DE 230 at 8 (citing Jicarilla
+Apache Nation, 131 S.Ct. at 2328), that does not obviate the more specific requirement here that
+it must use "best efforts" to protect crime victims' rights. The victims have explained in detail
+why production of the documents to them is the only course of action consistent with the
+Government's "best efforts" obligations. The victims, moreover, have not made any general
+claim, but only a specific claim that on the unique facts of this case the CVRA requires
+production of the documents. The Government does not even try to argue that withholding the
+documents in this case is somehow consistent with its CVRA best efforts obligations,
+presumably because no such argument would be plausible. For this reason as well, the Court
+should produce all the documents to the victims.
+III.THE VICTIMS HAVE A RIGHT UNDER THEIR CVRA'S "FAIRNESS" RIGHT
+TO RECEIVE THE DOCUMENTS.
+The victims finally argued in their motion that the CVRA's right "to be treated with
+fairness" entitled them to access to documents helpful to their case. DE 226 at 14-17. The
+victims noted that criminal defendants receive exculpatory information automatically from the
+Government, and the situation here requires analogous treatment.
+Id. In response, the
+6
+
+
+Case 9:08-cv-80736-KAM Document 244 Entered on FLSD Docket 10/28/2013 Page 7 of 9
+Government claims that the victims do not have a "liberty" or "property" interest sufficient to
+trigger a due process claim, citing various Fourteenth Amendment cases. DE 230 at 8-9. But,
+once again, the Government evades the issue. The victims indisputably have a statutory right
+under the CVRA to be "treated with fairness." If the Government is correct that the crime
+victims here lack a sufficient life, liberty, or property interest to invoke that right, then no crime
+victim in any case would ever be able to invoke that right. Surely, the right to fairness must
+mean something, particularly given that Senator Kyl, a CVRA co-sponsor, has directly stated
+that "ItJhe broad rights articulated in this section [§ 3771(a)(8)] are meant to be rights themselves
+and are not intended to just be aspirational. One of these rights is the right to be treated with
+fairness. Of course, fairness includes the notion of due process. Too often victims of crime
+experience a secondary victimization at the hands of the criminal justice system. This provision
+is intended to direct Government agencies and employees, whether they are in executive or
+judiciary branches, to treat victims of crime with the respect they deserve." 150 Cong. Rec.
+S4269 (Apr. 22, 2004).
+The Government never even claims that it could somehow be "fair" to the victims for the
+Government to withhold information that would allow the victims to prove their case,
+particularly where the Government has repeatedly refused to stipulate to the relevant facts
+surrounding the victims' treatment. See DE 225-1 at 1-6 (affidavit recounting the Government's
+repeated efforts to block a stipulation concerning relevant facts). The victims have persuasively
+explained why their congressionally-recognized right to "fairness" requires the relevant
+documents be produced to them. For this reason as well, the Court should produce to the victims
+all of the documents that the Government is withholding on grounds of privilege.
+7
+
+
+Case 9:08-cv-80736-KAM Document 244 Entered on FLSD Docket 10/28/2013 Page 8 of 9
+CONCLUSION
+The Court should enter an order directing the Government not to withhold material
+evidence in this case and should provide to the victims the materials it has received for in camera
+review.
+In addition, to solve the problem that the Government has not indicated which
+documents apply to which requests, the Government should be required to provide such a
+responsive document.
+DATED: October 28, 2013
+Respectfully Submitted,
+/s/
+JAFFE, WEISSING,
+1. FISTOS & LEHRMAN, P.L.
+425 North Andrews Avenue, Suite 2
+and
+Paul G. Cassell
+ro Hac Vic
+J. Quinney College of Law at th
+University of Utah
+332 S. 1400 E.
+Salt Lake City, UT 84112
+Telephone: (801) 585-5202
+Facsimile: (801) 585-6833
+E-Mail: cassellp@law.utah.edu
+Attorneys for Jane Doe #1 and Jane Doe #2
+8
+
+
+Case 9:08-cv-80736-KAM Document 244 Entered on FLSD Docket 10/28/2013 Page 9 of 9
+CERTIFICATE OF SERVICE
+I certify that the foregoing document was served on October 28, 2013, on the following
+using the Court's CM/ECF system:
+Dexter Lee
+A.
+Villafaña
+500 S. Australian Ave., Suite 400
+West Palm Beach, FL 33401
+Telephone: (561) 820-8711
+Facsimile: (561) 820-8777
+E-mail: Dexter.Lee @usdoj.gov
+E-mail:
+Attorneys for the Government
+Roy Black, Esq.
+Jackie Perczek, Esq.
+Black, Srebnick, Kornspan & Stumpf, P.A.
+201 South Biscayne Boulevard, Suite 1300
+Miami, FL 33131
+Telephone: (305) 37106421
+Email: pleading@royblack.com
+Jay P. Lefkowitz
+Kirkland & Ellis, LLP
+601 Lexington Avenue
+New York, NY 10022
+Telephone: (212) 446-4970
+Email: lefkowitz@kirkland.com
+G. Weinberg, P.C.
+20 Park Plaza, Suite 1000
+Boston, 02116
+Telephone: (617) 338-9538
+Email: owlmgw@att.net
+Criminal Defense Counsel for Jeffrey Epstein
+Is/l
+J.

vision-fixhub/court-01/aabd56d98609cf94f62ad220573f4890de42ff25caac0f98b0db572c0e722f25.receipt.json

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vision-fixhub/court-01/aadc65cc9e6a37876523ff82cc24a115588cc669867dca791f7b6510134ee0e5.md

@@ -0,0 +1,47 @@
+Filing # 109662729 E-Filed 07/01/2020 12:21:07 PM
+IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
+IN AND FOR PALM BEACH COUNTY, FLORIDA
+CA FLORIDA HOLDINGS, LLC,
+Publisher of the PALM BEACH POST,
+Plaintiff,
+V.
+DAVE ARONBERG, as State Attorney of
+Palm Beach County, Florida; SHARON R
+BOCK, as Clerk and Comptroller of Palm
+Beach County, Florida.
+Defendants.
+/
+COPY
+CASE NO.: 19-CA-014681
+DEFENDANT, DAVE ARONBERG'S MOTION FOR ATTORNEYS' FEES
+Defendant, DAVE ARONBERG, as State Attorney of Palm Beach County, Florida, by and
+through the undersigned attorneys, moves the Court, pursuant to Florida Statutes, Section 57.105,
+to award him reasonable attorneys' fees for the defense of Plaintiff's First Amended Complaint,
+(the "Complaint"), and as grounds therefor, would show that on June 8, 2020, Plaintiff was served
+a copy of this Motion, together with a letter from the undersigned attorney, in accordance with
+subsection (4) of the above Statute, demanding dismissal of the Complaint, at least 21 days prior
+to the filing of this Motion. In said letter, Defendant's attorney advised Plaintiff of the facts which
+establish that the Complaint is without support of the facts or the law.
+WHEREFORE, Defendant, DAVE ARONBERG, as State Attorney of Palm Beach
+County, Florida, respectfully requests the Court enter an Order requiring Plaintiff and Plaintiff's
+attorneys to pay said Defendant's attorneys' fees incurred herein after service of this Motion.
+*** FILED: PALM BEACH COUNTY, FL SHARON R BOCK, CLERK. 07/01/2020 12:21:07 PM ***
+
+
+CERTIFICATE OF SERVICE
+I hereby certify that on this 1st day July, 2020, the foregoing was electronically filed via
+the Florida E-File Portal for electronic service on the parties of record herein.
+SCHOLZ & WYLER, LLC
+Is/ Douglas A. Wyler
+Arthur I. L
+_. Esquire
+Fla. Bar No.: 108249
+Richard J. Scholz, Esquire
+Fla. Bar No.: 002126Y
+Douglas A. Wyler, Esquire
+Fla. Bar No.: 119979
+961687 Gateway Blvd., Suite 201-1
+Fernandina Beach, Florida 32034
+(904) 261-3693
+(904) 261-7879
+NOT A CERTAIN

vision-fixhub/court-01/aadc65cc9e6a37876523ff82cc24a115588cc669867dca791f7b6510134ee0e5.receipt.json

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vision-fixhub/court-01/ab148711ba83d2622312e2538d7b0e4215955d5f19678a3ad3de345da7d65f78.md

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+Case 9:08-cv-80736-KAM Document 195 Entered on FLSD Docket 06/27/2013 Page 1 of 1
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No. 08-80736-CIV-MARRA
+JANE DOE #1 and JANE DOE #2,
+Petitioners,
+VS.
+UNITED STATES OF AMERICA,
+Respondent.
+NOTICE OF APPEAL BY INTERVENOR JEFFREY EPSTEIN
+Intervenor Jeffrey Epstein hereby appeals to the United States Court of Appeals for the
+Eleventh Circuit from an Order Granting Petitioners' Motion to Proffer Government
+Correspondence in Support of CVRA Claims & Granting Motion to Unseal Correspondence and
+Related Unredacted Pleadings of Petitioners dated June 18, 2013 [DE 188], an Order Denying
+Government's Motion to Dismiss for Lack of Subject Matter Jurisdiction & Order Lifting Stay of
+Discovery dated June 19, 2013 [DE 189], and an Omnibus Order dated June 19, 2013 [DE 190].
+We certify that on June 27, 2013, the foregoing document was filed electronically with
+the Clerk of the Court using the CM/ECF system.
+By:
+Respectfully submitted,
+BLACK, SREBNICK, KORNSPAN
+& STUMPF, P.A.
+201 South Biscayne Boulevard
+Suite 1300
+Miami, Florida 33131
+Telephone (305) 371-6421
+Fax (305) 358-2006
+/sl
+ROY BLACK, ESQ.
+Florida Bar No. 126088
+Email: rblack@royblack.com
+JACKIE PERCZEK, ESQ.
+Florida Bar No. 042201
+Email: iperczek@royblack.com

vision-fixhub/court-01/ab148711ba83d2622312e2538d7b0e4215955d5f19678a3ad3de345da7d65f78.receipt.json

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+}

vision-fixhub/court-01/ab22d7c5a87785fba3604e153a42651912a48aa27b140bf45483e070f1b94cbb.md

