diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02820992/EFTA02820992.md b/marker2/court-redacted-v-epstein-81111/EFTA02820992/EFTA02820992.md new file mode 100644 index 0000000000000000000000000000000000000000..9925e59dfa289b4eebbc33c0cc3255b6ec4311d3 --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02820992/EFTA02820992.md @@ -0,0 +1,70 @@ +**CIVIL RICO CASE STATEMENT +PURSUANT TO LOCAL RULE 12.1** + +1. 1. Plaintiff M.J. alleges a violation of Florida Statutes §§ 772.103(3) (participation in an enterprise through a criminal activity) and 772.103(4) (conspiracy to do so). The following information describes both the § 772.103(3) claim and the § 772.103(4) conspiracy claim, with the additional note that the conspiracy was between defendant Jeffrey Epstein, [REDACTED], [REDACTED], Ghislaine Maxwell, Jean Luc Brunel and other persons whose identity is, at this time, unknown to M.J.. Epstein, [REDACTED], [REDACTED] and others all conspired together to violate the provisions of § 772.103(3), doing so willfully and with full knowledge of the criminal activities that were planned as part of the criminal enterprise. For convenience in this statement, Florida Statutes §§ 772.103(3) and (4) will be referred to as the “Florida Civil RICO provisions.” +2. 2. Epstein served as the leader, boss, and “C.E.O.” of the criminal enterprise. He also criminally sexually abused and prostituted M.J. and other minor girls who were victims of the criminal enterprise. He also paid for [REDACTED] and [REDACTED] and numerous other associates to be a part of the enterprise and conspired with them to commit criminal acts of sexual abuse and prostitution of minors. The basis for Epstein’s liability is also described in M.J.’s complaint. +3. 3. The other wrongdoers and criminal participants included [REDACTED], Ghislaine Maxwell, and Jean Luc Brunel. (M.J. is uncertain as to the precise spelling of their names and their full legal names.) They assisted defendant Jeffrey Epstein in recruiting and procuring minor girls to satisfy Epstein’s criminal sexual purposes and for prostitution, as described in MJ’s complaint, and to satisfy their own sexual interests. For example, to further the interests of the local Palm Beach chapter of this expansive criminal enterprise they helped to arrange for minor girls to travel to Epstein’s West Palm Beach mansion to satisfy his sexual desires for minor girls. [REDACTED], [REDACTED] and many others also conspired with Epstein to commit acts of sexual abuse and prostitution with minor girls and aided and abetted Epstein in the abuse and prostitution. [REDACTED], [REDACTED] and other members of this criminal organization had full knowledge of the crimes of the enterprise; they knew full well that the girls who were coming to Epstein’s mansion were minors and that Epstein was sexually abusing and prostituting these minors, some of whom were as young as 12. [REDACTED] and [REDACTED] willfully and knowingly participated in the activities of the enterprise and intended to make the criminal activities of the enterprise succeed. Among other things, [REDACTED] helped arrange for recruiters of the minor girls. She also spoke personally to the recruiters as well as to the minor girls who were victims of Epstein’s sexual abuse. At Epstein’s specific direction, [REDACTED] spoke to the recruiters about subjects such as finding more minor girls to satisfy Epstein’s criminal sexual appetite. [REDACTED] also served as Epstein’s scheduler, scheduling appointments for the minor girls to ostensibly do “work” when in fact (as she well knew) she was scheduling them to be sexually abused and prostituted by Epstein. [REDACTED] thus procured minor girls for prostitution and caused them to be prostituted and the term “work” was a code or slang word used by the various criminal enterprise members to avoid detection by law enforcement. [REDACTED], who is known to be Epstein’s bisexual sex slave, also directly participated in the sexual abuse of the minor girls by participating in unlawful sexual activities and prostitution with the girls. Both [REDACTED] and [REDACTED] assisted Epstein in attempting to keep Epstein’s criminal sexual abuse unknown + +to law enforcement and other authorities and in discouraging the minor girls from reporting the crimes to law enforcement and other authorities. Maxwell and Brunel participated by helping to create the impression that the girls would be going to meet with Epstein for legitimate “modeling” purposes. Maxwell and Brunel specifically intended to have Epstein abuse the girls and acted with full awareness of Epstein’s intentions. Both Brunel and Maxwell recruited minor females for Epstein as well as for themselves in an effort to further the goals of the criminal organization – to sexually abuse and molest underage minor females and avoid detection of law enforcement. Brunel used his modeling agency to locate underage girls for Epstein and others to sexually abuse. Maxwell personally brought underage girls to Epstein for him to sexually abuse, she also presented him with underage girls for him to maintain as sex slaves and to travel the globe with him and others, prostituting underage sex slaves to others. Maxwell was also a participant in sexually abusing minor females. Maxwell served many additional purposes for the criminal organization and was highly ranked within the organization, thus she was able to act on her own accord, without needing orders from Epstein. Maxwell’s roles and actions on behalf of the criminal enterprise have included but not been limited to: procuring minor females for her and Epstein and others to sexually abuse, hiring personnel to work for Epstein and for the various positions in the criminal organization, developing relationships with politically connected individuals to protect the organization, managing and organizing the records of the enterprise, maintaining computer records and images of underage minor females with their names and phone numbers, threatening witnesses who have information that could hurt the enterprise, and assisting Epstein and other members of the criminal enterprise to continue the criminal activity of the organization and avoid law enforcement detection or prosecution. + +1. 4. The names of all of the victims are unknown to the plaintiff at this time. However, they include M.J. herself as well as the victims in the multitude of other civil cases, both filed and unfiled, against Epstein. A list of more than 30 such minor female victims was previously provided by the U.S. Attorney’s Office for the Southern District of Florida to Epstein (but not to M.J.). The injuries to those victims resulted from criminal sexual activity and prostitution with Epstein and [REDACTED] and at times Maxwell. The injuries they suffered are like those suffered by M.J. in this action, as described in her complaint. For example, M.J. and the other victims suffered grave emotional distress and financial injury from being forced to engage in unlawful sexual activities with him to which, as minors, they could not lawfully consent, and from being introduced into a deviant sexual lifestyle. They also suffered distress and financial injury from being prostituted by him. +2. 5. The pattern of racketeering and/or criminal activity is also described in the complaint, which M.J. incorporates by reference into this statement here and at all other points in the statement. The criminal activity included Epstein using paid employees and underlings (including [REDACTED] and [REDACTED]) to repeatedly find, procure, and bring to him minor girls in order for Epstein to solicit, induce, coerce, entice, compel or force these minor girls to engage in unlawful sexual activity and acts of prostitution and Epstein using Ghislaine Maxwell and Jean Luc Brunel and others yet unnamed to create the impression that he was involved in legitimate modeling and other activities. + 1. a. The criminal activity and specific statutes violated are listed in the complaint and include, but are not necessarily limited to: (i) procuring for prostitution, or causing to be prostituted, minors, in violation of Florida Statutes Chapter 796; (ii) acts of battery in violation of Florida Statutes Chapter 784; (iii) commercial sexual exploitation of a + +child in violation of Florida Statutes § 827.071; and (iv) tampering with a witness in violation of Florida Statutes § 914.22. The criminal activities also include violations of federal criminal statutes, including sexual trafficking of children by fraud, in violation of 18 U.S.C. § 1591, use of a means of interstate commerce to entice a minor to commit prostitution, in violation of 18 U.S.C. § 2422, as well as wire fraud, in violation of 18 U.S.C. § 1343. + +- b. The dates of the events are not fully known to M.J. at this time. However, at a minimum, Epstein obtained minor girls (including M.J.) for sexual purposes of the period of approximately 1998 through November 2005. Epstein could better determine than M.J. the precise dates of his abuse of her by reviewing his schedule or computer records for this period of time and looking for notations of days on which she performed “work” for him. Epstein has pled guilty to two such criminal offenses against minor girls, although the total number of indictable or chargeable offenses would easily number more than 1000. On each of these occasions, as described in the complaint, Epstein would have his underlings, co-conspirators or associates (including [REDACTED]) procure a minor girl to satisfy his sexual desires and then would satisfy his sexual desires through criminal sexual contact with the minor girls. Epstein would also watch [REDACTED] or Maxwell sexually abuse the minor girls to satisfy his sexual desires. Epstein had a particular interest in minor girls, including girls as young as 12. On occasion, he would turn away girls who were 18 or over because of his perverse and unlawful sexual interest in young girls. Epstein recruited and paid the girls for the sexual activities. In doing so, he procured for prostitution, and caused to be prostituted, many young girls under the age of 18, in violation of (among other statutes) Florida Statute § 796.03. The pattern of criminal and unlawful sexual activity extended from at least 1998 through November 2005 and upon information and belief actually existed and operated in a criminal organizational structure for many years prior to 1998. Epstein committed unlawful sexual abuse against M.J. at least 20 times between Summer of 2002 to Spring 2004 while she was a minor. Other criminal activities involving tampering with and harassing witnesses occurred from June 2002 through early 2008 (and perhaps later). +- c. On many of the occasions, the exact dates of which are not as yet determined by the M.J., Epstein would represent that he was interested in a “massage” or legitimate “work” when in fact he was interested in unlawful sexual activity with the minor girls, including fondling the girls, masturbating in their presence, and vaginally penetrating them or causing them to be penetrated. Epstein and others acting under his direction falsely represented to the minor girls that he was interested in a “massage” or “work” when in fact he was interested in procuring the girls for unlawful sexual activity and acts of prostitution. Epstein and others acting under his direction used means of interstate communications to make these false representations, including cellular telephones. Similar to all known crime families or criminal organizations that operate to commit crimes, this criminal enterprise made use of seemingly innocuous code words such as “message” and “work” to describe the continuous criminal activity of procuring underage girls to sexually molest, abuse and exploit. +- d. Epstein has pled guilty to two Florida felony criminal offenses against minor girls, as alleged in the complaint and Epstein is a Registered Sexual Offender for life. + +e. The relationship of the criminal activity to the enterprise is also described in the complaint. The Florida offenses to which Epstein pled guilty are but a few of the many instances of his plan succeeding. The acts are all related to each other, are arranged, and are part of common plan for these reasons: they have the same intent (to gratify Epstein's unlawful sexual interest in minor girls as well as to gratify the unlawful sexual interests in minor girls of others at times); the same results (the unlawful sexual abuse and prostitution of minor girls); the same accomplices (including [REDACTED] and frequently [REDACTED], Maxwell, and Brunel); the same victims (M.J. was herself victimized more than 20 times, and many other girls were also victimized repeatedly); the same means (there was a standard payment of several hundred dollars for going to the mansion, and standard escalation feature depending on the nature of the sexual acts that Epstein performed); the same methods of commission (Epstein obtained young, skinny, and attractive girls to satisfy his sexual desires while they were economically disadvantaged and lacked a stable family life and therefore, he perceived, would be interested in obtaining money and unlikely to report his crimes to law enforcement); and the same frequency (remarkably Epstein's criminal enterprise operated constantly to procure underage minor females to be sexually abused by Epstein every single day, oftentimes 2 or 3 different underage females in a single day). The acts were also interrelated by common characteristics, namely the identity of the perpetrator (Epstein and often [REDACTED] or sometimes Maxwell) and the common results of his crimes (sexual abuse and acts of prostitution with minor girls). The acts also constituted a clear pattern of criminal activity, including giving the impression to the girls who were being recruited that they would have legitimate modeling opportunities. + +6. The criminal acts of Epstein occurred repeatedly over a substantial period of time and were not isolated events. In particular, Epstein committed repeated (more than 20) criminal acts of sexual abuse against M.J. from approximately Summer 2002 to Spring 2004. He committed similar criminal acts of unlawful sexual activity and prostitution against other minor girls for a period of time from at least 1998 to November 2005. The acts occurred frequently during this time, so frequently that it is impossible to calculate how many different illegal sexual acts were committed by Epstein and his criminal enterprise, but it is fair to say that serious felonies were committed by this criminal organization on an everyday basis. The acts were part of Epstein's regular way of doing business (e.g., obtaining sexual gratification from minors) during this period of time. Epstein and others acting at his direction (including [REDACTED]) made hundreds of telephone calls in furtherance of these illegal activities. The sexual acts against minors may have temporarily ceased in approximately November 2005 when Epstein learned that law enforcement authorities were investigating his crimes. Given Epstein's long history of sexually abusing minors and the frequency at which he has done so and the fact that despite his arrest and jail sentence his criminal organization remains intact, it is highly likely that he will continue his sexual desires for minor girls. In addition, Epstein committed criminal acts of tampering with witnesses in violation of Florida Statutes § 914.22. For example, Epstein paid the minor girls money not only with the intent to prostitute them but also with the specific intent of causing the minor girls not to communicate to law enforcement officers information about the sexual abuse committed against them. Epstein made bigger payments to the minor girls depending on the degree of force he used towards them, making larger payments when he was more concerned about the + +fact they might report the crimes committed against them. Without specifically detailing acts committed against certain known minors, Epstein has paid \$1000 on occasion after forcibly holding the head of a minor down and pumping his penis inside her against her will. Epstein has also intimidated and reprimanded his co-conspirators and associates for any cooperating with law enforcement and has made it known that his associates must stay loyal to the criminal enterprise above all else. These obstructions may interfere with the ability of law enforcement to discover and prosecute all of Epstein's crimes. They may likewise interfere with the ability of M.J. to discover all of the information supporting her claim. Epstein also selected impoverished girls for his crimes, believing that the payments would be more effective in obtaining their silence and that their economic circumstances might make them less likely to report to law enforcement. If all else failed, after having unlawful sex with the minor girls, Epstein would tell them not to tell anyone about their unlawful encounter or "bad things" would happen. In addition, since November 2005 and through the early part of 2008 (and perhaps later), Epstein and others acting at his direction have attempted to discourage the victims of his crimes from reporting his crimes and cooperating with law enforcement. For example, persons acting at the direction of Epstein have aggressively attempted to "interview" the victims or to "tail" the victims in their cars. They also harassed a victim shortly before she was to testify at a grand jury investigating Epstein and aggressively intimidated a victim to scare her away from proceeding to trial against him. These efforts have been made not for legitimate investigative reasons but rather for the purpose of discouraging the victims from cooperating with law enforcement (and, in at least one case, the investigating grand jury) and from filing civil lawsuits to vindicate their rights. + +7. The enterprise is also described in the complaint, which allegations M.J. expressly incorporates into this statement as part of the description of the enterprise. The enterprise included, at a minimum, a group of individuals associated in fact to assist Epstein in recruiting and procuring minor girls and obtaining criminal gratification of his illegal sexual interest in minor girls and at least two individuals (Ghislaine Maxwell and Jean Luc Brunel) who were free to act independently and advance their own interests, including their own sexual interests. + +1. a. The persons constituting the enterprise included a group of individuals associated in fact. These individuals include Epstein, [REDACTED], [REDACTED], Ghislaine Maxwell, and Jean Luc Brunel, as well as other yet unnamed persons whose names M.J. intends to identify during the discovery phase of this case. +2. b. The criminal enterprise had a definite hierarchal structure, although all the details of that structure are not completely known to M.J.. Through discovery, M.J. intends to ascertain the precise structure of the enterprise that enabled Epstein to commit sexual crimes against here. While M.J. does not currently know all of the details of the structure, she does know that the enterprise operated together on a continuing basis, in an extremely efficient and organized manner, with largely the same personnel for a common purpose. The shared purpose of the enterprise was to satisfy Epstein's, as well as certain other individual's, illegal interest in having sexual activities with minor girls as well. The enterprise was not a mere informal conspiracy, but had a definite clear structure. Epstein served effectively as the leader, C.E.O. or "Boss" of this organization, directing his various levels of underlings how to recruit and procure young girls for his sexual activities and when to bring the girls to his mansion as well as how to avoid law enforcement + +detection. Epstein's key "lieutenant" in the Palm Beach branch of this national and possibly international organization was [REDACTED], who served as both his scheduler and a recruiter/procurer of the girls. This was an important function, as the recruiting was necessary to satisfy Epstein's desire to abuse a large number of different minor girls with different (albeit similar) physical attributes and the scheduling was necessary to insure that the minor girls would be brought to Epstein's mansion to be sexually abused and prostituted at a time when Epstein was there (but not at the same time, when they might learn of other girls' identities and possibly become emboldened to report his activities to law enforcement.) Scheduling was also necessary to ensure secrecy, so that as few persons as possible were aware that minor girls were coming at unusual hours to Epstein's mansion. [REDACTED] also needed (directly or indirectly) to make transportation arrangements for many of the girls, as they were often too young to drive themselves to and from the mansion. [REDACTED] also served as a recruiter and helped Epstein satisfy his criminal sexual desires by, on occasion, directly participating in sexual abuse and prostitution of the minor girls. Epstein, [REDACTED], and [REDACTED] all took steps to conceal the existence of the enterprise and to discourage the girls from reporting the sexual abuse and prostitution to law enforcement or other authority figures. Epstein also used otherwise-legitimate business activities to help further the purpose of the criminal enterprise. These apparently legitimate activities provided "cover" for Epstein and his associates to commit the crimes. Ghislaine Maxwell and Jean Luc Brunel also helped to provide "cover" for the enterprise by creating the impression that there were legitimate modeling opportunities and other legitimate opportunities available for the girls if they went to see Epstein. Epstein also maintained the appearance of an extremely wealthy, upstanding and prominent figure to discourage the minor girls from reporting the abuse to law enforcement. To further impress the underage minor victims, he would tell them that he was a famous scientist, a brain surgeon, an inventor of various products including a state of the art liposuction device. He would also brag about the famous people with whom he was good friends. By projecting an image of financial power (and, relatedly, strong political connections to prominent politicians and current and former government officials and personal connections to prominent scientists), Epstein hoped to discourage the minor girls from reporting what he was doing to them by making it appear that they would not be believed. These business activities helped Epstein secure the financial resources to commit the crimes against the minor girls and to pay for prostituting them. For example, the activities paid for maintaining the mansion where the girls were abused and paid for the cellular telephones and other means of communications that were used to recruit and procure the girls. The business activities also helped to provide the funds to pay [REDACTED] and [REDACTED] large sums of money to participate in the illegal enterprise and make payments to the girls for performing sexual acts. In sum, Epstein and the persons under his direction associated in fact and functioned as a continuing unit. This enterprise produced a course of conduct that lead to a pattern of criminal activity involving more than 100 instances of sexual abuse and prostitution of minor girls. This enterprise was the vehicle for Epstein to commit his crimes against M.J. and other + +minor girls and operated on a continuing basis from June 2002 to November 2005 (and, in regard to witness tampering and harassment, through at least early 2008). The enterprise enabled Epstein to sexually abuse and prostitute M.J. in particular on more than 20 occasions from February 2003 through June 2005. + +- c. Epstein served as the effective leader or "C.E.O." of the enterprise. +- d. Epstein was associated with the enterprise as its effective leader or "C.E.O." +- e. Epstein directed the affairs of the enterprise and the others in the enterprise responded to his commands, although Ghislaine Maxwell and Jean Luc Brunel acted independently to advance their own interests (including sexual interests) along with the interests of Epstein. +- f. Based on the facts that she currently possesses, M.J. specifically alleges and intends to prove both that (i) Epstein was an individual separate and disctinct from the enterprise and (ii) the defendant was a member of the enterprise, namely that he served as the effective leader of the enterprise. With regard to point (i), the illegal enterprise had a definite structure and operational function apart from Epstein. The structure is described in greater detail in this statement in answer 5.b above. With regard to point (ii), the defendant was a member of the enterprise and served to execute many of the decisions and activities of the enterprise and to command the execution of others. Epstein personally engaged in sexual abuse of minor girls, including M.J.. Epstein also directed others to engage in sexual abuse of minor girls, including [REDACTED]. Epstein also procured girls for prostitution and caused these girls to be prostituted. Epstein also served as the leader of the enterprise. +- g. Epstein was a direct perpetrator of the racketeering activity. In particular, Epstein engaged in criminal acts of sexual abuse and prostitution with minor girls, as well as procuring girls for prostitution. He also directed others (i.e., [REDACTED]) to engage in such criminal acts and served as the leader of the criminal enterprise. + +8. The relationship between the pattern of criminal activity and the enterprise is not completely known to M.J. at this time, and it is not known how much money or other consideration was generated by the enterprise through these illegal means. Through discovery, she intends to understand the relationship more fully. At this time, however, as described in addition in the complaint and parts 5, 6 and 7 in this statement, there was a criminal entity separate and apart from the pattern of activity in which it engaged. The pattern of criminal activity was the series of crimes committed by Epstein and others, and includes the specific crimes identified in part 5.a. above. These offenses were closely related and formed a clear pattern, as described in part 5.b above. These acts included acts of sexual abuse and procuring the prostitution of minors by Epstein personally and by [REDACTED] acting at Epstein's direction. In contrast, the enterprise was the group of persons who associated together for the common purpose of engaging in the criminal course of conduct described at greater length elsewhere in this statement, including part 5.e above. The group of persons included Epstein, [REDACTED], [REDACTED], Maxwell, and Brunel and others whose identity is, at this time, unknown to M.J.. + +9. In this part of the statement, M.J. will provide a description of the relationship between the otherwise-lawful activities of the enterprise and the criminal activities of the enterprise. The lawful and unlawful activities of the enterprise have been described in addition in paragraphs 10 through 18 and 42 through 43 of the complaint and previous answers found in parts 5, 6 + +and 7 above (which M.J. expressly incorporates into her answer here). The usual and daily activities of the criminal enterprise included scheduling meetings, activities, and other events for Epstein – including scheduling “private time” in his mansion for Epstein to commit sexual crimes against minor girls. ██████ served as Epstein’s scheduler, scheduling both otherwise-lawful activities to provide “cover” for Epstein as well as the illegal sexual activities. The exact frequency with which the sexual crimes took place varied and is not known, at this time, to M.J.. However, when Epstein was in West Palm Beach, it often occurred on a weekly or daily basis (and, in some instances, took place on several times during a single day). The scheduling was designed to secure a private place in Epstein’s mansion when few other persons would be present at the mansion, so as to reduce the chance of detection of Epstein’s sexual abuse and prostitution as well as to make it more difficult for the minor girls to report his actions to law enforcement or other authorities. The usual activities of the enterprise also included maintaining the mansion and securing means of communication (i.e., cellular telephones) to recruit minor girls and procure them for prostitution. The activities further included arranging transportation for the girls to and from the mansion if it was necessary. The enterprise also attempted to make Epstein appear to be an upstanding and law-abiding member of community and a successful businessperson, for reasons described in paragraph 6.b above. The enterprise served as the usual way in which Epstein would obtain sexual gratification. + +1. 10. Through his criminal enterprise, Epstein received perverse and unlawful sexual gratification from sexually abusing minor girls and engaging in acts of prostitution with them. He also received perverse sexual gratification from directing others (e.g., ██████) to sexually abuse and prostitute minor girls. +2. 11. While M.J.’s civil action alleges violations of the Florida Civil RICO statute rather than violations of the federal civil RICO statute, it should be noted that means of interstate communications were used to perpetrate the crimes against minor girls (including M.J.), including cellular and other telephones that Epstein used, or caused to be used, to arrange his illegal sexual activities and to recruit additional minor girls to participate in these activities. Through his recruitment and procuring of young girls, Epstein’s activities directly affected interstate commerce. +3. 12. Based on the information currently known to her, M.J. does not allege that Epstein, who is a billionaire banker, used the enterprise to personally make a financial profit or to obtain the collection of an unlawful debt, only because that information has not yet been made available to MJ. Epstein did, however, make payments to and prostitute the minor girls for the sexual gratification that he obtained from them and to discourage them from reporting his crimes to law enforcement and other authorities. Epstein also has, through his criminal organization, prostitutes underage girls to others, and Epstein and the criminal organization gained valuable consideration from that activity, although it is unknown the type and amount of remuneration at this time. +4. 13. Based on the information currently known to her, M.J. does not allege that Epstein, who is a billionaire banker, used the enterprise to obtain or maintain control of a business enterprise or real property. Epstein did, however, use his West Palm Beach mansion (and his various other properties including his personal island) to perpetrate the crimes against the then-minor girls. He also used his financial success to provide “cover” for his crimes, as described in part 6.b above. +5. 14. The criminal enterprise is described in the complaint and part 6 of this statement above, + +which description M.J. incorporates here. + +a. The enterprise including persons unknown to M.J., but at least included Epstein and his paid assistants [REDACTED] and [REDACTED] as well as associates of Epstein (who were free to act independently and to advance their own interests) Ghislaine Maxwell and Jean Luc Brunel + +b. Under the direction of Epstein, [REDACTED], [REDACTED] and others whose names are unknown to M.J. arranged for minor girls to come to Epstein's mansion where he could sexual abuse them and prostitute them to satisfy his perverse sexual desires, as well as the perverse sexual desires of Ghislaine Maxwell and Jean Luc Brunel. [REDACTED] and [REDACTED] were responsible for recruiting the girls and procuring them for prostitution. [REDACTED] was also responsible for scheduling a time when both Epstein and the minor girl could meet together at Epstein's mansion for the sexual abuse and for making travel arrangements (if necessary) for the girls. [REDACTED] was also responsible for ensuring the privacy of the room in Epstein's mansion where Epstein would sexually abuse the girls. [REDACTED] would participate in abusing and prostituting the girls for Epstein's sexual gratification. [REDACTED] and [REDACTED] received payments and other forms of compensation from Epstein for performing these illegal activities and for participating in the enterprise. Epstein, [REDACTED], and [REDACTED] also all took steps to discourage the girls from reporting these crimes to law enforcement, including making cash payments to the girls. Ghislaine Maxwell and Jean Luc Brunel helped to persuade the girls that legitimate modeling opportunities could be had if they went to see Epstein. + +c. As a result of the criminal enterprise, M.J. (then a minor) suffered criminal sexual abuse at the hands of Epstein. As alleged in greater detail in the complaint, this abuse lead to significant past and future physical injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of privacy, and other damages, including consequential damages from Epstein controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. In addition, the time involved in the abuse created lost opportunities to pursue other activities (including economic activities) and lead to past and future financial and proprietary losses to M.J., as well as the need for psychiatric services. M.J. has also suffered a loss of income, a loss of capacity to earn income in the future, and a loss of the capacity to enjoy life. It has also lead to the need to file this civil suit, with consequent attorney's fees. All of these damages were caused by, and proximately caused by, the criminal enterprise and its criminal acts. All of these injuries were inflicted directly on M.J. and occurred by reason of the criminal acts of the enterprise, including the acts of sexual abuse by Epstein. + +d. The defendant "person" in the Florida Civil RICO action is, at this time, only defendant Epstein. Defendant Epstein is associated with a criminal enterprise that conducted and participated, both directly and indirectly, in a pattern of criminal activity in violation of both Florida and federal criminal law. The exact relationship between Epstein and the criminal enterprise is described in greater detail in parts 5 and 6 above. + +15. The criminal conspiracy involving the enterprise is described in the complaint as well as parts 5, 6, and 7 above. M.J. expressly incorporates that information into her statement here. The conspiracy was formed of Epstein, [REDACTED], [REDACTED], and many others, who agreed to arrange for illegal sexual gratification by Epstein through the sexual abuse and prostitution of minor girls both by Epstein personally and by others (i.e., [REDACTED]) while he watched, as + +well as to provide illegal sexual gratification to Ghislaine Maxwell and Jean Luc Brunel. Certain other names of other criminal enterprise members and co-conspirators are known yet currently unnamed, and many other names are currently unknown but Plaintiff intends to learn the names and roles of all involved in the criminal activity of this enterprise. The many enterprise members conspired to commit similar crimes and to conceal those crimes also in furtherance of the criminal enterprise. The object and substance of the conspiracy was to obtain minor girls for Epstein so that he could satisfy his perverse sexual interest in minor girls, to recruit minor girls to be abused and prostituted for his gratification, to keep the existence of the sexual abuse from being learned by law enforcement and other authorities, and to discourage the victims from reporting the abuse to authorities, as well as to provide sexual gratification to Maxwell and Brunel. The conspiracy started in approximately June 2002 in West Palm Beach, Florida, and other locations. The sexual abuse of the minor girls appears to have, at least temporarily, ceased in approximately 2005. The conspiracy extended beyond November 2005 to early 2008 (and perhaps later) in its efforts to keep the criminal conspiracy unknown, as described in part 5.f above. The conspiracy committed numerous overt acts. For example, [REDACTED] and [REDACTED] arranged for minor girls to be brought to Epstein's West Palm Beach mansion so that he could sexually abuse the girls and obtain sexual gratification. Epstein sexually abused minor girls at his mansion and made payments to them and otherwise prostituted them there. + +1. 16. M.J. suffered injuries, including financial and proprietary injuries, as described in part 13.C above. +2. 17. The enterprise injured M.J. and the other minor girls by enabling Epstein to sexually abuse and prostitute the girls. +3. 18. Defendant Epstein is liable for all the damages for his criminal activity and the activity of his criminal enterprise. (If additional defendants are added to the complaint, these other defendants may also be jointly and severable liable for the damages.) The damages for which Epstein is liable include compensatory damages (including damages for emotional distress as well as damages for financial and proprietary losses), attorney's fees, and such further relief as the Court deems just and proper. The amount of these damages is significant. These damages are trebled by operation of Florida Statutes 772.104. M.J. is aware of the provision in Florida Statutes 772.104(3) ("In no event shall punitive damages be awarded under this section"), but is nonetheless entitled to punitive damages by virtue of her other counts in her complaint. She is seeking punitive damages for Epstein's outrageous and egregious conduct and crimes under other provisions of law in this lawsuit. +4. 19. All of the above answers must be read in light of the complaint that has been filed in this case. M.J. expressly incorporates by reference her complaint as part of the answer to each of the above questions. 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This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.) **NOTICE: Attorneys MUST Indicate All Re-filed Cases Below.** + +**I. (a) PLAINTIFFS** + +M.J., + +**(b) County of Residence of First Listed Plaintiff Palm Beach County** +(EXCEPT IN U.S. PLAINTIFF CASES) + +**(c) Attorney's (Firm Name, Address, and Telephone Number)** + +J [REDACTED] +J. Jaffe, Weissing, [REDACTED]s, Fistos & Lehrman +425 N. Andrews Avenue, Suite 2 +Fort Landerdale FI 33301 + +**DEFENDANTS** + +JEFFREY EPSTEIN and [REDACTED] + +County of Residence of First Listed Defendant +(IN U.S. PLAINTIFF CASES ONLY) + +NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE TRACT LAND INVOLVED. + +Attorneys (If Known) + +(4) Check County Where Action Arose: MIAMI- DADE MONROE BROWARD PALM BEACH ST. LUCIE INDIAN RIVER OKEECHOBEE HIGHLANDS + +**II. BASIS OF JURISDICTION** + +(Place an "X" in One Box Only) + +- 1 U.S. Government Plaintiff +- 3 Federal Question (U.S. Government Not a Party) +- 2 U.S. Government Defendant +- 4 Diversity (Indicate Citizenship of Parties in Item III) + +**III. CITIZENSHIP OF PRINCIPAL PARTIES** (Place an "X" in One Box for Plaintiff and One Box for Defendant) + +| Citizen of This State | PTF | | PTF | | | +|-----------------------|-------------------------------------|-----|---------------------------------------------------------------|--------------------------|---| +| | 1 | DEF | 1 | DEF | | +| | | 1 | Incorporated or Principal Place of Business In This State | | 4 | +| | | 2 | Incorporated and Principal Place of Business In Another State | | 5 | +| | | 3 | Foreign Nation | | 6 | + +**IV. NATURE OF SUIT** (Place an "X" in One Box Only) + +| CONTRACT | TORTS | PERSONAL INJURY | FORFEITURE/PENALTY | BANKRUPTCY | OTHER STATUTES | +|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| +| 110 Insurance