@@ -0,0 +1,171 @@
+Case 9:08-cv-80119-KAM Document 371 Entered on FLSD Docket 10/26/2009 Page 1 of 4
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CIV-80119-MARRA/
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-08380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+DEFENDANT'S RE-NOTICE (DATE CHANGE ONLY) OF INDEPENDENT
+MEDICAL EXAMINATION OF PLAINTIFF, JANE DOE # 6(80994)
+Defendant, JEFFREY E. EPSTEIN, pursuant to Rule 35, Fed. R. Civ. P.., notices
+the Plaintiff for an independent/psychological medical examination and states:
+An appointment for examination of the Plaintiff has been made with Ryan
+I, M.D. of C.W.
+, M.D., P.A. at 9:00 a.m. on November 23, 2009 at Prose Court
+Reporting located at One Clearlake Centre, 250 Australian Avenue South, Suite #1500,
+West Palm Beach, FL, 33401. The Plaintiff is to wear comfortable clothing and bring a
+sweater. The examination shall consist of an interview and testing and will likely last
+until 5:30 p.m. See infra and Motion attached at DE (308) for scope, time and place of
+IME. See Exhibits attached as well.
+
+
+Case 9:08-cv-80119-KAM Document 371 Entered on FLSD Docket 10/26/2009 Page 2 of 4
+2.
+Plaintiff has not provided an available date; however, unless a timely and
+valid objection to this Notice is made, the Plaintiff is required by this Rule to be in
+attendance at the above-scheduled examination.
+3.
+Pursuant to Rule 35, if the psychiatrist performing the examination is
+called as a witness, the psychiatrist shall not be identified as one appointed by the Court.
+The cost of the examination will be originally borne by the Defendant but
+is subject to taxation by the Court upon proper motion.
+The interview will be videotaped.
+6. Dr. Halls' specialties and qualifications are attached to the Motion
+to Compel the IME at DE (308). The time, place, manner, conditions and scope
+of the examination are attached to the Motion to Compel the IME at DE (308).
+See Affidavit attached thereto. All of the above documents have been provided
+to the Plaintif's counsel and, therefore, sufficient notife had been made.
+By:
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed
+with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is
+being served this day on all counsel of record identified on the following Service List in
+the manner specified by CM/ECF on this 26* day of October, 2009
+Repetly substited,.
+ROBERT D. CRITTON, JR., ESQ.
+Florida Bat No 224162
+rcrit@bcldlaw.com
+
+
+Case 9:08-cv-80119-KAM Document 371 Entered on FLSD Docket 10/26/2009 Page 3 of 4
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER &
+COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Counsel for Defendant Jeffrey Epstein)
+Certificate of Service
+Jane Doe No. 2 v. Jeffrey Epstein
+Case No. 08-CV-80119-MARRA/J
+Stuart S. Mermelstein, Esq.
+LEsq.
+Adam D. Horowitz, Esq.
+Rothstein Rosenfeldt Adler
+Mermelstein & Horowitz, P.A.
+401 East Las Olas Boulevard
+18205 Biscayne Boulevard
+Suite 1650
+Suite 2218
+Fort Lauderdale, FL 33301
+Miami, FL 33160
+Phone: 954-522-3456
+305-931-2200
+Fax: 954-527-8663
+Fax: 305-931-0877
+edwards@rra-law.com
+ssm@sexabuseattorney.com
+Counsel for Plaintiff in Related Case No
+ahorowitz@sexabuseattorney.com
+08-80893
+Counsel for Plaintiffs
+In related Cases Nos. 08-80069, 08-80119,
+08-80232,
+, 08-80380, 08-80381, 08-80993, Paul G. Cassell, Esq.
+08-80994
+Pro Hac Vice
+332 South 1400 E, Room 101
+Richard Horace Willits, Esq.
+Salt Lake City, UT 84112
+Richard H. Willits, P.A.
+801-585-5202
+2290 10t Avenue North
+801-585-6833 Fax
+Suite 404
+cassellp@law.utah.edu
+Lake Worth, FL 33461
+Co-counsel for Plaintiff Jane Doe
+561-582-7600
+Fax: 561-588-8819
+Isidro M.
+Esq.
+Counsel for Plaintiff in Related Case No.
+08-80811
+224 Datura Street, Suite 900
+reelrhw@hotmail.com
+West Palm Beach, FL 33401
+Jack Scarola, Esq.
+Jack P.
+_ Esq.
+561-832-7137 F
+isidrogarcia@bellsouth.net
+Counsel for Plaintiff in Related Case No.
+
+
+Case 9:08-cv-80119-KAM Document 371 Entered on FLSD Docket 10/26/2009 Page 4 of 4
+Searcy Denney Scarola Barnhart & Shipley, 08-80469
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33409
+561-686-6300
+Fax: 561-383-9424
+isx(@searcylaw.com
+jph@searcylaw.com
+Counsel for Plaintiff, C.M.A.
+Robert C. Josefsberg, Esq.
+Katherine W. Ezell, Esq.
+Podhurst Orseck, P.A.
+25 West Flagler Street, Suite 800
+Miami, FL 33130
+305 358-2800
+Fax: 305 358-2382
+riosefsberg@podhurst.com
+kezell@podhurst.com
+Bruce Reinhart, Esq.
+Bruce E. Reinhart, P.A.
+250 S. Australian Avenue
+Suite 1400
+West Palm Beach, FL 33401
+561-202-6360
+Fax: 561-828-0983
+ecf@brucereinhartlaw.com
+Counsel for Defendant
+Counsel for Plaintiffs in Related Cases
+Nos. 09-80591 and 09-80656
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+Theodore J. Leopold, Esq.
+jagesq@bellsouth.net
+Spencer T. Kuvin, Esq.
+Counsel for Defendant Jeffrey Epstein
+Leopold, Kuvin, P.A.
+2925 PGA Blvd., Suite 200
+Palm Beach Gardens, FL 33410
+561-684-6500
+Fax: 561-515-2610
+Counsel for Plaintiff in Related Case No.
+08-08804

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@@ -0,0 +1,167 @@
+Case 9:08-cv-80119-KAM Document 115 Entered on FLSD Docket 05/27/2009 Page 1 of 6
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+JANE DOE NO.2,
+Plaintiff,
+CASE NO.; 08-CV-80119-MARRA/J|
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO.3,
+Plaintiff,
+CASE NO.; 08-CV-80232-MARRA/J
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO.4,
+Plaintiff,
+CASE NO.; 08-CV-80380-MARRA/]
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 5,
+Plaintiff,
+CASE NO.; 08-CV-80381-MARRA/]
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+
+
+Case 9:08-cv-80119-KAM Document 115 Entered on FLSD Docket 05/27/2009 Page 2 of 6
+Page 2
+JANE DOE NO. 6,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 7,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+C.M.A.,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE,
+Plaintiff,
+vS.
+JEFFREY EPSTEIN, et al.,
+Defendants.
+CASE NO.; 08-CV-80994-MARRA/
+CASE NO.; 08-CV-80993-MARRA/|
+CASE NO.; 08-CV-80811-MARRA/
+CASE NO.; 08-CV-80893-MARRA/_
+
+
+Case 9:08-cv-80119-KAM Document 115 Entered on FLSD Docket 05/27/2009 Page 3 of 6
+Page 3
+DOE II,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN, et al,
+Defendants.
+JANE DOE NO. 101,
+Plaintiff,
+CASE NO.; 08-CV-80469-MARRA/]
+CASE NO.; 08-CV-80591-MARRA/)
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 102,
+Plaintiff,
+CASE NO.; 08-CV-80656-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+DEFENDANT, EPSTEIN'S RESPONSE IN OPPOSITION TO PLAINTIFFS'
+JANE DOE'S 2 THROUGH 7, MOTION FOR ENLARGEMENT OF TIME
+TO RESPOND TO DEFENDANT'S MOTION TO COMPEL
+AND/OR IDENTIFY JANE DOE IN THE STYLE ET AL.
+Defendant, JEFFERY EPSTEIN, (EPSTEIN), by and through his undersigned
+attorneys, hereby files his Response in Opposition to Plaintiffs' Motion for Enlargement
+of Time to Respond to Epstein's Motion to Compel and/or Identify Jane Doe in the style
+
+
+Case 9:08-cv-80119-KAM Document 115 Entered on FLSD Docket 05/27/2009 Page 4 of 6
+Page 4
+of this case and Motion to Identify Jane Doe in Third-Party Subpoenas for purposes of
+Discovery, or alternatively Motion to Dismiss Sua Sponte, and states as follows:
+1.
+Epstein filed the Motion to Compel and/or Identify Jane Doe's 2 through
+7 on May 5, and 6, 2009.
+2.
+Plaintiffs' Response is due on May 22, 2009. While the undersigned
+counsel agreed that Plaintiffs could have an extension of time of one week to file and
+serve their opposition Motion (i.e., until May 29, 2009), Plaintiffs do not find it a
+reasonable agreement. Plaintiffs have requested an additional twenty (20) days to
+respond to the Motion to Compel and/or Identify. As set forth in the Motion to
+Compel and/or Identify, the failure and/or refusal to allow Epstein to identify Jane
+Doe's 2 through 7 in various third-party subpoenas is preventing meaningful discovery
+and the preparation of Epstein's defenses in this matter in anticipation of trial. The
+Motion to Compel and/or Identify Jane Doe is incorporated herein by reference.
+Therefore, all those arguments apply herein.
+3.
+As set forth in the Motion to Compel and/or Identify, Jane Doe Numbers
+2 through 7, these cases have been filed for some time. Therefore, discovery should
+have been permitted so that Epstein would be able to properly prepare and defend the
+claims brought against him by Jane Doe Numbers 2 through 7. Plaintiffs, and their
+counsel, have not agreed to the relief set forth in the Motion to Compel and/or Identify
+Jane Doe Numbers 2 through 7. CMA agreed to such relief. Exhibit "A". Therefore,
+any extension granted to Jane Doe's Numbers 2 through 7 will further delay discovery
+
+
+Case 9:08-cv-80119-KAM Document 115 Entered on FLSD Docket 05/27/2009 Page 5 of 6
+Page 5
+in this matter. Such a delay has been addressed by Epstein filing his Motion to Strike
+cases from the current trial docket, dated May 19, 2009.
+Discovery should not be delayed in these matters any longer.
+WHEREFORE, Epstein hereby respectfully requests that an Order be entered
+requiring Plaintiffs, Jane Doe's #2 through #7 to file their opposition Motion to the
+Motion to Compel and/or Identify on or before May 29, 2009, and for such other and
+further relief as this Court deems just and proper.
+Michael/J. Pike, Esq.
+Attornes-for Defendant Epstein
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed
+with the Clerk of the Court using CM/ECF. I also certify that the foregoing document
+is being served this day on all counsel of record identified on the following Service List
+in the manner specified by CM/ECF on this 1Z day of May, 2009:
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+ssm@sexabuseattorney.com
+ahorowitz@sexabuseattorney.com
+Counsel for Plaintiff Jane Doe #2
+Jack Alan Goldberger
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Co-Counsel for Defendant Jeffrey Epstein
+
+
+Case 9:08-cv-80119-KAM Document 115 Entered on FLSD Docket 05/27/2009 Page 6 of 6
+Page 6
+By: _
+D. CRUTON, JR., ESQ.
+Florida Bar No. 224162
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER & COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Counsel for Defendant Jeffrey Epstein)

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vision-fixhub/court-01/ab466d7a94cd298129bf70c2a24bead5e381bf18252a10a7de997a775ab8f0b6.md

@@ -0,0 +1,33 @@
+Case 1:20-cv-02365-LJL-DCF Document 49 Filed 09/10/21 Page 1 of 1
+Sanders LLP
+Troutman Pepper
+875 Third Avenue
+New York, New York 10022
+troutman.com
+troutman"
+pepper
+Bennet J. Moskowitz
+bennet.moskowitz@troutman.com
+September 10, 2021
+VIA ECF
+Hon. Debra C. Freeman
+Daniel
+Moynihan
+United States Courthouse
+500 Pearl St.
+New York, NY 10007
+Re:
+Jane Doe v. Darren . Indyke and Richard D. Kahn, in their capacities as
+the Executors of the Estate of Jeffrey E. Epstein, 1:20-cv-02365-LJL-DCF
+Dear Judge Freeman:
+We represent Defendants Darren |. Indyke and Richard D. Kahn, Co-Executors
+of the Estate of Jeffrey E. Epstein, in the referenced action. We write jointly with Plaintiff
+to report that the parties are attempting to resolve this matter extrajudicially. Accordingly,
+to preserve the parties' resources and in the interest of judicial economy, the parties
+respectfully request that the Court enter a sixty-day stay of this action, through November
+9, 2021. Should the parties resolve Plaintiff's claims through settlement, they will
+thereafter promptly discontinue this action with prejudice.
+Respectfully submitted,
+/s/ Bennet J. Moskowitz
+Bennet J. Moskowitz
+cc: Counsel of Record (via ECF)

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vision-fixhub/court-01/ab516e542d9b62650a448f450f2e910648b65daad0de3f2756882460bc72a352.md