120 Marine
130 [REDACTED] Act
140 Negotiable Instrument
150 Recovery of Overpayment & Enforcement of Judgment
151 Medicare Act
152 Recovery of Defaulted Student Loans (Excl. Veterans)
153 Recovery of Overpayment of Veteran's Benefits
160 Stockholders' Suits
190 Other Contract
195 Contract Product Liability
196 Franchise | 310 Airplane
315 Airplane Product Liability
320 Assault, Libel & Slander
330 Federal Employers' Liability
340 Marine
345 Marine Product Liability
350 Motor Vehicle
355 Motor Vehicle Product Liability
360 Other Personal Injury | 362 Personal Injury - Med. Malpractice
365 Personal Injury - Product Liability
368 Asbestos Personal Injury Product Liability
370 Other Fraud
371 Truth in Lending
380 Other Personal Property Damage
385 Property Damage Product Liability | 610 Agriculture
620 Other Food & Drug
625 Drug Related Seizure of Property 21 USC 881
630 Liquor Laws
640 R.R. & Truck
650 Airline Regs.
660 Occupational Safety/Health
690 Other | 422 Appeal 2X USC 158
423 Withdrawal
28 USC 157
PROPERTY RIGHTS
820 Copyrights
830 Patent
840 Trademark | 400 State Reapportionment
410 Antitrust
430 Banks and Banking
450 Commerce
460 Deportation
470 Racketeer Influenced and, Corrupt Organizations
480 Consumer Credit
490 Cable Sat TV
810 Selective Service
850 Securities/Commodities Exchange
875 Customer Challenge
12 USC 3410
890 Other Statutory Actions
891 Agricultural Acts
892 Economic Stabilization Act
893 Environmental Matters
894 Energy Allocation Act
895 Freedom of Information Act
900 Appeal of Fee Determination Under Equal Access to Justice
950 Constitutionality of State Statutes | +| REAL PROPERTY | CIVIL RIGHTS | PRISONER PETITIONS | LABOR | SOCIAL SECURITY | FEDERAL TAX SUITS | +| 210 Land Condemnation
220 Foreclosure
230 Rent Lease & Ejectment
240 Torts to Land
245 Tort Product Liability
290 All Other Real Property | 441 Voting
442 Employment
443 Housing: Accommodations
444 Welfare
445 Amer. w/Disabilities Employment
446 Amer. w Disabilities Other | 510 Motions to Vacate Sentence
530 General
535 Death Penalty
540 Mandamus & Other
550 Civil Rights
555 Prison Condition | 790 Other Labor Litigation
791 Empl. Ret. Inc. Security Act
462 Naturalization Application
463 Habeas Corpus-Atien Detainee
465 Other Immigration Actions | 861 HIA (1395ff)
862 Black Lung (923)
863 DIWC/DIWW (405(g))
864 SSID Title XVI
865 RSI (405(g))
870 Taxes (U.S. Plaintiff or Defendant)
871 IRS Third Party 26 USC 7609 | 895 Economic Stabilization Act
893 Environmental Matters
895 Freedom of Information Act
950 Constitutionality of State Statutes | + +**V. ORIGIN** (Place an "X" in One Box Only) + 1 Original Proceeding 2 Removed from State Court 3 Re-filed- (see VI below) 4 Reinstated or Reopened 5 Transferred from another district (specify) 6 Multidistrict Litigation 7 Appeal to District Judge from Magistrate Judgment + +**VI. RELATED/RE-FILED CASE(S).** (See instructions second page): + a) Re-filed Case YES NO b) Related Cases YES NO + JUDGE DOCKET NUMBER + +**VII. CAUSE OF ACTION** Cite the U.S. Civil Statute under which you are filing and Write a Brief Statement of Cause (Do not cite jurisdictional statutes unless diversity): + 18 USC 2255, Sexual exploitation of a minor + LENGTH OF TRIAL via \_\_\_\_ days estimated (for both sides to try entire case) + +**VIII. 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Apt. 102 Palm Beach, FL 33480 + +Civil Action No. + +## SUMMONS IN A CIVIL ACTION + +A lawsuit has been filed against you. + +Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ. P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff's attorney, whose name and address are: J. + +Jaffe, Weissing, Fistos & Lehrman 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 + +If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court. + +Date: + +CLERK OF COURT + +Signature of Clerk or Deputy Clerk + +AO 440 (Rev. 12/09) Summons in a Civil Aaron (Paso 2) + +Civil Action No. + +## PROOF OF SERVICE + +(This section should not be filed with the court unless required by Felt R. Civ. P. 4 (7)) + +This summons for (name of individual and sale. If an)) was received by me on (date) + +O I personally served the summons on the individual at (place) on (date) or + +Date: + +O I left the summons at the individual's residence or usual place of abode with (name) . a person of suitable age and discretion who resides there, on (date) , and mailed a copy to the individual's last known address; or + +O I served the summons on (name of individual) designated by law to accept service of process on behalf of Mame of organization) on (date) , who is or + +O I returned the summons unexecuted because ; or + +O Other awe: + +My fees are S for travel and S for services, fora total of S 0.00 + +I declare under penalty of perjury that this information is true. + +Sereer's signature + +Printed name and tide + +Server's address + +Additional information regarding attempted service, etc: \ No newline at end of file diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821005/EFTA02821005.metadata.json b/marker2/court-redacted-v-epstein-81111/EFTA02821005/EFTA02821005.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..52f57d5455f39e18436eee0e2241839da252bec7 --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821005/EFTA02821005.metadata.json @@ -0,0 +1,170 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-redacted-v-epstein-81111/EFTA02821005.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2214, + "elapsed_seconds": 1.07, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 181.152, + 79.24407958984375 + ], + [ + 437.5708923339844, + 79.24407958984375 + ], + [ + 437.5708923339844, + 101.25 + ], + [ + 181.152, + 101.25 + ] + ] + }, + { + "title": "SUMMONS IN A CIVIL ACTION", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 227.66400000000002, + 251.91 + ], + [ + 386.77801513671875, + 251.91 + ], + [ + 386.77801513671875, + 264.87 + ], + [ + 227.66400000000002, + 264.87 + ] + ] + }, + { + "title": "PROOF OF SERVICE", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 255.204, + 102.96124267578125 + ], + [ + 360.46799999999996, + 102.96124267578125 + ], + [ + 360.46799999999996, + 115.0745849609375 + ], + [ + 255.204, + 115.0745849609375 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 59 + ], + [ + "Line", + 30 + ], + [ + "Text", + 18 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 69 + ], + [ + "Line", + 29 + ], + [ + "Text", + 16 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02821005" + } +} \ No newline at end of file diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821007/EFTA02821007.md b/marker2/court-redacted-v-epstein-81111/EFTA02821007/EFTA02821007.md new file mode 100644 index 0000000000000000000000000000000000000000..b528c36edd86b58055c5bb41d703be86afd77324 --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821007/EFTA02821007.md @@ -0,0 +1,358 @@ +### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA + +CASE NO.: + +M.J., + +Plaintiff, + +vs. + +JEFFREY EPSTEIN and + +Defendants. + +#### COMPLAINT + +Plaintiff, M.J., by and through her undersigned counsel, sues the Defendants, Jeffrey Epstein and and alleges: + +- I. This is an action in an amount in excess of \$15,000.00, exclusive of interest and costs and is within the jurisdictional limits of this Court. +- 2. This Complaint is brought under a fictitious name in order to protect the identity of the Plaintiff because this Complaint makes allegations of sensitive nature of offenses against a then minor child. +- 3. At all times material to this cause of action, the Plaintiff, M.J. (hereinafter referred to as "Plaintiff), was a resident of Palm Beach County, Florida. +- 4. At all times material to this cause of action, Defendant, Jeffrey Epstein, had a residence located at 358 El Brillo Way, West Palm Beach, Palm Beach County, Florida. + - 5. Defendant, Jeffrey Epstein, is currently a citizen of the United States Virgin Islands. + +6. At all times material to this cause of action, Defendant, Jeffrey Epstein, was an adult male born in 1953. + +7. Defendant, is currently a citizen of New York, where she currently resides. + +8. At all times material, the Defendants Jeffrey Epstein and both owed a duty unto Plaintiff to treat her in a non-negligent manner and to not commit or conspire to commit intentional or tortious illegal acts against her. + +# FACTUAL ALLEGATIONS + +9. At all times material, Defendant. Jeffrey Epstein, was an adult male, over 50 years old. Defendant Epstein is known as a billionaire, yet even those closest to him, including family members, long time employees and those that he considers his closest friends have no idea what he does or did to earn money to support his lifestyle. + +10. Defendant Epstein owns, directly or through nominee individuals used to conceal his interests, a fleet of airplanes, motor vehicles, boats and a helicopter. He owns numerous properties and homes, including a 51,000-square-foot mansion in Manhattan, a \$30 Million 7,500-acre ranch in New Mexico, a 70-acre private island formerly known as Little St. James in St. , U.S. Virgin Islands (he is alleged to have renamed this island Little St. Jeff's after himself), a mansion in London, England. a home in Paris, France, and a mansion in Palm Beach County, FL. The allegations herein primarily concern the defendant's conduct while at his mansion in Palm Beach County, FL. + +I I. Defendant Epstein has a sexual preference and obsession for underage minor females, specifically targeting female children age 12 to 17, and Defendant Epstein acts on that obsession by luring underage minor females to him where he attempts to sexually molest and batter these underage minor females on an everyday basis, oftentimes 2 or 3 different underage minor females on one day. + +12. Sometime prior to 1998, Defendant Epstein devised a complex plan, scheme and criminal enterprise to gain access to countless underage minor females, some as young as 12 years old, for the purpose of coercing the minor females into various acts of sexual misconduct that he committed upon them. His enterprise operated with a definite hierarchal structure with his various employees/assistants and associates, including Defendant, Jean Luc Brunel, Ghislain Maxwell, Leslie Groff, t, various housekeepers, butlers and pilots, performing their respective roles to ensure the goals of the enterprise: operate an organized and efficient system to maximize the number of underage minor females for Defendant Epstein (and others) to sexually abuse and exploit while avoiding law enforcement detection. + +13. Defendant Epstein, with help from his assistants and associates, recruited and procured underage minor females, lured them to one of his mansions, had the underage minor female taken to a room to be alone with him, then he would appear naked or wearing only a towel and sexually batter or otherwise sexually exploit the underage minor female. He would then pay the underage minor female for the sex acts he committed against her (typically between \$200 and \$300 per molestation session, or as his criminal enterprise commonly refers to it — per "massage"). Prior to leaving, Defendant Epstein's assistant would get the phone number of the underage minor female and input it into his computer system or otherwise keep it on file. He would then offer the underage minor female to return to his house to make money in exchange for him committing sexual acts against her, and he also typically informed her of another option make more money recruiting and procuring other underage minor females for him to sexually + +abuse. He would tell the underage minor female that he will pay her for each underage minor female that she brings to him (again, typically between \$200 and \$300), and he encouraged, and oftentimes forcefully demanded, her to bring him as many underage minor females as she was able. Through this general pitch, Defendant Epstein created a vast pyramid of underage minor females recruiting and procuring other underage minor females for his purpose of coercing these underage females into sexual acts for money. + +14. Defendants Epstein and and the criminal enterprise specifically targeted underprivileged and economically disadvantaged children to sexually exploit and molest and otherwise prey upon the vulnerabilities of these young girls. + +15. It is unknown exactly how long Defendant Epstein's aforementioned criminal enterprise operated, although information and belief indicates that it was continuously and actively in operation from at least 1998 through Defendant Epstein's criminal arrest in 2006. + +16. The complete list of underage minor females that were sexually abused by Defendant Epstein over the years is believed to have been kept on a computer system controlled by Defendant Epstein and accessible by several of his employees, including Defendant . It is also known that much of the data regarding the names, addresses and whereabouts of each underage minor female was input by one of his assistants, including Defendant + +was listed in the Federal Non-prosecution Agreement related to Defendant Epstein's criminal plea on sex charges against minors as a criminal co-conspirator for her role in the criminal activity that was committed by Defendant Epstein against many underage minor females. She was employed by Defendant Epstein to maintain his schedule, arrange for underage minor females to be with Defendant Epstein, maintain contact with the underage minor females, schedule the underage minor females' transportation to and from Defendant Epstein's + +mansion, and greet the underage minor female at the house before taking her upstairs to be alone with Mr. Epstein. Upon information and belief, Defendant remains employed by Defendant Epstein and continues to work for Defendant Epstein in furtherance of the goals of the criminal enterprise. + +18. Defendant Epstein used his vast wealth and power to lure underprivileged minor females to him, and to coerce them into prostitution once he was alone with the underage minor female. He sexually battered, molested, committed lewd and lascivious acts upon and otherwise exploited numerous underage minor females and then gave them money. So long as the underage minor female followed his demands and advances, he assumed the role of a friend or mentor or father figure to the minor female in an attempt to groom the minor female; however, if any minor female resisted his sexual advances, Defendant Epstein became frustrated, angry and threatening towards the underage minor. His intent was to groom each minor female into engaging in sexual acts with him as well as to "work" for him, i.e. bring him other underage minor females to sexually molest, batter and exploit. He was masterful in his exploitation and grooming of these minor females with an additional intent of gaining trust and cooperation from these minors to prevent any one of them from reporting his criminal acts to law enforcement. Certain of his many co-conspirator associates, including Ghislane Maxwell and Jean Luc Brunel, helped in this recruiting process by creating the impression that legitimate modeling opportunities were available for the minor females. + +19. Through information and belief, Defendant Epstein has been successful in luring hundreds of underage minor girls to him for the purpose of him (and sometimes others) sexually abusing them. He intentionally preys upon underage minor females that are middle school or high school children who are not working prostitutes, and he takes pleasure in using his power + +and influence to coerce these minor females into acts of prostitution with him personally and sometimes with his friends and associates as well, including but not limited to Ghislaine Maxwell and + +20. Over time, Defendant Epstein fine-tuned his operation to further his goals of gaining access to a greater number and variety of underage girls while avoiding detection by law enforcement. He also provided the roadtnap for his enterprise should the illegal sexual exploitation of the enterprise be detected — he or the criminal enterprise would (and did) retain legal representation for each criminal enterprise member who would instruct each member to invoke his/her 5th amendment rights, they would hide behind the 5th amendment to avoid turning over incriminating materials (i.e. computer system that logged information about the underage sexual molestation victims, scheduling books, message pads, and tangible items such as vibrators and dildos), they would destroy evidence and refuse all cooperation with law enforcement. + +21. The plan and scheme was developed by Defendant Epstein, and he and his assistants and associates carried it out with each underage minor female in a well-planned and ritualistic manner; Epstein ran this criminal enterprise as an experienced Mob boss would run any organized crime family — in a well-planned, organized, arrogant and ruthless manner, with complete cooperation from his co-conspirator associates and underlings and an absolute dedication to carrying out the illegal operations of the criminal enterprise. + +22. Defendant Epstein frequently traveled between his various mansions and either he or an authorized agent would call to inform a recruiter, assistant, or scheduler at his next destination as to his arrival time. His scheduler, usually Defendant would then contact an underage minor female and schedule her to be at Defendant Epstein's mansion or to bring another underage minor female to his mansion at a particular time. Once the minor female was + +brought to Defendant Epstein's residence, she was greeted at the door of the mansion and lead inside by one of Defendant Epstein's employees, oftentimes Defendant + +would lead the underage minor female up to Defendant Epstein's room and leave the underage minor alone in the room. Defendant, Jeffrey Epstein, himself would then appear naked or wearing only a towel. He would then demand a massage and during the massage he would attempt, usually successfully, to perform one or more lewd, lascivious, and sexual acts, including, but not limited to, masturbation, touching of the underage minor female's sexual organs, coercing or forcing the underage minor female to perform sex acts with him, using vibrators or sexual toys on the underage minor female, coercing the underage minor female into sexual intercourse with himself or others, and digitally penetrating the underage minor female. He would then give the Plaintiff money for engaging in this sexual activity. + +24. Consistent with Defendants Epstein and foregoing scheme or plan, in or around the summer of 2002, Plaintiff, an economically poor and vulnerable child, was told by another one of Epstein's underage minor sex abuse victims, that she could make \$300 cash by giving an old man a massage on Palm Beach. + +25. Plaintiff's then minor acquaintance (also a sexual abuse victim of Epstein) telephoned Defendant Epstein and scheduled for Plaintiff to go to Defendant Epstein's house to give him a massage. During that call, Defendant Epstein himself got on the phone and spoke with Plaintiff MJ and asked her personally to come to his mansion in Palm Beach. + +26. Plaintiff then took a taxicab to Defendant Epstein's mansion and was greeted by Epstein's top assistant, Defendant + +27. Defendant , in furtherance of the scheme to exploit Plaintiff, escorted Plaintiff upstairs to Defendant Jeffrey Epstein's large bathroom, where Defendant set up the + +massage table and showed Plaintiff different massage lotions to use. Defendant then left Plaintiff alone in the room. Plaintiff was alone in Defendant Epstein's bathroom until Defendant Jeffrey Epstein emerged wearing only a towel. + +28. Defendant Epstein then walked to the massage table that was already open in the room. He lied face down on the table and told Plaintiff to start massaging him, at which time he engaged in a conversation with Plaintiff. During the conversation, Defendant Epstein asked Plaintiff her age and she told him she had recently turned 16. + +29. Consistent with all of Defendant Epstein's known underage minor female victims, Plaintiff had no massage experience whatsoever and she informed him of that, and Defendant Epstein began instructing Plaintiff on how he liked his massage. + +30. After approximately 1\$ minutes, Defendant Epstein turned over onto his back, and he commanded Plaintiff to massage his chest. + +31. Defendant Epstein then suddenly removed his towel and his penis was already erect. He then commanded Plaintiff to remove her shirt and bra and to begin "pinching his nipples" as he began masturbating with his right hand. + +32. As he was masturbating, Defendant Epstein began fondling Plaintiff's breasts. + +33. Defendant Jeffrey Epstein, while masturbating with his right hand, reached out his left hand and grabbed Plaintiff's vagina and butt over her clothes. Plaintiff pushed Defendant's hand away and told him repeatedly not to touch her like that. Epstein was persistent in his attempt to grab Plaintiff's vagina and continued to grab her vagina and butt on multiple occasions after she told him not to. + +34. Defendant Epstein continued to masturbate his exposed penis until he ejaculated in front of the then minor Plaintiff. + +35. Plaintiff was shocked and embarrassed by the events and Defendant Epstein talked to her to persuade her that everything he was doing with he was normal. + +36. Epstein paid Plaintiff \$300 for allowing him to grope her and masturbate in her presence. + +37. Plaintiff returned to Epstein's home on approximately 20 occasions. On each occasion Epstein grabbed Plaintiff's bare breasts, exposed his penis, masturbated and ejaculated in Plaintiff's presence, and paid her \$300 each time. + +38. Defendant Epstein coerced Plaintiff into acts of prostitution, preying on her low economic status and troubled upbringing, complimenting Plaintiff for being "special" to him and having a "very pretty body" and making promises to Plaintiff such as — he told Plaintiff that if she graduated high school, then he would buy her a computer, something that she wanted yet could not afford. + +39. On multiple occasions Defendant Epstein pressured Plaintiff to bring him other underage minor females to abuse; he told Plaintiff that he would pay her \$300 for each girl she brought him, but Plaintiff refused to bring other girls. + +40. Defendant Epstein told Plaintiff that he would pay her more money if she would give him oral sex and that he would pay her \$600 for actual sexual intercourse. Plaintiff refused. + +41. Defendant Epstein personally called Plaintiff at least five times to tell her when she should be at his house to "work" or give him a "massage" (Epstein's criminal enterprise's learned code words for paying minors for Epstein and others to interact with them sexually). + +42. Every other time (approximately 15) Defendant called to inform Plaintiff of the date and time when she needed and was expected to be at Epstein's mansion to "work". + +43. The acts referenced above, committed by Defendant, Jeffrey Epstein, against the then minor Plaintiff were committed in violation of numerous State and Federal criminal statutes + +condemning battery, assault and the exploitation of minor children, contributing to the delinquency of a minor and other crimes, specifically including, but not limited to, those criminal offenses outlined in Chapters 796, 800, and 827 of the Florida Statutes, as well as those designated in Florida Statutes §796.03, §796.07, §796.045, §796.04, §796.09, §39.01, §450.151, and §827.04. + +44. The above-described acts took place in Palm Beach County, Florida at the residence of the Defendant, Jeffrey Epstein. My assertions by Defendants, Jeffrey Epstein and that they were unaware of the age of the then minor Plaintiff are belied by their actions and rendered irrelevant by the provisions of applicable Florida Statutes concerning the sexual exploitation and abuse of a minor child. The Defendants, Jeffrey Epstein and at all times material to this cause of action, knew and should have known of the Plaintiffs minority as Plaintiff specifically told Epstein her age and Defendant Epstein and criminal organization has a history of seeking out underage minor children to sexually abuse. In fact, one primary goal of the organization is to sexually abuse females who are under the age of IS, and oftentimes Defendant Epstein has turned away females (i.e. refused to engage in sexual acts with them) for being "too old" once she reaches 18 years of age. and he has reprimanded girls for bringing him other girls who are over the age of majority. + +45. In June 2008, in the Fifteenth Judicial Circuit in Palm Beach County, Florida, Defendant Epstein entered pleas of "guilty" to various Florida State crimes related to his exploitation of minors for sex. + +46. As a condition of that plea and in exchange for the Federal Government entering into a Non-Prosecution Agreement with Defendant Epstein, wherein the Federal Government agreed to effectively stay any prosecution of Jeffrey Epstein, and other criminal coconspirators 1 and Leslie Groff, Defendant Epstein agreed to admit that approximately 40 underage minor females, whose names were provided to Defendant Epstein, were his victims. Plaintiff was not included in that list as she moved away from the West Palm Beach area in part to escape from Epstein, and she has lived in fear of Epstein and his organization and has not yet been contacted by law enforcement. + +47. Beginning in or about June 2008 and continuing to the present time, defendant Epstein has been aware he faces significant financial liability for his sexual offenses, both to MJ and to many other similarly-situated girls whom he abused. MJ and these other girls are creditors of Epstein, in that have filed and can file tort actions against him under both Florida and Federal laws. Accordingly, Epstein has conveyed substantial assets and property into the names of other persons and into overseas bank accounts and other financial institutions. These assets and properties could have been attachable and used to pay the debts owed to MJ and to the other girls that Epstein has abused. + +48. As an example of the fraudulent conveyances that Epstein has attempted, in approximately October 2009, Epstein placed his personal 727 aircraft up for sale, with the intent that the proceeds of that sale would be hidden so that MJ and other creditors of Epstein would not be able to secure payment from that substantial asset. + +49. While Epstein is clearly distinct from the criminal enterprise that he oversees that asset, as well as his other airplanes and helicopters and other assets, have been used continuously and repeatedly to further the interest and endeavors of Epstein and his criminal enterprise. + +50. As another example of the fraudulent transfers that Epstein has made, Epstein has titled a F-150 Truck in the name of Larry Visoki (Epstein's personal pilot). Visoski was unaware that the truck was titled in his name when he was questioned under oath in a deposition. + +51. In approximately 2009, Defendant Epstein purchased a \$68,000 Land Rover and registered it in Visoski's name with the intent to hide this asset from MJ and other creditors. + +52. In approximately 2009, Defendant Epstein purchased a Mercedes-Benz 2005 by wiring funds to Visoski and then placing the car in Visoski's name. + +53. In approximately 2009, Defendant Epstein bought a Jaguar X-Type 2005 so that he (Epstein) would have another car around Palm Beach available for his friends to use and then placed the car in Visoski's name. + +54. In approximately September 2009, Visoski attempted to sell a Ferrari owned by Epstein for \$159,000. Epstein intended for the sale to hide the value of this Ferrari and prevent MJ and other creditors from recovering from him. + +55. Epstein is concealing substantial assets through a new corporation, Shmitka Air, Inc., whose representative is Larry Visoski. In September 2010, Epstein attempted to sell a 1999 Bell Helicopter for approximately \$1,900,000. This sale was an attempt to prevent MJ and other creditors from recovering from him. + +56. Epstein is also concealing substantial assets through an entity known at JEGE, Inc. He is currently attempting to sell an aircraft for \$10,000,000 through that entity in an attempt to prevent MJ and other creditors from recovering from him. + +57. Through information and belief, Epstein and/or his criminal enterprise provides the financial support for his various employees, co-conspirators, other criminal enterprise members and associates. + +58. In addition to Epstein's various houses, he owns or controls other condominiums, including approximately 8 to 10 units at 301 East 66 Street, in New York City, where certain of his or his Criminal Enterprise associates live or reside, including Jean Luc Brunel, Nadia + +and at times various underage minor girls are stashed at this location as well. + +59. Defendant Epstein has numerous overseas contacts and accounts and sophistication in international business transactions. He previously served as a trader at Bear Stearns and founded his own financial management firm, J. Epstein and Col. (later called Financial Trust Co.) located on his private island in the U.S. Virgin Islands where, until his recent incarceration, according to him he allegedly managed the assets of billionaire clients. + +60. After extensive investigation into Epstein's employment history, including questioning of Epstein's family, those whom Epstein considers friends and longtime employees of Epstein, the only known client of Epstein was Limited, Inc. Founder Leslie Wexner, although it is believed that even that relationship has been severed. No other legitimate means of income have been reported. + +#### COUNT I + +# 11.'"1 IT' RN' AGAINST DEFENDANT EPSTEIN + +61. Plaintiff M.J. adopts and rcalleges paragraphs I through 60 above. + +62. In the summer of 2002, just after Plaintiff turned 16 years old, Defendant Epstein committed battery against Plaintiff when he intentionally touched intimate areas of her body and person in an offensive manner while she was a minor child. + +63. Defendant Epstein intentionally touched Plaintiff MJ's private areas multiple times against the will of MJ. + +64. Defendant Epstein's tortious commission of battery upon Plaintiff was done willfully. + +65. As a direct and proximate result of the offenses committed by Defendant Epstein against the then minor Plaintiff, MJ, she has in the past suffered and will in the future suffer injury, pain and suffering, emotional distress, psychological and psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of self-esteem, loss of dignity, loss of enjoyment of life, invasion of her privacy and other damages associated with Defendant's manipulation and leading her into a perverse and unhealthy way of life. Plaintiff will incur medical and psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, and loss of proper and complete education. These injuries are permanent in nature and Plaintiff MJ will continue to suffer these losses in the future. + +WHEREFORE, Plaintiff MJ demands judgment against Defendant Epstein for compensatory damages, punitive damages and such other relief as this Court deems proper and hereby demands trial by jury on all issues triable as of right by a jury. + +### COUNT II INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS AGAINST DEFENDANT EPSTEIN + +66. The Plaintiff adopts and realleges paragraphs 1 through 60 above. + +67. Defendant Epstein's extreme and outrageous conduct towards the then minor Plaintiff was intentional and reckless. + +68. Defendant Epstein acted with the intent to cause severe emotional distress or with reckless disregard for the high probability of causing severe emotional distress. + +69. As a direct and proximate result of the offenses committed by Defendant Epstein against the then minor Plaintiff, MJ, she has in the past suffered and will in the future suffer injury, pain and suffering, emotional distress, psychological and psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of self-esteem, loss of dignity, loss of enjoyment of life, invasion of her privacy and other damages associated with Defendant's manipulation and leading her into a perverse and unhealthy way of life. Plaintiff will incur medical and + +psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, loss of proper and complete education. These injuries are permanent in nature and Plaintiff MJ will continue to suffer these losses in the future. + +WHEREFORE, Plaintiff M.J. demands judgment against Defendant Epstein for compensatory damages. punitive damages and such other relief as this Court deems proper and hereby demands trial by jury on all issues triable as of right by a jury. + +### COUNT III CONSPIRACY TO COMMIT TORTIOUS ASSAULT OR BATTERY AGAINST DEFENDANT + +70. The Plaintiff adopts and =lieges paragraphs I through 60 above. + +71. Defendant is one of Defendant Epstein's top assistants, as referenced previously in this Complaint. Defendant Epstein, Defendant and others reached an agreement amongst and between them and otherwise conspired for the purpose of allowing Defendant Epstein and others to commit the tortious and illegal acts described above against Plaintiff MJ. + +72. Defendant aided, abetted and assisted Defendant Epstein in his organized scheme and plan to sexually exploit Plaintiff and commit battery against her and/or commit or attempt to commit numerous other crimes against her, including coercing her into prostitution. + +73. Defendant conspired with Defendant Epstein to commit tortious and illegal conduct against Plaintiff, and in furtherance of the conspiracy specifically engaged in overt acts such as contacting Plaintiff MJ on many occasions, scheduling the then minor Plaintiffs appointment for a "massage" knowing that Defendant Epstein was going to commit battery against Plaintiff, attempt sexual battery against Plaintiff, and force her into prostitution and otherwise did everything in her ability to conceal the illegal operation and refuse cooperation with law enforcement. + +74. Additionally, Defendant greeted Plaintiff on the occasions when Plaintiff arrived at Epstein's home and personally lead Plaintiff to Defendant Epstein's bathroom where Epstein appeared for the purposes of committing crimes against Plaintiff. + +75. Defendant Epstein's battery against Plaintiff was facilitated by Defendant and the conspiracy resulted in the various aforementioned crimes being committed against Plaintiff MJ as well as many other underage minor females. + +76. As a direct and proximate result of Defendant, participation in the aforementioned conspiracy, Plaintiff, MJ, she has in the past suffered and will in the future suffer injury, pain and suffering, emotional distress, psychological and psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of self-esteem, loss of dignity, loss of enjoyment of life, invasion of her privacy and other damages associated with Defendant's manipulation and leading her into a perverse and unhealthy way of life. Plaintiff will incur medical and psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, loss of proper and complete education. These injuries are permanent in nature and Plaintiff MJ will continue to suffer these losses in the future. + +WHEREFORE, Plaintiff MJ demands judgment against Defendant for compensatory damages, punitive damages and such other relief as this Court deems proper and hereby demands trial by jury on all issues triable as of right by a jury. + +### COUNTS IV THROUGH XXIII CAUSES OF ACTION AGAINST DEFENDANTS EPSTEIN AND PURSUANT TO 18 USC 42255 IN VIOLATION OF VARIOUS ENUMERATED OFFENSES CONTAINED WITHIN THAT FEDERAL STATUTE + +77. Plaintiff, MJ, adopts and realleges paragraphs I through 60 above. + +78. The allegations contained herein in Counts IV through XXIII are separate and distinct legal remedies. + +79. As a condition of Defendant, Jeffrey Epstein's criminal plea, and in exchange for the Federal Government not prosecuting the Defendant for numerous federal offenses, the Defendant, Jeffrey Epstein, entered into a Non-Prosecution Agreement with the Federal Government; that agreement governed not only Defendant Epstein's conduct but also the conduct of his "co-conspirators" including Defendant as she played an essential and criminal role in the commission of these offenses. + +80. The Plaintiff, MJ, was in fact a victim of one or more offenses enumerated in Title 18, United States Code, Section 2255, and as such asserts a cause of action against the Defendant, Jeffrey Epstein, and against Defendant pursuant to this Section of the United States Code and the agreement between the Defendant, Jeffrey Epstein. and the United States Government. + +81. Specifically, Defendants Epstein and + +(a) knowingly conspired with others known and unknown to use a facility or means of interstate commerce to knowingly persuade, induce, or entice minor females, including Plaintiff MJ, to engage in prostitution, in violation of title 18, United States Code, Section 2422(b). + +(b) knowingly and willfully conspired with others known and unknown to travel in interstate commerce for the purpose of engaging in illicit sexual conduct with minors, including Plaintiff MJ, as defined in 18 U.S.C. § 2423(f), with minor females, in violation of Title 18, United States Code, Section 2423(b); all in violation of Title 18, United States Code, Section 2423(e); + +(c) used a facility or means of interstate or foreign commerce to knowingly persuade, induce, or entice minor females, including Plaintiff MJ, to engage in prostitution; in violation of Title 18, United States Code, Section 2422(b): + +(d) traveled in interstate commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 U.S.C. § 2423(0, with minor females, including Plaintiff MJ; in violation of Title 18, United States Code, Section 2423(b). + +82. As a direct and proximate result of the aforementioned criminal offenses enumerated in Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff, Plaintiff, MJ, she has in the past suffered and will in the future suffer injury, pain and suffering, emotional distress, psychological and psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of self-esteem, loss of dignity, loss of enjoyment of life, invasion of her privacy and other damages associated with Defendant's manipulation and leading her into a perverse and unhealthy way of life. Plaintiff will incur medical and psychological expenses. These injuries arc permanent in nature and Plaintiff MJ will continue to suffer these losses in the future. Plaintiff, M.J., has also incurred attorneys' fees. + +83. With regard to each of the following counts, Plaintiff suffered personal injury, as outlined above from the acts above, as a result of the violations of federal criminal law by Defendant Epstein enumerated in paragraph 33, on approximately 20 occasions, and 's hi le the dates are not all precisely documented or diaried by Plaintiff, Defendants Epstein and committed these crimes and inflicted said injuries on or about the following dates: + +COUNT IV August 2002 COUNT V September 2002 COUNT VI October 2002 COUNT VII November 2002 COUNT VIII December 2002 COUNT IX January 2003 + +COUNT X February 2003 COUNT XI March 2003 COUNT XII April 2003 COUNT XIII May 2003 COUNT XIV June 2003 COUNT XV July 2003 COUNT XVI August 2003 COUNT XVII September 2003 COUNT XV III October 2003 COUNT XIX November 2003 COUNT XX December 2003 COUNT XXI January 2004 COUNT XXII February 2004 COUNT XXIII March 2004 + +WHEREFORE, with regard to each and every one of these counts, Plaintiff, MJ, demands judgment against Defendant, Jeffrey Epstein, for compensatory damages, loss of income, a loss of the capacity to earn income in the future, attorney's fees, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. + +# COUNT XXIV Civil Remedy for Criminal Practices + +84. Plaintiff realleges paragraphs 1 through 60 above and for the purposes of this count incorporates and alleges the RICO Statement that has been filed contemporaneously herewith as Exhibit "A." + +85. The allegations contained herein in Count XXIV are a separate and distinct legal remedy brought pursuant to Florida Statute 772.104(1) and (2). + +86. Defendant, Jeffrey Epstein, was associated with an enterprise, a group of individuals associated in fact although not a legal entity, which was comprised of at least Defendant Jeffrey Epstein, Leslie Groff, Jean Luc Brunel, Ghislaine Maxwell, and (and likely many other yet unknown persons); Defendant Epstein participated in this enterprise, or conspired or endeavored to so participate, through a pattern of criminal activity in violation of Florida Statutes §772.103(3)-(4), as further outlined in detail in the RICO statement tiled with this court. + +87. This enterprise was separate and distinct from Epstein himself and had a definite hierarchical structure. Epstein served informally but effectively as the leader, C.E.O, or "boss" of this organization similar to the way an experienced mob boss runs his organized crime family, directing his underlings how to recruit and procure underage girls for his sexual activities and the sexual activities of others, developing the use of slang or code words to be used to discuss the illegal activities of the organization, designing a plan or scheme to gain the cooperation of underage minor females, developing methods and techniques to otherwise avoid detection from law enforcement including making large charitable donations to law enforcement agencies, powerful politicians, businessmen and world leaders, associating with powerful social people and highly influential politicians and attorneys, gathering information to blackmail or extort powerful people, devising a plan to attack the credibility and character of anyone that dare unveil the illegal operations of the enterprise and to take an oath to remain silent and/or lie when confronted by law enforcement about the illegal operations and activities of the criminal organization. Epstein's key "lieutenant" in the local Palm Beach branch of the National + +organization was 1= who served as both his scheduler and a recruiter/procurer of the girls. a lso served as a recruiter and helped Epstein satisfy his criminal sexual desires by, on occasion, directly participating in sexual abuse and prostitution of the minor girls. Epstein also used otherwise-legitimate business activities to help further the purpose of the criminal enterprise. These apparently legitimate activities provided "cover" for Epstein and his associates to commit the crimes. Epstein and his associates maintained the appearance of running an upstanding investment business, as well as other legitimate businesses with connections to modeling agencies and other powerful business and political people, to discourage the minor girls from reporting the abuse to law enforcement. Ghislane Maxwell and Jean Luc Brunel helped to provide "cover" by creating the impression that legitimate modeling opportunities were available for the girls. There are many other known and unknown associates of the criminal organization, that worked throughout the country and possibly internationally, who performed functions to perpetuate the criminal activities of the organization. + +88. Defendant Jeffrey Epstein participated in this enterprise through a pattern of criminal activity in that he engaged in at least two incidents of criminal activity, as defined and required in Florida Statute 772.102 and as described below, that have the same or similar intents, results, accomplices, victims, or methods of commission and are not isolated incidents. + +89. Defendant Jeffrey Epstein engaged in criminal activity by committing, attempting to commit, conspiring to commit or soliciting, coercing or intimidating another person to commit one or more of the following predicate acts as outlined and defined in Florida Statute 772.102: + +- (a) Procuring for prostitution, or causing to be prostituted, any person who is under the age of 18 years in violation of Florida Statutes Chapter 796.03; + - (b) Acts of battery in violation of Florida Statutes Chapter 784; + +(c) Forcing, compelling or coercing another to become a prostitute in violation of Florida Statutes Chapter 796.04; + +(d) knowingly recruiting, enticing, harboring, transporting, providing or otherwise obtaining by any means a person, knowing that coercion would be used to cause that person to engage in prostitution in violation of Florida Statutes Chapter 796.045; + +(e) tampering with a witness in violation of Florida Statutes Chapter 914.22; + +(f) altering, destroying, removing, or concealing records or documents or other evidence with the purpose to impair its verity or availability in violation of Florida Statutes Chapter 918.13; + +(g) maintaining a place (or more accurately "places") for the purpose of lewdness or prostitution; offering or securing another for the purpose of prostitution or for some other lewd or indecent act; receiving persons into his Palm Beach mansion for the purpose of prostitution or lewdness; directing, taking or transporting or agreeing to direct take or transport persons to his Palm Beach mansion with knowledge or reasonable belief that the purpose of such directing, taking or transporting was prostitution or lewdness; all in violation of Florida Statutes Chapter 796.07. + +90. The criminal acts of Defendant Epstein occurred repeatedly over a substantial period of time and were not isolated events. + +91. Under Defendant, Jeffrey Epstein's plan, scheme, and enterprise, Defendant, Jeffrey Epstein, paid employees and underlings, including but not limited to MI= to bring him minor girls to his Palm Beach mansion in order for the Defendant to solicit, induce, coerce, entice, compel or force such girls to engage in acts of prostitution and sexual misconduct with + +Defendant Epstein and sometimes and to otherwise commit acts of sexual battery thereon, and further Defendant Epstein worked in concert as part of the enterprise with those who were free to act independently and advance their own interests, including Ghislaine Maxwell and Jean Luc Brunel, to obtain minor girls for sexual purposes. + +92. Plaintiff, MJ, was the victim of Defendant, Jeffrey Epstein's plan, scheme, and enterprise and was so injured by reason of his violations of the provisions of s. 772.104. Plaintiff, MJ, was called on the telephone by Defendant Epstein and other employees of his, including and transported to the Defendant, Jeffrey Epstein's residence, where she was placed in a room along with the Defendant, enticed to commit acts of prostitution, and had acts of sexual battery and sexual exploitation committed against her. Defendant, Jeffrey Epstein, conspired with his assistants and employees in order to accomplish their common motive or intent of seeking out, gaining access to, and exploiting minor children such as the Plaintiff, MJ, in the aforementioned ways, and he further conspired with his employees, assistants and underlings to ensure that the crimes of this criminal enterprise were concealed or undetected by law enforcement. Those who were free to act independently and advance their own interests, including Ghislaine Maxwell and Jean Luc Brunel, also worked with the enterprise to conceal the activities of the enterprise. + +93. After law enforcement began to detect the criminal activities of Defendant Epstein and the other persons involved in the criminal enterprise, the enterprise used resources and information to conceal the illegal activities of the enterprise, threaten the victims of the crimes of the enterprise if they revealed the scope of the enterprise to law enforcement, and concealed or destroyed documents relevant to the prosecution of the various members of the enterprise. The enterprise also made various efforts to discourage the victims from cooperating with law + +enforcement and from filing civil lawsuits to vindicate their rights. Epstein and other members of the enterprise made cash payments and gave gifts to the victims of the enterprise in order to discourage them from reporting crimes to law enforcement and other authorities. + +94. Through information and belief, this criminal enterprise gained valuable consideration from the practice of sex-trafficking underage children and providing underage children to other adults and otherwise derived valuable consideration for running a national and oftentimes international sex-trafficking and underage prostitution ring, typically by coercing and introducing the economically disadvantaged underage minor females into prostitution and sometimes into being underage sex slaves for the enterprise. + +95. The evidence clearly and convincingly establishes that Plaintiff MJ was injured by reason of violations of the provisions of 772.103, and as such is entitled to threefold the actual damages sustained and a minimum of \$200, and reasonable attorney's fees and court costs. + +96. In the alternative, and pursuant to s. 772.104, Plaintiff MJ was injured due to sex trafficking committed in violation of s. 772.103 and is thus entitled to threefold the amount gained from the sex trafficking and to a minimum amount of damages not less than \$200, reasonable attorney's fees and court costs. + +97. Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, loss to her property and business opportunities and other losses. + +WHEREFORE, under the provisions of Florida Statutes Chapter 772, Plaintiff, MJ, demands judgment against Defendant. Jeffrey Epstein, for any minimum damages authorized by law, all actual damages sustained (to be trebled as authorized by law), court costs and attorneys' fees, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. + +# COUNT XXV + +# Cause of Action Pursuant to Florida Statute 796.09 Against Defendant, Jeffrey Epstein + +98. Plaintiff adopts and reallegcs paragraphs 1 through 60 above. + +99. The allegations contained herein in Count XXV are a separate and distinct legal remedy. + +100. Defendant, Jeffrey Epstein, was a wealthy and powerful man, and Plaintiff was an economically disadvantaged and impressionable minor. + +101. Plaintiff MJ had never engaged in any act of prostitution prior to meeting Epstein or being introduced to any of the members of the criminal enterprise of which Defendant Epstein was an operating member and leader. + +102. Defendant, Jeffrey Epstein, used his vast wealth and power to coerce Plaintiff into prostitution and/or coerced her to remain in prostitution. + +103. Defendant, Jeffrey Epstein, coerced Plaintiff into prostitution in one or more of the following ways: + +- A. Domination of her mind and body through exploitive techniques; +- B. Inducement; +- C. Promise of greater financial rewards; +- D. Exploitation of a condition of developmental disability, cognitive limitation, affective disorder, and/or substance dependency; + - E. Exploitation of human needs for food, shelter or affection; + - F. Exploitation of underprivileged and vulnerable economic condition or +- G. Use of a system of recruiting other similarly situated minor girls to further coerce and induce Plaintiff into the lifestyle of prostitution; and + +situation; + +H. Exploitation through demonstration of abundant wealth and power to impress a young and vulnerable then minor Plaintiff and to coerce her into prostitution. + +104. As a direct and proximate result of the offenses committed by Defendant, Jeffrey Epstein, against Plaintiff pursuant to Florida Statutes §796.09, the Plaintiff has in the past suffered, and will in the future suffer, injury, pain and suffering, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other damages associated with Defendant, Jeffrey Epstein, controlling, manipulating and coercing her into a perverse and unconventional way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature and the Plaintiff will continue to suffer these losses in the future. + +WHEREFORE, Plaintiff, Jane Doe, demands judgment against the Defendant, Jeffrey Epstein, for compensatory damages, punitive damages as specifically allowed by this and other statutes and by law, attorney's fees, and such other and further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. + +# COUNT XXV + +### Cause of Action Pursuant to Florida Statute 726.101 Against Defendant, Jeffrey Epstein + +105. This count alleges an action for redress of fraudulent transfers brought under Florida's Uniform Fraudulent Transfer Act, sections 726.101, et seq., Fla.Stats. ("FUFTA"). + +106. Plaintiff adopts and realleges paragraphs I through 60 above. + +107. M.J. is a creditor of defendant Jeffrey Epstein. She has various claims against him for repeated sexual molestation of her when she was a minor, as alleged in the other counts of this complaint. + +108. Given the egregious acts of sexual molestation the defendant perpetrated against her, M.J. has a claim against defendant, once punitive damages are added, is worth in excess of \$50,000,000. Therefore, he is facing judgments in excess of 550,000,000 from her. Epstein is thus a debtor of M.J., as defined in the FUFTA. + +109. Defendant Jeffrey Epstein has numerous overseas contacts and sophistication in international business transactions. He previously served as a trader at Bear Steams and founded his own financial management firm, J. Epstein and Col. (later called Financial Trust Co.) located on his private island in the U.S. Virgin Islands where, until his recent incarceration, he managed the assets of billionaire clients. + +110. Defendant Jeffrey Epstein has transferred, is transferring, and intends to transfer in the near future his assets, to locations overseas and elsewhere and/or to nominee individuals who conceal Epstein's interest in the assets, with the actual intent to hinder, delay and defraud M.J. To prevent M.J. from satisfying any judgment that she might obtain in her pending lawsuit again him, Epstein has moved and intends to move his significant financial assets to locations overseas (i.e., to Israel) or in other unreachable areas and to title his assets (including real property, aircraft, boats, vehicles, and financial instruments) in the names of other persons or entities, even though he maintains (directly or indirectly) control over those assets. These transfers are designed by Epstein to prevent M.J. from being able to collect on any judgment she might obtain against him, including any punitive damages judgment. + +111. In recent lawsuits against him very similar to those filed by M.J., defendant Epstein has refused to answer and taken the Fifth when asked whether he intends to conceal assets from those with claims against him. + +112. In recent lawsuits against him very similar to those filed by M.J., defendant Epstein refused to answer and took the Fifth Amendment when asked whether he intends to remain in the country in the future. + +113. Epstein could currently post a \$15 million bond to satisfy a judgment in this case without financial or other difficulty. + +WHEREFORE plaintiff M.J. demands judgment against defendant Epstein as follows: + +(a) An accounting by defendant Jeffrey Epstein of all of his significant financial assets, whether held in this country or overseas, and all significant transfer of assets in the last three years; + +(b) Avoidance of the fraudulent tiansfers or obligations to the extent necessary to satisfy M.J.'s claims; + +(c) An attachment or other provisional remedy against the asset transferred or other property of the transferee in accordance with applicable law; + +(d) An injunction against defendant Jeffrey Epstein and such transferees as may be appropriate, or both, against further transfers of any assets pending further order of the Court and posting of a bond to protect M.J..; + +(e) Appointment of a receiver to take charge of the assets of defendant Jeffrey Epstein until the Court is satisfied that M.J. interests in having assets available from the defendant to satisfy any judgment are fully protected; + +(f) Posting by defendant Jeffrey Epstein of a \$15,000,000 bond to satisfy any judgment obtained by M.J. in her pending lawsuits; and + +(g) All other relief that the circumstances may require to protect M.J. and her ability to satisfy any judgment she might obtain. + +Plaintiff also demands a jury trial on all issues so triable by jury. + +Dated: Sept. 17, 2010 + +Respectfully submitted, + +![]()BY: + +![]() \ No newline at end of file diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821007/EFTA02821007.metadata.json b/marker2/court-redacted-v-epstein-81111/EFTA02821007/EFTA02821007.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1fefeb3b4e9f9f0e76a55f7b4993cf80da38bfaa --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821007/EFTA02821007.metadata.json @@ -0,0 +1,1370 @@ +{ + "source_pdf": 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JEFFREY EPSTEIN 9 East 71st Street New York, NY 10021 + +A lawsuit has been filed against you. + +Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ. P. 12 (02) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiffs attorney, whose name and address are: J. + +, Jaffe, Weissing, . Fistos & Lehrman 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 + +If you fail to respond. judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court. + +Date: SEPTEMBER 17, 2010 + +![](_page_0_Picture_20.jpeg) + +Steven M. Larimore Clerk of Court + +St-1111O\S + +s/Gregory Maestre Deputy Clerk U.S. District Courts AO440 (Rev. 12/09) Summons in a Civil Action + +## UNITED STATES DISTRICT COURT + +for the + +Southern District of Florida + +M.J. + +Plaintiff + +v. + +JEFFREY EPSTEIN and + +Defendant + +To: (Defendant's name and address) + +Civil Action No. + +10-CV-81111-DIMITROULEAS:SNOW + +## SUMMONS IN A CIVIL ACTION + +230 Everglade Avenue. Apt. 102 Palm Beach, FL 33480 + +A lawsuit has been filed against you. + +Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ. P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. 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Larimore Clerk of Court + +SUMMONS + +s/Gregory Maestre Deputy Clerk U.S. District Courts \ No newline at end of file diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821036/EFTA02821036.metadata.json b/marker2/court-redacted-v-epstein-81111/EFTA02821036/EFTA02821036.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..965f3193a752397f6f9efc9ea5fdad2ed4a8f632 --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821036/EFTA02821036.metadata.json @@ -0,0 +1,204 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-redacted-v-epstein-81111/EFTA02821036.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2593, + "elapsed_seconds": 1.28, + "image_assets": [ + "_page_0_Picture_20.jpeg", + "_page_1_Picture_21.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 181.152, + 80.51715087890625 + ], + [ + 436.57958984375, + 80.51715087890625 + ], + [ + 436.57958984375, + 99.89031982421875 + ], + [ + 181.152, + 99.89031982421875 + ] + ] + }, + { + "title": "SUMMONS IN A CIVIL ACTION", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 227.5, + 251.91 + ], + [ + 385.56000000000006, + 251.91 + ], + [ + 385.56000000000006, + 265.0745849609375 + ], + [ + 227.5, + 265.0745849609375 + ] + ] + }, + { + "title": "UNITED STATES DISTRICT COURT", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 181.76399999999998, + 80.90716552734375 + ], + [ + 437.319580078125, + 80.90716552734375 + ], + [ + 437.319580078125, + 101.02032470703125 + ], + [ + 181.76399999999998, + 101.02032470703125 + ] + ] + }, + { + "title": "SUMMONS IN A CIVIL ACTION", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 227.66400000000002, + 251.91 + ], + [ + 385.7239074707031, + 251.91 + ], + [ + 385.7239074707031, + 265.8345947265625 + ], + [ + 227.66400000000002, + 265.8345947265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 74 + ], + [ + "Line", + 35 + ], + [ + "Text", + 20 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 71 + ], + [ + "Line", + 35 + ], + [ + "Text", + 21 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02821036" + } +} \ No newline at end of file diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821036/_page_0_Picture_20.jpeg b/marker2/court-redacted-v-epstein-81111/EFTA02821036/_page_0_Picture_20.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..6e7918ab1f158fef27f91a7a6f808b109cad8272 --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821036/_page_0_Picture_20.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:3c6d3a087eb62b1cced3501347c01d24b7c9a1bf6a311c6074e2af6bfffaa543 +size 15676 diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821036/_page_1_Picture_21.jpeg b/marker2/court-redacted-v-epstein-81111/EFTA02821036/_page_1_Picture_21.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..bdbc6c1b1ba5eff005d6fd72e8247c2e087a2e7e --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821036/_page_1_Picture_21.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:8c67ceabab733a087c3999e2da87bd41e109940616cbafe7a39de57da4b6ec4d +size 16014 diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821038/EFTA02821038.md b/marker2/court-redacted-v-epstein-81111/EFTA02821038/EFTA02821038.md new file mode 100644 index 0000000000000000000000000000000000000000..3ba4064f09b040487b7b7c01815854ec310d8a3c --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821038/EFTA02821038.md @@ -0,0 +1,46 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA + +CASE NO. 10-81111-CIV-DIMITROULEAS + +Plaintiff, + +vs. + +JEFFREY EPSTEIN and + +Defendants. + +## ORDER REOUIRING COUNSEL TO MEET, FILE JOINT SCHEDULING REPORT AND JOINT DISCOVERY REPORT + +THIS ORDER has been entered upon the filing of the Complaint. Plaintiff's counsel is hereby ORDERED to forward to all Defendants, upon receipt of a responsive pleading, a copy of this order. + +It is further ORDERED: + +- I. Pretrial discovery in this case shall be conducted in accord with Federal Rule of Civil Procedure 26 and Southern District of Florida Local Rule 16.1. +- 2. Within thirty-five (35) calendar days of the filing of the first responsive pleading by the last responding defendant, unless this action is excluded under Rule 26(a)(IXB), the parties shall file a Joint Scheduling Report and Joint Proposed Order pursuant to Local Rule 16.1.B.2.1 In preparing the Joint Scheduling Report and Joint Proposed Order the parties shall adhere to the following deadlines: + +A. The parties must confer within fifteen (15) calendar days after the filing of the + +This time period is inclusive of the additional time provided pursuant to Rule 6(d). + +first responsive pleading by the last responding defendant, to consider the nature and basis of their claims and defenses and the possibilities for a prompt settlement or resolution of the case, to make or arrange for the disclosures required by Rule 26(a)(1), and to develop a proposed discovery plan that indicates the parties' views and proposals concerning the matters listed in Rule 26(f). The parties are jointly responsible for submitting a written report of this conference outlining the proposed discovery plan at the time they file their Joint Scheduling Report and Joint Proposed Order. + +B. Counsel for the parties shall hold a scheduling conference either at the same time as the discovery conference described in Rule 26(f) or within ten (10) calendar days thereafter. See Local Rule 16.1.B. + +C. Within seven (7) calendar days of the scheduling conference, counsel shall file a joint scheduling report pursuant to Local Rule 16.1.B. This report shall indicate the proposed month and year for the trial plus the estimated number of trial days required. Should this be a case in which a class is sought, the report shall include a date by which any motions for class certifications shall be filed. + +D. The Court notes that, pursuant to Local Rule 16.2, parties are required to agree upon a mediator and advise the Clerk's office of their choice within fourteen(14) days of this Court issuing a Scheduling Order. + +3. The parties may submit a single report combining the discovery plan report and the scheduling conference report. However, unilateral submissions are prohibited. + +4. Failure of counsel or unrepresented parties to file a discovery plan report or joint scheduling report may result in dismissal, default, and the imposition of other sanctions including attorney's fees and costs. + +5. If a case is settled, counsel are directed to inform the Court promptly at (954) 769- 5650, and to submit an appropriate stipulation Order for Dismissal, pursuant to Rule 41(a)(1) . Such an Order must be filed within ten (10) calender days of notification of the Court. + +DONE AND SIGNED in at Fort Lauderdale, Broward County, Florida, this 21st day of September, 2010. + +> 6.2 LLIAM P. DIMITR United States District Judge + +Copies furnished to: + +J. \ No newline at end of file diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821038/EFTA02821038.metadata.json b/marker2/court-redacted-v-epstein-81111/EFTA02821038/EFTA02821038.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1bc2f6c1f988a595292d70c88e95adf42afe1ebe --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821038/EFTA02821038.metadata.json @@ -0,0 +1,189 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-redacted-v-epstein-81111/EFTA02821038.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 3446, + "elapsed_seconds": 0.93, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF FLORIDA", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 206.24400000000003, + 72.08999999999999 + ], + [ + 405.8953857421875, + 72.08999999999999 + ], + [ + 405.8953857421875, + 100.18353271484375 + ], + [ + 206.24400000000003, + 100.18353271484375 + ] + ] + }, + { + "title": "ORDER REOUIRING COUNSEL TO MEET, FILE JOINT SCHEDULING REPORT \nAND JOINT DISCOVERY REPORT", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 79.56, + 298.08 + ], + [ + 532.9690551757812, + 298.08 + ], + [ + 532.9690551757812, + 327.3630676269531 + ], + [ + 79.56, + 327.3630676269531 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 49 + ], + [ + "Line", + 24 + ], + [ + "Text", + 10 + ], + [ + "SectionHeader", + 2 + ], + [ + "ListItem", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "ListGroup", + 1 + ], + [ + "Footnote", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 49 + ], + [ + "Line", + 25 + ], + [ + "Text", + 6 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 23 + ], + [ + "Line", + 12 + ], + [ + "Text", + 5 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02821038" + } +} \ No newline at end of file diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821041/EFTA02821041.md b/marker2/court-redacted-v-epstein-81111/EFTA02821041/EFTA02821041.md new file mode 100644 index 0000000000000000000000000000000000000000..f227e6bc4bcbf37bbfbf067021505c7fed5c6c9f --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821041/EFTA02821041.md @@ -0,0 +1,41 @@ +AO 440 (Rev. 12/09) Summons in a Civil Action (Page 2) + +Civil Action No. + +PROOF OF SERVICE + +(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (1)) + +This summons for (name of individual and title, if any) JEFFREY EPSTEIN +was received by me on (date) SEPT. 20, 2010 + + I personally served the summons on the individual at (place) \_\_\_\_\_ +on (date) \_\_\_\_\_; or + + I left the summons at the individual's residence or usual place of abode with (name) MARK +, a person of suitable age and discretion who resides there, +on (date) OCT. 8, 2010, and mailed a copy to the individual's last known address; or + + I served the summons on (name of individual) \_\_\_\_\_, who is +designated by law to accept service of process on behalf of (name of organization) \_\_\_\_\_ +on (date) \_\_\_\_\_; or + + I returned the summons unexecuted because \_\_\_\_\_; or + + Other (specify): + +My fees are \$ \_\_\_\_\_ for travel and \$ \_\_\_\_\_ for services, for a total of \$ 0.00 + +I declare under penalty of perjury that this information is true. + +Date: 10-29-10 + +*[Handwritten signature]* +Server's signature +THOMAS MARSIGLIANO, INVESTIGATOR +Printed name and title + +RO BOX 1485, PORT WASHINGTON N.Y. +Server's address 11050 + +Additional information regarding attempted service, etc: \ No newline at end of file diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821041/EFTA02821041.metadata.json b/marker2/court-redacted-v-epstein-81111/EFTA02821041/EFTA02821041.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1b4b1b6414c92f666ba2601b30481f40d018acda --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821041/EFTA02821041.metadata.json @@ -0,0 +1,78 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-redacted-v-epstein-81111/EFTA02821041.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1313, + "elapsed_seconds": 6.22, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "PROOF OF SERVICE", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 263.872, + 109.35000000000001 + ], + [ + 357.504, + 109.35000000000001 + ], + [ + 357.504, + 119.88 + ], + [ + 263.872, + 119.88 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 39 + ], + [ + "PageHeader", + 2 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02821041" + } +} \ No newline at end of file diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821042/EFTA02821042.md b/marker2/court-redacted-v-epstein-81111/EFTA02821042/EFTA02821042.md new file mode 100644 index 0000000000000000000000000000000000000000..d5d18199f91232a396920963b74048cb5b8b7d9b --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821042/EFTA02821042.md @@ -0,0 +1,34 @@ +AO 88A (Rev. (6/09)) Subpoena to Festify at a Deposition in a Civil Action (Page 2) + +Civil Action No. CASE NO.: 9:10-cv-81111 + +PROOF OF SERVICE + +(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.) + +This subpoena for (name of individual and title, if any) JEFFREY EPSTEIN +was received by me on (date) SEPT 20, 2010 + + I served the subpoena by delivering a copy to the named individual as follows: ON OCT. 8, 2010 +I DELIVERED A COPY OF THE SUBPOENA TO MARK AT 9 EAST 71ST STREET +NEW YORK NY. RESIDENCE OF JEFFREY EPSTEIN (date) 10-8-10; or + + I returned the subpoena unexecuted because: + +Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness fees for one day's attendance, and the mileage allowed by law, in the amount of \$ + +My fees are \$ \_\_\_\_\_ for travel and \$ \_\_\_\_\_ for services, for a total of \$ 0.00 + +I declare under penalty of perjury that this information is true. + +Date: OCT. 28, 2010 + +![]()Server's signature + +THOMAS MARSIGLIANO, INVESTIGATOR +Printed name and title + +PO. 