@@ -0,0 +1,104 @@
+Case 9:09-cv-80591-KAM Document 6 Entered on FLSD Docket 04/29/2009 Page 1 of 4
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+JANE DOE NO. 2,
+Plaintiff,
+CASE NO.: 08-CV-80119-MARRA
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 3,
+Plaintiff,
+CASE NO.: 08-CV-80232-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 4,
+Plaintiff,
+vs. JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80380-MARRA/
+JANE DOE NO. 5,
+Plaintiff,
+CASE NO.: 08-CV-80381-MARRA/
+VS.
+JEFFREY EPSTEIN,
+
+
+Case 9:09-cv-80591-KAM Document 6 Entered on FLSD Docket 04/29/2009 Page 2 of 4
+Defendant.
+JANE DOE NO. 6,
+Plaintiff,
+CASE NO.: 08-80994-CIV-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 7,
+Plaintiff,
+CASE NO.: 08-80993-CIV-MARRA/_
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+C.M.A.,
+CASE NO.: 08-80811-CIV-MARRA/_
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE,
+Plaintiff,
+CASE NO.: 08- 80893-CIV-MARRA/
+VS.
+JEFFREY EPSTEIN et al,
+2
+
+
+Case 9:09-cv-80591-KAM Document 6 Entered on FLSD Docket 04/29/2009 Page 3 of 4
+Defendants.
+DOE II,
+CASE NO.: 09- 80469-CIV-MARRA
+Plaintift,
+VS.
+JEFFREY EPSTEIN et al,
+Defendants.
+JANE DOE NO. 101,
+Plaintiff,
+CASE NO.: 09- 80591-CIV-MARRA
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+ORDER
+THIS CAUSE is before the Court on Plaintiffs' Motion for Protective Order Against
+Piecemeal Depositions of Jane Doe No.'s 2, 3, 4, and 7 and Motion to Consolidate Cases for
+Purposes of Discovery (DE 66 in 08-80119; DE 58 in 08-80232; DE 73 in 08-80380; DE 23 in
+08-80993). The Court has reviewed the motions, responses, replies, and is otherwise fully
+advised in the premesis. It is hereby
+ORDERED AND ADJUDGED as follows:
+Plaintiffs' Motion for Protective Order Against Piecemeal Depositions is GRANTED,
+pursuant to Fed. R. Civ. P. 26(c). As to each of the ten above-styled cases, Defendant is limited
+3
+
+
+Case 9:09-cv-80591-KAM Document 6 Entered on FLSD Docket 04/29/2009 Page 4 of 4
+to a single deposition of each Plaintiff, during which Defendant may depose the plaintiff as both
+a party and a witness to all other cases of a similar nature of which the plaintiff deposed is aware.
+Defendant should not expect to be able to re-depose any plaintiff relative to any new cases that
+may be filed. Therefore, Defendant should examine each plaintiff about the facts relating to all
+individuals of whom they are aware, regardless of whether an individual has in fact filed a claim
+against Defendant. In the event additional cases are filed, upon a showing of good cause, the
+Court will determine whether Defendant will be permitted to re-depose any of the plaintifts as
+witnesses to the allegations made in those newly filed cases.
+Plaintiffs' Motion to Consolidate Cases for Purposes of Discovery is GRANTED. In the
+interests of judicial economy and efficiency, cases 08-80119, 08-80232, 08-80380, and 08-80993
+are hereby CONSOLIDATED for purposes of discovery only.
+Additionally, the parties in the other six above-styled causes (08-80381, 08-80994,
+08-80811, 08-80893 09-80469, 09-80591) are hereby ORDERED TO SHOW CAUSE on or
+before May 5, 2009 why all of the cases should not be consolidated for discovery purposes.
+DONE AND ORDERED in
+at West Palm Beach, Palm Beach County,
+Florida, this 28" day of April, 2009
+Copies furnished to:
+all counsel of record
+KENNETH A. MARRA
+United States District Judge
+4

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vision-fixhub/court-01/ab9e451f8c6e840bc83e73a2ec442492f3f54eadff41814db6502a00807b6026.md

@@ -0,0 +1,90 @@
+Case 9:08-cv-80119-KAM Document 549 Entered on FLSD Docket 05/26/2010 Page 1 of 4
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA/
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related Cases:
+08-80232, 08-80380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092,
+PLAINTIFES JANE DOES 2-8' UNOPPOSED MOTION FOR
+ENLARGEMENT OF TIME TO FILE RESPONSE TO DEFENDANT'S
+RULE 4 APPEAL OF PORTIONS OF THE MAGISTRATE'S ORDERS
+DATED FEBRUARY 4, 2010 (DE 480) AND APRIL 1, 2010 (DE 513)
+Plaintiffs, Jane Does 2-8, by and through undersigned counsel, file this Unopposed
+Motion for Enlargement of Time to File Response to Defendant's Rule 4 Appeal of Portions of
+The Magistrate's Orders Dated February 4, 2010 (DE 480) and April 1, 2010 (DE 513), and state
+as follows:
+Defendant Epstein filed his Rule 4 Appeal on May 12, 2010.
+Plaintiffs'
+Response is presently due to be filed on May 26, 2010.
+Plaintiffs request a brief enlargement of time of two (2) days, until and including
+May 28, 2010, to file their Response.
+3.
+Plaintiffs' counsel requires an enlargement of time due to demands on Plaintiffs'
+
+
+Case 9:08-cv-80119-KAM Document 549 Entered on FLSD Docket 05/26/2010 Page 2 of 4
+counsel in this and other cases and matters, including A.G.D. et al. v. Siegel, case no. 09-CV-
+80959, U.S. District Court, S.D. Fla; and Doe v. Waterford Kids Academy, Inc., case no. 09-CA-
+10377, Orange County Circuit Court.
+4.
+Plaintiffs bring this Motion in good faith and not for purposes of undue delay.
+5. Pursuant to S.D.Fla.L.R. 7.I(A), Plaintiffs' counsel has conferred with counsel for
+Defendant regarding the relief sought in this Motion, who has advised Plaintiffs' counsel that
+Defendant has no objection to the enlargement of time requested.
+WHEREFORE, Plaintiffs respectfully request an enlargement of time of two (2) days,
+until and including May 28, 2010, to file their Response to Defendant's Rule 4 Appeal.
+Dated: May 26, 2010.
+Respectfully submitted,
+By: s/ Stuart S. Mermelstein
+Stuart S. Mermelstein (FL Bar No. 947245)
+ssm@sexabuseattorney.com
+Adam D. Horowitz (FL Bar No. 376980)
+ahorowitz@sexabuseattorney.com
+MERMELSTEIN & HOROWITZ, P.A.
+Attorneys for Plaintiffs
+18205 Biscayne Blvd., Suite 2218
+Miami, Florida 33160
+Tel: (305) 931-2200
+Fax: (305) 931-0877
+
+
+Case 9:08-cv-80119-KAM Document 549 Entered on FLSD Docket 05/26/2010 Page 3 of 4
+CERTIFICATE OF SERVICE
+I hereby certify that on May 26, 2010, I electronically filed the foregoing document with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served
+this day to all parties on the attached Service List in the manner specified, either via transmission
+of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for
+those parties who are not authorized to receive electronically Notices of Electronic Filing.
+Is/ Stuart S. Mermelstein
+
+
+Case 9:08-cv-80119-KAM Document 549 Entered on FLSD Docket 05/26/2010 Page 4 of 4
+SERVICE LIST
+DOE vs. JEFFREY EPSTEIN
+United States District Court, Southern District of Florida
+Jack Alan Goldberger, Esq.
+jgoldberger@agwpa.com
+Robert D. Critton, Esq.
+rcritton@bclclaw.com
+James
+bedwards@rra-law.com
+Isidro Manuel
+isidrogarcia@bellsouth.net
+Jack
+jph@searcylaw.com
+Katherine Warthen Ezell
+KEzell@podhurst.com
+Michael James Pike
+MPike@bclclaw.com
+Paul G. Cassell
+cassellp@law.utah.edu
+Richard Horace Willits
+lawyerwillits@aol.com
+Robert C. Josefsberg
+rjosefsberg@podhurst.com

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vision-fixhub/court-01/ac08794c9a1b55a5eccbc9330aebd07c2778acb07044c82992a369aeaea296c2.md