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I am over the age of 18, am otherwise competent to testify and base the following on my personal knowledge. +- 2. On Wednesday, October 13, 2010, an unmarked and unpostmarlced envelope was discovered in the mailbox at Mr. Espstein's vacation home in New York City at 9 East 71" Street. The envelope contained a Summons and Complaint In the subject action, a Civil Rico Case Statement, a deposition subpoena, notices of video depositions, interrogatories and requests for production. + - 3. Service was never delivered to anyone at Mr. Esptein's house. + +![](_page_0_Picture_12.jpeg) + +FURTHER AFFIANT SAYETH NOT. + +![]()RICHARD BARNETT + +Sworn and subscribed before me this 29th day of October, 2010 by Richard Barnett who is personally known to me or has produced Drivers Licence as identification. + +![]()NOTARY PUBLIC +STATE OF NEW YORK + +![](_page_1_Picture_52.jpeg) + +MY COMMISSION EXPIRES: 1/29/11 \ No newline at end of file diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821043/EFTA02821043.metadata.json b/marker2/court-redacted-v-epstein-81111/EFTA02821043/EFTA02821043.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..3f8997f23b2ea2a613c11e1b13dd8c637804702b --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821043/EFTA02821043.metadata.json @@ -0,0 +1,166 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-redacted-v-epstein-81111/EFTA02821043.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1163, + "elapsed_seconds": 2.65, + "image_assets": [ + "_page_0_Picture_12.jpeg", + "_page_1_Picture_52.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF FLORIDA", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 205.02, + 77.76 + ], + [ + 411.26400000000007, + 77.76 + ], + [ + 411.26400000000007, + 105.35302734375 + ], + [ + 205.02, + 105.35302734375 + ] + ] + }, + { + "title": "AFFIDAVIT OF RICIIARD BARNETT", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 203.18400000000003, + 324.0 + ], + [ + 411.26400000000007, + 324.0 + ], + [ + 411.26400000000007, + 339.7330322265625 + ], + [ + 203.18400000000003, + 339.7330322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 46 + ], + [ + "Line", + 22 + ], + [ + "Text", + 8 + ], + [ + "ListItem", + 3 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "ListGroup", + 1 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 23 + ], + [ + "Text", + 12 + ], + [ + "Line", + 11 + ], + [ + "PageFooter", + 4 + ], + [ + "PageHeader", + 2 + ], + [ + "Picture", + 2 + ], + [ + "Caption", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02821043" + } +} \ No newline at end of file diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821043/_page_0_Picture_12.jpeg b/marker2/court-redacted-v-epstein-81111/EFTA02821043/_page_0_Picture_12.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..7fe8d456e09d28532030b49c22eee9c1e4716ce0 --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821043/_page_0_Picture_12.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:5f4a624557be03671b05ce52fe86af2354e2376e855484dbf1d97c70bc3bc990 +size 7581 diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821043/_page_1_Picture_52.jpeg b/marker2/court-redacted-v-epstein-81111/EFTA02821043/_page_1_Picture_52.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..852c87e4d552cab423c4c8fc020c6490908fb92f --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821043/_page_1_Picture_52.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:00c96931ab44c700ce4065b1e61ec67baf836a252ca91d6214e3e4f0224b2741 +size 15901 diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821045/EFTA02821045.md b/marker2/court-redacted-v-epstein-81111/EFTA02821045/EFTA02821045.md new file mode 100644 index 0000000000000000000000000000000000000000..b0334d5589f6ff984ac0e9084f3e4be8b12019ab --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821045/EFTA02821045.md @@ -0,0 +1,101 @@ +### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA + +Case No. 9:10-cv-81111-WPD + +M.J., + +Plaintiff, + +vs. + +JEFFREY EPSTEIN and + +Defendant. + +# MOTION OF DEFENDANT JEFFREY ESPTEIN TO QUASH SERVICE OF PROCESS AND SUPPORTING MEMORANDUM OF LAW + +Defendant Jeffrey Epstein, by and through undersigned counsel, respectfully moves pursuant to Fed. R. Civ. P. 12(b)(5) to quash service of process, and without waiving any available jurisdictional defenses and without making a general appearance, states as follows: + +# SUMMARY OF ARGUMENT + +Plaintiff, M.J., attempted to effect service on Mr. Epstein by leaving a copy of the Summons and Complaint in an unmarked, unaddressed and unpostmarked envelope in a mailbox at Mr. Epstein's vacation house at 9 East 71" Street, New York, New York, at an unknown time between October 8, 2010 and October 13, 2010. Such "service" does not comply with the requirements for service of process under New York, Florida or federal law. The attempt at service of process was ineffective. Service of process should be quashed. + +# BACKGROUND + +- 1. The Complaint in this action was filed, and a summons was issued as to Jeffrey + +Case No. 9:10-cv-81111-WPD + +Epstein, on September 17, 2010. + +2. On Wednesday, October 13, 2010, an unmarked, unaddressed and unpostmarked envelope was discovered in the mailbox at Mr. Epstcin's vacation home at 9 East 7P1 Street, New York, New York. The envelope contained a Summons and Complaint in the subject action, a Civil Rico Case Statement, a deposition subpoena, notices of video depositions, interrogatories and requests for production. (Ex. A, Aff. Richard Barnett). + +3. Service was never delivered to anyone at Mr. Epstein's vacation home in New York. (Id.). + +4. On or about October 13, 2010, Plaintiff's counsel, Brad M, Esq. upon leaving a hearing in Bankruptcy Court before the Honorable Raymond Ray, advised Knight, Esq., that Plaintiff M.I. had service on Mr. Epstein at his building in New York. That prompted undersigned counsel's firm to review the court file in the instant case, which indicated that there was no return of service in the court file. As of today, there is a document which purports to be a return of service. + +#### ARGUMENT + +### NO SERVICE UNDER FLORIDA, NEW YORK OR FEDERAL LAW + +In this action, three methods of service of process are authorized by the Federal Rules of Civil Procedure. First, service can be effected pursuant to the procedures "in the state where the district court is located" — i.e. Florida. See Fed. R. Civ. P. 4(e)(1). Second, service can be effected in accordance with the procedures "in the state . . . where service is made" — i.e. New York. Id. Finally, service can be effected pursuant to federal procedures by delivering a copy of the summons and + +Case No. 9:10-cv-81111-WPD + +complaint to the individual personally, leaving a copy of same at the individual's dwelling "with someone of suitable age and discretion who resides there" or delivering a copy to an agent authorized to accept service of process. See Fed. R. Civ. P. 4(e)(1). Service was not effected pursuant to any of these three methods of service available to Plaintiff. + +No Service Under Florida Law. Under § 48.031(1Xa), Ha. Stat., service "is made by delivering a copy of it to the person to be served with a copy of the complaint, petition, or other initial pleading or paper or by leaving the copies at his or her usual place of abode with any person residing therein who is 15 years of age or older and informing the person of their contents. . . ." Leaving an unmarked envelope with a summon and complaint in a mailbox at a vacation residence does not comply with § 48.031(1)(a), Fla. Stat. + +No Service Under New York Law. Under New York law, personal service may be made inter alio on an individual by delivering the summons and complaint to the defendant or "to a person of suitable age and discretion at the actual place of business, dwelling place or usual abode of the [defendant)," and by mailing the summons and complaint to the person to be served at his last known address by first class mail. N.Y.C.P.L.R. §308(2). (McKinney 2008). Proof of such service must be "filed with the clerk of the court designated in the summons within twenty days of either such delivery or mailing, whichever is effected later." IS Neither of these procedures was followed in the instant case. Merely leaving an unmarked envelope with a summons and complaint in a mailbox does not comply with New York law on service of process. + +No Service under Federal Law. Under Fed. R. Civ. P. 4(e)(2), service is effected by delivering a copy of the summons and complaint to the defendant personally; by leaving a copy of + +Case No. 9:10-cv-81111-WPD + +same at the "individual's dwelling or usual place of abode with someone of suitable age and discretion who resides there; or by delivering a copy of same "to an agent authorized by appointment or by law to receive service of process." There is no question that service was not effected pursuant to any of foregoing provisions of federal law. + +Accordingly, service of process must be quashed because it was completely ineffective under Florida, New York and federal law. + +WHEREFORE, Defendant Jeffrey Epstein respectfully requests that service of process be quashed. + +Respectfully submitted, + +E. Knight + +Fla. Bar No. 607363 + +Lilly Ann + +Fla. Bar No. 195677 + +Helaine S. Goodner + +Fla. Bar No. 462111 + +BURNETT P.A. + +Espirito Santo Plaza, 14i° Floor + +1395 Brickell Avenue + +Miami, Florida 33131-3302 + +Telephone: (305) 789-9200 + +Facsimile: (305) 789-9201 + +Counsel for Defendant Jeffrey Epstein + +#### CERTIFICATE OF SERVICE + +I hereby certify that on October 29, 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 on all counsel of record or pro se parties identified 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 counsel or parties who are not authorized to receive electronically Notices of Electronic Filing. + +> s/Lill Ann Lilly Ann + +### SERVICE LIST + +M.J• v. Epstein + +United States District Court, Southern District of Florida + +J. brad@ athto'u. ice.co , Jaffe, Weissing, Fistos & Lehrman, PL 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone: (954) 524-2820 Facsimile: (954) 524-2822 Attorneys for Plaintiff M.J. 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+JEFFREY EPSTEIN and + +Defendant. + +## NOTICE OF APPEARANCE + +PLEASE TAKE NOTICE that Helaine S. Goodner of the law firm of Burnett, P.A. hereby gives notice of appearance as attorney to be noticed for Defendant JEFFREY ESPTEIN in the above-styled cause. All parties are requested to forward copies of all pleadings, notices, electronic notices, papers and correspondence to undersigned counsel. + +Case No. 9:10-cv-81111-WPD + +Respectfully submitted, + +lain Goodner + +E. Knight + +Fla. Bar No. 607363 + +Helaine S. Goodner + +Fla. Bar No. 462111 + +Lilly Ann + +Fla. Bar No. 195677 + +M ISIJRNEIT P.A. + +Espirito Santo Plaza, 14th Floor + +1395 Brickell Avenue + +Miami, Florida 33131-3302 + +Telephone: (305) 789-9200 + +Facsimile: (305) 789-9201 + +Counsel for Defendant Jeffrey Epstein + +## CERTIFICATE OF SERVICE + +I hereby certify that on November 1, 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 on all counsel of record or pro se parties identified on the attached Service List in the manner specificd, either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those counsel or parties who are not authorized to receive electronically Notices of Electronic Filing. + +s/Helaine S. Goodner + +Helaine S. Goodner + +Fla. Bar No. 462111 + +Case No. 9:10-ev-81111-WPD + +## SERVICE LIST + +M.J. v. Epstein + +Case No. 9:10-cv-8111I-WPD + +United States District Court, Southern District of Florida + +J. brad athtojustice.com + +Jaffe, Weissing, + +Fistos & Lehrman, PL 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone: (954) 524-2820 Facsimile: (954) 524-2822 Attorneys for Plaintiff M.J. 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I also certify that the foregoing document is being served this day on all parties on the attached Service List in the manner specified, either via transmission of Notices of Electronic Filing generated by CMIECF or in some other authorized manner for those parties who are not authorized to receive electronically filed Notices of Electronic Filing. + +J. + +## SERVICE LIST + +M.J. v. Jeffrey Epstein United States District Court, Southern District of Florida + +Lill Ann E. Kni ht + +Helaine S. Goodner + +BURNETT PA Espirito Santo Plaza, 14th Floor 1395 Brickell Avenue Miami, FL 33131-3302 + +Counsel for Defendant. 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I also certify that the foregoing document is being served this day on all parties on the attached Service List in the manner specified, either via transmission of Notices of Electronic Filing generated by CMIECF or in some other authorized manner for those parties who arc not authorized to receive electronically filed Notices of Electronic Filing. + +"WIWI. 3. + +# SERVICE LIST + +M.J. v. Jeffrey Epstein United States District Court, Southern District of Florida + +Lill Ann E. Kni ht + +Helaine S. Goodner + +BURNETT PA Espirito Santo Plaza, 14i° Floor 1395 Brickell Avenue Miami, FL 33131-3302 + +Counsel for Defendant. Jeffrey Epstein + +Civil Action No. + +PROOF OF SERVICE + +(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (1)) + +This summons for (name of individual and title, if any) JEFFREY EPSTEIN +was received by me on (date) SEPT. 20, 2010 + + I personally served the summons on the individual at (place) \_\_\_\_\_ +on (date) \_\_\_\_\_; or + + I left the summons at the individual's residence or usual place of abode with (name) MARK +, a person of suitable age and discretion who resides there, +on (date) OCT. 8, 2010, and mailed a copy to the individual's last known address; or + + I served the summons on (name of individual) \_\_\_\_\_, who is +designated by law to accept service of process on behalf of (name of organization) \_\_\_\_\_ +on (date) \_\_\_\_\_; or + + I returned the summons unexecuted because \_\_\_\_\_; or + Other (specify): + +My fees are \$ \_\_\_\_\_ for travel and \$ \_\_\_\_\_ for services, for a total of \$ 0.00 + +I declare under penalty of perjury that this information is true. + +Date: 10-29-10 + +*[Handwritten signature]* +Server's signature +THOMAS MARSIGLIANO, 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I am over the age of 18, am otherwise competent to testify and base the following on my personal knowledge. +2. 2. I was on the premises of 9 East 71st Street, New York, New York, the entire day of October 8, 2010. +3. 3. On October 8, 2010, no individual by the name of "Mark" worked, resided or was present on the premises of 9 East 71st Street, New York, New York. +4. 4. On October 8, 2010, no individual by the name of "Mark" received a subpoena at 9 East 71st Street, New York, New York. + +FURTHER AFFIANT SAYETH NOT. + +![]()RICHARD BARNETT + +![](_page_0_Picture_106.jpeg) + +NOTARY PUBLIC STATE OF NEW YORK + +Sworn and subscribed before me this '2- day of It-AVert'ev- , 2010 by Richard Barnett who is personally known to me or has produced as identification. + +HARRY I. BELLER Notary Public. State of New York No. 018E4853924 Oualified in Rockland County 111 Commission Expires Feb. 17. 20.L.7 + +MY COMMISSION EXPIRES: \ No newline at end of file diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821058/EFTA02821058.metadata.json b/marker2/court-redacted-v-epstein-81111/EFTA02821058/EFTA02821058.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..282704e64f764d7d291c0bfc8b5f34a3633bfc98 --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821058/EFTA02821058.metadata.json @@ -0,0 +1,157 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-redacted-v-epstein-81111/EFTA02821058.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1235, + "elapsed_seconds": 4.46, + "image_assets": [ + "_page_0_Picture_106.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 204.40800000000002, + 80.19 + ], + [ + 408.81600000000003, + 80.19 + ], + [ + 408.81600000000003, + 106.11000000000001 + ], + [ + 204.40800000000002, + 106.11000000000001 + ] + ] + }, + { + "title": "AFFIDAVIT OF RICHARD BARNETT", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 201.95999999999998, + 324.81000000000006 + ], + [ + 408.204, + 324.81000000000006 + ], + [ + 408.204, + 338.58 + ], + [ + 201.95999999999998, + 338.58 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 49 + ], + [ + "Line", + 24 + ], + [ + "Text", + 21 + ], + [ + "SectionHeader", + 4 + ], + [ + "PageHeader", + 2 + ], + [ + "ListGroup", + 2 + ], + [ + "Caption", + 2 + ], + [ + "Picture", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 29 + ], + [ + "Line", + 13 + ], + [ + "Text", + 4 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02821058" + } +} \ No newline at end of file diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821058/_page_0_Picture_106.jpeg b/marker2/court-redacted-v-epstein-81111/EFTA02821058/_page_0_Picture_106.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..eb39c58517005b8a309a7f87b1ddd4c3aaf06ba2 --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821058/_page_0_Picture_106.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:458b5651621e13fa67210e2699de5a41def3f2e2462798a141332b4c8b05bd76 +size 7218 diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821060/EFTA02821060.md b/marker2/court-redacted-v-epstein-81111/EFTA02821060/EFTA02821060.md new file mode 100644 index 0000000000000000000000000000000000000000..47bd55995301f02775b266ed50228e2a6db2c6d7 --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821060/EFTA02821060.md @@ -0,0 +1,63 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA + +Case No. 9:10-cv-81111-WPD + +M.J., + +Plaintiff, + +vs. + +JEFFREY EPSTEIN and + +Defendant. + +## NOTICE OF FILING SUPPLEMENTAL AFFIDAVIT + +Defendant Jeffrey Epstein, hereby files the Supplemental Affidavit of Richard Barnett (Exhibit A) in support of its Motion of Defendant Jeffrey Esptein to Quash Service of Process and Supporting Memorandum of Law (D.E. 7). + +Respectfully submitted, + +s/Lilly Ann + +E. Knight + +Fla. Bar No. 607363 + +Lilly Ann + +Ha. Bar No. 19 77 + +Helaine S. Goodner + +Fla. Bar No. 462111 + +BURNETT P.A. + +Espirito Sar•fiaza, 14i6 Floor + +1395 Brickell Avenue + +Miami, Florida 33131-3302 + +Telephone: (305) 789-9200 + +Facsimile: (305) 789-9201 + +Counsel for Defendant Jeffrey Epstein + +Case No. 9:10-cv-81111-WPD + +## CERTIFICATE OF SERVICE + +I hereby certify that on November 3, 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 on all counsel of record or pro se parties identified 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 counsel or parties who are not authorized to receive electronically Notices of Electronic Filing. + +> s/Lill Lill Ann + +## SERVICE LIST + +M.J. v. Epstein + +United States District Court, Southern District of Florida + +J. S athtojusuce.cona Jaffe, Weissing, Fistos & Lehrman, PL 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone: (954) 524-2820 Facsimile: (954) 524-2822 Attorneys for Plaintiff M.J. 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The Court has carefully considered the Motion and is otherwise fully advised in the premises. + +Accordingly, it is ORDERED AND ADJUDGED that the Motion of Defendant Jeffrey Epstein to Quash Service of Process and Supporting Memorandum of Law [DE-7] is hereby DENIED WITHOUT PREJUDICE to file a motion that complies with the requirements of S.D. Fla. L.R. 7.I.A.3., which requires the moving party to certify that he has conferred, or describes a reasonable effort to confer, with the parties affected in a good faith effort to resolve the dispute. + +DONE AND ORDERED in 8th day of November, 2010. at Fort Lauderdale, Broward County, Florida this + +Copies furnished to: Counsel of Record + +United States District Judge \ No newline at end of file diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821062/EFTA02821062.metadata.json b/marker2/court-redacted-v-epstein-81111/EFTA02821062/EFTA02821062.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..a61a16eddba28b4ef38ff6c891de73e42b336a93 --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821062/EFTA02821062.metadata.json @@ -0,0 +1,109 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-redacted-v-epstein-81111/EFTA02821062.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1091, + "elapsed_seconds": 0.69, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF FLORIDA", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 206.856, + 71.28 + ], + [ + 405.5581359863281, + 71.28 + ], + [ + 405.5581359863281, + 100.4830322265625 + ], + [ + 206.856, + 100.4830322265625 + ] + ] + }, + { + "title": "ORDER DENYING MOTION WITHOUT PREJUDICE", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 158.50799999999998, + 284.31 + ], + [ + 454.9107666015625, + 284.31 + ], + [ + 454.9107666015625, + 299.2330627441406 + ], + [ + 158.50799999999998, + 299.2330627441406 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 53 + ], + [ + "Line", + 27 + ], + [ + "Text", + 11 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02821062" + } +} \ No newline at end of file diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821063/EFTA02821063.md b/marker2/court-redacted-v-epstein-81111/EFTA02821063/EFTA02821063.md new file mode 100644 index 0000000000000000000000000000000000000000..785509fe2aa5dda970547e99f1767416a59ca9d6 --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821063/EFTA02821063.md @@ -0,0 +1,123 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA + +Case No. 9:10-cv-81111-WPD + +M.J., + +Plaintiff, + +vs. + +JEFFREY EPSTEIN and + +Defendant. + +# RENEWED MOTION OF DEFENDANT JEFFREY EPSTEIN TO QUASH SERVICE OF PROCESS AND SUPPORTING MEMORANDUM OF LAW + +Defendant Jeffrey Epstein, by and through undersigned counsel, respectfully moves pursuant to Fed. R. Civ. P. 12(6)(5) to quash service of process, and without waiving any available jurisdictional defenses and without making a general appearance, states as follows. + +# SUMMARY OF ARGUMENT + +Plaintiff, M.J., attempted to effect service on Mr. Epstein by leaving a copy of the Summons and Complaint in an unmarked, unaddressed and unpostmarked envelope in a mailbox at Mr. Epsteins' vacation house at 9 East 71" Street, New York, New York, at an unknown time between October 8, 2010 and October 13, 2010, and by purportedly leaving a summons with "Mark" at Mr. Epstein's alleged "residence or usual place of abode." Such purported "service" does not comply with the requirements of service of process under New York, Florida or federal law. The attempt at service of process was ineffective. Service of process should be quashed. + +#### BACKGROUND + +I. The Complaint in this action was filed, and a summons was issued as to Jeffrey Epstein, on September 17, 2010. + +2. The Proof of Service filed by Plaintiff (D.E. 11 at 3) recites that the process server left the summons at Mr. Epstein's + +> residence or usual place of abode with Mark, a person of suitable age and discretion who resides there, on Oct. 8, 2010, and mailed a copy to the individual's last known address .... + +The foregoing proof of service was originally filed on October 29, 2010. (D.E. 5). It was subsequently stricken (D.E. 10), and then refiled on November 2, 2010 (D.E. 11). + +3. On Wednesday, October 13, 2010, an unmarked, unaddressed and unpommarked envelope was discovered in the mailbox at Mr. Epstein's vacation home at 9 East 71" Street, New York, New York. The envelope contained a Summons and Complaint in the subject action, a Civil Rico Case Statement, a deposition subpoena, notices of video depositions, interrogatories and requests for production. (Affidavit of Richard Barnett, D.E. 7-1; Exhibit "A" to D.E. 7). + +4. According to the Affidavit of Richard Barnett, who was at the premises the entire day of October 8, 2010, no individual by the name of "Mark" worked, resided or was present on the premises of 9 East 71" Street, New York, New York. (Supplemental Affidavit of Richard Barnett, D.E. 12-1; Exhibit "A" to D.E. 12). + +Case No. 9:10-cv-81111-WPD + +#### ARGUMENT + +## NO SERVICE WAS MADE ON MR. EPSTEIN + +In this action three methods of service of process arc authorized by the Federal Rules of Civil Procedure. First, service can be effected pursuant to the procedures "in the state where the district court is located" - i.e. Florida. See Fed. R. Civ. P. 4(e)(1). Second, service can be effected in accordance with the procedures "in the state ... where service is made" - i.e. New York. Id. Finally, service can be effected pursuant to federal procedures by delivering a copy of the summons and complaint to the individual personally, leaving a copy of same at the individual's dwelling "with someone of suitable age and discretion who resides there" or delivering a copy to an agent authorized to accept service of process. See Fed. R. Civ. P. 4(e)(1). Service was not effected pursuant to any of the foregoing methods of service. + +No Service Under Florida Law. Under § 48.031(1)(a), Fla. Stat., service "is made by delivering a copy of it to the person to be served with a copy of the complaint, petition, or other initial pleading or paper or by leaving the copies at his or her usual place of abode with any person residing therein who is 15 years of age or older and informing the person of their contents ...." Plaintiff did not comply with § 48.031(1)(a), Fla. Stat. First, leaving an unmarked envelope with a summon and complaint in a mailbox at a vacation residence does not comply with § 48.031(I)(a), Fla. Stat. Second, although the process server recited that he left the summons with "Mark," there was no "Mark" on the premises on October 8, let alone a "Mark" who resided at 9 East 71' Street. (See Ex. B). Finally, the proof of service does not state that "Mark" was informed of the contents of the complaint, as required by § 48.031(1Xa), Fla. Stat. + +Case No. 9:10-cv-8I 1 1 1 -WPD + +No Service Under New York Law. Under New York law, personal service may be made by delivering the summons and complaint to the defendant or "to a person of suitable age and discretion at the actual place of business, dwelling place or usual abode of the [defendant]," and by mailing the summons and complaint to the person to be served at his last known address. N.Y.C.P.L.R. § 308(2). (McKinney 2008). In addition, proof of such service must be "filed with the clerk of the court designated in the summons within twenty days of either such delivery or mailing, whichever is effected later." Id. The foregoing requirements were not satisfied in the instant case. First, merely leaving an unmarked envelope with a summons and complaint in a mailbox does not constitute "mailing" under New York law. Second, there was no substitute service because there was no "Mark" on the premisses on October 8, 2010. (See Ex. B). Third, in violation of New York law, proof of service was not filed with the Clerk of the United States District Court for the Southern District of Florida within twenty (20) days of purported service. See C.P.L.R. § 308(2). Although the summons was purportedly delivered on October 8, 2010, it was not filed in the district court until October 29, 2010 -- after the 20-day period expired. Finally, C.P.L.R. 308(2) requires that the proof of service state the "date, time and place of service ...." The Affidavit filed by Plaintiff does not state the time or place of service, as required by C.P.L.R. § 308(2). + +Failure to comply strictly with the requirements of C.P.L.R. 308(2) requires dismissal. See, e.g., Fova, Inc. v. Latino Films, Inc., 2010 N.Y. Misc. LEXIS 4069, at \*7 (Sup. Ct. N.Y. County Aug. 11, 2010) (affidavit of service which failed to state address that the summons was mailed to was a jurisdictional defect requiring dismissal); Stanley Agency v. Behind the Bench, 2009 N.Y. Misc. LEXIS 833, at \*21 (Sup. Ct. Kings County April 13, 2009) (same). + +Case No. 9: I 0-cv-811 I I -WPD + +No Service Under Federal Law. Under Fed. R. Civ. P. 4(e)(2), service is effected by delivering a copy of the summons and complaint to the defendant personally, by leaving a copy of same at the "individual's dwelling or usual place of abode with someone of suitable age and discretion who resides there; or by delivering a copy of same "to an agent authorized by appointment or by law to receive service of process." Service was not effected pursuant to any of foregoing provisions of federal law. + +Accordingly, service of process must be quashed because it was invalid under Florida, New York and federal law. + +Certificate of Good Faith Conference Pursuant to S.D. Fla. L.R. 7.1. I hereby certify that counsel for the movant has conferred with all parties or non-parties who may be affected by the relief sought in this motion in a good faith effort to resolve the issues but has been unable to do so. + +WHEREFORE, Defendant Jeffrey Epstein respectfully requests that service of process be quashed. + +Case No. 9:10-cv-81111-WPD + +Respectfully submitted, + +E. Kni ht + +E. Knight + +Fla. Bar No. 607363 + +Helaine S. Goodner + +Fla. Bar No. 462111 + +Lilly Ann + +Fla. Bar No. 195677 + +L. Ackerman + +Fla. Bar No. 235954 + +BURNETT P.A. + +Espirito Santo Plaza, 14th Floor + +1395 Brickell Avenue + +Miami, Florida 33131-3302 + +Telephone: (305) 789-9200 + +Facsimile: (305) 789-9201 + +Counsel for Defendant Jeffrey Epstein + +# CERTIFICATE OF SERVICE + +I hereby certify that on November 10, 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 on all counsel of record or pro se parties identified 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 counsel or parties who are not authorized to receive electronically Notices of Electronic Filing. + +Si E. Knight + +. Knight + +Fla. Bar No. 607363 + +Case No. 9:10-cv-81111-WPD + +## SERVICE LIST + +M.J. v. Epstein + +Case No. 9:10-cv-81111-WPD + +United States District Court, Southern District of Florida + +J. brad a athto'ustice.com + +, Jaffe, Weissing, + +Fistos & Lehrman, PL 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone: (954) 524-2820 Facsimile: (954) 524-2822 Attorneys for Plaintiff M.J. 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I am an attorney in good standing with the Florida Bar and admitted to practice in the Southern District of Florida. +- 2. The law firm of Jaffe Weissing Fistos and Lehrman, of which I am apartner, filed a recent lawsuit on September 17, 2010 against Jeffrey Epstein, case number 10- 81111, in federal Court in the Southern District of Florida. +- 3. Defendant Epstein is aregistered sex offender as a result of his pleading guilty to felonies related to his illegal sexual conduct with minor children. +- 4. Through discovery in other cases, I learned that Ghislaine Maxwell and Jean Luc Brunel were close friends and business associates of Mr. Epstein who had important and relevant information concerning Mr. Epstein. +- 5. Both Ms. Maxwell and Mr. Brunel avoided having their depositions taken by relaying false information that they were out of the country with no intentions of returning. +- 6. Ms. Maxwell relayed through counsel that, just before her scheduled deposition, her mother became deathly ill, and Ms. Maxwell was therefore going to be with her mother outside the United States with no intention of returning. +- 7. She was photographed a month later in the United States attending Chelsea Clinton's wedding and that photograph was captured in US Weekly magazine. +- 8. According to widely circulated press reports, including a 60 minutes documentary and Ian Halperin's book "Bad and Beautiful: Inside the Dazzling and Deadly World of Supermodels", Mr. Brunel has been known as adrug abuser that has molested children through his modeling agencies. +- 9. Mr. Brunel frequently stayed at Epstein's house as a house guest and also has reported his primary address at an apartment building in New York at 301 East 66th Street, an apartment that is believed to be owned by Mr. Epstein. +- 10. Mr. Brunel visited Mr. Epstein approximately 67 times while Mr. Epstein was in jail serving his jail sentence for his sexual crimes in Palm Beach County. +- 11. Mr. Brunel was set for deposition and avoided his deposition by providing information through his counsel that he was out of the country with no intention of ever returning to the United States. +- 12. When Mr. Brunel relayed the information that he was out of the country with no plans to return, he was actually staying with Mr. Epstein at Mr. Epstein's according to Mr. Epstein's probation logs. +- 13. During discovery it was nearly impossible to take the deposition of someone that could provide relevant information against Mr. Epstein that was not represented by an attorney being paid by Mr. Epstein. +- 14. It was learned that in addition to paying for his own counsel, Mr. Epstein also paid for counsel for the following other material witnesses: (Epstein's executive assistant and procurer of girls for him to abuse), Larry Visoski (Epstein's personal pilot), Dave Rogers (Epstein's personal pilot), Larry (Epstein's personal pilot), (Epstein's housekeeper), (Epstein's live-in sex slave), Ghislaine Maxwell (manager of Epstein's affairs and businesses) , Mark Epstein (Epstein's brother), and Janusz Banasiak (Epstein's house manager). + +1. 15. In this case of MJ v. Jeffrey Epstein, case 10-81111, I contacted Mr. Epstein's counsel, Mr. Knight to request that he accept service for his client and he declined. +2. 16. My law firm was then forced to retain the services of ██████████ Marsigliano, a private investigator in New York, to serve Mr. Epstein. +3. 17. My law firm has been forced to spend more than \$1,400.00, on the service of process in this case to date. +4. 18. In a previous civil case against Jeffrey Epstein that I litigated on behalf of my client, Jane Doe, case number 08-80893, Mr. Epstein invoked his 5th amendment right against self-incrimination on nearly all discovery requests as well as all relevant questions posed to him and his co-conspirators in deposition. +5. 19. One piece of "evidence" that Mr. Epstein was ordered to produce included correspondence between him and his lawyers and the United States government. +6. 20. Mr. Epstein alleged to have produced all correspondence from the U.S. government to him or his attorneys but did not produce that correspondence from him or his attorneys to the government. +7. 21. I recently learned that there exists additional correspondence between Mr. Epstein or his attorneys and the United States government that was not produced for some unknown reason. +8. 22. Specifically, I learned that there exists correspondence between Epstein attorney Lilly Ann ██████████ and former United States prosecutor Matthew Menchel as well as between Epstein attorney Ken Starr and various government attorneys and/or supervisors. + +I declare under penalty of perjury that the foregoing is true and correct. + +FURTHER AFFIANT SAYETH NAUGHT. + +Dated this 11th day of November, 2010. + +![]()The foregoing instrument was acknowledged before me this 11th day of November, 2010 by BRAD ██████████, who is personally known to me. + +![]()Print Name: \_\_\_\_\_ + +My Commission Expires: + +![](_page_1_Picture_396.jpeg) \ No newline at end of file diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821070/EFTA02821070.metadata.json b/marker2/court-redacted-v-epstein-81111/EFTA02821070/EFTA02821070.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1ce25a309785420b5d09843ec2b02b6275402384 --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821070/EFTA02821070.metadata.json @@ -0,0 +1,134 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-redacted-v-epstein-81111/EFTA02821070.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 5077, + "elapsed_seconds": 6.98, + "image_assets": [ + "_page_1_Picture_396.