@@ -0,0 +1,198 @@
+Case 9:09-cv-80591-KAM Document 44-1 Entered on FLSD Docket 06/08/2009 Page 1 of 5
+The Psychological Trauma Center
+a division of Preventive Psychiatry Associates Medical Group, Inc.
+Medical Director: Gilbert W. Kliman, M. D.
+2105 Divisadero St, San Francisco, CA 94115
+Phone (415)292-7119 Fax (415) 749-2802
+www.expertchildpsuchiatry.com
+Forensic Child Psychiatric Evaluations, Life Care Plans de Testimony
+DECLARATION OF GILBERT KLIMAN, M. D.
+June 4, 2009
+RE: EXPECTATION OF HARM FROM DISCLOSING THE PLAINTIFFS' IDENTITIES
+IN DOES V JEFFREY EPSTEIN
+1. I, Gilbert W. Kliman, M.D., of 2105 Divisadero Street, San Francisco, California,
+CA. Physicians License G55912, declare the following under penalty of perjury:
+2. I have been retained by plaintiffs' law firm, Mermelstein & Horowitz, to give expert
+testimony. If called as a witness, I would testify truthfully and competently concerning
+my psychiatric findings about each of the plaintiffs' alleged experiences of sexual abuse,
+and the enduring effects that I find each of the young women have suffered as a direct
+result of the sexual acts perpetrated by the defendant.
+3. I have been asked to respond to the Defense motion, which requests that some of the
+plaintiffs, who are now adults, should be publicly named. It is my opinion that
+involuntary public disclosure will result in the plaintiffs experiencing revictimization,
+albeit by a justice system that is designed to protect them. If their identities are released,
+the victims will be at-risk of having their personal lives scrutinized by friends, extended
+family, spouses, children, fellow students, employers and fellow employees, the media
+and general public. This type of exposure humiliates many victims and represents another
+betrayal of trust. Public exposure places the plaintiffs at further risk of stigmatization,
+shame and retraumatization.
+4. Due to traumatization the plaintiffs are arrested in their development, and even those
+who are now legally adults are arrested in part to adolescent aspects of psychology.
+5. The plaintiffs do not hold their heads high with pride for having been sexually
+controlled by Mr. Epstein. They hold their heads low with shame. The internal life of a
+typical adolescent, into late adolescence and early adult years in the best of
+circumstances, usually involves generous proportions of self-consciousness, shame, selfabsorption and self-doubt and self-blame about sexual acts.
+
+1
+
+
+Case 9:09-cv-80591-KAM Document 44-1 Entered on FLSD Docket 06/08/2009 Page 2 of 5
+6. Clinically harmful levels of shame, self-consciousness, self-doubt and self-blame are
+even more prominent among victims of molestations than among the general population.
+7. Molested teenagers are particularly vulnerable to wrongful manipulations and special
+clinical harms from the experiences of shame and humiliation. In fact, shame and efforts
+to cope with it played an underlying role in the harm to each plaintiff. Each was lured
+into Mr. Epstein's sexual lair with the promise of overcoming bodily and sexual shame
+by earning money and bettering their lot in life. The defendant capitalized on their sexual
+naiveté, insecurities and effort to better themselves, and he worked hard to overcome
+their shame at his enlistment of them in his selfish gratifications.
+8. The defendant who wishes to make their identities public is one whom the criminal
+justice system has already determined is a person who has already committed a crime of
+child molestation. That surely means he has already exploited and manipulated the girls'
+state of adolescent sexuality, including their embarrassment, awkwardness and bodily
+self-consciousness. He perverted their nascent and developing moral structures by posing
+as a generous, avuncular mentor who could coach them about their bodies, sex and love.
+The exploitation of adolescent bodies, sex and love is - from a psychoanalytic point of
+view - an influence on the developing moral conscience of the children, as well as on
+their sexual urges. Now the ravaging of their internal and private moral conscience is
+intended by the perpetrator to be made a public ravaging.
+9. Among sexual trauma victims, the insidious and destructive persistence of shame,
+humiliation and associated self-blame is well-documented (Finkelhor and
+Stigmatization, as experienced by a sexual trauma victim, has especially painful and
+pathologic consequences. Shame lingers and becomes integrated within the adolescent
+victim's malleable emerging identity, character structure and self image. Moral clarity is
+distorted. Perceptions of self-blame and guilt are magnified. The impact of shame lends
+to cultivating a self image of being "spoiled goods."
+10. Stigmatization following sexual trauma results in long-term risks that can negatively
+shape multiple facets of adult development: sexual, emotional, interpersonal and
+vocational. Stigmatization, which is generally to be avoided among psychiatric patients,
+increases risks among those - as in our plaintiffs as a group - who experience clinical
+depression and self-destructive behaviors: drug use, criminal activity, even prostitution.
+Stigmatization following abuse is associated with delinquency due to increased anger
+and affiliation with deviant peers (Feiring et al., 2007).
+11. Shame and guilt are important dimensions of both complex and single event,
+posttraumatic stress disorder (PTSD). Symptoms of shame are associated with feelings of
+helplessness and powerlessness, which each of the plaintiffs endorsed experiencing in
+relation to Mr. Epstein.
+2
+
+
+Case 9:09-cv-80591-KAM Document 44-1 Entered on FLSD Docket 06/08/2009 Page 3 of 5
+12. The DSM-IV-TR recognizes both powerlessness and helplessness as requisite parts of
+the traumatic experience in Criterion A for the diagnosis of posttraumatic stress disorder
+Seligman, recent Past President of the American Psychological
+Association, coined relevant terms of "learned helplessness and "Loss of Personal Locus
+of Control." See Seligman, M.P. 1975: Helplessness, Depression, Development and
+Death. W. H. Freeman, San Francisco). The teenaged girls suffered the loss of personal
+locus of control to a much more experienced, sexually aggressive, powerful and
+dominant, manipulative perpetrator.
+13. Releasing names of the plaintiffs to the public will reenact experiences of
+powerlessness and helplessness in the face of a boundary violation. Repetition and
+reenactment represent central features of Criterion B in the DSM-IV-TR diagnosis of'
+posttraumatic stress disorder trauma. In effect, release of their identity and public
+intrusion into their personal life represents a reenactment of the shame of sexual
+traumatization. Repetition and reenactment are central pathologies that afflict sexual
+trauma survivors.
+14. Victims of sexual abuse often rely upon some form of dissociation, splitting or denial,
+as a defensive means to manage overwhelming affects associated with the sexual trauma.
+Each of the plaintiff girls has employed some variation of this defense, both during the
+massages and then subsequently following disclosure of the abuse. Primitive,
+maladaptive responses of this nature will become additionally reinforced as a result of
+public disclosure.
+15. Another aspect of the plaintiffs' experience, which is recognized by DSM-IV-TR, is
+that the trauma was associated with human design factors (such as cruel intention to do
+harm, rape, torture). Trauma of this origin has a tendency to produce more "severe or
+long lasting" posttraumatic stress disorder than natural events (DSM IV TR p. 464). A
+policy of deliberate revelation of the names of the victims would reinforce the sense of
+design, pattern and policy of human intentions.
+16. Negative expectations about significant activities are noted in DSM-IV-TR, as part of
+Criterion C. Symptoms of foreshortened future are characteristic of a traumatized
+individual's clinical course (C4). They expect revictimization. They expect bad outcomes
+(C7) in their social, educational, vocational, relational plans. They are hypervigilant
+(Criterion D4) for further trauma, and this affects lifestyle choices and future planning.
+Hypervigilance is part of the arousal set of criteria. Public disclosure of the victims'
+identity will aggravate existing symptoms of hypervigilance.
+17. The DSM-IV-TR diagnostic category of "chronic" is justified for each of the
+plaintiffs. Scientific literature shows that the prognostic consequences of PTSD and
+residual effects may last for decades (U.S. Dept. of Health, 2005; Issues in Child Abuse
+Prevention Number 9 Autumn1998: Long-term Effects of Child Sexual Abuse, Paul E
+Mullen and Jillian Fleming). The lasting impact upon character, identity and moral
+development will probably affect long-term influences upon adult development. It is
+more probable than not that stigmatization associated with public disclosure of the
+3
+
+
+Case 9:09-cv-80591-KAM Document 44-1 Entered on FLSD Docket 06/08/2009 Page 4 of 5
+plaintiffs" identities will intensify the scope, nature and severity of the chronic symptom
+course.
+18. In addition to PTSD, shame and humiliation themselves have also been associated
+with causing clinical depression. Coexisting PTSD and clinical depression places the
+plaintiff's at increased risk for re-victimization and high risk sexual behaviors (e.g.,
+sexually transmitted disease, premature pregnancy, rape) (Nelson, 2002), and at greater
+risk to victimize others (Filipas and Ullman, 2006; Desai, Centers for Disease Control,
+2002) who are in their control. Studies have also shown that chronic symptoms of PTSD,
+in association with a single episode of Major Depressive Disorder, can produce lifetime
+adjustment difficulties, which include suicidality (Oquendo et al, 2005; Dube et al, CDC,
+2001; Rohde, J. Am. Acad. Child and Adolescent Psychiatry 2005). The plaintiffs will be
+additionally vulnerable to these clinical outcomes, if they suffer the stigmatization and
+humiliation associated with public disclosure of their identities.
+19. Alternative hypothesis: I have applied the evidence shown from examination and
+testing of the plaintiffs and relevant observations and information from other
+professionals while testing an alternative hypothesis: that no harm would result from
+public disclosure of the plaintiffs' identities. During the evaluations with the six
+plaintiffs, I used generally acceptable criteria for establishing whether a DSM-IV-TR
+disorder occurred. I established that there were provable and diagnosable injuries,
+primarily posttraumatic stress disorder and comorbid depression. Based upon these
+diagnostic signs, it is more probable than not, that exposing the plaintiff's identity to the
+public is not a trivial concern or one without substantial clinical repercussions. I believe
+that most child, adolescent and adult psychiatrists would share the opinion that additional
+psychiatric injury will result from such exposure.
+20. However, consider for the sake of argument, that my diagnostic conclusions are
+incorrect, notwithstanding having fulfilled standard psychiatric evaluation procedures of
+taking a history from multiple sources, videotaping and transcribing my initial interview,
+and reviewing available medical and legal documents. Even if this was the case, and my
+diagnostic conclusions were faulty, I believe that multiple experts, even those who may
+now propose publication of the victims' names, would still come to a conclusion that the
+plaintiff's suffered sexual abuse, and in some cases, multiple acts of ongoing abuse, at the
+hands of Jeffery Epstein. Even without developing a subsequent disorder, there is much
+clinical evidence and scientific literature showing likelihood of substantial psychiatric
+harm to these sexually abused plaintiffs.
+21. To form these conclusions, I have used my extensive experience in forming these
+opinions. That experience is both as a treating child psychiatrist and separately as a
+forensic psychiatrist. I have treated hundreds of minor patients, as well as additionally
+evaluated hundreds of children and adolescents who have suffered sexual abuse. I have
+made long term followups of many of the children and have treated many adults who
+have been molested as adolescents. It is my opinion, with a reasonably high degree of
+medical certainty that the defense motion to allow public disclosure of the plaintiffs'
+identities is clinically and ethically a wrongful plan. The act of revealing their identities
+against their wishes places the plaintiffs at risk, in the best of circumstances, of suffering
+4
+
+
+Case 9:09-cv-80591-KAM Document 44-1 Entered on FLSD Docket 06/08/2009 Page 5 of 5
+an aggravation of existing diagnostic concerns. It is more probable than not that releasing
+personal identities will
+an exacerbation and magnification of symptoms lending to
+increased risk of revictimization and retraumatization.
+I declare under penalty of perjury under the laws of the State of California that the
+foregoing statements are true and correct, and that this declaration was executed at San
+Francisco, California on June 4, 2009.
+Sincerely,
+Babel Kina 1D
+Gilbert Kliman, M.D.
+Distinguished Life Fellow, American Psychiatric Association
+Senior Fellow, American Academy of Child and Adolescent Psychiatry
+Brockman Award Holder, for Distinguished Lifetime Contributions to
+Psychoanalysis and Psychiatry, bestowed by the American College of Psychoanalysis and
+Psychiatry
+LEONID NAKHODKIN ≤
+Сомм.# 1791115
+NOTARY PUBLIC- CALIFORNIA
+ÔTY & COUNTY OF SAR FRANCISCO
+Mr CoNa, EXP. FEE. 27, 2012 T
+State of California, City & County of San Francisco
+Subscribed and sworn to (or affirmed before me on this
+day of yu nor by Gilbert Kinceeu
+proved to me on the basis of sailstactory evidence
+1 a no need a lockde .
+5

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vision-fixhub/court-01/ac14aa157dd2778f72909a229c8946c828f343aa24e60bde4eb60d550023d12c.md

@@ -0,0 +1,37 @@
+Case 9:08-cv-80232-KAM Document 21 Entered on FLSD Docket 07/21/2008 Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80232-MARRA/
+JANE DOE NO. 3,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+DECLARATION OF JEFFREY M. HERMAN REGARDING SERVICE
+OF PROCESS AND THIS COURT'S ORDER TO SHOW CAUSE
+Jeffrey M. Herman, deposes and states as follows:
+I am counsel for Plaintiff in this action. After the parties' briefed the issue of service
+of process on Defendant Jeffrey Epstein, this Court found valid service under New York law and
+entered an Order to Show Cause Why Default Should Not be Entered Against Defendant Jeffrey
+Epstein, dated July 16, 2008.
+I submit this Declaration to correct what appears to be a factual error in the Court's
+Order to Show Cause. I do so even though this error is in Plaintiff's favor.
+3.
+In the Order to Show Cause, this Court finds that "It]he process server also mailed a
+copy of the summons and complaint to Defendant on May 5, 2008, via first class mail. (DE 4)." It is
+my understanding that the Affidavit of Service (DE 4) crosses out language regarding mail to the
+Defendant, and that the process server in this case did not mail a copy of the Summons and
+Complaint to the Defendant's New York address. In none of the papers Plaintiff filed in this matter
+is it asserted that the Summons and Complaint was mailed, nor did Plaintiff claim that service was
+valid under New York law.
+
+
+Case 9:08-cv-80232-KAM Document 21 Entered on FLSD Docket 07/21/2008 Page 2 of 2
+CASE NO.: 08-CV-80232-MARRA
+Under penalties of perjury, I declare the foregoing to be true and correct.
+Dated: July 21, 2008.
+s/ Jeffrey M. Herman
+Jeffrey M. Herman
+Herman & Mermelstein, P. A.
+2
+www.hermanlaw.com

vision-fixhub/court-01/ac14aa157dd2778f72909a229c8946c828f343aa24e60bde4eb60d550023d12c.receipt.json

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vision-fixhub/court-01/ac30ada9c9d9ed8cd752b8555eaf34d2e9dc12382331c5854e67f563d89e0862.md

@@ -0,0 +1,31 @@
+Filing # 117976955 E-Filed 12/10/2020 10:51:36 AM
+CA FLORIDA HOLDINGS, LLC,
+Publisher of THE PALM BEACH POST,
+Plaintiff,
+DAVE ARONBERG, as State Attorney of
+Palm Beach County, Florida, SHARON R. BOCK,
+as Clerk & Comptroller, Palm Beach County,
+Defendants.
+CASE NO: 2019-CA-014681
+COPY
+AMENDED NOTICE FOR NON-JURY TRIAL
+Defendant, DAVE ARONBERG, as State Attorney of Palm Beach County, Florida, by and
+take approximately a half-day to try and is presently limited to the issue of entitlement regarding
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on this 10th day of December, 2020, a copy of the foregoing has
+been electronically filed with the Florida E-File Portal for e-service on all parties of record herein.
+SCHOLZ & WYLER, LLC
+Is/ Douglas A. Wyler
+Arthur I. I
+_ Esq.
+Fla. Bar No.: 10249
+Richard J. Scholz, Esq.
+Fla. Bar No.: 0021261
+Douglas A. Wyler, Esq.
+Fla. Bar No.: 119979
+961687 Gateway Blvd., Suite 201-I
+Fernandina Beach, Florida 32034
+(904) 261-3693
+(904) 261-7879 Fax
+Primary: jacobsscholzlaw@comcast.net
+FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 12/10/2020 10:51:36 AM

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vision-fixhub/court-01/ac389bbcc65bb35edf542c082fc23c04470100add396763d8a2572e8fa4a0753.md

@@ -0,0 +1,76 @@
+Case 9:08-cv-80380-KAM
+Document 6 Entered on FLSD Docket 05/22/2008 Page 1 of 1
+Form 42 - DOORMAN WITH MILITARY
+HERMAN & MERMELSTEIN PA
+ATTN:
+U.S. SOUTHERN DIST. COURT
+FLORIDA COUNTY
+Index No. 08CV80380
+JANE DOE NO.4
+plaintiff
+Date Filed
+- against -
+Office No.
+JEFFREY EPSTEIN
+defendant
+Court Date:
+STATE
+OF NEW YORK, COUNTY OF NEW YORK
+: SS:
+HARRY
+being duly sworn, deposes and says; I am over 18 years
+of age, not
+7th day of May, 2008
+a party to this action, and reside in the State of New York. That on the
+07:45 AM
+9 EAST 71ST ST
+NEW YORK, NY 10021
+I served the SUMMONS AND COMPLAINT
+after prior attempts were made on: 04/23/2008 06:15 PM 04/24/2008 02:30 PM 05/01/2008 06:27PD
+upon JEFFREY EPSTEIN
+the DEFENDANT therein named by delivering and leaving a true copy or copies
+of the aforementioned documents with
+"JOHN
+", ASSISTANT & HOUSE STAFF EMPLOYEE WHO
+REFUSED TRUE NAME
+a person of suitable age and discretion, who refused access to DEFENDANT's
+actual apartment, and accepted in accordance with his/her everyday duties.
+Deponent describes the person served as aforesaid to the best of deponent's ability
+at the time and circumstances of the service as follows:
+SEX: MALE
+COLOR:
+HAIR:
+AGE: 45 HEIGHT: 6:0 WEIGHT: 200
+OTHER IDENTIFYING FEATURES: MUSTACHE/BEARD
+On_05/12/2008-I deposited-in the United States mail a true copy of-the aforementioned --
+documents properly-enclosed and-sealed-in a-post-paid wrapper-addressad to-the-said
+DEFENDANT at the above address - That-address,inglast known residence, usual place of abode of the DEFENDANT.
+cepy fatted 1st-olass mait-marked pereenal-"-confidential not-indieating en the-outside thereof--
+by-return address or-otherwise that said notico is-frol-at attorney-er cencorne-actien against
+the person to-be serued ** & 5/5/08 9:20PM
+That at the time of service as aforesaid, I asked person spoken to whether DEFENDANT
+was in the military service of the State of New York or United States and received a negative
+reply. Upon information and belief based upon the conversation and observation as aforesaid
+I aver that the DEFEAT Se not
+I aver that the DEFENDANT is not in the military service of the State of New York or the
+United States as that term is defined in the statutes of the State of New York or the Federal
+DEPONENT STATED AT THE TIME OF
+SEPONENT STATED AT THE TIME OF SERVICE HE HAD LEGAL
+PAPERS IN A FLORIDA ACTION•
+Sworn to before me this
+12th day of May,
+2008ni
+SAMSON
+Notary Public, Sta
+New York
+No. 01NE-4783767
+Qualified in NEW YORK COUNTY
+Commission Expires 11/03/2009
+AETNA
+CENTRA
+JUDICIAL
+225 BROADWAY, SUITE 1802
+NEW YORK, NY,
+10007
+Reference No: 3HM4124083
+SERVICES