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "AFFIDAVIT OF JAMES", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 222.285, + 76.14 + ], + [ + 433.608, + 76.14 + ], + [ + 433.608, + 89.91 + ], + [ + 222.285, + 89.91 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 563 + ], + [ + "Line", + 45 + ], + [ + "ListItem", + 14 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 344 + ], + [ + "Line", + 31 + ], + [ + "Text", + 15 + ], + [ + "PageHeader", + 2 + ], + [ + "ListGroup", + 2 + ], + [ + "Picture", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02821070" + } +} \ No newline at end of file diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821070/_page_1_Picture_396.jpeg b/marker2/court-redacted-v-epstein-81111/EFTA02821070/_page_1_Picture_396.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..9fa371c8b85fb62ecee4a52866579f0601080961 --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821070/_page_1_Picture_396.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:d3e089caee7d6537613afbf653187c7f7b4362d2298fbe486e8e98b1fc3a420e +size 11091 diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821072/EFTA02821072.md b/marker2/court-redacted-v-epstein-81111/EFTA02821072/EFTA02821072.md new file mode 100644 index 0000000000000000000000000000000000000000..c46a4e9cbe27f2c2d0cb80a78a6c17e5865e1223 --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821072/EFTA02821072.md @@ -0,0 +1,43 @@ +## UNITED STATES DISTRICT COURT + +## SOUTHERN DISTRICT OF FLORIDA + +CASE NO. 9:10-CV-81111-WPD + +IN RE PLAINTIFF MJ + +## AFFIDAVIT OFD MARSIGLIANO + +1. Your Affiant is aformer New York City Police Detective and acurrent private investigator licensed by the State of New Yo11242nduct investigatio rve process, Ihave been retained by the law firm of Jaffe Weissing Fistos and Lehrman to serve a summons, complaint, subpoena for deposition, interrogatories, request for production on Jeffrey Epstein. The case is MJ v. Jeffrey Epstein, No. 10-81111, and is currently pending in the U.S. District Court for the Southern District of Florida. + +2. On Se tember 20, 2010 I received apackage from the law firm of I.! . Jaffe Weissing Fistos and Lehrman which contained the summons, complaint, subpoena for deposition, interrogatories, request for production on MJ v. Jeffrey Epstein. I was advised by Michael Fisten, a Florida Licensed Private Investigator who is working for the law firm of la Jaffe Weissing MIS Fistos and Lehrman that the summons should be served at Epstein's New York residence located at 9 East 71 Street, New York City, New York. + +3. I had learned from Investigator Fisten that Epstein's New York residence has been featured in Magazines and News Papers as aresidence that once belonged to Epstein's long time associate Leslie Wexner and now belongs to Jeffrey Epstein. Investigator Fisten also related to me that while Epstein was on probation in 2010, Epstein listed his residence in New York as 9 East 71 Street on official probation travel documents and that an asset investigation revealed that Epstein was the owner of the residence. + +4. On Tuesday the 21' Day of September 2010 your Affiant conducted surveillance at the Epstein residence. Activity was observed in and out of the residence which would indicate that persons(s) were residing within. At one point Federal Agents from the Department of State secured the Epstein residence and closed the street where the residence was located. The State Department Agents were providing security for aforeign dignitary that was visiting the Epstein residence. + +5. On Friday the 8th day of October 2010, your Affiant knocked on the residential front door of the Epstein residence located at 9 East 71 Street, New York, New York. A male who identified himself as "Marc" answered the front door. Your Afliant advised "Mark" that I was a New York Private Investigator and that I had court papers to serve on Jeffrey Epstein for a lawsuit in Florida. Mark advised that Mr. Epstein was not at home at the time. Mark agreed to accept service for Mr. Epstein. I left the summons, complaint, subpoena for deposition, interrogatories, request for production with "Mark" who reentered the residence carrying the package in his hands. + +6. Based on my interaction with "Mark" and my observations, it was obvious that "Mark" was familiar with Jeffrey Epstein, had authority to answer the door of Mr. Epstein's home and accept service for Mr. Epstein. + +7. Mark agreed to give the papers to Mr. Epstein or Epstein's lawyers before accepting the documents and returning back inside the home. + +8. Your affianiared the proper return of service documents and forwarded them to Attorney to file in Florida. + +Ideclare under penalty of perjury that the foregoing is true and correct. + +FURTHER AFFIANT SAYETH NAUGHT. + +Dated this dcday of November, 2010. + +omas M ano, Private Investigator + +The foregoing instrument was acknowledged before me this ,..5"Lh day of November, 2010 by Marsigliano, who is personally known to me. ntooi!i4.0~ ALLSIssigat + +My Commission Expires: + +## NOTARY PUBLIC + +Print Names + +worn OESSNER stare at Now York No. SO404970982 OuoRiled In laNnou\_C fCommission Expires nw=14 \ No newline at end of file diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821072/EFTA02821072.metadata.json b/marker2/court-redacted-v-epstein-81111/EFTA02821072/EFTA02821072.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b9ca21e57848d715fa140631e1f90c84aed1e487 --- /dev/null +++ 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COMPEL AND INCORPORATED MEMORANDUM OF LAW + +Plaintiff, Jane Doe, respectfully files this motion for entry of an order directed to Jean Luc Brunel and his counsel ordering them to show cause why they should not be held in contempt, for sanctions, and for an order compelling Jean Luc Brunel to appear for a deposition within 20 days. After plaintiff Jane Doe served Brunel with a subpoena for a deposition in this case, his attorney, on his behalf, represented that Brunel would appear for a deposition if Jane Doe would postpone the scheduled deposition date. As an accommodation to him, Jane Doe did postpone the scheduled deposition date, but then Brunel has not appeared as agreed for a deposition. After much communication in an attempt to coordinate Brunel's deposition, Brunel's counsel represented that Brunel was outside of the country, and thus unavailable, when in fact he was inside the country + +and easily available for a deposition. Because of these false representations, this Court should direct Brunel and his counsel to show cause why they should not be held in contempt. This Court should also compel Brunel to appear for the deposition that was previously scheduled and that he has avoided only through these false representations. Finally, the Court should sanction the appropriate person(s) for causing the undersigned to spend unnecessary time filing this motion. + +# BACKGROUND + +Jane Doe personally served Jean Luc Brunel in New York City to appear for deposition in this case. The subpoena indicated a deposition date of September 22, 2009 at 10:00 A.M. in New York City, New York. Brunel is an important witness in this case, as he is a good friend of Epstein's and has information regarding Epstein's pattern and practice of obtaining young girls for sexual purposes, relevant issues not yet admitted by Defendant Epstein. + +Shortly after Brunel was served, counsel for Jane Doe was contacted by Tama Beth Kudman, Esq., a licensed attorney in Florida. Kudman stated that she represented Brunel with regard to the subpoena and that she would produce Brunel for deposition in West Palm Beach if Jane Doe would agree not to go forward with the deposition date in New York. Counsel for Jane Doe honored that request, and with Kudman jointly arranged a deposition date for Brunel in West Palm Beach for October. + +Shortly before his deposition was to take place, Ms. Kudman contacted counsel for Jane Doe to move that deposition date because of a personal conflict. Once again, counsel for Jane Doe agreed. After several conversations regarding the deposition of + +Brunel, Kudman asked that counsel for Jane Doe set Brunel for deposition in January of 2010, as that was a time when she could assure his availability. + +In January, counsel for Jane Doe again contacted Ms. Kudman to arrange a mutually convenient deposition time. Ms. Kudman stated that Brunel would be in Florida the first week of February and she would work to coordinate his deposition for that time. + +The undersigned's office contacted Ms. Kudman's office on several occasions in January to coordinate a February deposition date of Brunel. On January 29, 2010, Ms. Kudman returned the call and left a voicemail apologizing for not returning the call sooner and indicating that she had only been waiting to hear from Mr. Brunel as to his availability, and she invited the undersigned to contact her the following week to set it up. On February 5, 2010, counsel for Jane Doe contacted Ms. Kudman to coordinate Brunel's deposition. During that telephone conversation, Ms. Kudman represented that her client, Mr. Brunel, had previously left the country to go to his home country of France before the New Year. Ms. Kudman further represented that while she believed he was going to return, it turned out that he had no plans to return. Ms. Kudman also stated that if Brunel was in the country, she would make good on her representation that she would produce him. However, she had just spoken to him via a telephone call from him in France. Brunel told Kudman that he was staying there indefinitely with no plans to return. In subsequent telephone conversations, Ms. Kudman continued to represent that Mr. Brunel had been out of the country since sometime prior to the New Year and was not planning to return. + +Counsel for Jane Doe responded that this representation seemed quite strange, since Brunel has a significant business in the United States. Kudman replied that it was simply too expensive for him to return and that because of the expense he had no intentions of returning. Counsel for Jane Doe then pointed out that when Brunel was served, Kudman had promised he would be produced for deposition. Kudman replied that because he is in France with no plans to return there was simply nothing she could do. Kudman further advised counsel for Jane Doe that if he wanted to take Brunel's deposition in France, then it would be necessary to obtain a Letters Rogatory and go through the Consulate. After these procedures, Kudman then indicated it would be necessary to take a trip to France for his deposition. Counsel for Jane Doe indicated that he might be willing to go through that process, but that he would like for Kudman to tell him if Brunel happened to return to the United States. Kudman promised that she would. + +Remarkably, after all of these representations had been made by Kudman, it turns out that Brunel was actually in the United States during the time when Jane Doe was trying to take his depositon. In fact, on February 16, 2010, counsel for Jane Doe took the deposition of Jeffrey Epstein's house manager, Janusz Banaziak. Mr. Banaziak was asked if he knew Mr. Brunel. In summary, he responded that he knew him as Mr. Epstein's friend. He elaborated that Mr. Brunel had stayed with Epstein at Epstein's Palm Beach home on at least two occasions in 2010. The first 2010 visit was in January, when Mr. Brunel stayed for approximately 3 days. Then Mr. Brunel stayed at Mr. Epstein's home from approximately February 1091 or 11'" through February le, + +2010. It was known by Epstein that Brunel was coming to stay at the house in February 2010, as he was picked up at the airport and driven to Epstein's home by Epstein's bodyguard, Igor Zinoview, and after his stay with Epstein, Brunel was driven from Epstein's house to the airport by . See deposition of Janusz Banaziak at page 154-161 and 168-16 attached hereto as Exhibit "A." + +## MEMORANDUM OF LAW + +As is readily apparent from the foregoing facts, Ms. Kudman has either made false representations about Mr. Brunet's whereabouts or Mr. Brunel has made false representations about his whereabouts that she passed on. In either case, they should be required to show cause why her and/or she should not be held in contempt of court for making false representations. See, e.g., Acton v. Target Corp., 2009 WL 5214419 at \*5 (W.D. Wash. 2009) (entering order to show cause why counsel should not be held in contempt for making false representations). In particular, Mr. Brunel and Ms. Kudman should explain how it came to pass that Mr. Brunel was in Florida at the very time that Jane Doe was attempting to take his deposition while Ms. Kudman was confidently reporting that he was unavailable in France. Given the known facts, Ms. Kudman was either an unwitting messenger who passed along false representations delivered to her by her client Mr. Brunel, or she was a knowing participant in Brunel and/or Epstein's attempt to obstruct discovery; either way a show cause order should be entered and the appropriate person(s) sanctioned and held in contempt. + +Mr. Brunel and Ms. Kudman should also be required to provide a full explanation of who precisely is paying the attorney fees for Ms. Kudman's services. Most, if not all, + +of the witnesses that have been deposed in this and related cases against Epstein have appeared with counsel retained and paid for by Defendant Jeffrey Epstein. In this instance, we know that Mr. Epstein was together with his house guest, Mr. Brunel, at a time when Brunel's counsel was representing that Brunel was out of the country and could thus not attend a deposition. Mr. Epstein also knew at that time that the undersigned had been trying to coordinate Brunel's deposition for months. Therefore, there is no doubt that Mr. Epstein was assisting Mr. Brunel and/or Ms. Kudman in obstructing discovery. At the very least, Mr. Epstein was an accomplice, but was he the person paying the attorney to make false representations and tamper with important witnesses? While Mr. Epstein may be able to invoke his 5th amendment rights on such questions, Mr. Brunel and Ms. Kudman do not have that luxury, and at this point they should be required to provide these answers. + +Again, as the facts make clear, Ms. Kudman has not delivered on promises made (as an officer of the court) to counsel for Jane Doe, and Mr. Brunel has not appeared for a deposition. As such, Jane Doe moves this Court to enter an order directing Mr. Brunel to promptly appear for a deposition in West Palm Beach within 14 days. He was properly served with a subpoena by Jane Doe, and only through deceitful maneuvers he has been able to avoid his deposition. This Court should not permit subpoenas to be avoided in this fashion. + +WHEREFORE, Jane Doe respectfully requests the Court to direct Mr. Brunel and Ms. Kudman to show cause why they should not be held in contempt for making false representations in an effort to avoid a deposition. If the Court finds that they are in + +contempt, the Court should also impose appropriate sanctions, including attorney's fees for Jane Doe in connection with filing this motion. The Court should also compel Mr. Brunel to appear for a deposition within 14 days of the Court's order and grant any additional relief the Court deems just and proper. + +# PRE-FILING CONFERENCE + +Counsel for Jane Doe has attempted to confer with Ms. Kudman about this motion, but she declined to make Brunel available for deposition, and in fact has again stated as recently as March 5, 2010 that Brunel has been out of the country since prior to the New Year with no plans to return. + +DATED: March 10, 2010 + +Respectfully Submitted, + +AFFE, WEISSING, , FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 Florida Bar No.: 542075 E-mail: brad@pathtojustice.com + +and + +Paul G. Cassell Pro Hac Vice 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: 801-585-5202 Facsimile: 801-585-6833 E-Mail: cassellp@law.utah.edu + +### CERTIFICATE OF SERVICE + +I HEREBY CERTIFY that on March 10, 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 on 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 filed Notices of Electronic Filing. + +> s/ J. + +### SERVICE LIST + +Jane Doe v. Jeffrey Epstein United States District Court, Southern District of Florida + +Jack Alan Goldberger, Esq. Jaoldberaer@aawoa.com + +Robert D. Critton, Esq. rcritton@bciclaw.com + +Isidro Manual isidrogarcia@bellsouth.net + +Jack jph@searcylaw.com • + +Katherine Warthen Ezell KEzell@podhurst.com + +Michael James Pike MPike@bciclaw.com + +Paul G. Cassell cassellp@law.utah.edu + +Richard Horace Willits lawyerswillits@aol.com + +Robert C. Josefsberg + +CASE NO: 08-CV-80119-MARRA/[REDACTED] + +[rjosefsberg@podhurst.com](mailto:rjosefsberg@podhurst.com) + +Adam D. Horowitz +[ahorowitz@sexabuseattorney.com](mailto:ahorowitz@sexabuseattorney.com) + +Stuart S. 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0000000000000000000000000000000000000000..fa8570720b88355cfedf2ef9cf2748b7964d5bb9 --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821084/EFTA02821084.md @@ -0,0 +1,177 @@ +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA + +M.J., CASE NO. 9:10-CV-81111-WPD + +Plaintiff, + +Vs. + +JEFFREY EPSTEIN, and + +Defendants. + +PLAINTIFF M.J.'S RESPONSE TO ESPTEIN'S MOTION TO QUASH SERVICE OF PROCESS AND MOTION FOR A HEARING TO PROVE FRAUD, TO PROVE PROPER SERVICE, TO OBTAIN SANCTIONS FOR EPSTEIN'S SUBMISSION OF A FRAUDULENT AFFIDAVIT, TO OBTAIN A WARNING FORBIDDING FURTHER OBSTRUCTIONS IN THE CASES, AND TO SET AN ACCELERATED SCHEDULE FOR DISCOVERY + +Plaintiff, M.J., hereby files this response to Epstein's Motion to Quash Service of Process and for a hearing to demonstrate fraud, to prove the defendant Epstein was properly served, to obtain sanctions for his submission of fraudulent affidavits, to obtain a warning forbidding any further obstruction in the case, and to set an accelerated schedule for discovery including an Order that Epstein is in default for failing to timely answer the complaint. + +Plaintiff M.J. was repeatedly sexually abused by defendant Jeffrey Epstein when she was a minor. Epstein is a politically-connected billionaire. M.J. filed suit in this Court against Epstein, seeking substantial damages. After Epstein's counsel refused to accept service of M.J.'s complaint, M.J.'s counsel sent a private investigator to Epstein's New York mansion (Epstein's usual place of abode) to serve Epstein. On Friday, + +October 8, 2010, the investigator hand-delivered to one of Epstein's employees, who identified himself as "Mark," a copy of the summons and complaint and other related documents, which "Mark" then took into Epstein's mansion. This constituted proper service under the federal rules. + +Epstein's answer to M.J.'s complaint was accordingly due on Friday, October 29, 2010. Rather than answer the complaint, however, on October 29, Epstein's legal counsel filed a motion to "quash" service of process, alleging that process was not properly made. Attached to the Motion was an Affidavit of Richard Barnett, which swore that an "unmarked and unpostmarked envelope was discovered in the mailbox at Mr. Epstein's vacation home in New York at 9 East 7151 Street on Wednesday October 13, 2010. . . . Service was never delivered to anyone at Mr. gpsitein's house." The statement that the service was not delivered to anyone at the house was false and nothing short of an intentional fraud being committed on the court. The circumstances surrounding the making of this statement strongly suggest that Barnett swore to this false statement deliberately, for the purpose of obstructing proper proceedings in this case. Defendant Epstein's history of obstructing sexual abuse litigation against him strongly supports the conclusion that Epstein contrived for Barnett to perjure himself in the affidavit. + +M.J. accordingly asks that Epstein's Motion To Quash be denied and that she be granted a hearing to prove these facts, to prove that service has properly been made, to obtain appropriate sanctions for the perjury, to have the court warn Epstein against further improper obstruction, and to set an accelerated discovery schedule in this case, + +and to Order Epstein to immediately file an Answer to MJ's Complaint or alternatively to Strike Epstein's pleadings. + +# FACTUAL BACKGROUND + +At any hearing the Court might conduct, M.J. is prepared to establish the following facts through competent and admissible testimony. In this pleading, M.J. will also provide affidavits and other evidence sufficient to permit the Court to move forward on the basis of this pleading alone. Because Epstein has a history of not responding directly to allegations made by girls he has sexually abused, M.J. is numbering each of her individual facts. If Epstein does not respond to M.J.'s facts specifically, the Court should draw the obvious conclusion that the fact is accurate. + +# M.J.'s Facts Supporting Proper Service of Process + +- 1. On September 17, 2010, M.J. filed a complaint in this Court, alleging that defendant Jeffrey Epstein had repeatedly sexually abused her while she was a minor. See M.J. v. Epstein, No. 9:10-CV-81111-WPD (DE 1). +- 2. On about September 2, 2010, counsel for M.J., asked Knight, legal counsel for Jeffrey Epstein, in writing if he would accept service of process for Epstein. Epstein's counsel refused to accept service. +- 3. Counsel for M.J. then retained the services of Marsigliano, a Private Investigator in New York, to make service on Epstein and one whom the law firm of , Jaffe, Weissing has been forced to pay \$1,400.00, up to this point just to obtain service on Epstein. Declaration of - Exhibit 1 at ¶16-17. + +4. Marsigliano was provided with the address of Epstein's New York mansion, where Epstein was residing. Marsigliano conducted several days of surveillance on Epstein's mansion in an attempt to personally serve Epstein. Declaration of Marsigliano (Exhibit 2) at ¶2-5 (hereinafter "Marsigliano Dec."). + +5. On Friday, October 8, 2010, Marsigliano went to Epstein's mansion at 9 East 71st Street, and he knocked on the door. An employee of Epstein who identified himself as "Mark" answered the door and informed Mr. Marsigliano that Epstein was "not home" before he accepted service for Epstein. See Marsigliano Dec. at ¶5-7. + +6. On October 13, 2010, Mr. Knight approached Mr. after a hearing to discuss this case on behalf of his client and Mr. informed Mr. Knight that someone at Epstein's residence in New York had accepted service for Epstein. + +7. On October 29, 2010, proof of service was lodged with the Court (DE\_5) — (corrected to DE\_11-Summons (Affidavit) Returned Executed). That proof of service stated that Marsigliano had left the summons "at [Epstein's] residence or usual place of abode with Mark, a person of suitable age and discretion who resides there . . . ." + +8. The foregoing service constituted proper service the Federal Rules of Civil Procedure. See Fed. R. Civ. P. 4(e)(2)(8). Under the Federal Rules of Civil Procedure, an answer to a properly served complaint must be filed within 21 days. Fed. R. Civ. P. 12(a)(1)(A)• + +# False Statement by Richard Barnett, an Agent of Epstein + +9. On October 29, 2010, Lilly Ann , legal counsel for Epstein, filed a motion in this Court to Quash Service of Process. (DE 7). + +10. Attached to the pleading was an Affidavit of a Richard Barnett. The affidavit stated: + +"On Wednesday, October 13, 2010, an unmarked and unpostmarked envelope was discovered in the mailbox at Mr. E[ps]tein's vacation home in New York City at 9 East 7151 Street. The envelope contained a Summons and Complaint in the subject action, a Civil Rico Case Statement, a deposition subpoena, notices of video depositions, interrogatories and requests for production. Service was never delivered to anyone at Mr. EThs]tein's house." + +Affidavit of Richard Barnett at ¶ 2-3 (emphasis rearranged) (DE\_7-1). The affidavit also stated that Barnett had been duly sworn. Barnett signed the document before a New York Notary Public, although it should be noted that the Notary does not properly indicate how Richard Barnett was properly identified. Id. + +11. The affidavit of Richard Barnett was patently false. As recounted above, service had been delivered to "Mark" at Epstein's house on October 8, 2010. See Para. 5, supra. + +12. The affidavit of Richard Barnett is written to obscure important information. In particular, the affidavit uses the passive voice to state that "an unmarked . . . envelope was discovered in the mailbox" at Epstein's home. The affidavit does not state who made the discovery. The affidavit does not state whether Barnett has personal knowledge of the facts contained in his affidavit. + +13. Barnett subsequently filed a second affidavit, this time to merely announce that nobody named "Mark" was at the house on October 8, 2010. While this may be true, this only demonstrates that the person who accepted service on October 8, 2010 at Mr. + +Epstein's residence lied about his name, and accordingly Mr. Barnett's second affidavit is virtually worthless. + +# Epstein's Pattern of Obstruction in Other Similar Civil Suits Against Him + +14. The false affidavit filed by Barnett in this case parallels other false statements made and evasive actions taken by Epstein's associates in other similar civil cases filed against him by other young girls he sexually abused. More than 20 civil cases like M.J.'s have been filed against Epstein in the last three years. Epstein has settled all of the cases. Among those cases was a federal lawsuit filed by Jane Doe in this court, styled as Jane Doe v. Epstein, 9:08-cv-80893. M.J.'s legal counsel also handled Jane Doe's case against Epstein. + +15. While working on that case and others like it, learned through deposition that Ghislaine Maxwell was involved in managing Epstein's affairs and companies. See Dec. at ¶ 4. + +16. Epstein's housekeeper, Alfredo Rodriguez, also testified that Maxwell took photos of girls without the girls' knowledge, kept the images on her computer, knew the names of the underage girls and their respective phone numbers and other underage victims were molested by Epstein and Maxwell together. In light of this and other information, served her for deposition in 2009. Maxwell was represented by Brett Jaffe of the New York firm of and Gresser, and understood that her attorney was paid for (directly or indirectly) by Epstein. She was reluctant to give her deposition, and tried to work with her attorney to take her deposition on terms that would be acceptable to both sides. The result was a confidentiality + +agreement, under which Maxwell agreed to drop any objections to the deposition. Maxwell, however, contrived to avoid the deposition. On June 29, 2010, one day before was to fly to New York to take Maxwell's deposition, her attorney informed that Maxwell's mother was deathly ill and Maxwell was consequently flying to England with no intention of returning to the United States. Despite that assertion, Ghislaine Maxwell was in fact in the country on July 31, 2010, as she attended the wedding of Chelsea Clinton (former President Clinton's daughter) and was captured in a photograph taken for US Weekly dated August 16, 2010. See Dec. at ¶ 6-7. + +17. Maxwell was not the only important witness to lie to avoid deposition by in the Jane Doe case. Jean Luc Brunel did so as well. Upon review of message pads police took from Epstein's home, many were discovered to be from Jean Luc Brunel, a citizen and one of Epstein's closest friends. Brunel left messages for Epstein that were taken by Epstein's staff such as "He has a teacher for you how to speak Russian. She is 2x8 years old not blonde: Lessons are free and you can have 151 today if you call". Exhibit 3. In light of the circumstances of the case, this appeared to be an encrypted message suggesting that Brunel might have been procuring two eight-yearold girls for Epstein to sexually abuse. According to widely circulated press reports, Brunel is in his sixties and has a reputation throughout the world (and especially in the modeling industry) as a cocaine addict that has for years molested children through modeling agencies while acting as their agent. Brunel is also someone that visited Epstein on approximately 67 occasions while Epstein was in jail. See Dec. at + +¶ 8-10. Brunel currently runs the modeling agency MC2, a company for which Epstein provides financial support. + +18. In view of this information suggesting Brunel could provide significant evidence of Epstein's trafficking in young girls for sexual abuse, had Brunel served in New York for deposition. Before the deposition took place, Brunel's attorney (Tama Kudman of West Palm Beach) contacted to delay the deposition date. Eventually Kudman informed in January 2009 that Brunel had left the country and was back in France with no plans to return. This information was untrue; Brunel was actually staying with Epstein in West Palm Beach as evidenced by Epstein's probation file where Epstein was required to note is house guests. See Dec. at 111-12. As a result, filed a Motion for Order to Show Cause, (DE 483), attached hereto as Exhibit 4. (Because Epstein settled this case, the motion was never ruled upon.) + +19. was also informed that Epstein paid for not only his representation during the civil process but also paid for legal representation for (Epstein's executive assistant and procurer of girls for him to abuse), Larry Visoski (Epstein's personal pilot), Dave Rogers (Epstein's personal pilot), Larry (Epstein's personal pilot), (Epstein's housekeeper), (Epstein's live-in sex slave), Ghislaine Maxwell (manager of Epstein's affairs and businesses) , Mark Epstein (Epstein's brother), and Janusz Banasiak (Epstein's house manager). It was nearly impossible to take a deposition of someone that would have helpful information that was not represented an attorney paid for by Epstein. See Dec. at ¶ 13-14. + +20. Epstein has deliberately hidden relevant correspondence regarding his guilt of sex offenses by making only partial productions of correspondence in other cases, as detailed at greater length in M.J.'s contemporaneously filed Motion for Instructions to Epstein to Preserve Certain Correspondence. + +21. Epstein has harassed girls who have filed civil suits against him, as detailed at greater length in M.J.'s contemporaneously filed Motion for a Protective Order Barring Direct or Indirect Conduct with Her. + +22. In view of this pattern of obstruction other cases, the reasonable inference arises that Barnett's false statement in his affidavit was not an accident, but rather a deliberate evasion orchestrated by Epstein to delay the orderly processing of this case. + +## LEGAL MEMORANUM + +#### I. THE COURT SHOULD HOLD AN EVIDENTIARY HEARING ON THE CIRCUMUSTANCES SURROUNDING BARNETT'S FALSE STATEMENT. + +Before this case can proceed to its conclusion, Epstein must be served. There is now an evidentiary dispute about whether service has been properly made. M.J.'s investigator, Marsigliano, has provided a sworn statement to this Court that he handed the complaint and other materials to Epstein's representative inside his home. Epstein, on the other hand, has submitted a sworn statement to this Court — through Richard Barnett — that this event never happened. Accordingly, this Court has a pure and simple factual dispute to resolve. + +M.J. respectfully requests a brief evidentiary hearing on the matter, at which she would plan to call four witnesses: First, Mr. Marsigliano to testify to his service of the complaint; Second, "Mark" [Last Name Unknown] to testify to his receipt of the + +complaint in Epstein's New York mansion; third, Richard Barnett to establish that he has given a false statement to the Court that no such service had occurred and to develop the reasons why he swore to such a false statement; and finally, Jeffrey Epstein, to establish (either directly or circumstantially) his awareness that a false statement was being submitted to the Court on his behalf and his direct involvement in orchestrating that false statement. M.J. estimates that the hearing could be held in approximately one hour. + +The appropriate way to resolve this factual dispute is through such a brief evidentiary hearing. Because Epstein has raised a specific factual dispute under Fed. R. Civ. P. 12(b)(5) — i.e., whether service was made on an individual residing at his dwelling -- M.J. now bears the burden of establishing that particular fact. See Grand Entertainment Group, Ltd. V. Star Media Sales, Inc., 988 F.2d 476, 488 (3d Cir. 1993). The court must then "weigh and determine [the] disputed issues of facts on a Rule 12(b)(5) motion." Cranford v. United States, 359 F.Supp.2d 981, 984 (E.D. Cal. 2005). An evidentiary hearing is the proper vehicle for resolving this particular factual dispute. See Blair v. City of Worcester, 522 F.3d 105, 115 (1st Cir. 2008) (reversing district court for refusing to hold an evidentiary hearing where factual issues surrounding service of process were disputed). + +# II. M.J. HAS PROPERLY SERVED EPSTEIN. + +M.J. will establish at the evidentiary hearing that she delivered her complaint and the other required documents to the caretaker at Epstein's mansion in New York, where he often went. This was sufficient service. + +Federal Rule of Civil Procedure 4(e)(2)(B) provides that service can be made by "leaving a copy of [the complaint and other documents] at the individual's dwelling or usual place of abode with someone of suitable age and discretion who resides there . . . + +Epstein's counsel admit they have received proof of service from Marsigliano attesting that he left M.J.'s complaint with the caretaker at Epstein's residence or usual place of abode. See Epstein's Mot. to Quash at 2 ("As of today, there is a document which purports to be a return of service."). In his motion to quash, Epstein concedes the materials were left at his "vacation home." Barnett Aff. at 1. Epstein's New York Mansion is well known for being the largest private residence in Manhattan and for being owned by Epstein. Given Marsigliano's affidavit and Epstein's concession about the fact that it is his home, the Court should conclude that the New York mansion was in fact Epstein's dwelling or usual place of abode. See Blair v. City of Worcester, 522 F.3d 105, 110 (151 Cir. 2008) ("A return of service generally serves as prima facie evidence that service was validly performed."); Gottlieb v. Sandia Am. Corp., 452 F.2d 510, 514 n. 5 (3rd Cir.1971) ("although a marshal's return is not conclusive on the question of service on an agent, it will stand in the absence of proof to the contrary"). The Court may take judicial notice of facts contained in the record in adjudicating service of process issues. Sidney v. Wilson, 228 F.R.D. 517 (S.D.NY. 2005). Marsigliano's return of service attesting that the mansion is Epstein's dwelling or usual place of abode is such a fact, particularly given that "in a high mobile and affluent society, it is + +unrealistic to interpret Rule 4(d)(1) 1 so that the person to be served has only one dwelling house or usual place of abode." 