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vision-fixhub/court-01/ac574fc6784ae215f6fc832d9075aba6205d29f095964cc20500f0eaff3952e0.md

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+Case 9:08-CV-80119-KAM Document 328-6 Entered on FLSD Docket 09/25/2009 Page 1 of 8
+Entered on FLSD Docket 08/05/2009 Page 1 of 8
+Jane Doe #5
+V.
+Jeffrey Epstein
+AFFIDAVIT OF RICHARD C.W.
+L.M.D.
+STATE OF FLORIDA
+COUNTY OF SEMINOLE
+On this day personally appeared before me, the undersigned authority, Richard
+c.W.L
+M.D., who, being by me first duly sworn under oath deposes and says:
+1.
+My name is Richard C.W.
+M.D. Iam over the age of majority, and make
+this affidavit and declaration upon the basis of personal knowledge of the factual matters
+contained herein.
+2.
+since 1996.
+I have maintained a private practice in psychiatry and forensic psychiatry
+3. I, also, currently serve as a Courtesy Clinical Professor of Psychiatry at the
+University of Florida, College of Medicine, Gainesville, Florida; Affiliate Professor, Dept of
+Psychiatry and Behavioral Medicine, University of South Florida; and Professor of
+Psychiatry, Department of Medical Education, University of Central Florida College
+Medicine.
+4.
+I received my undergraduate degree from the Johns
+University and
+PENDANTS
+
+
+
+Case 9:08-cv-80119-KAM Document 328-6 Entered on FLSD Docket 09/25/2009 Page 2 of 8
+Entered on FLSD Docket 08/05/2009 Page 2 of 8
+medical degree from the University of Florida College of Medicine, Gainesville, Florida.
+I served as a Lieutenant Commander in the United States Navy, where I
+researched and evaluated biological and neurochemical factors associated with the onset of
+psychiatric disorders and served as a representative to the Joint Services Task Force
+planning Operation Homecoming, the return of POW's from Vietnam.
+6.
+I have previously served as an assistant clinical professor at the University of
+South Florida College of Medicine, directed one of the ten model mental health centers in
+the United States, and served as a medical consultant to the Kennedy Space Center.
+7. I am a former member of the academic faculty at the University of Texas, in
+Houston, Texas where I served as Assistant Professor and then Associate Professor of
+Psychiatry and Internal Medicine, Director of Clinical Research, Director of Residency
+Training, Chief of the Consultation/Liaison Service, and Chief Psychiatrist at the M.D.
+Cancer Hospital in Houston.
+8.
+I, also, have served as a Professor of Internal Medicine and Psychiatry at the
+Medical College of Wisconsin where I was appointed Chief of Psychiatry at the Milwaukee
+County and Froedtert Hospitals.
+9.
+In addition, I have served as a Professor of Psychiatry and Internal Medicine
+and Associate
+at the University of Tennessee College of Medicine, Memphis.
+10.
+The amended complaint filed by Jane Doe #5 against Jeffrey Epstein makes
+2
+
+
+Case 9:08-CV-80119-KAM Document 328-6 Entered on FLSD Docket 09/25/2009 Page 3 of 8
+Case 9:08-CV-80119-KAM Document 247-6 Entered on FLSD Docket 08/05/2009 Page 3 of 8
+sensitive allegations of sexual assault and abuse upon a minor and seek damages in excess
+of $50 million. Jane Doe #5 alleges confusion, shame, humiliation, embarrassment, and
+severe psychological and emotional injuries. It is further alleged that she suffered, and will
+continue to suffer, severe and permanent traumatic injuries, including mental,
+psychological, and emotional damages.
+11.
+She alleges the intentional infliction of emotional distress and that Mr.
+Epstein's conduct caused severe emotional distress, severe mental anguish and pain.
+12. She further alleges that she has suffered personal injury including mental,
+psychological and emotional damage.
+13.
+Plaintif's counsel has retained an expert witness, Dr. Kliman of the
+Psychological Trauma Center, a division of Preventive Psychiatry Associates Medical
+Group, Inc., of San Francisco, California, of which Gilbert W. Kliman, MD, is the medical
+director. Dr. Kliman's initial records indicate the following concerning Jane Doe #5.
+14. Plaintiff reports she went to three different schools in the eighth grade. (Page
+3, GK Contemp note)
+15. Plaintiff reports "T have had girls be mean to me and even rumor that they
+would slice my throat when I was younger." (Page 4, GK Contemp note)
+16.
+Plaintiff noted that she had caught her mother and stepfather having sex.
+(Page 7, GK Contemp note)
+3
+
+
+Case 9:08-cv-80119-KAM Document 328-6 Entered on FLSD Docket 09/25/2009 Page 4 of 8
+Entered on FLSD Docket 08/05/2009 Page 4 of 8
+17.
+"I got kicked out when I was 18 (by both parents). (Page 7, GK Contemp note)
+18.
+Plaintiff noted that her mother suffers from depression/stress. (Page 7, GK
+Contemp note)
+19.
+Plaintiff noted that during her sophomore and junior years of high school she
+drank every weekend and started trying drugs. (Page 7, GK Contemp note)
+• 20.
+"Her problems began during adolescence." (Page 7, GK Contemp note)
+21. Family psychiatric history includes: a history of a blood relative having been
+sexually abused, plaintiff's mother was physically abused by sisters, and plaintiff's father
+"was very irresponsible as a father figure when I was growing up" and used drugs. (Pages
+7 and 8, GK Contemp note)
+22. Plaintiff noted "My stepfather hit me on a few occasions. But on one
+occasion, I lost hearing in my ear for two weeks." (Page 8, GK Contemp note)
+23. Plaintiff reported that she has been sexually active since age 13 and had 8-10
+partners. (Page 8, GK Contemp note)
+24.
+Plaintiff reported that she had been raised by her father between ages 12 to 18
+and that she found her childhood hard to remember, unhappy and painful. (Page 8, GK
+Contemp note)
+25. Plaintiff reports that her drug use has included marijuana and pain pills
+without prescription and that on several occasions she has drunk too much alcohol. (Page
+4
+
+
+Case 9:08-CV-80119-KAM Document 328-6 Entered on FLSD Docket 09/25/2009 Page 5 of 8
+Entered on FLSD Docket 08/05/2009 Page 5 of 8
+9, GK Contemp note)
+26.
+Plaintiff reported that her mother's sisters had paid a male to rape her (the
+mother) in a closet at school. She had been raped three times, twice in childhood and once
+on a date. Also, an uncle raped the mother. (Page 1, GK Follow-up note)
+27. Plaintiff reported having suicidal thoughts in the 9i or 10% grade. (Page 4,
+GK Follow-up note) (Pre-Epstein)
+28.
+All of the above show that this plaintiff came from an unstable and disturbed
+home, had been subject to previous physical and sexual abuse, was fearful, isolated, and
+had had suicidal ideation prior to meeting Mr. Epstein. For further elaboration of her
+history and background, access to all available records is crucial if one is to fully
+understand the impact of any of these events on her subsequent behavior and proportion
+the impact of specific events, if any, or her current and future level of function.
+29. In Dr. Kliman's initial replenishment retainer agreement and fee schedule
+(date 7/18/08), in a heading entitled "Regarding Full Disclosure," Dr. Kliman notes that
+prior to deposition, counsel will make every effort necessary to provide experts with
+information requested by the experts including: 1) a list of all depositions, statements,
+declarations, and motions in the case, 2) a copy of any requested items, and 3) most
+importantly, a list of all medical, clinical, school, and work records known to the attorney
+in the case.
+5
+
+
+Case 9:08-cv-80119-KAM Document 328-6 Entered on FLSD Docket 09/25/2009 Page 6 of 8
+Entered on FLSD Docket 08/05/2009 Page 6 of 8
+30.
+Dr. Kliman notes on page 8 of his contract opinior formation that he will not
+form opinions, give reports, or testify in certain circumstances.
+These include
+circumstances where he has reason to believe a retaining attorney has " available important
+and relevant documents which are being deliberately withheld from us." "We define such
+as documents in possession of retaining attorney, which we have requested or that we have
+stated would ordinarily be part of medical opinion formation on the topics concerning,
+which our input is requested." We request the same.
+31. It is critical for an IME examiner to be able to make a cogent assessment of
+any plaintiff and to understand their medical, social, academic, psychological and
+psychiatric condition/state prior to any act of alleged victimization. There are a number of
+variables that combine to determine the effects of such alleged victimization, including the
+type and character of the alleged assault, and key victim variables such as demographics,
+psychological reactions at the time of the trauma, previous psychiatric or psychological
+history, previous victimization history, current or previous psychological difficulties, and
+general personality dynamics and coping style, as well as sociocultural factors such as drug
+use/abuse; poverty; social inequity and/or inadequate social support; any previous history
+of abuse within or outside the family; whether individuals were abused by strangers,
+acquaintances or family members; and whether there was any history of indiscriminate
+behavior that may have placed them at increased risk. It is important to know if there had
+6
+
+
+Case 9:08-CV-80119-KAM Document 328-6 Entered on FLSD Docket 09/25/2009 Page 7 of 8
+Entered on FLSD Docket 08/05/2009 Page 7 of 8
+been previous sexual conduct, contact with police or welfare agencies, alcohol or drug
+use/abuse, voluntary sexual activity, contraceptive use, genital infections, or apparent
+indifference to previous abuse.
+32.
+It is also essential to understand the plaintiff's level of emotional support,
+whether any significant psychiatric illnesses were present, whether they were taking any
+medications (prescribed or non-prescribed), whether there had been previous suicide
+attempts, thoughts, plans, etc.
+33.
+Knowledge of plaintifl's relationships to her family and familial factors,
+including social disadvantage, family instability, impaired parent/child relationship, and
+parental adjustment difficulties is also critical.
+34.
+It is, therefore, crucial that the independent medical examiner has available to
+him a full and complete record that includes medical, previous legal, social, criminal,
+academic, psychological and psychiatric records/data; psychological tests; laboratory tests;
+and clinical, hospital, physician records. These, in essence, are the same and similar records
+that plaintiff's expert witness (Di. Kliman) feels are essential for him to do an appropriate
+evaluation. To obtain the necessary information, it will be necessary to identify the plaintiff
+by name. Such identification will not humiliate the plaintiff since all we are requesting is
+pertinent information as noted above relative to their past medical and psychiatric histories
+and conduct. We would concur and request of the court that the same and such other
+7
+
+
+Case 9:08-CV-80119-KAM Document 328-6 Entered on FLSD Docket 09/25/2009 Page 8 of 8
+Entered on FLSD Docket 08/05/2009 Page 8 of 8
+similat information be made available to us to conduct our examination.
+Respectfully submitted,
+Rutal faire
+Richard C. W. 1
+Courtesy Clinical Professor of Psychiatry, University of Florida, College of Medicine
+Affiliate Professor, Department of Psychiatry and Behavioral Medicine, University of South
+Florida
+Professor of Psychiatry, Department of Medical Education, University of Central Florida
+College of Medicine
+8

vision-fixhub/court-01/ac574fc6784ae215f6fc832d9075aba6205d29f095964cc20500f0eaff3952e0.receipt.json

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vision-fixhub/court-01/ac6a2e483ca590b24cd186bd094cd941b97e5a315a53dbd6c91b6cdf674252bd.md