2 + +The only question for the Court, then, is whether M.J. has left a copy of her complaint and other documents with someone at the home. For the reasons explained in Part I above, the Court should find that Marsigliano did in fact leave the complaint. Service was accordingly proper. + +It is also clear now that Epstein's attorneys have received the complaint on his behalf — thereby effectively giving him actual notice of the claim M.J. has filed against him. "To the extent that there is any rule or guide to be followed by the federals in such a case [of disputed service] it is that where actual notice of the commencement of the action and the duty to defend has been received by the one served, the provisions of Rule (4)(d)(1)3 should be liberally construed to effectuate service and uphold the jurisdiction of the court, thus insuring the opportunity for a trial on the merits." Karlsson v. Rabinowitz, 318 F.2d 666, 668 (41h Cir. 1966). Rule 4 is a flexible rule that should be liberally construed so long as a party receives sufficient notice of the complaint, United Food & Commercial Workers Union v. Alpha Beta Co., 736 F.2d 1371, 1382 (9th Cir.1984)." Epstein has received ample notice here. + +The Court was referring to an earlier version of what is now Fed. R. Civ. P. 4(e)(2). + += This problem may be particularly acute for the super-wealthy like Epstein. According to Wikipedia, "[i]n addition to his private island in the U.S. Virgin Island (Little St. James Island), Epstein owns a 50,000 square foot townhouse in Manhattan that was formerly owned by Les Wexner, a villa in Palm Beach, Florida, and a fortress on a ranch in Santa Fe, New Mexico. Wikipedia entry for Jeffrey Edward Epstein (visited on Oct. 30, 2010). Accordingly, it may be difficult to identify a single "dwelling" for Epstein. + +3 The Court was referring to an earlier version of what is now Fed. R. Civ. P. 4(e)(2). + +#### III. THE COURT SHOULD IMPOSE SANCTIONS ON EPSTEIN FOR FILING A FRAUDULENT AFFIDAVIT WITH THE COURT. + +For the reasons explained above — and based on the testimony M.J. will provide at the evidentiary hearing -- the Court should conclude that Barnett knowingly filed a false affidavit with the Court and that Epstein was responsible for the filing. The Court should then impose appropriate sanctions on Epstein to prevent such future misbehavior. The Court has authority to impose sanctions on Epstein, both under Fed. R. Civ. P. 11(c) (authorizing sanction on a "party"), and under the Court's inherent power to sanction those who commit fraud before it. See, e.g. v. Tenneco Packaging Co., Inc., 293 F.3d 1306, 1320 (1191 Cir. 2002) (discussing inherent power of the district courts to impose sanctions). + +As recounted at greater length in the facts section of this pleading, Epstein is a billionaire who has obstructed other proceedings in the past. Accordingly, the sanctions the Court imposes should be substantial, so that they reflect the need to deter similar behavior by Epstein in the future. As Rule 11 explains, the sanction should be designed "to deter petition of the conduct or comparable conduct ...." Fed. R. Civ. P. 11(c)(2). + +Epstein should also be ordered to pay all the costs and attorneys' fees M.J. has incurred in responding to his fraudulent argument that he was not served. + +#### IV. THE COURT SHOULD WARN EPSTEIN THAT FURTHER OBSTRUCTION IN THIS CASE WILL NOT BE TOLERATED. + +As noted above, Epstein has a history of obstructing similar proceedings with a variety of dilatory tactics. Accordingly, he should be warned that any further obstruction + +in this case — including the submission of any more fraudulent affidavits — will not be tolerated. + +#### V. THE COURT SHOULD ESTABLISH AN EXPEDITED SCHEDULE FOR RESOLVING THIS CASE. + +Given Epstein's obvious intent to obstruct and delay these proceedings, M.J. respectfully requests that the Court directly intervene now and set up an appropriate, accelerated schedule for bringing this case to trial. M.J. is fully prepared to proceed expeditiously. And Epstein, a billionaire, has vast financial resources that he can use to prepare this case for trial quickly. Moreover, Epstein has now defended more than twenty civil suits filed against him of a similar nature. Therefore, he is fully aware of the scope of the claims and the kinds of defenses that need to be raised. Therefore, the Court should set up an expedited schedule. + +# POSITION OF THE PARTIES + +M.J. conferred with counsel for defendant Epstein and understands that defendant Epstein objects to all these requests. + +# CONCLUSION + +M.J. requests this Court: enter and Order denying Epstein's Motion To Quash, or alternatively that MJ be granted a hearing to prove that service was properly made; to obtain appropriate sanctions for the perjury and false affidavits filed on behalf of Epstein; to have the court warn Epstein against further improper obstruction; and to set an accelerated discovery schedule in this case; and finally to Order Epstein to immediately file an Answer to MJ's Complaint or alternatively to Strike Epstein's pleadings. + +Respectfully Submitted, + +DATED: November 11, 2010 + +AFFE, WEISSING, , FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 Florida Bar No.: 542075 E-mail: brad@pathtojustice.com + +## CERTIFICATE OF SERVICE + +I HEREBY CERTIFY that on November 11, 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 on 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 filed Notices of Electronic Filing. + +> s/ J. J. + +## SERVICE LIST + +M.J. v. Jeffrey Epstein United States District Court, Southern District of Florida + +Lill y Ann + +E. Kni ht + +Helaine S. Goodner + +BURNETT PA + +Espirito Santo Plaza, 14th Floor + +1395 Brickell Avenue + +Miami, FL 33131-3302 + +Counsel for Defendant, Jeffrey Epstein \ No newline at end of file diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821084/EFTA02821084.metadata.json b/marker2/court-redacted-v-epstein-81111/EFTA02821084/EFTA02821084.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b6281f9b41bfcb34ea793a307803998b13e94f0f --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821084/EFTA02821084.metadata.json @@ -0,0 +1,966 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-redacted-v-epstein-81111/EFTA02821084.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 16, + "chars": 24256, + "elapsed_seconds": 2.01, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF FLORIDA", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 201.96000000000004, + 71.0675048828125 + ], + [ + 410.520751953125, + 71.0675048828125 + ], + [ + 410.520751953125, + 99.54998779296875 + ], + [ + 201.96000000000004, + 99.54998779296875 + ] + ] + }, + { + "title": "FACTUAL BACKGROUND", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 247.86, + 165.24 + ], + [ + 401.6507873535156, + 165.24 + ], + [ + 401.6507873535156, + 180.17999267578125 + ], + [ + 247.86, + 180.17999267578125 + ] + ] + }, + { + "title": "M.J.'s Facts Supporting Proper Service of Process", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 160.95600000000002, + 385.55999999999995 + ], + [ + 454.6352844238281, + 385.55999999999995 + ], + [ + 454.6352844238281, + 401.04998779296875 + ], + [ + 160.95600000000002, + 401.04998779296875 + ] + ] + }, + { + "title": "False Statement by Richard Barnett, an Agent of Epstein", + "heading_level": null, + "page_id": 3, + "polygon": [ + [ + 142.596, + 632.61 + ], + [ + 471.95550537109375, + 632.61 + ], + [ + 471.95550537109375, + 649.6800079345703 + ], + [ + 142.596, + 649.6800079345703 + ] + ] + }, + { + "title": "Epstein's Pattern of Obstruction in Other Similar Civil Suits Against Him", + "heading_level": null, + "page_id": 5, + "polygon": [ + [ + 105.87599999999998, + 165.24 + ], + [ + 524.48681640625, + 165.24 + ], + [ + 524.48681640625, + 180.17999267578125 + ], + [ + 105.87599999999998, + 180.17999267578125 + ] + ] + }, + { + "title": "LEGAL MEMORANUM", + "heading_level": null, + "page_id": 8, + "polygon": [ + [ + 258.876, + 386.37 + ], + [ + 390.5945129394531, + 386.37 + ], + [ + 390.5945129394531, + 401.04998779296875 + ], + [ + 258.876, + 401.04998779296875 + ] + ] + }, + { + "title": "I. 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KRISCHER, ESQUIRE +State Attorney +401 North Dixie Highway +West Palm Beach, Florida 33401 +By: LANNA BELOHLAVEK, ESQUIRE +Assistant State Attorney + +ON BEHALF OF THE DEFENDANT: +ATTERBURY, GOLDBERGER & WEISS, P.A. +250 Australian Avenue South +Suite 1400 +West Palm Beach, Florida 33401 +By: JACK GOLDBERGER, ESQUIRE + +ORIGINAL + +June 30, 2008 +Palm Beach County Courthouse +West Palm Beach, Florida 33401 +Beginning at 8:40 o'clock, a.m. + +• + +BE IT REMEMBERED that the following proceedings were had in the above-entitled cause before the HONORABLE DEBORAH DALE PUCILLO, one of the judges of the aforesaid court, at the Palm Beach County Courthouse, located in the City of West Palm Beach, State of Florida on June 20, 2008 beginning at 8:40 o'clock, a.m. with appearances as hereinbefore noted, to wit: + +THEREUPON: + +MR. GOLDBERGER: Good morning, Judge, Jack Goldberger on behalf of Jeffrey Epstein. + +THE COURT: Good morning. + +MR. GOLDBERGER: Your Honor, we are here for aplea conference. + +THE COURT: Raise your right hand. + +THEREUPON: + +JEFFREY EPSTEIN, after being called as awitness by the Defense and after being first duly sworn by the Court, was examined and testified as follows: + +THE DEFENDANT: Yes, + +THE COURT: Is this one case or two? + +MS. BELOHLAVEK: Two. + +THE COURT: May I see the PC + +affidavit in both cases, please? + +MS. BELOHLAVEK: There are no PC + +affidavits. There was originally an + +Indictment, the second charge was filed + +. arising out of the booking. It was all + +testimony presented to the grand jury. + +THE COURT: Let me see the Indictment + +then? + +I have one Indictment, one + +Information? + +MS. BELOHLAVEK: Correct. + +THE COURT: So one case is charged by + +Indictment, one is charged by Information? + +MS. BELOHLAVEK: Correct. + +THE COURT: In case 2006036744 you + +are charged with procuring aperson under + +18 for prostitution, a second degree + +felony, maximum penalty of fifteen years + +Department of Corrections; minimum, some + +period of probation. No mandatory minimum + +apply, is that correct, State? + +MS. BELOHLAVEK: Correct. + +THE COURT: And in case number 06 + +9454CF, you are charged with felony + +solicitation to prostitution, a third + +a + +1 degree felony, punishable by a maximum 2 penalty of five years in the Department of 3 Corrections, and a minimum, probation. No 4 mandatory minimums, correct? + +5 MS. BELOHLAVEK: Correct. + +6 THE COURT: The defendant has no 7 prior criminal record? + +8 MS. BELOHLAVEK: Correct. + +9 MR. GOLDBERGER: Yes, Your Honor. + +10 THE COURT: You checked the NCIC as 11 well as State records? + +12 MS. BELOHLAVEK: Yes. + +13 THE COURT: And the guideline score 14 sheet I have before me shows 21.5 months in 15 the Department of Corrections as the lowest 16 permissible prison sentence in months. + +17 Both sides agree to the preparation of the 18 guideline score sheet? + +19 MR. GOLDBERGER: We so agree, Your 20 Honor. + +21 MS. BELOHLAVEK: Yes. + +22 THE COURT: What is proposed -- it 23 goes on for pages. + +24 MR. GOLDBERGER: Your Honor, much of 25 the documentation is acknowledgement by my + +1 client to community control, sex offender +2 status. + +3 THE COURT: I understand. + +4 Okay. What is proposed -- those +5 are the maximums and minimums, Mr. Epstein. +6 What is proposed is that you will be +7 pleading guilty to felony solicitation to +8 prostitution and procuring a person under +9 18 for prosecution. A PSI would be waived, +10 you would be adjudicated guilty of both +11 felonies, is that correct? + +12 MS. BELOHLAVEK: Correct. + +13 THE COURT: And on 06 9454, the +14 defendant to be sentenced to 12-months in +15 the Palm Beach County -- detention +16 facility? He's going to do time in the +17 jail? + +18 MS. BELOHLAVEK: Yes. + +19 THE COURT: With credit for one day +20 served. And on 08 9381, he is to be +21 sentenced to six months in the Palm Beach +22 County jail detention facility, with credit +23 for one day served. And the six month +24 sentence is to be served consecutive to the +25 12 month sentence? + +1 MS. BELOHLAVEK: Correct. + +2 THE COURT: Following the six months 3 sentence, the defendant will be placed on 4 12-months of community control one. The 5 conditions of the community control are 6 attached hereto and incorporated herein. + +7 As a special condition of 8 community control, he's to have no 9 unsupervised contact with minors and the 10 supervising adult must be approved -- and I 11 would say, pre-approved, approved ahead of 12 time, not after the fact by the Department 13 of Corrections. And you would mean by that 14 his community control officer? + +15 MS. BELOHLAVEK: Correct. + +16 THE COURT: The defendant is 17 designated as a sexual offender pursuant to 18 Florida Statute 943.0435 and must abide by 19 all the corresponding requirements of the 20 statute, a copy of which is attached hereto 21 and incorporated herein. The defendant 22 must provide a DNA sample in court at the 23 time of this plea. Is this the -- and the 24 attachments are the terms and conditions of 25 community control. There are some + +squiggles on the bottom of the page, what would those squiggles be? + +MR. GOLDBERGER: Thank you, Your Honor, those are my client's signature acknowledging that we have gone over all the conditions. + +THE COURT: One page after the plea sheet that really spells out the terms and conditions of community control, Florida Statute 948.101, Mr. Epstein, is that squiggle at the bottom your squiggle? + +THE DEFENDANT: Yes, + +THE COURT: Would those be your initials? + +THE DEFENDANT: Yes, + +THE COURT: Did you read all of that. page? + +THE DEFENDANT: Yes, + +THE COURT: Can you read? + +THE DEFENDANT: Yes, + +THE COURT: How far did you go in school? + +THE DEFENDANT: High school. + +THE COURT: That's your highest degree? + +r + +1 THE DEFENDANT: Yes. + +2 THE COURT: And is this your 3 signature on the plea sheet that recites 4 the terms of the plea I just read? + +5 THE DEFENDANT: Yes, + +6 THE COURT: Did you read that 7 document as well? + +8 THE DEFENDANT: Yes, + +9 THE COURT: You understand once you 10 do your 12 months followed by your six 11 months all in the Palm Beach County jail 12 you will then be put on community control 13 which involves having an electronic monitor 14 attached to you and -- + +15 MR. GOLDBERGER: Actually Your Honor, 16 the agreement of the parties is to, it's 17 community control one which is not monitor. + +18 THE COURT: community control 19 one, is that spelled out in here? + +20 MS. BELOHLAVEK: Yes. + +21 MR. GOLDBERGER: Yes, it is, Your 22 Honor. + +23 MS. BELOHLAVEK: He does not fall 24 under the Jessica Lunsford Act which 25 requires the bracelet. + +1 + +THE COURT: Community control two. + +2 + +MS. BELOHLAVEK: Correct, + +3 + +THE COURT: Community control one -- +that would be no electronic monitor? + +5 + +MR. GOLDBERGER: That is correct. + +6 + +THE COURT: Now which of the terms +and conditions of community control one are +you incorporating? + +8 + +9 +MR. GOLDBERGER: I can go through +them with Your Honor. + +10 + +11 +THE COURT: None of the them appear +to be articulated in the plea sheet which +is why I'm asking. + +12 + +13 +14 +MR. GOLDBERGER: These are the +15 +standard conditions of community control by +16 +statute would apply to anyone that goes on +17 +community control and out of an abundance +18 +of caution, we simply memorialized those +19 +standard conditions in the plea sheet +20 +agreement. + +21 + +22 +THE COURT: The Court shall require +23 +intensive supervision and surveillance for +24 +an offender placed on community control +which may include but is not limited to +25 +specified contact with the parole and + +• + +1 probation officer, specified by who? + +2 PROBATION OFFICER: Specified by you, 3 Your Honor. + +4 THE COURT: I don't see that in the 5 plea sheet. That's why I'm asking the 6 questions. No one has specified how often, 7 how frequently he is to have contact with 8 his parole and probation officer. 9 Confinement to an agreed upon residence 10 during the hours away from employment and 11 public service activity, has that been 12 articulated? + +13 MS. BELOHLAVEK: I believe 14 Judge McSorley has a standard order 15 somewhere on the bench up there regarding 16 this, I'm told by the prosecutor. + +17 MS. LENHARDT: Judge, usually this is 18 the probation sheet she hands out to folks. + +19 THE COURT: I have seen those 20 sheets -- I have seen them incorporated in 21 plea agreements which is why I'm asking. + +22 MR. GOLDBERGER: I see. + +23 THE COURT: Is there some reason you 24 didn't use this particular document in this 25 case? + +1 MS. BELOHLAVEK: I didn't realize 2 until Ms. Lenhardt just told me that Judge 3 McSorley has that. + +4 MR. GOLDBERGER: We'd be happy to 5 execute that document, Your Honor. We were 6 -- we overreacted by just having him sign 7 off on all conditions of community control. + +8 THE COURT: Well, this is -- + +9 MR. GOLDBERGER: Perhaps the better 10 practice would be -- + +11 THE COURT: This is, the reason 12 Judge McSorley does this which makes 13 ultimate sense is we're going to be here 14 half the morning if we're going to decide 15 among ourselves now what the -- + +16 MR. GOLDBERGER: That makes sense. + +17 THE COURT: I'm not going to leave 18 this just unspecified. + +19 MS. BELOHLAVEK: We can take care of 20 that right now if you could give us a few 21 minutes. + +22 THE COURT: All right. + +23 These are the standard conditions 24 that Judge McSorley normally uses. If you 25 like them, you need to circle the ones that + +apply and everyone must initial them. we + +will go over it. If you wish to change + +you understand there is quite a bit of + +latitude given the court in putting + +somebody on community control. If you + +agree to some change, let me know, but + +understand at the outset that I'm abig fan + +of specificity. Iwant to know what he + +will be doing for employment. I want to + +know exactly where he is going to be living + +and I want it on the record now. It can + +change but it can only change with + +preapproval by DOC. I want it crystal + +clear. I don't want the community control + +officer who gets this case the day he walks + +out the Palm Beach County to have any doubt + +or confusion as to exactly what this + +defendant is supposed to do, where he is + +supposed to be when, exactly what I am + +requesting that officer to supervise. + +MS. BELOHLAVEK: Absolutely. + +THE COURT: Okay. + +MR. GOLDBERGER: We will work on it. + +Thank you, Your Honor. + +THE COURT: We will recall that case. + +1 2 3 4 5 6 7 8 9 10 (Brief recess.) MR. GOLDBERGER: Your Honor, we are back on Jeffrey Epstein, actually it worked, we had an opportunity to go through Judge McSorley's conditions of community control and we asked the Department of Corrections representative to assist us to make sure we did everything properly. They were very helpful and we executed the document. + +11 12 13 14 15 16 MS. BELOHLAVEK: Yes, and Your Honor, this defendant doesn't fall under the sex offender probation but we have included special sex offender conditions as part of the community control and they are all circled there. + +17 18 19 20 THE COURT: The plea agreement stated the defendant is designated as a sexual offender pursuant to Florida Statute 942.035. + +21 22 23 24 MS. BELOHLAVEK: Correct. But the sex offender probation, the statute is different and only applies to certain offenses and this one was not enumerated. + +25 THE COURT: Okay. I want to make + +sure both I and the defendant are clear. + +The sexual offender statute you are + +referring to in the plea sheet is the one + +that requires registration? + +MS. BELOHLAVEK: Correct. + +MR. GOLDBERGER: Correct. + +THE COURT: And we will talk about + +that. + +MR. GOLDBERGER: Okay. + +THE COURT: But it is not the one + +that requires the special conditions of sex + +offender probation? + +MS. BELOHLAVEK: Correct. + +THE COURT: Now, rather than 948, do + +you want me to disregard 948? He's read + +it? + +MS. BELOHLAVEK: He's read it. + +THE COURT: We will leave it in + +there. But these conditions we are going + +to go over right now are going to be viewed + +in my mind, yes, and they have been signed + +by the defendant and we will go over that + +in asecond as apart of the whole plea. + +MS. BELOHLAVEK: Correct. + +THE COURT: So circled are + +0 + +1 conditions, A, you will remain confined to 2 your residence except one half hour before 3 and after your approved employment, 4 community service work or any other 5 activity approved by your probation 6 officer. + +7 B, you will maintain an hourly 8 accounting of all your activities on a 9 daily log which you will submit to your 10 supervising officer upon request. + +11 My understanding about the daily 12 log, maybe I'm just confused from other 13 cases I've heard, is the daily log is a 14 weekly log, I guess it is submitted ahead 15 of time, is that correct? + +16 PROBATION OFFICER: That is correct, 17 Your Honor. + +18 THE COURT: So part A, where he has 19 to stay in his residence except for one 20 hour before and after the approved 21 employment, community service work and 22 other activity. All that's information 23 that will be recorded in writing and the 24 defendant will have a copy and he will know 25 exactly where he is supposed to be when. + +co + +PROBATION OFFICER: That is correct, Your Honor. + +THE COURT: As will his supervising probation officer. And then to document that he's supposedly done all that he himself will be keeping a daily log? + +PROBATION OFFICER: That is correct, Your Honor. + +THE COURT: And the log form will be provided by the department and he will be turning that in every time he meets with the probation officer? + +PROBATION OFFICER: That is correct, Your Honor. + +THE COURT: Okay. So that applies and F applies. Does E apply? No. + +MS. BELOHLAVEK: Did I circle E? + +THE COURT: No. F -- made one up, the defendant will be residing at 358 El Brillo Way, Palm Beach, Florida, 33480. He knows now that that's where he will be living when he is released after his 12 months and six months. + +MR. GOLDBERGER: That is correct, Your Honor. + +1 + +THE COURT: That's a private +residence? + +3 + +MR. GOLDBERGER: That is his home. + +4 + +THE COURT: Does he own the +residence? + +5 + +6 + +MR. GOLDBERGER: He does, Your Honor. + +7 + +THE COURT: Is there any possibility +that he no longer owns the residence? + +8 + +9 + +MR. GOLDBERGER: Not anticipated, +Your Honor. + +10 + +11 + +THE COURT: Okay. Should he not be +for whatever reason -- 18-months is a long +time, should he not be owning that +residence or able to reside there, he will +have the obligation of notifying his +probation officer prior, and I emphasize +this, prior to his release from custody. I +assume that the department will be notified +prior to, to his release? + +18 + +19 + +20 + +PROBATION OFFICER: That is correct, +Your Honor. + +21 + +22 + +THE COURT: And then you would need +to send someone to meet with him before he +walks out of the Palm Beach County jail and +verify his address and employment + +23 + +25 + +a + +information? + +PROBATION OFFICER: That is correct. + +THE COURT: All address -- I assume all of this to and from work and any other approved activities restricts him to Palm Beach County, is that correct? + +PROBATION OFFICER: That is correct, Your Honor. + +THE COURT: So let's be clear, everything, from the day he walks out occurs in Palm Beach County, is that clear? + +MR. GOLDBERGER: We understand, Your Honor. That's correct. + +THE COURT: Then the additional condition of his probation, they are not sex offender standard conditions, they are just conditions that are being imposed especially in this case? + +MS. BELOHLAVEK: Correct. + +THE COURT: They are as follows, you shall submit to amandatory curfew from 10 p.m. to 6:00 a.m. regardless of any other restrictions regarding work or approved activity, there will be no exceptions to being at home in house from 10 p.m. to 6 + +a.m., is that correct? + +MS. BELOHLAVEK: Yes. + +THE COURT: If the victim was under age of 18 years which I gather is the case because it's circled, you shall not live within 1000 feet of aschool, day care center, park, playground or other place where children regularly congregate. + +Has someone verified that 358 El Brillo is such aplace? + +MS. BELOHLAVEK: No, but that will be done prior to his release. + +THE COURT: So 358 El Brillo will not be approved if it should happen to be one thousand feet from aschool, day care center, park, playground or other place this is rather open. + +MR. GOLDBERGER: Where children gather. + +THE COURT: Where children regularly congregate. + +MS. BELOHLAVEK: Right. + +THE COURT: The Court knows 358 El Brillo Way is aresidential neighborhood, are there areas there where children + +a • + +regularly congregate? + +MS. BELOHLAVEK: I personally do not know. + +THE COURT: Neither do I, which is why I'm asking. Has that been investigated? + + MR. GOLDBERGER: We have done our due diligence, for what it's worth, there is a residential street. There are not children congregating on that street. We think the address applies, if it doesn't, we fully recognize that he can't live there. + +THE COURT: Okay. D is, you shall not have any contact with the victim, are there more than one victim? + +MS. BELOHLAVEK: There's several. + +THE COURT: Several, all of the victims. So this should be plural. I'm making that plural. You are not to have any contact direct or indirect, and in this day and age I find it necessary to go over exactly what we mean by indirect. By indirect, we mean no text messages, no e-mail, no Face Book, no My Space, no telephone calls, no voice mails, no + +• + +messages through carrier pigeon, no + +messages through third parties, no hey + +would you tell so and so for me, no having + +afriend, acquaintance or stranger approach + +any of these victims with amessage of any + +sort from you, is that clear? + +THE DEFENDANT: Yes, II= + +THE COURT: And then it states, + +unless approved by the victim, the + +therapist and the sentencing court. Okay. + +THE DEFENDANT: I understand. + +THE COURT: And the sentencing court. + +So, if there is adesire which, I would + +think would be abit strange to have + +contact with any of the victims the court + +must approve it. + +MS. BELOHLAVEK: Correct. + +THE COURT: If the victim was under + +the age of 18, which was the case, you + +shall not until you have successfully + +attended and completed the sex offender + +program. So, is this sex offender program + +becoming a condition of probation? + +MS. BELOHLAVEK: That is not. I + +don't believe I circled that one. + +THE COURT: You did. + +MR. GOLDBERGER: That's amistake on our part. Actually the statute that he is pleading guilty to does not require the -- + +THE COURT: I understand that, but you circled it. + +MS. BELOHLAVEK: I apologize, that one is not. He has already been in treatment with aprivate psychiatrist. + +THE COURT: Which you find to be an adequate substitute for sex offender program? + +MS. BELOHLAVEK: I -- it is not required and based upon the evaluation and my contact with that doctor, I don't believe it's necessary at this point. + +THE COURT: Has that been -- I assume you have alaw degree and do not have a Ph.D in apsychology or MD in psychiatry? + +MS. BELOHLAVEK: That is correct, I don't. + +THE COURT: So it is just your judgement -- + +MS. BELOHLAVEK: Correct. + +THE COURT: -- that his treatment + +• + +• + +1 with some fancy private psychiatrist or psychologist in his case is okay? + +MS. BELOHLAVEK: That is correct. + +THE COURT: So you are not imposing E? + +MS. BELOHLAVEK: Correct. + +THE COURT: F, if the victim was under the age of 18, you shall not work or play or as avolunteer in any school, day care center, park, play ground or other place where children regularly congregate, is that understood? + +THE DEFENDANT: Yes, mil. + +THE COURT: Children will be defined as anyone under the age of 18. There are a lot of places where children regularly congregate. What kind of work do you do? + +THE DEFENDANT: Banking. + +THE COURT: Here in Palm Beach County? + +THE DEFENDANT: Virgin Islands, + +THE COURT: You understand you will not travel from Palm Beach County for the duration of this? + +THE DEFENDANT: Yes, [REDACTED]. + +MR. GOLDBERGER: Your Honor, I'm +sorry to interrupt, we do cover the +employment later in the agreement as to +what he is going to be doing during the one +year that he is on community control. + +THE COURT: Okay. And let me -- +condition G, which is circled, unless +otherwise indicated in the treatment plan +provided by sexual offender treatment +program. + +MR. GOLDBERGER: That's not in there. + +THE COURT: Is that what you want? + +MS. BELOHLAVEK: No. + +THE COURT: But you do want the, you +will not view, own or possess any obscene +pornographic -- + +MS. BELOHLAVEK: Correct. + +THE COURT: Okay. But are you saying +that this therapist can okay him to own +certain pornographic material? + +MS. BELOHLAVEK: No, not at all. + +MR. GOLDBERGER: No, Your Honor. + +THE COURT: Would be really helpful +if people read these things before they + +- 1 +- 2 +- 3 +- 4 +- 5 +- 6 +- 7 +- 8 +- 9 +- 10 +- 11 +- 12 +- 13 +- 14 +- 15 +- 16 +- 17 +- 18 +- 19 +- 20 +- 21 +- 22 +- 23 +- 24 +- 25 + +signed them thoroughly. + +Unless otherwise indicated in the treatment plan. I'm just going to strike out, provided by the sexual offender treatment program. Is that what you intend, that his therapist can -- + +MS. BELOHLAVEK: No. + +THE COURT: No? + +MS. BELOHLAVEK: No. + +THE COURT: Unless otherwise indicated. + +MR. GOLDBERGER: The parties have agreed that during the period that he is -- cannot be -- + +THE COURT: Condition G will now read, you shall not view, own, possess any obscene, pornographic or sexually stimulating visual or auditory material including telephonic, electronic media, computer program or computer services that are relevant to your deviant behavior pattern. And who is going to enforce that? + +MS. BELOHLAVEK: The community control officer. + +THE COURT: How? + +MS. BELOHLAVEK: They have the obligation and included in there for warrantless search to check at any time his home, his computer, anything he has contact with. + +THE COURT: And do they regularly do that? + +PROBATION OFFICER: Yes, ██████████. + +THE COURT: Since we have the pleasure of having someone from the Department of Corrections here. + +Okay. H, you shall submit two specimens of blood to the Florida Department of Law Enforcement to be registered in the DNA data bank. + +J, you shall submit to a warrantless search by your probation officer or community control officer of your person, residence or vehicle. + +G -- where is the G? + +MS. BELOHLAVEK: That was under the original part, not under the sex offender one. + +THE COURT: Okay. Defendant to have contact with the community control officer + +at a minimum one time a week. + +Defendant to work at Florida +Science Foundation, 250 Australian Avenue, +West Palm Beach, Florida. Is that +volunteer work or work for pay? + +MR. GOLDBERGER: It is a 501C +corporation that he has formed, Your Honor, +that will be doing charitable work. + +THE COURT: That he has formed? + +MR. GOLDBERGER: Yes. + +THE COURT: What exactly is Florida +Science Foundation? + +MR. GOLDBERGER: Do you want to +explain? + +THE DEFENDANT: It funds science +programs around the state and the country. + +THE COURT: How long has it been in +existence? + +THE DEFENDANT: Fifteen years. + +THE COURT: How many programs has it +funded? + +THE DEFENDANT: Numerous, more than +50. + +THE COURT: What is your position +with the organization? + + THE DEFENDANT: President. + + THE COURT: Is there aboard of directors? + + THE DEFENDANT: Yes, INS + + THE COURT: Who's on the board of directors? + + THE DEFENDANT: Two attorneys. + +THE COURT: What exactly do you do? + + to THE DEFENDANT: I'm an investment banker but my -- + + THE COURT: No, no, I mean with the science foundation. + +THE DEFENDANT: We fund science programs -- + +THE COURT: I don't want to know what we do, I want to know what you do. How often are you there? + +THE DEFENDANT: I'm there every day, I research, I take in people who want to make presentations about why they need money for funding medical research, advanced science research. My background is in physics. I go through all the programs in detail, review the science work potentials, I follow through on adaily + +1 + +basis with what they have been given money +to do. + +2 + +THE COURT: Who are some recent +grantees? + +3 + +4 + +THE DEFENDANT: Harvard University. + +5 + +There is a full program of Evolutionary +Dynamics, Neuro Science Institute of +California, the Physics Institute, MIT. + +6 + +7 + +California, the Physics Institute, MIT. + +8 + +9 + +THE COURT: Do you ever have occasion +to deal with anyone under the age of +10 +11 +eighteen? + +THE DEFENDANT: Not very often. It +12 +13 +is, if someone is in college -- sorry. + +13 + +THE COURT: Right, that's why I'm +15 +asking the question. + +THE DEFENDANT: Most of the people I +16 +17 +fund are all usually professors. + +THE COURT: Thank you. You +18 +19 +understand that you can't have contact with +20 +anyone if -- this organization, do they +21 +ever have any involvement with high +22 +schools? + +THE DEFENDANT: No, [REDACTED]. + +THE COURT: Students or teachers? + +THE DEFENDANT: No, [REDACTED]. + +1 + +THE COURT: Okay. + +2 + +MS. BELOHLAVEK: Those are + +3 + +duplicates, you will see those are the same +as the ones on the previous page, however, +it was reproduced. + +4 + +5 + +THE COURT: The next condition, you + +6 + +shall maintain a driving log. You shall + +7 + +not drive a motor vehicle while alone + +8 + +without prior approval of your supervising +officer. + +10 + +11 + +If there was sexual contact, you + +12 + +shall submit to at probationer's or + +13 + +community controllee's expense an HIV test + +14 + +with results to be released to the victims, + +15 + +victim's parent or guardian -- will be + +16 + +victims, plural. Has that been done? + +17 + +MR. GOLDBERGER: Not yet. + +18 + +THE COURT: Do we have a time frame + +19 + +on that? I would think ASAP might be good + +20 + +on something like that. + +21 + +MS. BELOHLAVEK: I believe they can + +22 + +actually do that at the jail. + +23 + +THE COURT: At his expense? + +24 + +MS. 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08-CV-80380-MARRA, + +JANE DOE NO. 5, CASE NO.: 08-CV-80381-MARRAME + +VS. + +JEFFREY EPSTEIN, + +Defendant + +JANE DOE NO. 6, + +Plaintiff, + +vs. + +JEFFREY EPSTEIN, + +Defendant. + +CASE NO.: 08-CV-80994-MARRAMS + +JANE DOE NO. 7, CASE NO.: 08-CV-80993-MARRAMII/ + +PlaintifZ + +vs. + +JEFFREY EPSTEIN, + +Defendant. + +C.M.A., CASE NO.: 08-CV-Wall-MARRA/NM + +Plaintiff, + +vs. + +JEFFREY EPSTEIN, + +Defendant. + +JANE DOE, CASE NO.: 08-CV80893-MARIWJOIINSON + +Plaintiff, + +vs. + +JEFFREY EPSTEIN, + +Defendant. + +JANE DOE NO. II, CASE NO.: 08-CV-80469-MARRAIMMI + +Plaintiff. + +vs. + +JEFFREY EPSTEIN, + +Defendant. + +JANE DOE NO. 101, CASE NO.: 09-CV-80591-MARla + +Plaintiff; + +vs. + +JEFFREY EPSTEIN, + +Defendant. + +JANE DOE NO. 102, CASE NO.: 09-CV-80656-MARRAMMI + +Plaintiff, + +vs. + +JEFFREY EPSTEIN, + +Defendant. + +### PLAINTIFFS JANE DOE NO. 101 and JANE DOE NO. 102'S MOTION FOR NO-CONTACT ORDER + +Plaintiffs, Jane Doe No. 101 and Jane Doe No. 102 (together, the "Plaintiffs") hereby move this Court for aNo-Contact Order directed to Defendant, Jeffrey Epstein, and, as grounds, state as follows: + +1. After investigations by the Palm Beach Police Department, the Palm Beach Stale Attorney's Office, the Federal Bureau of Investigation, and the United States Attorney's Office for the Southern District of Florida (the "USAO"), Defendant, Jeffrey Epstein, in June 2008, entered pleas of "guilty" in the Fifteenth Judicial Circuit in Palm Beach Count, Florida, to various Florida state crimes involving the solicitation of minors for prostitution and the procurement of minors for the purposes of prostitution. + +2. During the course of Defendant's state plea conference of June 30, 2008, Palm Beach Circuit Court Judge Deborah Dale Pucillo ordered Defendant "not to have any contact, direct or indirect" with any victims. (Transcript of the Plea Conference at 20, relevant pages attached hereto as Exhibit A). Judge Dale Pucillo went on to clarify that, by "indirect," she meant that Defendant should not send any text messages, e-mails, Facebook contact, My Space contact, telephone calls, voicemaits, or messages through third parties to "any of these victims." Id. Judge Dale Pucillo expressly stated that the no-contact order should apply to "all of the victims." Id. + +3. In addition, after Defendant entered into anon-prosecution agreement with the USAO, Assistant United States Attorney Villafafia provided Defendant's attorneys with a list of individuals whom the USAO had identified as victims of child sex exploitation as defined in 18 U.S.C. § 2255 (the "USAO List"). The USAO was prepared to indict Defendant based upon Defendant's sexual exploitation of these minor victims. It was the intent of the USAO to place these identified victims in the same position as they would have been had Defendant been + +convicted at trial. Thus, upon information and belief, AUSA Villafana and Mr. Michael Tein, former counsel for Defendant, along with Mr. Jack Goldberger, who still represents Defendant, entered into a verbal agreement at the time AUSA Villafafta provided the USAO List to them, whereby neither Defendant, Jeffrey Epstein, nor his agents would have any direct or indirect contact with the victims named on the USAO List. + +4. Nevertheless, during a March 25th meeting with Defendant's counsel, Defendant's counsel told Plaintiffs' counsel that it is Defendant's position that the no-contact order agreed to during the state plea conference does not apply to anyone other than those three victims who were officially part of Defendant's state plea. + +5. Upon Plaintiffs' counsel seeking reassurance from Defendant's counsel that neither Defendant nor his agents would contact victims on the USAO List, Defendant's counsel responded that Defendant, Jeffrey Epstein, would not contact any of undersigned counsel's clients as long as Mr. Josefsberg was representing them in connection with settlement discussions. + +6. As a result, on April 17, 2009, Plaintiffs' counsel sent defense counsel aletter requesting that Defendant provide written confirmation that neither he nor his agents will directly or indirectly contact any of the victims represented by Plaintiffs' counsel (the "No-Contact Letter") (April 17, 2009 Letter attached hereto as Exhibit B). On May 18, 2009, Plaintiffs' counsel again requested this written confirmation (E-mail correspondence attached hereto as Exhibit C). Despite Plaintiffs' reasonable requests, Defendant's counsel first responded by stating that the Non-Prosecution Agreement does not prevent some font of contact with undersigned counsel's clients. (Redacted May 18, 2009 letter from Mr. Robert Critton is attached hereto as Exhibit D). Defendant's counsel then sent aletter on May 21, 2009 citing the Comment to Rule 4-4.2 of the Rules of Professional Conduct that states that "fplarties to a matter + +may communicate directly with each other." (Redacted May 21, 2009 Letter from Mr. Critton is attached hereto as Exhibit E). Thus, despite Mr. Critton's statement that it is not Defendant's intention to have direct contact with undersigned counsel's clients, Defendant obviously believes he can change his intentions if he so chooses. + +7. Defendant, Jeffrey Epstein, is adesignated sexual offender who sexually abused Jane Doe No. 101 and Jane Doe No. 102 when the victims were minors. As aresult of his abuse, Plaintiffs have in the past suffered, now suffer, and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of selfesteem, loss of dignity, and invasion of their privacy. Any further direct or indirect contact with Defendant and/or his agents would cause agreat deal of additional damages. Moreover, any desire or need on the part of Defendant to contact these victims---implied by virtue of his refusal to unambiguously confirm that he will not contact them—is disturbing and suspect, at best. At a minimum, Defendant's refusal to avoid contact works as aploy to attempt to keep Plaintiffs in "victim mode." + +WHEREFORE, Plaintiff respectfully requests this Court to enter an order prohibiting Defendant, Jeffrey Epstein, and any of his agents from any direct or indirect contact with Plaintiffs, except through Plaintiffs' attorney of record through the duration of this Court's order. + +### Memorandum In Support + +As previously stated, during the course of Defendant's state plea conference of June 30, 2008, Palm Beach Circuit Court Judge Deborah Dale Pacific, ordered Defendant "not to have any contact, direct or indirect" with any of Defendant's victims. However, for what could only be dubious purposes, Defendant seeks to take advantage of the fact that only three of Defendant's numerous victims were officially a part of the State of Florida's criminal prosecution of + +Defendant and that he entered into anon-prosecution agreement with the USAO. Thus, despil the no-contact order being considered astandard condition of probation or community contr( for sex offenders such as Defendant, and despite his counsel having agreed to a no-contact ordc with AUSA Villafaiia for all of Defendant's victims on the USA° List, Defendant is now takin. the position that neither Judge Dale Pucillo's no-contact order nor his agreement with the USA( via his counsel restricts him from contacting any of the victims except for the three victim directly involved in the state plea. Because of the non-prosecution agreement, there is no federa conviction against Defendant with respect to Plaintiffs and other victims on the USAO List Mu are similarly situated and, thus, no accompanying sentencing court to issue ano-contact order However, each of the victims on the USAO List is supposed to be in the same position as Defendant bad been convicted in federal court. In crimes involving victims, at the time of sentencing, a sentencing judge generally has wide discretion to order that the defendant have ne contact with the victim or victims of the crime or crimes for which the defendant is being sentenced. Where the defendant is given a sentence of probation or community control, the nocontact order can be made acondition of the defendant's supervision. The case for judicial intervention is heightened in cases such as this one, where Defendant has sexually exploited numerous minors. Jane Doe No. 101 and Jane Doe No. 102, like alt of the other young women on the USAO List, were sexually abused by Defendant; any further direct contact with Defendant and/or his agents would cause agreat deal of additional damages. Previous contact by Defendant and his agents with other victims has bad aterrible effect on the young women's ability to heal the scars of Defendant's abuse. Additionally, Defendant's contacting his victims also has the predictable effect of undermining the victims' willingness to proceed with their civil actions against Defendant. Defendant's demonstrated use of his wealth, power, and influence has the immediate effect of intimidating young women who have already been traumatized by + +his sexual exploitation. Indeed, any desire or need on the part of Defendant to contact his victims, implied by virtue of his refusal to confirm that he will not contact them directly or indirectly, is disturbing and suspect, at best. Plaintiffs thus ask this Court to provide the protection and peace of mind that each of them needs. + +WHEREFORE, Plaintiffs respectfully move this Court to enter an order granting Plaintiffs' Motion for No-Contact Order prohibiting Defendant, Jeffrey Epstein, from any contact or communication with Plaintiffs Jane Doc No. 101 and Jane Doe No. 102, either directly or indirectly, except through Plaintiffs' attorney of record for the duration of the order. + +## CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.I.A.3 + +On May 18, 2009, undersigned counsel conferred with counsel for Defendant in agood faith effort to resolve the issues raised in this motion, and Defendant's counsel advised that Defendant opposes this motion. + +Date: May 22, 2009 + +/s/Rabert C. Josersi:erg + +Robert C. Josefsberg, Bar No. 040856 Katherine W. Ezell, Bar No. 114771 Podhurst Orseck, P.A. City National Bank Building 25West Flagler Street, Suite 800 Miami, Florida 33130 (305) 358-2800 (305) 358-2382 (fax) riosefsberaRoodhurst.com kezell(aModhurst.com + +Attorneys for Plaintiffs Jane Doe No. 101 and Jane Doe No. 102 + +### Certificate of Service + +Ihereby certify that, on May 22, 2009, I electronically filed the foregoing document with the Clerk of the Coen using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of record identified 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 counsel or parties who are not authorized to receive electronically Notices of Electronic Filing. + +Is/ Robert Josefsberx + +Ruben C. Josefsberg, Bar No. 040856 + +Katherine W. Ezell, Bar No. 114771 + +Podhurst Orseck, P.A. + +City National flank Building + +25 West Flagler Street, Suite 800 + +Miami, Florida 33130 + +(305) 358-2800 + +(305) 358-2382 (fax) + +ijosefsbera@podhurst.com + +kezelltetyclhurst.com + +Attorneys for Plaintiffs Jane Doe No. 101 + +and Jane Doe No. 102 + +#### SERVICE LIST + +JANE DOE NO. 2 v. JEFFREY EPSTEIN Case No. 08-CV-80119-MAltRA/JOHNSON United States District Court, Southern District of Florida + +Robert Critton, Esq. Michael I. Pike, Esq. Burman, Critton, Luther & Coleman LLP 515 North Flagler Drive, Suite 400 West Palm Beach, FL 33401 Phone: (561) 842-2820 Fax: (561) 515-3148 reritabolclanoin LapikeQbelclaw.cont Counsel for Defendant, Jeffrey Epstein + +Jack Goldberger, Esq. Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 Phone: (561) 6594300 Fax: (561) 835-8691 jagestAbellsouth.net Co-Counsel for Defendant, Jeffrey Epstein + +Bruce E. Reinhart, Esq. Bruce E. Reinhart, PA. 250 South Australian Avenue, Suite 1400 West Palm Beach, FL 33401 Phone: (561) 202-6360 Fax: (561) 828-0983 ecfabrucereinhattlaw.com Counsel for Co-Defendant, + +Jack Scarola, Esq. Jack P.M, Esq. Seamy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: (561) 686-6300 Fax: (561) 383-9456 hattearcvlaw.com ivhe4searcvlaw.com Counsel for Plaintiff CM.A. + +Adam Horowitz, Esq. Stuart Mermelstein, Esq. Mermelstein & Horowitz, P.A. 18205 Biscayne Blvd., Suite 2218 Miami, FL 33160 Phone: (305) 931-2200 Fax: (305) 931-0877 ahorowitzlasexabuscattomev.com smermelsteinotexabuseattornev.com Counsel for Plaintiffs in Related Cases Nos. 0840069, 08-80119.0840232, 08-80380, 08- 80381, 08-80993, 08-80994 + +Spencer Todd Kuvin, Esq. Theodore Jon Leopold, Esq. Leopold Kuvin, P.A. 2925 PGA Boulevard, Suite 200 Palm Beach Gardens, FL 33410 Phone: (561) 515-1400 Fax: (561) 515-1401 skuvinailleopoldkuvin.com deovoldOleopoldkuvin.com Counsel for Plaintiff in Related Case No. 08-08804 + +Richard Willits, Esq. Richard H. Willits, P.A. 2290 10th Ave North, Suite 404 Lake Worth, FL 33461 Phone: (561) 582-7600 Fax: (561) 588.8819 lawverwillits(alaol.coni reelritwOhotmaiLcom Counsel for Plaintiff in Related Case No. 08-80811 + +Brad Esq. Law Office of Brad & Associates, LLC 2028 Street, Suite 202 Hollywood, FL 33020 Phone: (954) 414-8033 Fax: (954) 924-1530 bedwarclsarra-law.com beailbradedwanislaw.coui Counsellor Plaintiff in Related Case No. 08-80893 Isidro Manuel Esq. + +Elkins & Boehringer + +224 Datum Avenue, Suite 900 + +West Palm Beach, FL 33401 + +Phone: (561) 832-8033 + +Fax: (561) 832-7137 + +isidrogarcia(bellsouth.net + +Counsel for Plaintiff in Related Case No. 08-80469 + +# EXHIBIT A + +to + +Plaintiffs Jane Doe 101 and Jane Doe 102's + +Motion for No-Contact Order + +1 2 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CRIMINAL DIVISION + +3 + +4 6 7 8 STATE OF FLORIDA ) vs ) CASE NO. 06 CF9454AMB ) 089381CFAMB JEFFREY EPSTEIN Defendant. ) + +9 + +• PLEA CONFERENCE + +10 + +11PRESIDING: HONORABLE DEBORAH DALE PUCILLO + +12 APPEARANCES: + +ON BEHALF OF THE STATE: BARRY E. KRISCHER, ESQUIRE State Attorney North Dixie Highway West Palm Beach, Florida 33401 By: LANNA BELOHLAVEK, ESQUIRE Assistant State Attorney + +17 ON BEHALF OF THE DEFENDANT: ATTERBURY, GOLDBERGER & WEISS,P.A. 18250 Australian Avenue South Suite 1400 19West Palm Beach, Florida 33401 By: JACK GOLDBERGER, ESQUIRE + +20 + +21 + +22 + +23 + +June 30, 2008 24Palm Beach County Courthouse West Palm Beach, Florida 33401 25Beginning at 8:40 o'clock, a.m. + +CERTIFIED COPY + +regularly congregate? + +MS. BELOHLAVEK: I personally do not know. + +THE COURT: Neither do I, which is why L'm asking. Has that been investigated? + +MR. GOLDBERGER: We have done our due diligence, for what it's worth, there is a residential street. There are not children congregating on that street. We think the address applies, if it doesn't, we fully recognize that he can't live there. + +THE COURT: Okay. D is, you shall not have any contact with the victim, are there more than one victim? + +MS. BELOHLAVEK: There's several. + +THE COURT: Several, all of the victims. So this should be plural. I'm making that plural. You are not to have any contact direct or indirect, and in this day and age I find it necessary to go over exactly what we mean by indirect. By indirect, we mean no text messages, no ezmail, no Face Book, no My Space, no telephone calls, no voice mails, no + +1 2 3 4 5 6 messages messages would you afriend, through carrier pigeon, no through third parties, no hey tell so and so for me, no having acquaintance or stranger approach any of these victims with amessage of any sort from you, is that clear? + +8 9 10 THE COURT: And then it states, unless approved by the victim, the therapist and the sentencing court. Okay. + +11 THE DEFENDANT: I understand. + +12 13 14 15 16 THE COURT: And the sentencing court. So, if there is adesire which, I would think would be abit strange to have contact with any of the victims the court must approve it. + +17 MS. BELOHLAVEK: Correct. + +18 19 20 21 22 23 THE COURT: If the the age of 18, which was shall not until you have attended program. becoming victim was under the Case, you successfully and completed the sex offender So, is this sex offender program acondition of probation? + +24 25 don't MS. BELOHLAVEK: That is not. I believe I circled that one. + +THE DEFENDANT: Yes, + +# EXHIBIT B + +to + +Plaintiffs Jane Doe 101 and Jane Doc 102's Motion for No-Contact Order + +# Podhurst Orseck TRIAL dr APPELLATE LAWYERS + +Aaron S. Podhurst RobertSasefsberg Joel D Steven C Maria Victor MM., Jr. Katherine W. Ezell Stephen R Rosenthal Ricardo M -04 Ramon A. Rasco Alexander T. Rtmdlet John Oravante, M Carolina Maharbiz + +April 17, 2009 + +## VIA FACSIMILE + +David Spicer, Esq. 11000 Prosperity Farms Road Suite 104 Palm Beach Gardens, FL 33410 + +Robert Critton, Esq. Burman, Critton, Luther & Coleman LLP 515 North Flagler Drive, Suite 400 West Palm Beach, FL 33401 + +Jack Goldberger, Esq. Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 + +Gentlemen: + +Robert Orseric (19341978) + +wafter H. Beckham, Jr. Karen Podhurst Dem Of Counsel + +During our recent meeting with Mr. Black, we were told that it is your client's position that the no-contact order agreed to during the state plea colloquy does not apply to any of our clients except for those victims who were part of Mr. Epstein's state plea. Our understanding is that AUS A Villafana and Messrs. Tein and Goldberger entered a verbal agreement at the time that the list of victims was provided to those defense counsel that Mr. Epstein, including his agents, would have no direct or indirect contact with the victims named on this list. In addiditon, under applicable Florida Bar Rules governing contact by attorneys and their agents with persons represented by counsel, any contact with any of our clients or their family members by Mr. Epstein, his counsel and/or his agents must strictly be through us. Mr. Leficowitz had previously reassured us that Mr. Epstein would not contact any of our clients as long as I am "representing them in connection with settlement discussions." Due to our differences regarding the retroactivity issue and the "per plaintiff' v. per incident/count issue, we have apparently reached a dead end regarding settlement + +We are concerned that Mr. Epstein could misconstrue ow impasse in conjunction with Mr. Lefkowitz' e-mail to mean that now that we are no longer "representing them in connection with settlement discussions," he may contact them. Pleasebe assured that it is our position that regardless of whether we are representing our clients during settlement discussions and/or trial preparation, we, and the rules of professional conduct, prohibit contact. + +In other to be crystal clear as to whom we represent, we have attached a list of our present clients. We expect each member of Mr. Epstein's defense team to abide by the applicable rules of professional conduct. We request written confirmation from Mr. Epstein that neither he nor his agents will contact any of the victims represented by us. + +If this correspondence is in any way unclear, please contact us. + +Sincerely, + +Robert C. 74Jo -t berg + +cc: Roy Black, Esq. w/ enclosures Jay Lefkowitz, Esq. w/ enclosures + +## List of Clients Represented by Podhurst, Orsetk P.A. as of April 17, 2009' + +![](_page_19_Picture_5.jpeg) + +We will wpplement this list as necessary. + +# EXHIBIT C + +to + +Plaintiffs Jane Doe 101 and Jane Doe 102's Motion For No-Contact Order + +### ROBERT C. JOSEFSBERG + +From: ROBERT C. JOSEFSBERG Sent: Monday, May 18, 2009 4:48 PM To: 'rcrit©bcfclaw.comi; jagesg@bellsouth.net Subject: Epstein No Contact Letter Importance: High Attachments: No Contact Letter of April 17.pdf + +Gentlemen: + +On April 17, 2009 we sent your team the attached No Contact Letter. To date, we have not heard back from you or any other members of Mr. Epstein's defense team. If we don't hear back from you by Wednesday, May 20, 2009, we will seek relief in court. It you have any questions, please do not hesitate to contact us. + +Robert C. Josefsberg + +# EXHIBIT D + +to + +Plaintiffs Jane Doe 101 and Jane Doe 102's + +Motion for No-Contact Order + +![](_page_23_Picture_288.jpeg) + +**BURMAN, CRITTON, LUTTIER +& COLEMAN LLP** + +A LIMITED LIABILITY PARTNERSHIP + +J. MICHAEL BURMAN, P.A.1 +GREGORY W. COLEMAN, P.A.1 +ROBBICK D. CRITTON, JR., P.A.1 +BERNARD LEBEDEKER +MARK T. LUTTIER, P.A. +JEFFREY C. PEPPIN +MICHAEL J. PICK +HEATHER MONAMARA RUDA + +1 FLORIDA BOARD CRITERIED +CIVIL TRIAL LAWYER + +ADELQUI J. BENAVENTE +PARALEGAL / INVESTIGATOR + +BARBARA M. McKENNA +ASHLEB STOKEN-BARING +BETTY STOKES +PARALEGALS + +RITA H. BUDNYK +OF COUNSEL + +May 18, 2009 + +Katherine W. Ezell, Esq. +Robert Josefsberg, Esq. +Podhurst Orseck, P.A. +25 West Flagler Street, Suite 800 +Miami, FL 33130 + +Re: [REDACTED] + +Dear Kathy and Bob: + +[REDACTED] + +Additionally, Bob, you wrote a letter on April 17, 2009 stating your position regarding "No Contact" with any of your firm's clients based on your interpretation of the Non-Prosecution Agreement. I do not concede that your position is correct nor that the Non-Prosecution Agreement prevents some forms of contact with your clients. + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +L • A • W • Y • E • R • S + +May 18, 2009 +Page 2 + +[REDACTED] + +Cordially yours, + +![]()RDC/clz + +cc: Jack Goldberger, Esq. + +b7D + +# EXHIBIT E + +to + +Plaintiffs Jane Doe 101 and Jane Doe 102's Motion for No-Contact Order + +1. MICHAEL BURMAN, P.A., GREGORY W. COLEMAN. PA. ROBERT D CRIITON.A. RAJ BERNARD LEBEDEKER MARK T LUTTIBR. PA. JEFFREY C. PEON MICHAEL). PIKE HEATHER IkNAMARA RUDA + +Maim DOARDCOMMSD °VILMA,. LAMM + +![](_page_26_Picture_2.jpeg) + +# BURMAN, CRITTON, LUTTIER & COLEMAN LLP + +ALIMITED LIABILITY PARTNERSHIP + +## Sent by E-Mall and U.S. Mail + +Robert C. Josefsberg, Esq. Katherine Ezell, Esq. Podhurst Orseck, PA. 25West Flagler Street, Suite 800 Miami, FL 33130 + +Dear Bob: + +May 21, 2009 + +ADELQUIJ BENAVENTE PAIIALECIAL I 0NE311OATOR + +BARBARA M. McKENNA ASHUB STOKEN•BARDA3 BETTY STOKES PARALEGALS + +RITA IL BUDNYK CeCotaNa. + +As I advised you yesterday, I am responding to your April 17, 2009 letter. As I stated in my e-mail, I think your request is unnecessary. Despite what Roy may have said to you, my client has had no contact with any of your clients. To my knowledge, the only one who has "breached" any agreement regarding contact Is your own client, awho, as I advised you in a letter last week, contacted Jack Goldberger's her. office looking for her settlement check. Mr. Goldberger, of course, did not speak with + +Professional Lawyers who represent Mr. Epstein are well familiar with the Rules of equally Conduct, including Rule 4-4.2. At the same time, I am certain you are familiar with that Rule. The Comment provides "Parties to a matter may communicate directly with each other...". + +attorneys To who my knowledge, neither Mr. Epstein nor any attorney or agent of those represent Mr. Epstein, have contacted or attempted to contact your clients. Given that it is not Mr. Epstein's Intention to have direct contact with your counsel. clients, it is unnecessary to respond point by point to statements attributed to my co- + +L•A•W•Y•E'R'S + +May 21, 2009 + +Page 2 + +Rather than to be concerned about what my client is doing, I would ask that you advise your clients not to contact Mr. Epstein's lawyers directly. Neither I nor the attorneys who represent Mr. Epstein want to be put in a position where we are set up by any of your clients. + +![]()![]()RDC/msc + +cc: Roy Black, Esq. +Jay Lefkowitz, Esq. +J. Michael Burman, Esq. +Jack Goldberger, Esq. + +Josefsberg.011.doc + +### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA + +JANE DOE NO. 2, CASE NO.: 08-CV-80119-MARRAMM + +Plaintiff + +vs. + +JEFFREY EPSTEIN, + +Defendant. + +JANE DOE NO. 3, + +Plaintiff; + +vs. + +JEFFREY EPSTEIN, + +Defendant. + +, JANE DOE NO. 4, + +Plaintiff, + +vs. + +JEFFREY EPSTEIN, + +Defendant. + +CASE NO.: 08-CV-80232-MARIZAIMM + +CASE NO.: 08-CV-80380-MARRAIMM + +JANE DOE NO. 5, CASE NO.: 08-CV-80381-MARRAM. + +Plaintiff; + +VS. + +JEFFREY EPSTEIN, + +Defendant. + +JANE DOE NO. 6, CASE NO.: 08-CV-80994-MARItAt= + +Plaintiff, + +vs. + +JEFFREY EPSTEIN, + +Defendant. + +JANE DOE NO. 7, CASE NO.: 08-CV-80993-MARRA/MMI + +Plaintiff, + +vs. + +JEFFREY EPSTEIN, + +Defendant. + +C.M.A., CASE NO.: 08-CV-80811-MARRAUM + +Plaintiff, + +vs. + +JEFFREY EPSTEIN, + +Defendant + +JANE DOE, CASE NO.: 08-CV-80893-MARRAJ + +Plaintiff, + +vs. + +JEFFREY EPSTEIN, + +Defendant. + +JANE DOE NO. II, CASE NO.: 08-CV-80469-MARRA/JOHNSON + +Plaintiff, + +vs. + +JEFFREY EPSTEIN, + +Defendant. + +JANE DOE. NO. 101, CASE NO.: 09-CV-80591-MARRA/JOHNSON + +Plaintiff, + +vs. + +JEFFREY EPSTEIN, + +Defendant. + +JANE DOE NO. 102, CASE NO.: 09-CV-80656-MARRA/JOffNSON + +Plaintiff, + +vs. + +JEFFREY EPSTEIN, + +Defendant + +#### ORDER + +THIS CAUSE comes before the Court on Plaintiffs' Motion for No-Contact Order (DE #\_J, filed May 22, 2009. 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COURT SOUTHERN DISTRICT OF FLORIDA + +JANE DOE NO. 2, + +Plaintiff; + +vs. + +JEFFREY EPSTEIN + +Defendant. + +JANE DOE NO. 3, + +Plaintiff; + +vs. + +JEFFREY EPSTEIN + +Defendant. + +JANE DOE NO. 4, + +Plaintiff, + +vs. + +JEFFREY EPSTEIN + +Defendant. + +JANE DOE NO. 5, + +CASE NO.: 08-CV-80119-MARRAMOHNSON + +CASE NO.: 08-CV-80232-NIAFtRAMIIII + +CASE NO.: 08-CV-80380-MARRAJIMI + +CASE NO.: 08-CV-80381-MARRAIIIIII + +Plaintiff, + +JEFFREY EPSTEIN, + +Defendant. + +JANE DOE NO. 6, + +Plaintiff, + +JEFFREY EPSTEIN, + +Defendant. + +JANE DOE NO. 7, + +Plaintiff, + +JEFFREY EPSTEIN + +Defendant. + +C.M.A., + +Plaintiff, + +JEFFREY EPSTEIN + +Defendant. + +JANE DOE, + +CASE NO.: 08-80994-CIV-MARRAi + +CASE NO.: 08-80993-CIV-MARRA/JOHNSON + +CASE NO.: 08-80811-CIV-MARRAMMI + +CASE NO.: 08-80893-CIV-MARRAJ + +Plaintiff, + +JEFFREY EPSTEIN et al, + +Defendants. + +DOE U, CASE NO.: 09-80469-CIV-MARRAIIIIIII + +Plaintiff, + +JEFFREY EPSTEIN et al, + +Defendants. + +JANE DOE NO. 101, CASE NO.: 09-80591-CIV-MARRA-MMI + +Plaintiff, + +JEFFREY EPSTEIN + +Defendant. + +JANE DOE NO. 102, CASE NO.: 09-00656-CIV-MARRAIIIIIII + +Plaintiff, + +JEFFREY EPSTEIN, + +Defendant. + +/ + +/ + +DEFENDANT, DOE JEFFREY EPSTEIN'S. RESPONSE TO JANE DOE NO. 101 AND JANE NO. 102'S MOTION FOR A NO CONTACT ORDER + +Defendant, JEFFREY EPSTEIN, ("MR. EPSTEIN"), by and through his undersigned attorneys responds to the Plaintiffs' Jane Doe No. 101 and Jane Doe No. 102("Plaintiffs") Motion for a No Contact Order [DE I I3j and states: + +1. Plaintiffs' Motion was completely unnecessary and awaste of attorney time and judicial resources. Plaintiffs' motion was filed to cast afalse light on Mr. Epstein and his attorneys, and to draw attention away from the fact that many of the alleged "victims" on the referenced "list" were or are admitted prostitutes, dancers at strip clubs (Platinum Gold, Cheetah, Diamond Dolls, T's Lounge, Flashdance, etc.) or have criminal records or warrants for their arrests, to reference only a few issues about them. + +2. Plaintiffs seek an advisory opinion on an issue which does not exist. Neither Mr. Epstein nor his attorneys have initiated any contact, direct or indirect, with any alleged "victims", nor does Plaintiffs' counsel or any alleged person by way of affidavit alleged any type of contact, direct or indirect. The undersigned's May 21, 2009 (Exhibit I hereto) letter could not have been clearer as to the position of Mr. Epstein and his attorneys, i.e. "To my knowledge, neither Mr. Epstein nor any attorney or agent of those attorneys who represent Mr. Epstein, have contacted or attempted to contact your clients. Given that it is not Mr. Epstein's intention to have any direct contact with your clients, it is unnecessary to respond point by point to any statements attributed to my co-counsel." To the extent it was not clear in the undersigned's letter, neither Mr. Epstein nor his attorneys, nor their agents intend to have any direct or indirect contact with Plaintiffs counsels' clients. What else is there to say? + +3. Is Plaintiffs' counsel suggesting that Mr. Epstein cannot even be at the depositions of his clients as parties or witnesses? That certainly will be direct 'eye' contact at a + +minimum. If that is Plaintiffs' position then Jane Doe 101 and 102, and any other matters where Plaintiffs' firm's clients are involved, should be stayed until expiration of the Non-Prosecution Agreement, otherwise Mr. Epstein will be denied his due process right of any civil party to be present at opposing party's deposition. + +4. Rather than to mislead the court by providing a substantially redacted copy of the undersigned's May 18, 2009 letter, a full copy of the letter redacting only the client's full name is attached as Exhibit 2. The letter is important in that the Defendant and his attorneys recognize that no contact included not serving his client with adeposition subpoena through aprocess server, i.e. potentially an "agent" by serving her attorney. As this court will note from paragraph 2of Exhibit 1, avery cautious approach was taken by Defendant and his attorneys, in stating "However, based on the position that you, Bob, have taken, I am providing/serving you with the subpoena for L.S.P.'s deposition on June 11." + +5. Plaintiffs' counsel further tries to obfuscate Defendant's position by redacting the last paragraph of the May 18, 2009 letter, which states "Finally as I also indicated in our telephone conversation, your client contacted Jack Goldberger's [one of Mr. Epstein's attorneys] office last week suggesting that Jack was holding up the settlement. He did not speak with her. I don't know where Ms. P got that idea." Plaintiffs' counsel should be more concerned about controlling their own clients. + +6. Rather than the Plaintiffs filing this needless, unwarranted and excessive motion where they take another shot at Mr. Epstein so they can remind the court of their alleged damages, maybe, they should focus more on the background of their own clients, including the individual referenced in the May 18, 2009 letter. + +7. Finally, Mr. Epstein pled guilty to one count of felony solicitation (which was not related to a minor), under §796.07(2)(f), F.S. and one count of procuring a minor for prostitution under §796.03 F. S. Plaintiffs' reference to both counts being related to "minors" is again misleading and incorrect. + +8. At the time of the state court plea on June 30, 2008, neither Defendant nor his counsel nor the state attorney's office had seen the "secret" list of alleged victims, i.e. Mr. Epstein was forced to agree to a list of individuals that the USAO refused to provide pre-plea. The list was not provided to Mr. Epstein's attorney until after the plea and Mr. Epstein was in jail. With the parties to the plea completely unaware who would be on the list, how then could the state plea be construed as a limitless no contact order. Mr. Epstein is doing more than the law requires. + +WHEREFORE, Defendant, Mr. Epstein, requests this court deny the motion as premature and unnecessary based on the current state of the facts. + +## Certificate of Service + +IHEREBY 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 Clvf/ECF on this 29th day of May , 2009 + +Doe 101 v. Epstein + +Page 7 + +Respectfully sub + +By: + +ROBERT D. QRITTON, JR., ESQ. + +Florida Bar o. 224162 + +rcritAbelclaw.com + +MICHAEL J. PIKE, ESQ. + +Florida Bar #617296 + +mpikeabc1claw.corn + +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 E stein Case No. 08-CV-80119-MARRA/ + +Stuart S. Mermelstein, Esq. Adam D. Horowitz, Esq. Mermeistein & Horowitz, P.A. 18205 Biscayne Boulevard Suite 2218 Miami, FL 33160 305-931-2200 Fax: 305-931-0877 ssm@sexabuseattornev.com ahorovvitz(asexabuseattomev.com + +Counsel for Plaintiffs in Related Cases Nos. 08-80069, 08-80119, 08-80232, 08-80380, 08- 80381, 08-80993, 08-80994 + +Richard Horace Willits, Esq. Richard H. Willits, P.A. 229010'" Avenue North Suite 404 Lake Worth, FL 33461 561-582-7600 Fax: 561-588-8819 + +Counsel for Plaintiff in Related Case No. 08- 80811 reelrhwabotmail.corn + +Jack Scarola, Esq. Jack P.■ **Esq. Searcy Denney Scarola P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 561-686-6300 Fax: 561-383-9424 isxasearcylaw.com johOsearcylaw.com Counsel for Plaintiff, C.M.A. Barnhart & Shipley,** + +**Brad ME, Esq. Rothstein Rosenfeldt Adler 401 East Las Olas Boulevard Suite 1650 Fort Lauderdale, FL 33301 Phone: 954-522-3456 Fax: 954-527-8663 bedwards@na-law.com Counsel for Plaintiff in Related Case No. 08- 80893** + +**Paul G. Cassell, Esq. Pro Hac Vice 332South 1400 E, Room 101 Salt Lake City, UT 84112 801-585-5202 801-585-6833 Fax cassello@law.utalLedtt Co-counsel for Plaintifflane Doe** + +Isidro M. Esq. Law Firm, P.A. 224 Datum Street, Suite 900 West Palm Beach, FL 33401 561-832-7732 561-832-7137 F isidrozarciaebellsouth.net Counsel for Plaintiff in Related Case No. 08- 80469 + +Robert C. Josefsberg, Esq. Katherine W. Ezell, Esq. Podhurst Orseck, P.A. 25West Flagler Street, Suite 800 Miami, FL 33130 305 358-2800 Fax: 305 358-2382 + +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 ecfObrucereinhartlaw.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.cont tleorteldaiccilaw.com + +dosefsberg@podhurst.com kezell&odhurst.com + +Counsel for Plaintiffs in Related Cases Nos. 0940591 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 iaizes4Qbellsouth.net + +Counsel for Defendant Jeffrey Epstein + +![](_page_9_Picture_3.jpeg) + +I. MICHABL BURALIAI, PA' 01010ORY 74 COUTBIAN,PA. ROBTfiCt D. CRITION. IL. PA: BERNARD USTIVBXBR MARK T.11/11111. PA. JEMMY C. ASPS, Id/CHAILL J. TIX8 HBA11121t MoNAMARA kUDA + +PI.0701.10ANDOMMIUD CIVILIIUALIAWYSt + +### BURMAN, CRITTON, LUTTIER & COLEMAN LLP + +A LITAITIM LIABILITY PARTNERSHIP + +Sent by E-Mail and U.S. Mai( + +Robert C. Josefsberg, Esq. Katherine Emil. Esq. Podhurst Orseck, PA 25 West Flagier Street, Suite 800 Miami, FL 33130 + +Dear Bob: + +May 21, 2009 + +ADOLQUI I. IfINAVENTE MPAISCIAL/ 1101:1010%. + +BAABARA AL Me/WM Ulna STOICINBAUX0 SEIM STORM nutAuximA + +AMA R. WON= OF COWAN& . + +As I advised you yesterday, I am responding to your April 17, 2009 letter. As I stated In my e-mail, I think your request is unnecessary. Despite what Roy may have said to you, my client has had no contact with any of your clients. To my knowledge, the only one who has 'breached" any agreement regarding contact is your own client, S who, as I advised you In a letter last week, contacted Jack Gokiberger's office looking for her settlement check. Mr. Goldberger, of course, did not speak with her. + +Lawyers who represent Mr. Epstein are well familiar with the Rules of Professional Conduct, including Rule 4-42. At the same time, I am certain you are equally familiar with that Rule. The Comment provides "Parries to a mafter may communicate directly with each other...'. + +To my knowledge, neither Mr. Epstein nor any attorney or agent of those attorneys who represent Mr. Epstein, have contacted or attempted to contact your clients. Given that it is not Mr. Epstein's Intention to have direct contact with your clients, It is unnecessary to respond point by point to statements attributed to my cocounsel. + +EXHIBIT 3. + +L •A•W•Y•B•R•8 + +SUN. FLAMER DRIVE / SUM1 400 I WEST PALM BEACH, FLORIDA 33401 + +113LEPRONE (56I) 842-2220 FAX (561) 844-6929 + +saallabololaw.00m + +May 21, 2009 Page 2 + +Rather than to be concerned about what my client Is doing, I would ask that you advise your clients not to contact Mr. Epstein's lawyers directly. Neither I nor the attorneys who represent Mr. Epstein want to be put in a position where we are set up by any of your clients. + +RDC/mso cc: Roy Black, Esq. Jay Lefkowttz, Esq. J. Michael Burman, Esq. Jack Goldberger, Esq. + +Jcadifsbesp.011.0oo + +![](_page_11_Picture_2.jpeg) + +# BURMAN, CRITTON, LUTTIER & COLEMAN LLP + +I. MICHAEL BURMAN.PA OREOORY W. COLEMAN, PA. ROBERT D. CRITTON•JR., PA! BERNARD LEBEDBIUIR MARK t LUTTIER. P.A. JEFFREY C. PEFIN MICHAELJ. PIKE HEATHER MeNAMARA RUDA + +' FLOPODA DOAAD CERTUND aYR. TRIAL LAVIYER + +A LIMITED LIABILITY PARTNERSHIP + +Katherine W. Ezell, Esq. Robert Josefsberg, Esq. Podhurst Orseck, P.A. 25West Flagler Street, Suite 800 Miami, FL 33130 + +Re: See Vaal + +Dear Kathy and Bob: + +May 18, 2009 + +ADELQUI I. BENAVENTE MRAUQILI DIVINTI0ATOR + +BARBARA M. McKEDINA ASHLUISIDICENBARDIO BETTY STOKES PARALBOALS + +RIIAH. BUDNYK cROOIRISaL + +enclosing the settlement check made payable to your firm and your client, in the amount of \$50,000.00. Upon clearance of the funds, forward the original release to me. + +Additionally, Bob, you wrote a letter on April 17, 2009 stating your position Non regarding "No Contact" with any of your firm's clients based on your interpretation of the Non -Prosecution Agreement. I do not concede that your position is correct nor that the However, -Prosecution Agreement prevents some forms of contact with your clients. with based on the position that you, Bob, have taken, I am providing/serving you the subpoena for ars Pass deposition on June 11. + +If that date and time does not work for you, please let me know and we will recoordinate a date within a reasonable time frame. + +As I advised you in our conversation Warrant today, May 18, 2009, there is a No-Bond for Ms. Pies arrest. Apparently your client was arrested In March of this Beach year for County one count of battery and two counts of domestic violence based upon the Palm Sheriffs office booking records. She apparently violated her SOR, and therefore aWarrant Is outstanding. + +While I have an obligation to provide you our firm's check made payable to your her firm which and Ms. would Plat we are specifically opposed to the disbursement of any funds to in any way suggest that Mr. Epstein or his attorneys are aiding a any fugitive. Because there is a Warrant for her arrest and she is afugitive, disbursement of funds to her maybe considered by the Palm Beach Sheriffs office to be "aiding a + +L'A -W•Y•E•R•S + +515N. FLAGLER DRIVE / SUITE 400 / WEST PALM BEACH, FLORIDA 33401 TELEPHONE (561) 842-2820 FAX (561) 844-6929 + +EXHIBIT .02 + +May 18, 2009 Page 2 + +disbursement. fugitive". With the funds now under your control, you must make your own decision on + +Finally as I also indicated in our telephone conversation, your client contacted He Jack Goldberger's office last week suggesting that Jack was holding up the settlement. did not speak with her. I don't know where Ms. Pappgot that idea. + +Cordially + +Robe' •. 