@@ -0,0 +1,40 @@
+Case 9:08-cv-80736-KAM Document 256 Entered on FLSD Docket 09/22/2014 Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+NO. 08-80736-CIV-MARRA
+JANE DOE #1 and JANE DOE #2,
+Plaintiffs,
+VS.
+UNITED STATES OF AMERICA,
+Defendant.
+ORDER ON MOTION FOR INTERVENTION BY JEFFREY EPSTEIN
+THIS CAUSE is before the Court upon the Motion of Jeffrey Epstein ("Epstein") for
+Limited Intervention (DE 215). This matter is fully briefed and is now ripe for review. The
+Court has carefully considered the briefs and is fully advised in the premises.
+"Permissive intervention under [Federal Rule of Civil Procedure 24(b)] is appropriate
+where a party's claim or defense and the main action have a question of law or fact in common
+and the intervention will not unduly prejudice or delay the adjudication of the rights of the
+original parties." Mt. Hawley Ins. Co. v. Sandy Lake Properties, Inc., 425 F.3d 1308, 1312 (11th
+Cir. 2005). Through his Motion, Epstein asks to intervene "for the limited purpose of protecting
+his interests in the secrecy of matters which occurred before the federal grand jury of which he
+was a target." Motion at 1. After carefully reviewing the briefs from the parties involved, the
+Court finds that Epstein has a legitimate interest in asserting a claim that the grand jury material
+may be protected from disclosure by the Federal Rule of Criminal Procedure 6(e). See United
+States v. Eisenberg, 711 F.2d 959, 961 (11th Cir. 1983). This claim will present questions of law
+and fact in common with the main action.
+
+
+Case 9:08-cv-80736-KAM Document 256 Entered on FLSD Docket 09/22/2014 Page 2 of 2
+Further, the Court finds that the intervention will not unduly prejudice or delay the
+adjudication of the rights of the original parties. Accordingly, the Court will exercise its
+discretion to permit Epstein to intervene pursuant to Federal Rule of Civil Procedure 24(b). This
+order should not be construed as an indication of how the Court will rule on the merits of the
+claim that the documents in question are protected.
+It is therefore ORDERED AND ADJUDGED that the Motion of Jeffrey Epstein for
+Limited Intervention (DE 215) is GRANTED.
+DONE AND ORDERED in
+at West Palm Beach, Palm Beach County,
+Florida, this 21" day of September, 2014.
+KENNETH A. MARRA
+United States District Court
+2

vision-fixhub/court-01/ac6a2e483ca590b24cd186bd094cd941b97e5a315a53dbd6c91b6cdf674252bd.receipt.json

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vision-fixhub/court-01/ac70dd619590774fc1205eb08b301b039906619c2e0a916cefa0ebee94f8f4d3.md

@@ -0,0 +1,87 @@
+Dave Aronberg on Twitter: "the following link: https://t.co/AD/cMS2b.| became Palm Beach County State Attorney in: 2013... (2/3)* / Twitter
+4/13/22, 11:54 AM
+* Thread
+-
+Dave Aronberg @ @aronberg • Jan 30, 2020
+In response to a large number of requests, my office is posting online all the
+public records from the investigation and prosecution of #JeffreyEpstein,
+These records, which have all been released previously pursuant to public
+records requests, can be accessed through.. (1/3)
+• 9
+17 46
+• 57
+1 Dave Aronberg ®
+@aronberg
+...
+the following link:
+sa15.org/stateattorney/..
+sa15.org > Newsroom > Public Records
+The Jeffrey Epstein case occurred several years and
+multiple State Attorney administrations before |
+beçame Palm Beach County State Attorney in 2013...
+(2/3)
+1:28 PM - Jan 30, 2020 - Twitter Web App
+ti
+NOT A
+Q.
+Search Twitter
+New to Twitter?
+Sign up now to get your own personalized timeline!
+G Sign up with Google
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+Sign up with phone or email
+By signing up, you agree to the Terms of Service and
+Privacy Policy, including Cookie Use.
+Relevant people
+Dave Aronberg @
+I @aronberg
+Follow
+State Attorney for Palm Beach County
+since 2013, Former State Senator &
+House Fellow iri Treasury Dept.
+"One of the best cookie jars on
+cable.*-Room Rater
+What's happening
+War in Ukraine • LIVE
+Ukrainian humanitarian corridors
+halted as evacuation routes
+deemed too dangerous'
+_ The Times @ - April 12, 2022
+Explained: The weapons of the
+Ukraine war
+The Telegraph @ - April 12.2022
+The railway workers keeping
+Ukraine running
+US national news - 1 hour ago
+New York City police name
+suspect in Brooklyn subway
+shooting
+Trending with
+laines
+Sports: Trending
+Wade
+Trending with Hines
+- Bob Stoops
+Show more
+Party_JOINT
+https://twitter.com/aronberg/status/1222949739865497602
+ID#. J11 EV# Jil
+DATEADMITED: 9/6/2022
+Case No. 2019-CA-014681
+ABRUZZO CLERK
+CA Aronter OPAZZA BEACH COUNTY, FL, JOSEfI ABRUZZO, CLERK. 3/27/2023 3:44:22 PM
+Joint Exhibit
+J11
+
+
+Dave Aronberg on Twitter: *the following link: https://t.co/AOlcgMS2b.I became Palm Beach County State Attorney in 2013...(2/3)* / Twitter
+Don't miss what's happening
+People on Twitter are the first to know.
+Log in
+4/13/22, 11:54 AM
+Sign up
+NOT A CERTIFIED COPY
+https://twitter.com/aronberg/status/1222949739865497602
+
+CA/Aronberg OPAZZE BEACH COUNTY, FL, |
+ABRUZZO, CLERK. 3/27/2023 3:44:22 PM

vision-fixhub/court-01/ac70dd619590774fc1205eb08b301b039906619c2e0a916cefa0ebee94f8f4d3.receipt.json

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vision-fixhub/court-01/ac7c17a773b35f1b1d7d448f615ac088b70faab013d37d58ab1f1243dba8b88e.md

@@ -0,0 +1,76 @@
+Case 9:08-cv-80119-KAM Document 563 Entered on FLSD Docket 06/14/2010 Page 1 of 3
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related Cases:
+08-80232, 08-80380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092,
+NOTICE OF WITHDRAWAL OF SUBPOENA
+PLEASE TAKE NOTICE that Plaintiffs Jane Doe Nos. 2-7, by and through
+undersigned counsel, hereby file this Notice of Withdrawal of Subpoena served on the following:
+Richard Kahn
+1365 York Avenue
+Apt. 28
+New York, NY 10021
+Dated: June 14, 2010
+Respectfully submitted,
+By:
+Is/ Jessica D. Arbour
+Stuart S. Mermelstein (FL Bar No. 947245)
+ssm@sexabuseattorney.com
+Adam D. Horowitz (FL Bar No. 376980)
+ahorowitz@sexabuseattorney.com
+Jessica D. Arbour (FL Bar No. 067885)
+jarbour@sexabuseattorney.com
+MERMELSTEIN & HOROWITZ, P.A.
+Attorneys for Plaintiffs
+18205 Biscayne Blvd., Suite 2218
+Miami, Florida 33160
+Tel: (305) 931-2200
+Fax: (305) 931-0877
+
+
+Case 9:08-cv-80119-KAM Document 563 Entered on FLSD Docket 06/14/2010 Page 2 of 3
+CERTIFICATE OF SERVICE
+I hereby certify that on June 14, 2010, I electronically filed the foregoing document with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served
+this day to all parties on the attached Service List in the manner specified, either via transmission
+of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for
+those parties who are not authorized to receive electronically Notices of Electronic Filing.
+Is/ Jessica D. Arbour
+2
+
+
+Case 9:08-cv-80119-KAM Document 563 Entered on FLSD Docket 06/14/2010 Page 3 of 3
+SERVICE LIST
+DOE vs. JEFFREY EPSTEIN
+United States District Court, Southern District of Florida
+Jack Alan Goldberger, Esq.
+jgoldberger@agwpa.com
+Robert D. Critton, Esq.
+rcritton@bclclaw.com
+James
+bedwards @rra-law.com
+Isidro Manuel
+isidrogarcia@bellsouth.net
+Jack
+jph@searcylaw.com
+Katherine Warthen Ezell
+KEzell@podhurst.com
+Michael James Pike
+MPike@bclclaw.com
+Paul G. Cassell
+cassellp@law.utah.edu
+Richard Horace Willits
+lawyerwillits@aol.com
+Robert C. Josefsberg
+rjosefsberg@podhurst.com
+Brett Jaffe
+bjaffe@cohendresser.com
+3

vision-fixhub/court-01/ac7c17a773b35f1b1d7d448f615ac088b70faab013d37d58ab1f1243dba8b88e.receipt.json

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vision-fixhub/court-01/ac91e9ac19dd00cfd26157058ca31d07e648c6c6c0fef0a07c199fa1a9b2bc11.md

@@ -0,0 +1,208 @@
+Case 9:08-cv-80380-KAM Document 104 Entered on FLSD Docket 05/13/2009 Page 1 of 7
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80380-MARRA.|
+JANE DOE NO. 4,
+V.
+JEFFREY EPSTEIN,
+Plaintiff,
+Defendant.
+Defendant, Jeffrey Epstein's Reply to Plaintiff's Response In Opposition To
+Defendant's Motion To Stay And/Or Continue Action For Time Certain With Incorporated
+Memorandum Of Law
+Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN") by and through his
+undersigned attorneys, hereby files his Reply to Plaintiff's Response In Opposition to
+Defendant's Motion to Stay and/or Continue Action, and states:
+Introduction and Argument
+Plaintiff's Response in Opposition challenging the stay should not prevail when
+5" Amendment principles are at issue and when there exists a real, substantial and not
+remote possibility that Epstein may face criminal prosecution by the United States
+Attorneys' Office ("USAO") if the USAO unilaterally determines that Epstein somehow
+violated that certain Non-Prosecution Agreement dated June 30, 2008 ("NPA") and/or if
+Epstein is forced to waive those 5" Amendment rights and participate in civil discovery
+in order to defend this civil action.
+Epstein should not be confronted with the substantial risk of loosing this civil
+action by virtue of asserting his 5" Amendment privileges. Despite Plaintiff's contention,
+Epstein's Motion does not concentrate solely on the fact that the pleadings are not at
+
+
+Case 9:08-cv-80380-KAM Document 104 Entered on FLSD Docket 05/13/2009 Page 2 of 7
+Page 2
+the summary judgment stage. The motion also concentrates on Epstein's risk of loosing
+this entire civil action as a result of Epstein invoking his 5** Amendment rights. Severino
+v. Klytie's Developments, Inc., 2008 WL 1782637, *2 (D. Colo)(recognizing that a stay is
+appropriate under similar circumstances as in the instant case); see also infra.
+In fact, waiver of Epstein's 5" Amendment privileges should not be compelled to
+defend this civil action (and could be remedied by a reasonable stay), especially when
+civil discovery may lead to the USAO unilaterally declaring a violation of the NPA.
+The USAO has already unilaterally claimed that EPSTEIN violated the NPA by,
+among other things, "investigating the Plaintiffs (by and though his attorneys)
+whom brought civil suits against him for purposes of defending those civil
+actions" and "by contesting damages in this action and in the other civil actions."
+See Motion to Stay and Jack Goldberger Affidavit attached thereto as Exhibit "B". Thus,
+these are not vague assertions as Plaintiff claims. How can Epstein truly defend these
+matters and be afforded his due process rights when to do so might result in the USAO
+claiming a breach of the NPA? The fact is that he cannot. Notwithstanding the
+allegations against Epstein, this Court has an obligation to ensure his due process
+rights are upheld in both the civil and criminal contexts.
+Next, in her response, Plaintiff claims that a stay should not be entered because
+a parallel criminal proceeding against Epstein does not exist. Not only is Plaintiff's
+theory incorrect for reasons set out herein and in the Epstein's Motion to Stay, but her
+response ignores the significant fact that a stay may be issued in light of an ongoing
+investigation. It is clear from the NPA and Jack Goldberger's Affidavit (attached to the
+
+
+Case 9:08-cv-80380-KAM Document 104 Entered on FLSD Docket 05/13/2009 Page 3 of 7
+Page 3
+Motion to Stay) "...that the criminal matters against Epstein remain ongoing until the
+NPA expires by its terms in late 2010..., and the threat of criminal prosecution against
+Epstein by the USAO continues presently and through late 2010." See Jack
+Goldberger's Affidavit, 15 (attached to the Motion to Stay). In fact, the FBI refused to
+provide information regarding this case and other related cases filed against Epstein "..
+.stating the materials are at this time exempt from disclosure because they are in an
+investigative file, i.e., the matter is still an ongoing criminal investigation." See Jack
+Goldberger's Affidavit, 17 (attached to the Motion to Stay)
+Additionally, Plaintiff's response downplays the fact that civil discovery may result
+in the USAO claiming a breach of the NPA. Epstein wishes to vigorously defend this
+case and others filed against him; however, he does not wish to risk waiver of his 5"h
+Amendment privileges, at least before the NPA expires or any investigation is closed.
+Further, Plaintiff adopts the arguments set forth in Jane Doe's Response to the
+Motion to Stay filed in 08-CIV-80893, which asserts that the NPA is not attached to
+Epstein's Motion to Stay. The Court has a copy of the NPA. While it may be sealed,
+this Court may review same, in camera. As such, Plaintiff's Best Evidence argument
+(as adopted in the instant response) is entirely misplaced and should be disregarded.
+a.
+Justice Requires The Entry of A Stay
+As set out in the Motion to Stay, once the NPA expires, EPSTEIN intends to
+testify to all relevant and non-objectionable inquiries made to him in discovery be it a
+deposition, in interrogatories or in production requests.
+However, the current
+circumstances are such that by testifying or responding to discovery, EPSTEIN will be
+
+
+Case 9:08-cv-80380-KAM Document 104 Entered on FLSD Docket 05/13/2009 Page 4 of 7
+Page 4
+required to waive his constitutional privileges, thereby subjecting himself to scrutiny by
+the USAO as a result of matters alleged in this civil action (and others before this Court
+and in the State of Florida 15" Judicial Circuit Court, Palm Beach County).
+When an ongoing criminal investigation exists, courts have granted motions to
+stay civil proceedings. In St. Paul Fire and Marine Insurance Company v. U.S., 24 CI.Ct
+513 (1991), the court held that staying a civil action for 6-9 months was reasonable in
+light of a pending criminal investigation so long as the movant met certain elements
+(see infra) and the stay was not immoderate or unreasonable. Taking into consideration
+the Motion to Stay and this Reply as well as facts alleged by Plaintiff in her operative
+pleading against Epstein, it is clear that Epstein has met the elements of St. Paul Fire
+necessary for this Court to enter a stay:
+Epstein has made a clear showing, by direct or indirect proof, that
+the issues in the civil action are "related" as well as "substantially similar"
+to the issues in the criminal investigation.
+2.
+Epstein has made a clear showing of hardship or inequity if
+required to go forward with this civil case while the NPA and/or the
+ongoing investigation exist. (see supra and see also Motion to Stay and
+attached affidavit of Jack Goldberger, Esq. discussing Epstein's 5"h
+Amendment Rights and how those rights affect this civil litigation - see
+supra); and
+Epstein, in light of the stays granted by other courts, has shown
+that a stay in the instant matter until late 2010 (the date the NPA expires)
+and the likely date any ongoing investigation will be closed is not
+St. Paul Fire and Marine Insurance Company v. U.S., 24 CI.Ct at 515-16; see also
+Wilson v. National Association of Letter Carriers, 2006 WL 3791313, *1 (E.D. La.
+2006)(granting motion to stay civil proceeding for 2 years and 7 months pending
+
+
+Case 9:08-cv-80380-KAM Document 104 Entered on FLSD Docket 05/13/2009 Page 5 of 7
+Page 5
+criminal investigation); Ostrow v. U.S., 1986 WL 6855, *1 (M.D. Fla.)(recognizing a
+defendant's constitutional rights and allowing for a stay of the civil case until the criminal
+aspects/investigation of Defendant's companion case are closed).
+Here, Epstein is not required to "contemplate an in haec verba iron-clad
+comparison of separate issues by direct proof." St. Paul Fire and Marine Insurance
+Company v. U.S., 24 CI.Ct at 516. Instead, a reading of the complaint, the NPA (in
+camera), the pleadings in support of and against Epstein's Motion to Stay along with
+other pleadings in the clerk's file, makes it clear that the facts in the instant matter and
+those in the ongoing investigation are "related" and/or "substantially similar." Id. As
+such, permitting this civil action to go forward would create a hardship on Epstein in that
+he will be forced to invoke his 5* Amendment Privilege and risk loosing this case by
+virtue of not being able to present evidence, or waive that right and risk a potential
+criminal prosecution. Eastwood v. U.S., 2008 WL 5412857, *1 (E.D. Tenn.)) When a
+party to a civil action is subject to criminal proceedings and/or investigations that relate
+to such civil action, courts will often stay the civil proceeding so as to prevent the use of
+civil discovery and evidentiary procedures to obtain evidence for use in the criminal
+matter). Id. Courts will also stay a civil case to preserve 5" Amendment rights. Id.
+Further, a comparison of Fed.R.Civ. Pro. 26 may expand the rights of criminal discovery
+beyond the limits of Fed.R.Crim.Pro. 16(b). Epstein satisfies the requirements to stay
+this action as set forth in St. Paul Fire and in Eastwood, including the similarity of issues
+underlying the civil litigation and ongoing criminal investigation. As such, a stay should
+
+
+Case 9:08-cv-80380-KAM Document 104 Entered on FLSD Docket 05/13/2009 Page 6 of 7
+Page 6
+be entered in the instant matter. See also U.S. v. $75,020.00 In United States Funds, et
+al., 2009 WL 1010359 (M.D. G.a. 2009).
+III. Conclusion and Request for Relief
+Based upon the foregoing, Epstein is entitled to a full stay of this proceeding (and
+other related matters) until such time as the NPA expires and until the ongoing
+investigation by the USAO is closed (i.e., until late 2010). Alternatively, in an effort to
+protect Epstein's 5" Amendment and his due process rights in connection with
+defending these civil matters, this court should enter a stay of any discovery directed to
+Epstein and strike this case from the trial docket until the NPA and the ongoing
+investigation are both concluded and/or expired. In this manner, Plaintiff's investigation
+and discovery as to third parties will continue and will not be delayed. Epstein is
+invoking his 5" Amendment rights in the first place, which means that objections to
+discovery and deposition questions are being asserted so as not to waive those 5t
+Amendment rights. Once the NPA and the ongoing investigation terminate, this court
+could allow additional time for Plaintiff to complete Epstein's deposition and discovery
+directed to him, and then set this case on the Court's most available docket. Despite
+Plaintiff's contentions, Epstein's 5" Amendment rights and his due process rights
+associated therewith and in connection with defending this civil case should trump any
+civil claim for money damages when it comes to timing. Eastwood v. U.S., 2008 WL
+5412857, *6 (reasoning that a stay is warranted when the risk to an individual's
+constitutional rights is magnified).
+
+
+Case 9:08-cv-80380-KAM Document 104 Entered on FLSD Docket 05/13/2009 Page 7 of 7
+Page 7
+WHEREFORE, Epstein requests the following relief set forth above, and for such
+other and further relief as this court deems just and prope
+Robert D. Crifton, Jr.
+Attorney for Defendant Epstein
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
+served this day on all counsel of record identified on the following Service List in the
+maner spected by CECE on this fully or May, 209:
+Stuart S. Mermelstein, Esq.
+Jack Alan Goldberger
+Adam D. Horowitz, Esq.
+Atterbury Goldberger & Weiss, P.A.
+Mermelstein & Horowitz, P.A.
+250 Australian Avenue South
+18205 Biscayne Boulevard
+Suite 1400
+Suite 2218
+West Palm Beach, FL 33401-5012
+Miami, FL 33160
+561-659-8300
+305-931-2200
+Fax: 561-835-8691
+Fax: 305-931-0877
+jagesq@bellsouth.net
+ssm@sexabuseattorney.com
+Co-Counsel for Defendant Jeffrey Epstein
+ahorowitz@sexabuseattorney.com
+Counsel for Plaintiff Jane Doe #2
+Respectiny supmited,
+By: L
+ROBERTO CRITTON, JR., ESQ.
+Florida Bar No./ 224162
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER & COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Co-Counsel for Defendant Jeffrey Epstein)

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vision-fixhub/court-01/ac9ec130215fbdce55a4d8346c27d5378275073cc112dba18afe31093f81cdc0.md

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+'Case 9:08-CV-80994-KAM Document 8 Entered on FLSD Docket 10/14/2008 Page 1 of 9
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80994-Marral
+JANE DOE NO. 6
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+DEFENDANT'S, EPSTEIN, MOTION TO DISMISS & FOR MORE DEFINITE STATEMENT
+DIRECTED TO PLAINTIFF JANE DOE NO.6'S COMPLAINT
+Defendant, JEFFERY EPSTEIN, by and through his undersigned counsel, moves
+to dismiss and for more definite statement of Plaintiff JANE DOE NO. 6's Complaint.
+Rules 12(b)(6) and 12(e), Fed.R.Civ.P. (2008). In support of his motion, Defendant
+states:
+Introduction
+Defendant previously filed motions to dismiss and for more definite statement
+directed to the Amended Complaints filed against Defendant in this Court in JANE DOE
+NO. 2 (Case No. 08-CV-80119-Marra/
+), JANE DOE NO. 3 (Case No. 08-CV-
+80232-Marra
+), JANE DOE NO. 4 (Case No. 08-CV-80380-Marra/
+and JANE DOE NO. 5 (Case No. 08-CV-80381-Marra/
+Defendant is also
+filing similar motions in the actions filed by JANE DOE NO. 6 (Case No. 08-CV-80994-
+Marra/Johnsn), and JANE DOE NO. 7 (Case No. 08-CV-80993-Hurley/
+). The
+motions are directed to the Counts for Count I - "Sexual Assault and Battery," andCount
+III - "Coercion and Enticement to Sexual Activity in Violation of 18 U.S.C. §2422" in each
+
+
+'Case 9:08-cv-80994-KAM Document 8 Entered on FLSD Docket 10/14/2008 Page 2 of 9
+Case No. CV-80994-Marra-_
+Page No. 2
+of the respective complaints. However, there are distinctions in the six motions filed
+based on the complaint allegations. For example, in the previously filed four motions
+(Jane Doe Nos. 2 through 5), Defendant challenged the Plaintiffs' allegations as to
+assault in all four actions, and challenged the battery allegations in JANE DOE NOS. 2
+and 3, but not in JANE DOE NOS. 4 and 5. Defendant moved to dismiss the §2422
+count in all four of the JANE DOE Nos. 2 through 5 actions. As to JANE DOE NO. 6,
+Defendant challenges the battery allegations, but does not as to JANE DOE NO. 7 as
+the underlying facts of the requisite "touching" are alleged. Defendant challenges the
+18 U.S.C. §2422 count in both JANE DOE NO. 6 and NO. 7.
+Motion
+1. Counts I and III of JANE DOE NO. 6's Complaint are required to be dismissed for
+failure to state a claim upon which relief can be granted. Rule 12(b)(6). Plaintiff has
+failed to allege sufficient factual allegations in the Counts and instead alleges labels and
+conclusions, and an attempted formulaic recitation of the elements in each Count.
+2. In the alternative or in conjunction with, Defendant seeks more definite statement
+of Count I and III. In Count I, the Plaintiff is required to more definitely allege what was
+done to her; what EPSTEIN said and did, if anything, to create fear and apprehension in
+Plaintiff; what was the intentional offensive or harmful contact in pleading the elements
+of assault and battery. In Count III, Plaintiff is required to more definitely state the
+underlying factual allegations to support her claim as set forth in the statute, 18 U.S.C.
+§2422(b) and §2455. Rule 12(e). See discussion of law below herein.
+WHEREFORE, Defendant respectfully requests that this Court dismiss Counts I and
+Ill, and require Plaintiff to more definitely plead the underlying elements of her claims.
+
+
+'Case 9:08-cv-80994-KAM Document 8 Entered on FLSD Docket 10/14/2008 Page 3 of 9
+Page No. 3
+Supporting Memorandum of Law
+Standard on Rule 12(b)(6) Motion To Dismiss
+As established by the Supreme Court in Bell Atlantic Corp. V. Twombly, 127
+S.Ct. 1955 (2007), a motion to dismiss should be granted if the plaintiff does not plead
+"enough facts to state a claim to relief that is plausible on its face." Id, at 1974.
+Although the complaint need not provide detailed factual allegations, the basis for relief
+in the complaint must state "more than labels and conclusions, and a formulaic
+recitation of the elements of a cause of action will not do." Id, at 1965. Further, "flactual
+allegations must be enough to raise a right to relief above the speculative level ... on the
+assumption that all the allegations in the complaint are true (even if doubtful in fact)." Id.
+On a motion to dismiss, the well pleaded allegations of plaintiff's complaint are taken as
+true and construed in the light most favorable to the plaintiff. M.T.V. v. DeKalb County
+Sch. Dist., 446 F.3d 1153, 1156 (11th Cir.2006).
+Significantly, the Supreme Court in Bell Atlantic Corp. V. Twombly abrogated the
+often cited observation that "a complaint should not be dismissed for failure to state a
+claim unless it appears beyond doubt that the plaintiff can prove not set of facts in
+support of his claim that would entitle him to relief." Id, (abrogating and quoting Conley
+v.
+1. 355 U.S. 41, 45-46, 78 S.Ct. 99, 102, 2 L.Ed.2d 80 (1957)). The Supreme
+Court rejected the notion that "a wholly conclusory statement of claim [can] survive a
+motion to dismiss whenever the pleadings le[ave] open the possibility that a plaintiff
+might later establish some 'set of [undisclosed] facts' to support recovery." Id. As
+explained by the Supreme Court in Bell Atlantic Corp., supra at 1664-65:
+While a complaint attacked by a Rule 12(b)(6) motion to dismiss does not
+need detailed factual allegations,
+ibid.; Sanjuan V. American Bd. of
+Sychiatry and Neurology, Inc., 40 F.3d 247, 251 (C.A.7 1994), a plaintiff's
+obligation to provide the "grounds" of his "entitle[ment] to relief" requires
+
+
+•Case 9:08-Cv-80994-KAM Document 8 Entered on FLSD Docket 10/14/2008 Page 4 of 9
+Case No. CV-80994-Marra|
+Page No. 4
+more than labels and conclusions, and a formulaic recitation of the elements
+of a cause of action will not do, see Papasan v. Allain, 478 U.S. 265, 286,
+106 S.Ct. 2932, 92 L.Ed.2d 209 (1986) (on a motion to dismiss, courts "are
+not bound to accept as true a legal conclusion couched as a factual
+alevator, Factual legion muse outer at meet
+Procedure § 1216, pp. 235-236 (3d ed.2004) (hereinafter
+• Federal Practice ano
+(IT]he pleading must contain something more ... than ... a statement of facts
+that merely creates a suspicion [of] a legally cognizable right of action"), on
+the assumption that all the allegations in the complaint are true (even if
+doubtful in fact), see, e.g., Swierkiewicz v. Sorema N. A. 534 U.S. 506, 508,
+n. 1, 122 S.Ct. 992, 152 L.Ed.2d 1 (2002); Neitzke v.
+i, 490 U.S. 319,
+327, 109 S.Ct. 1827, 104 L.Ed.2d 338 (1989) (" Rule 12(b)(6) does not
+factual allegations: ishal based 02 a 410. 232, 236, 94 SC. int
+factual allegations"); Scheuer v.
+_ 416 U.S. 232, 236, 94 S.Ct. 1683,
+40 L.Ed.2d 90 (1974) (a well-pleaded complaint may proceed even if it
+appears "that a recovery is very remote and unlikely").
+Pursuant to Rule 12(e), a party may move for more definite statement of a
+pleading to which a responsive pleading is allowed where the pleading "is so vague or
+ambiguous that the party cannot reasonably frame a response." The motion is required
+to point out the defects and the desired details. Id.
+Count 1 - "Sexual Assault and Battery" is subject to dismissal as Plaintiff has
+failed to state a claim upon which relief can be granted.
+It is well settled that this Court is to apply Florida substantive law in this action.
+Erie R.Co. v. Tompkins, 58 S.Ct. 817 (1938). Pursuant to Florida law, although the term
+"assault and battery" is most commonly referred to as if it were a legal unit, or a single
+concept, "assault and battery are separate and distinct legal concepts, assault being the
+beginning of an act which, if consummated, constitutes battery." 3A Fla.Jur.2d Assault
+§1. An assault and battery are intentional acts. See generally, Spivey v. Battaglia, 258
+So.2d 815 (Fla. 1972); and Travelers Indem. Co. v. PCR, Inc., 889 So.2d 779 (Fla.
+2004).
+
+
+' Case 9:08-cv-80994-KAM Document 8 Entered on FLSD Docket 10/14/2008 Page 5 of 9
+Page No. 5
+An "assault" is an intentional, unlawful offer of corporal injury to another by force,
+or exertion of force directed toward another under such circumstances as to create a
+reasonable fear of imminent peril. See Lay v. Kremer, 411 So.2d 1347 (Fla. 1st DCA
+1982). It must be premised upon an affirmative act - a threat to use force, or the actual
+exertion of force. See 3A Fla.Jur.2d Assault §1 ("The essential element of the tort of
+assault is the violence offered, and not actual physical contact.").
+Tort of "battery" consists of the infliction of a harmful or offensive contact upon
+another with the intent to cause such contact or the apprehension that such contact is
+imminent. Quilling v. Price, 894 So.2d 1061 (Fla. 5" DCA 2005);
+v. Atlantic
+Federal Savings & Loan, 454 So.2d 52 (Fla. 4" DCA 1984)("'a battery consists of the
+intentional infliction of a harmful or offensive contact upon the person of another"). See
+3A Fla.Jur.2d Assault §1.
+With the standard of pleading established in Twombly, supra, in the context of
+the elements for assault and battery, Plaintiff has failed to state a claim upon which
+relief can be granted. Rule 12(b)(6). As to the elements of assault, here are no factual
+allegations as to what was said or done to Plaintiff such that it constituted an
+"intentional, unlawful offer of corporal injury to another by force, or exertion of force
+directed toward another under such circumstances as to create a reasonable fear of
+imminent peril." See 113 of Comp. The same is true for the claim of battery. Plaintiff
+makes the general allegation that "he (Defendant) sexually assaulted Jane." The other
+allegations in 113 pertain to what Plaintiff allegedly did. Under applicable law, Plaintiff is
+required to give more than labels and conclusions, and a formulaic recitation of the
+elements of a cause of action. Iwombly, supra. Plaintiff is required to allege the facts
+
+
+• Case 9:08-cv-80994-KAM Document 8 Entered on FLSD Docket 10/14/2008 Page 6 of 9
+Case No. CV-80994-Marra:
+Page No. 6
+of what was done to her; what EPSTEIN said and did, if anything, to create fear and
+apprehension in Plaintiff; what was the intentional offensive or harmful contact?
+As noted in the introduction and as this Court is well aware, there is more than
+one action brought against this Defendant attempting to allege similar sounding claims.
+The details as to a particular claim asserted by a particular Plaintiff are important to give
+this Defendant fair notice of Plaintiff's claim so he may properly respond. Accordingly,
+under applicable law, Plaintiff has failed to state a claim for sexual assault and battery.
+In the alternative to dismissing Count I, Defendant requests that Plaintiff be
+required to give more definite statement as to what was done to her; what EPSTEIN
+said and did, if anything, to create fear and apprehension in Plaintiff; what was the
+intentional offensive or harmful contact in pleading the elements of assault and battery.
+Rule 12(e). (
+Count III - "Coercion and Enticement to Sexual Activity in Violation of 18
+U.S.C. §2422" - is subject to dismissal as Plaintiff has failed to state a claim
+upon which relief can be granted. Rule 12(b)(6).
+Count III of Plaintiff's Complaint attempts to assert a claim for "Coercion and
+Enticement to Sexual Activity in Violation of 18 U.S.C. §2422." In her prayer for relief,
+Plaintiff demands judgment against EPSTEIN "for all damages available under 18
+U.S.C. §2255(a),...." Count Ill is required to be dismissed as Plaintiff has failed to
+state a claim under the statutes for which relief can be granted.
+The applicable version of these statutory provisions, (pre-2006 Amendments, as
+the Amended Complaint alleges a time period of "in or about 2004," 19), provides:
+CHAPTER 117-TRANSPORTATION FOR ILLEGAL SEXUAL ACTIVITY
+AND RELATED CRIMES
+§ 2422. Coercion and enticement
+
+
+• Case 9:08-cv-80994-KAM Document 8 Entered on FLSD Docket 10/14/2008 Page 7 of 9
+Case No. CV-80994-Marra
+Page No. 7
+(a) Whoever knowingly persuades, induces, entices, or coerces any
+individual to travel in interstate or foreign commerce, or in any Territory or
+Possession of the United States, to engage in prostitution, or in any sexual
+activity for which any person can be charged with a criminal offense, or
+attempts to do so, shall be fined under this title or imprisoned not more than
+20 years, or both.
+(b) Whoever, using the mail or any facility or means of interstate or foreign
+commerce, or within the special maritime and territorial jurisdiction of the
+United States knowingly persuades, induces, entices, or coerces any
+individual who has not attained the age of 18 years, to engage in prostitution
+or any sexual activity for which any person can be charged with a criminal
+offense, or attempts to do so, shall be fined under this title and imprisoned
+not less than 5 years and not more than 30 years.
+CHAPTER 110-SEXUAL EXPLOITATION AND OTHER ABUSE OF
+CHILDREN
+§ 2255. Civil remedy for personal injuries
+(a) Any minor who is a victim of a violation of section 2241(c), 2242, 2243,
+2251, 2251A, 2252, 2252A, 2260, 2421, 2422, or 2423 of this title and who
+sutters personal injury as a result of such violation may sue in any
+appropriate United States District Court and shall recover the actual
+damages such minor sustains and the cost of the suit, including a reasonable
+attorney's fee. Any minor as described in the preceding sentence shall be
+deemed to have sustained damages of no less than $50,000 in value.
+(b) Any action commenced under this section shall be barred unless the
+complaint is filed within six years after the right of action first accrues or in
+the case of a person under a legal disability, not later than three years after
+the disability.
+Relevant to Plaintiff's complaint, 18 U.S.C. 2255(a) creates a civil remedy for "a
+minor who is a victim of a violation of section ... 2422 ... of this title and who suffers
+personal injury as a result of such violation ...." Plaintiff has failed to plead any factual
+allegations whatsoever pertaining to violations of 18 U.S.C. 2422. Rather, Plaintiff has
+alleged conclusory allegations simply attempting to track parts of the statutory language
+in the statute without underlying factual allegations pertaining to the Plaintiff and any
+conduct by Defendant.
+See 128 of Comp. Plaintiff's allegations, (or lack of factual
+
+
+• Case 9:08-cv-80994-KAM Document 8 Entered on FLSD Docket 10/14/2008 Page 8 of 9
+Page No. 8
+allegations), are precisely what the standard set forth by the Supreme Court in Bell
+Atlantic Corp. prohibits - Plaintiff's complaint alleges only "labels and conclusions, and
+a (partial) formulaic recitation of the elements."
+First, the Complaint fails to designate whether Plaintiff is relying on §2422(a) or
+§2422(b). Second, although the complaint does contain a partial tracking of the
+language in 18 U.S.C. §2422(b), it contains absolutely no factual allegations concerning
+the requisite "using the mail or any facility or means of interstate or foreign commerce"
+by Plaintiff to state a cause of action based on a violation of 18 U.S.C. 2422(b). As well,
+there are no underlying factual allegations involving this Plaintiff as to the requisite
+elements that a defendant knowingly persuaded, induced, enticed, or coerced any
+individual (Plaintiff in this case) who has not attained the age of 18 years, to engage in
+prostitution or any sexual activity for which any person can be charged with a criminal
+offense, or attempted to do so. See 18 U.S.C. 2422(b); i.e. with what criminal offense
+could Plaintiff and Defendant have been charged. Again, a Plaintiff cannot simply track
+the language of a statute without some underlying factual allegations to state a claim
+upon which relief can be granted. Accordingly, Count Ill is required to be dismissed.
+In the alternative, Plaintiff should be required to more definitely state the
+underlying factual allegations to support her claim as set forth in the statute, 18 U.S.C.
+§2422(b) and §2455.
+Conclusion
+As discussed above herein, under the pleading standard established in Twombly,
+supra, and law concerning the elements of Count I and III, Plaintiff has failed to state
+claims upon which relief can be granted. Rule 12(b)(6). Plaintiff's complaint lacks
+
+
+• • • Case 9:08-cv-80994-KAM Document 8 Entered on FLSD Docket 10/14/2008 Page 9 of 9
+Case No. CV-80994-Marra
+Page No. 9
+underlying factual allegations and, thus, in the alternative to dismissal or in conjunction
+with, Plaintiff is required to more definitely state the requisite factual allegations.
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
+served this day on all counsel of record identified on the following Service List in the
+manner specified by CM/ECF on this 14* day of October, 2008:
+Adam D. Horowitz, Esq.
+Jeffrey Marc Herman, Esq.
+Stuart S. Mermelstein, Esq
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+ahorowitz@hermanlaw.com
+jherman@hermanlaw.com
+Irivera@hermanlaw.com
+Counsel for Plaintiff Jane Doe #2
+Respectfully submitted,/
+ROBERT D. CRITTON, JR., ESQ.
+Florida Bar No. 224162
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER & COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Co-Counsel for Defendant Jeffrey Epstein)

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