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4, + +CASE NO.: 08-CV-80380-MARRA/[REDACTED] + +Plaintiff, + +vs. JEFFREY EPSTEIN, + +Defendant. + +JANE DOE NO. 5, + +CASE NO.: 08-CV-80381-MARRA/[REDACTED] + +Plaintiff, + +vs. + +JEFFREY EPSTEIN, + +Defendant. + +JANE DOE NO. 6, + +Plaintiff, + +vs. + +JEFFREY EPSTEIN, + +Defendant. + +JANE DOE NO. 7, + +Plaintiff, + +vs. + +JEFFREY EPSTEIN, + +Defendant. + +CASE NO.: 08-80994-CIV-MARRA/ + +CASE NO.: 08-80993-CIV-MARRA + +C.M.A., CASE NO.: 08-80811-CIV-MARRA + +Plaintiff, + +vs. + +JEFFREY EPSTEIN, + +Defendant. + +JANE DOE, CASE NO.: 08- 80893-CIV-MARRA/ + +Plaintiff, + +vs. + +JEFFREY EPSTEIN et al, + +Defendants. + +DOE II, CASE NO.: 09- 80469-CIV-MARRA/M. + +Plaintiff, + +vs. + +JEFFREY EPSTEIN et al, + +Defendants. + +JANE DOE NO. 101, CASE NO.: 09- 80591-CW-MARRa + +Plaintiff, + +vs. + +JEFFREY EPSTEIN, + +Defendant. + +JANE DOE NO. 102 CASE NO.: 09- 80656-CIV-MARRA + +Plaintiff, + +vs. + +JEFFREY EPSTEIN, + +Defendant. + +## ORDER + +THIS CAUSE is before the Court upon Plaintiffs Jane Doe. No 101 and 102's Motion for No-Contact Order (DE 113) and Plaintiffs Jane Does' 2-7 Notice of Joinder in Plaintiffs' Motion (DE 145). The Court has reviewed the motions, responses, and replies (DE's 113, 127, 136, 145, 233), and is otherwise fully advised in the premises. Plaintiffs seek a Court order prohibiting Defendant or his agents from communicating with Plaintiffs directly or indirectly. Defendant. Defendant opposes the request as "needless, unwarranted and excessive." (DE 127 at 5). Nonetheless, Defendant states in his response that "neither Mr. Epstein nor his attorneys, nor their agents intend to have any direct or indirect contact with Plaintiffs counsels' clients." (DE 127 at 4). + +The Court notes that Defendant is already under court order not to have direct or indirect contact with any victims. See Transcript of Plea Conference at 20. During the course of Defendant's state plea conference of June 30, 2009, Palm Beach Circuit Court Judge Deborah Dale Pucillio explicitly instructed Defendant as follows: + +Court: Okay. D is, you shall not have any contact with the victim, are there more than one victim? + +Ms. Belohlavek: There's several. + +Court: Several, all of the victims. So this should be plural. I'm making that plural. You are not to have any contact direct or indirect, and in this day and age I find it necessary to go over exactly what we mean by indirect. By indirect, we mean no text messages, no e-mail, no Face Book, no My Space, no telephone calls, no voice mails, no messages through carrier pigeon, no messages through third parties, no hey would you tell so and so for me, no having a friend, acquaintance or stranger approach any of these victims with a message of any sort from you, is that clear? + +Defendant: Yes, + +Id. at 20-21. + +In light of Defendant's response to Plaintiffs' motion for no contact order, suggesting that the state court's order only applies to some victims and that panics are always allowed to contact each other directly, the Court finds it necessary to state clearly that Defendant is under this + +court's order not to have direct or indirect contact with any plaintiffs, regardless of the intended scope of the state court's order. Accordingly, it is hereby + +ORDERED AND ADJUDGED as follows: Plaintiffs Jane Doe. No 101 and 102's Motion for No-Contact Order (DE 113) is GRANTED. 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Because Epstein is on probation as a convicted sex offender, he is currently barred by a state court judge from having any contact with Jane Doe. This Court, too, has entered its own no-contact order. And, entirely apart from any court orders, Jane Doe has difficulty whenever she is compelled to see the man who repeatedly sexually abused her when she was a child. Accordingly, Epstein should not be permitted to have any manner of contact with Jane Doe at the settlement conference. Because Epstein has a history of "accidentally" having intimidating contact with his victims at court-ordered functions, Epstein should be required to be inside the building and in a secure + +room separate from Jane Doe at least one hour before the start of the July 6, 2010, settlement conference and remain there 30 minutes after Jane Doe leaves the conference. + +### BACKGROUND + +On June 30, 2008, Jeffrey Epstein pled guilty to one count of procuring a person under 18 for prostitution and one count of felony solicitation to prostitution before the Circuit Court of the Fifteenth Judicial Circuit in and for Palm Beach County, Florida. He was sentenced to 18 months in jail. In the course of the plea/sentencing colloquy, Palm Beach Circuit Court Judge Deborah Dale Pucillio explicitly instructed Defendant as follows: + +Court: Okay. [Item] D is, you shall not have any contact with the victim, . . . [is] there more than one victim? + +Ms. Belohlavek: There's several. + +Court: Several, all of the victims. So this should be plural. I'm making that plural. You are not to have any contact direct or indirect, and in this day and age I find it necessary to go over exactly what we mean by indirect. By indirect, we mean no text messages, no e-mail, no Face Book, no My Space, no telephone calls, no voice mails, no messages through carrier pigeon, no messages through third parties, no "hey would you tell so and so for me," no having a friend, acquaintance or stranger approach any of these victims with a message of any sort from you, is that clear? + +Defendant: Yes, + +Transcript of Plea Conference at 20-21. + +Read in context, Judge Pucillio was referring to all victims of sex offenses committed by defendant Epstein, whose names were listed in a document that has been described as an appendix to a non-prosecution agreement with the United States Attorney's Office for the Southern District of Florida. Jane Doe is listed in that document. + +The issue of the breadth of the no contact order has previously been before this Court. Several of the plaintiff/victims with suits pending against Epstein before this Court filed a + +motion for an order prohibiting defendant or his agents from communicating with them directly or indirectly Epstein opposed the requests as "needless, unwarranted and excessive." Case No. 9:08-CV-80119-KAM, doc. #127 at 5. This Court, however, firmly overruled Epstein's objections. This Court entered its own, additional no-contact order, ruling: + +In light of Defendant's response to Plaintiff's motion for no contact order, suggesting that the state court's order only applies to some victims and that parties are always allowed to contact each other directly, the Court finds it necessary to state clearly that Defendant is under this court's order not to have direct or indirect contact with any plaintiffs, regardless of the intended scope of the state court court's order. + +Order, doc. #238, at 4-5. + +In spite of two separate court orders from a state and federal court barring direct and indirect contact by Epstein with the victims in this case, on August 27, 2009, Epstein continues to look for opportunities to harass and intimidate his victims who have filed civil suits for his abuse. Sadly, repeated examples can be found in the docket of this Court. See, e.g., Plaintiffs Jane Doe No. 101 and Jane Doe No. 102's Motion for No-Contact Order (Case No. 9:08-CV-80119-KAM, doc. #113); Plaintiffs Jane Doe's 2-7's Response to Defendant's Motion to Compel and/or Identify Plaintiffs in the Style of this Case (doc. #144); Plaintiff Jane Does' 2-7 Motion for Protective Order (doc. #223); Plaintiff Jane Doe Nos. 2-8's Motion for Protective Order as to Jeffrey Epstein's Attendance at Deposition (doc. #292); Plaintiff Jane Doe's Motion for a Protective Order (doc. #297). Indeed, in one instance, defendant Epstein "accidentally" crossed paths with Jane Doe No. 4 when she was on her way to courtmandated deposition. As recounted by Jane Doe No. 4's legal counsel, when this happened "Jeffrey Epstein stopped walking and began staring at her. He intimidated her until she began to cry. Jeffrey Epstein made no immediate attempt to walk away from our client. + +Instead, he stopped and continued to stare at her until she ran away." Case No. 9:08-CV-80119-KAM, doc. #306, at p. 3. + +As the Court is aware, several months ago, Jane Doe attended one court-ordered mediation session in this case. Now, with the trial date looming, Epstein filed a motion on June 28, 2010, to force Jane Doe to attend a second mediation session. Case No. 9:08-CV-80893-KAM, doc. #168. That same day, the Court granted the motion, setting a second settlement conference. Magistrate Judge Palermo has now entered an order for the conduct of the settlement conference that will require both Jane Doe and Epstein to attend in person. Case No. 9:08-CV-80893-KAM, doc. #173. + +# DISCUSSION + +Jane Doe has no objection to attending another court ordered settlement conference in person. She does strenuously object, however, to being forced to run any risk that Epstein will "accidentally" have contact with her or otherwise use the conference as an occasion for intimidation. Her concerns that Epstein is plotting for this conference to be used for harassment purposes — rather than any legitimate settlement discussion — is heightened by the fact that Epstein has not made any new realistic settlement proposals to her. In fact, when Jane Doe raised this fear that it was her belief that Epstein was only trying to use this conference as an opportunity to scare and intimidate her, we requested of Epstein that he make an offer different from any past offers as a show of "good faith"; needless to say, that did not happen. + +In light of the history of Epstein's abuses in this case — and in light of two no-contact orders that are now in place against Epstein as result of his sex offense conviction — this Court should ensure that Epstein's motion is not a subterfuge for intimidation. Accordingly, + +Jane Doe asks this Court to order that Epstein be in a secure, separate room from Jane Doe at least one hour before the 9:30 a.m. start of the settlement conference and that he be ordered not to leave that room until 30 minutes after Jane Doe has left the building at the conclusion of the conference. + +## CONCLUSION + +The Court should order Epstein to be in a secure, separate room during the settlement conference one hour before the start of the conference and 30 minutes after Jane Doe leaves at the conclusion of the conference. + +DATED: June 30, 2010 + +Respectfully Submitted, + +, JAFFE, WEISSING, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 Florida Bar No.: 542075 E-mail: brad@pathtojustice.com + +and + +Paul G. Cassell Pro Hac Vice 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: 801-585-5202 Facsimile: 801-585-6833 E-Mail: cassellp@law.utah.edu + +### CERTIFICATE OF SERVICE + +I HEREBY CERTIFY that on June 30, 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 on 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 filed Notices of Electronic Filing. + +> s/ J. J. + +### SERVICE LIST + +Jane Doe v. Jeffrey Epstein United States District Court, Southern District of Florida + +Jack Alan Goldberger, Esq. Jaoldberaer@aqwpa.com + +Robert D. Critton, Esq. rcritton@bciclaw.com + +Isidro Manual isidrogarcia@bellsouth.net + +Michael James Pike MPike@bcIclaw.com + +Paul G. 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b/marker2/court-redacted-v-epstein-81111/EFTA02821185/EFTA02821185.md @@ -0,0 +1,38 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FL CASE NO. 08-80893-CIV-MAR + +JANE DOE, + +Plaintiff, + +v. + +JEFFREY EPSTEIN, + +Defendant. + +## ORDER ON PLAINTIFF'S MOTION FOR MODIFICATION OF MAGISTRATE JUDGE PALERMO'S ORDER SCHEDULING SETTLEMENT CONFERENCE + +THIS MATTER is before the Court upon Plaintiff Jane Doe's Motion For Modification of Magistrate Judge Palermo's Order Scheduling Settlement Conference to Ensure That Jane Doe is Not Forced to Come Into Contact With Convicted Sex Offender Epstein in Violation of No Contact Orders [DE # 187] (the "Motion"). Defendants filed a Response [DE # 191] to the Motion on July 1, 2010. + +A settlement conference in this matter has been scheduled for July 6, 2010. In the Motion, Plaintiff asks the Court to instruct Defendant to arrive one (1) hour prior to the start of the conference and to depart thirty (30) minutes after the conference so as to minimize the possibility of contact between the parties. The Court, having reviewed the Motion, the Response and being otherwise advised in the premises, hereby ORDERS and ADJUDGES that: + +1. The undersigned is aware of the no contact orders between the parties [See DE # 238, Case Number 08-80119-CIV-MARRA]. That order is in full effect and it shall apply to the July 6, 2010 settlement conference. + +2. Defendant Jeffrey Epstein is instructed to arrive for the July 6, 2010 conference at 8:30 A.M. + +3. Plaintiff's counsel shall call [REDACTED] at (305) 523-5760 immediately upon arrival at the courthouse complex. + +4. Following the conclusion of the settlement conference, the Court will dismiss the parties separately at different times. + +5. The parties are instructed not to communicate, speak or harass one another in any way. Any violation of this Order will not be tolerated. The parties are instructed to GOVERN THEMSELVES ACCORDINGLY. + +DONE and ORDERED in [REDACTED] at Miami, Florida this 1st day of July, 2010. + +![]()PETER R. PALERMO +SR. UNITED STATES MAGISTRATE JUDGE + +Copies furnished to: + +United States District Judge Kenneth A. 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Jane Doe asks for this Court for remedies and sanctions to provide for her safety and to insure that Epstein follows this Court's orders (and an order of the state court), including a referral to the U.S. Attorney's Office for prosecution of criminal contempt. + +To put the matter bluntly, defendant Epstein is intimidating Jane Doe in violation of three judicial no-contact orders. Last evening, he had a "private investigator" tail + +CASE NO: 08-CV-80893-MARRA.MMI + +Jane Doe - following her every move, stopping when she stopped, driving when she drove, refusing to pass when she pulled over. When Jane Doe ultimately drove to her home, the "private investigator" then parked in his car approximately 25 feet from Jane Doe's house and flashed his high beam lights intermittently into the home. Even more threateningly, at about 10:30 p.m., when Jane Doe fled her home in the company of retired police officer employed by Jane Doe's counsel, the "private investigator" attempted to follow Jane Doe despite a request not to do so. The retired officer was successfully able to take evasive action and has placed Jane Doe in a secure, undisclosed location last night. Other harassing actions against Jane Doe also occurred yesterday. + +Given the circumstances of this case, it is obvious that intimidation from the "private investigator" was instigated by billionaire Epstein. Epstein thus stands in clear violation of two, separate orders from this Court, one long-standing and one entered yesterday. First, a year ago, this Court stated that it "finds it necessary to state clearly that Defendant is under this court's order not to have direct or indirect contact with any plaintiffs . . . ." Order, Case no. 9:08-cv-80119, doc. #238 at 4-5 (emphasis added). Second, on top of this order, yesterday this Court entered another order directing Jane Doe and Epstein "not to communicate, speak or harass one another in any way." Order, Case no. 9:08-cv-80893, doc. #193 at 2 (emphasis added). + +Epstein's intimidation-by-surrogate also violates a no-contact order entered during the course of his guilty pleas on June 30, 2008, before Palm Beach Circuit Court Judge Deborah Dale Pucillo, who ordered Epstein "not to have any contact, direct or + +CASE NO: 08-CV-80893-MARRA/ + +indirect" with any victims. She also expressly stated that her no-contact order applied to "all of the victims." + +To protect her safety and to insure respect for court orders, Jane's Doe's counsel accordingly request, on an emergency basis: + +First, the Court should schedule an emergency hearing today, either in court or via telephone, to consider whether Epstein stands in civil contempt of the Court's orders; + +Second, the Court should find that Epstein stands in civil contempt of two separate orders of this Court; + +Third, the Court should then hear from Jane Doe directly and impose such civil contempt sanctions as it finds will enable Jane Doe to return safely to her home or other place of safety without facing the threat of any further harassment or intimidation. + +Fourth, as part of the sanction for Epstein's civil contempt, the Court should expand its current protective order to forbid Epstein or his agents from having any contact whatsoever, direct or indirect, with Jane Doe, but also with any of her family members or friends, as well as with any persons who have been identified by Jane Doe as possible witnesses in her case, without first seeking specific approval of the Court. + +Fifth, the Court should direct Epstein's legal counsel to file with the Court in advance of the mediation on Tuesday morning a certification that they have explained to him the consequences of any additional violations of the courts orders. + +CASE NO: 08-CV-80893-MARRa + +Sixth, Epstein should be directed not to have any agents attempt to follow or surveil Jane Doe as she leaves the courthouse after the settlement conference on Tuesday or after any other court hearing; + +Seventh, this Court should initiate criminal contempt sanctions against Epstein for the violations of its two orders under Fed. R. Crim. P. 42(a), by referring acriminal contempt action to the U.S. Attorney's Office for the Southern District of Florida; + +Eighth, the Court should also refer this matter to the U.S. Attorney's Office for the Southern District of Florida for investigation of possible criminal offenses, including witness tampering in violation of 18 U.S.C. § 1512(b) as well as its position on violations of the conditions of Epstein's non-prosecution agreement; and + +Ninth, the Court should refer this matter to Palm Beach Circuit Court Judge Deborah Dale Pucillo's criminal division presiding over Epstein's probation for consideration by her of whether Epstein has violated her order as well. + +Tenth, the Court should refer this matter to Epstein's probation officer for determination of any violations of his probation. + +Eleventh, the Court should request that Epstein pay a fine to Jane Doe's counsel in the amount of \$18,000 to cover any and all costs associated with relocating Jane Doe and keeping her safe through her trial date. + +Because Epstein's blatant defiance of this Court no-harassment order appears to be designed by him to intimidate not only Jane Doe but also other witnesses in the case (i.e., other young girls that he sexually abused), Jane Doe is filing this Emergency Motion Under Seal. + +CASE NO: 08-CV-80893-MARRA/ + +### BACKGROUND + +Counsel for Jane Doe proffer the following facts as officers of the Court. They proffer that they could prove these facts at any evidentiary hearing which the Court might decide to hold. Counsel for Jane Doe further represent to this Court that they have a genuine concern about the physical safety of their client. + +## Facts Leading Up to the Entry of Three Protective Orders + +The Court is familiar with the general circumstances of this case, which involves Jane Doe's lawsuit seeking significant compensatory and punitive damages from billionaire Jeffrey Epstein. The Court is also aware that Epstein has pled guilty to state sex charges on June 30, 2008. + +When he pled guilty before Palm Beach Circuit Court Judge Deborah Dale Pucillo, she ordered Epstein "not to have any contact, direct or indirect" with any victims. She also expressly stated that her no-contact order applied to "all of the victims." The relevant transcripts have been filed with this Court. (See case no. 9:08-cv-80119-KAM, doc. #113 at 3 and exhibits thereto.) + +To avoid any uncertainty about the scope of this state court order, several of the plaintiff/victims with suits pending against Epstein before this Court filed a motion for an order prohibiting defendant or his agents from communicating with them directly or indirectly. (Case No. 9:08-cv-80119, doc. #113.) Epstein opposed these requests as "needless, unwarranted and excessive." Doc. #127 at 5. This Court, however, firmly overruled Epstein's objections. On July 31, 2009, this Court entered its own no-contact order (in addition to the state court order), ruling: + +CASE NO: 08-CV-80893•MARRNJOHNSON + +In light of Defendant's response to Plaintiffs motion for no contact order, suggesting that the state court's order only applies to some victims and that parties are always allowed to contact each other directly, the Court finds it necessary to state clearly that Defendant is under this court's order not to have direct or indirect contact with any plaintiffs, regardless of the intended scope of the state court courts order. + +Order, Doc. #238, at 4-5 (emphasis added). + +Recently, with the case nearing trial, the Court ordered Jane Doe to attend a settlement conference on July 6, 2010. Jane Doe had concerns that the upcoming settlement conference, demanded by Epstein, was going to be used to harass and intimidate her. See Plaintiff Jane Doe's Motion for Modification of Magistrate Judge Palermo's Order Schedule settlement Conference, doc. #187. After a response from Epstein (doc. #191), the Court modified its order regarding the settlement conference to avoid harassment of Jane Doe. Significantly, in the final paragraph, the Court (Palermo, J.). starkly commanded: + +The parties are instructed not to communicate, speak or harass one another in any way. Any violation of this Order will not be tolerated. The parties are instructed to GOVERN THEMSELVES ACCORDINGLY. + +Case no. 9:08-cv-80893, Doc. #193 at 2 (italic added, capitalization in original). This Order was entered at 3:29 p.m., EDT, according to the PACER message sent to counsel in the case. + +## Intimidating Activities on the Evening of July 1, 2010 + +In spite of three court orders forbidding contact and harassment of Jane Doe, Epstein has (once again') shown his unwillingness to follow the rules. On the evening + +For two other examples of Epstein's unwillingness to follow the same rules that apply to other litigants, see Plaintiff's Motion in Limine to Prevent Improper Use of the 5th Amendment, doc. + +CASE NO: 08-CV-80893-MARRAMIE + +of July 1, 2010, sometime after the issuance of this Court's most recent order, Jane Doe left her house to go to the store and noticed a car (Infiniti SUV, license tag T-KNOLZ) following her everywhere she went. Feeling frightened, she pulled into a driveway in a nearby neighborhood at one point to allow the car to proceed past her, but the car pulled into the neighborhood and stopped nearby. It was clear the person in the car was following her and was intentionally making his presence known. Jane Doe pulled out of the driveway and headed home, with this other car tailing close behind. Once Jane Doe arrived to her house, she went inside and the person following in the Infiniti parked across the street outside her home. Jane Doe called her attorney expressing her fear and asking what could be done to protect her. She observed that the car kept creeping closer to her home every once in awhile. + +This intimidation of Jane Doe was so serious that, alerted by Jane Doe's counsel, aretired police officer called the police. The police responded to Jane Doe's home and confronted the man in the car. The man told the police that he was "private investigator." However he would not tell the police who had hired him, only that he was hired to -watch" Jane Doe. The name of the investigator appears to be Thaddeus Knowles. The police reported these facts to Jane Doe, but advised her that they did not have a legal basis to order him to leave the public street. (The police are also preparing areport on the incident.) + +Counsel for Jane Doe then arranged for the retired police officer to go to Jane Doe's home. This retired officer arrived at Jane Doe's home at approximately 10 p.m. + +#178 (recounting Epstein's misuse of the Fifth Amendment during his deposition); doc. #190 (recounting Epstein's willful violations of discovery orders). + +CASE NO: 08-CV-80893-MARRAa + +He immediately saw a car parked 25 feet from Jane Doe's home, facing her home. He also observed the purported "private investigator" in the car intermittently flashing his high beam lights into Jane Doe's home. The investigator was also intermittently attempting to videotape anyone inside the home. The retired police officer took videotapes of the investigator lighting up the interior of the home with his high beam lights, and also took photographs of this harassing action as well. The videotape and photographs could be provided quickly to the Court upon request. + +After consulting with Jane Doe, the retired police officer determined that Jane Doe felt like a prisoner in her own home and that she believed her physical safety and that of her family was threatened if she remained there. She further believed that this intimidation was being orchestrated by defendant Epstein. Jane Doe is not involved in other litigation and is not aware of any other person who would want to do something like this to her. Also, in the last 48 hours, Jane Doe has received telephone calls from two ex-boyfriends that investigators were at their homes, knocking on their doors and trying to talk to them about Jane Doe — apparently because of this case. And, of course, Jane Doe's settlement conference is just four days away and her trial is twoand-half-weeks away. + +In light of Jane Doe's concerns, the retired police officer believed that it was best to take Jane Doe from her home. He advised Jane Doe to pack asuitcase and leave the home with him. + +At approximately 10:30 p.m., the retired police officer then took Jane Doe in his car and pulled up next to the "private investigator." The retired police officer advised the + +CASE NO: 08-CV-80893-MARRA/ + +investigator that Jane Doe was leaving the home to go to another location and that he should not attempt to follow them. Nonetheless, the investigator attempted to follow the retired police officer as they drove away from Jane Doe's home. The retired police officer then took evasive action and was able to elude his pursuer. + +As a result of these activities, Jane Doe feels very threatened. She knows that she was followed for much of the day. She also know that this was not surreptitious surveillance by someone who was trying to discovery something about her, but rather quite visible surveillance by someone whose manifest intent was to make she that Jane Doe knew she was being followed. Thus, when she pulled over, he pulled over; when she parked, he parked visibly close by. The only reason for such activities could be to intimidate her on the eve of the court-ordered mediation. It may also be worth noting that Jane Doe is a petite young woman, physically smaller and younger than the male private investigator who has been following her. + +# Past Intimidation of Witnesses By Epstein + +The Court should be aware that this is not the first time Epstein has used scare tactics to intimidate witnesses. Indeed, as the Court is aware, despite numerous civil suits being filed against Epstein for sexual abuse, none of the victims in those cases have felt able to proceed to trial. Counsel for Jane Doe have been advised that many of these victims were afraid to take their cases all the way to trial. Jane Doe remains one of only three victims who has had the temerity not to settle her case against Epstein but stand on her right to a jury trial. + +CASE NO: 08-CV-80893-MARRAhil= + +In determining who is responsible for the intimidation that took place last night, this Court can consider all of the circumstances, including other documented examples of harassment by Epstein:2 + +Previous use of "investigators" to scare witnesses: The use of "investigators" to aggressively harass his victims is not new to Epstein, as investigators have in the past aggressively followed key witnesses to intimidate and scare them. See Palm Beach Police Department Incident Report at p. 86 (Attached as Exhibit A). + +Victim-to-victim communication: One of Epstein's sexual abuse victims was relayed a message from another victim speaking on Epstein's behalf regarding the criminal investigation of Epstein in 2006: 'Those who help will be compensated and those who hurt will be dealt with." See Palm Beach Police Department Incident Report, Id. at page 83. + +Witness tampering during the federal investigation: During the FBI investigation of his sexual abuse of young girls, Epstein intimidated and harassed other possible witnesses against him -- namely and Indeed, this intimidation was so serious that federal prosecutors prepared draft federal charges against him for witness tampering charges. (Attached as Composite Exhibit B) Ultimately, for reasons that are unclear, these charges were not filed. + +Threats Against Jane Doe 102: Epstein has even tracked down adverse witnesses as far away as Australia in the past to send the message not to testify against + +The Federal Rules of Evidence do not apply to this motion and, in any event, the federal rules authorize the Court to consider other bad acts in reaching aconclusion about disputed events. See Fed. R. Evid. 404(b). + +CASE NO: 08-CV-80893-MARFtALEM + +him regarding his illegal sexual exploits. See Complaint of Jane Doe 102 v. Epstein (attached as Exhibit C) + +Threats Against Alfredo Rodriguez: Jane Doe is not the only person to have received this impression that she is at risk if she does not accede to Epstein's demands. The Court is familiar with Alfredo Rodriguez, an employee of Epstein who kept a'black book" of the names of minor girls Epstein' was sexually abusing. See Criminal Complaint, U.S. v. Rodriguez, No. 9:10-CR-80015-KAM (doc. #3). Rodriguez stated that he was afraid that Jeffrey Epstein would make him "disappear" unless he had an "insurance policy" (i.e., the black book). Id. at 3. + +Please find, for the Court's consideration as well Exhibit D, the affidavit of the retired officer that assisted in protecting Jane Doe. + +The Court can consider all of this information as circumstantial evidence pointing to only one conclusion: that defendant Epstein is trying to intimidate Jane Doe before her upcoming settlement conference and trial. This is clear violation of the three court orders outlined above. + +## THE COURT SHOULD TAKE APPROPRIATE STEPS TO RESPOND TO THE VIOLATION OF ITS ORDERS AND TO ALER THE STATE COURT TO A POSSIBLE VIOLATION OF ITS ORDER + +Defendant Epstein is thumbing his nose at three separate court orders, two from this Court and one from the state court. The threatening message billionaire Epstein is trying to send to Jane Doe is obvious: settle this case next week or you are in danger. This is not the way in which a civil case should be litigated. The Court should not allow defendant Epstein's wealth to be deployed to pervert the course of justice. In entering + +CASE NO: 08-CV-80893-MARRNIIM + +its most recent no harassment order, Judge Palermo indicated that "[a]ry violation of this Order will not be tolerated." Jane Doe respectfully requests that the Court carry through on this promise and make it possible for her to return safely to her home. + +Jane Doe accordingly requests the following actions on an emergency basis: + +First, the Court should schedule an emergency hearing today, July 2, 2010, either in court or via telephone with counsel for Jane Doe and Epstein to learn whether Epstein will challenge any of the foregoing facts and the conclusion that he stands in civil contempt of this Court's orders and, if so, how to resolve those factual questions rapidly. As part of that hearing, counsel for Epstein should proffer whether Epstein will deny that he instigated the harassment that took place last night and answer questions about his involvement or whether instead he will refuse to answer such questions on grounds that they might incriminate him.3 The Court should thereafter conduct such further fact-finding as it deems necessary to reach a conclusion about whether Epstein has violated the Court's orders, giving both Jane Doe and Epstein an opportunity to be heard. + +Second, the Court should find that Epstein stands in civil contempt of two separate orders of this Court: (1) Judge Marra's long-standing direction "that Defendant is under this court's order not to have direct or indirect contact with any plaintiffs," Order, case no. 9:08-cv-808119, doc. #238, at 4-5 (emphasis added), and (2) Judge Palermo's + +3 If, as Jane Doe suggests, the Court ultimately proceeds first by way of civil and then only later by way of criminal contempt, Epstein would be entitled to invoke the Fifth Amendment only in the later criminal contempt proceedings. See Romero v. Drummond Co., Inc., 480 F.34 1234, 1243(11t1 Cir. 2007) (noting that the right to remain silent attaches to criminal contempt proceedings). Of course, in any civil proceeding, the finder of fact can draw an adverse inference from an invocation of the Fifth Amendment. + +CASE NO: 08-CV-80893-MARRal + +order yesterday that Jane Doe and Epstein "are instructed not to communicate, speak or harass one another in any way, Order, case no. 9:08-cv-80893, doc. #193, at 2 + +Third the Court should then impose such civil contempt sanctions as it finds, after the hearing, will enable Jane Doe to retum safely to her home (or, if necessary, other place of safety) without facing the threat of any further harassment or intimidation. See Chevrolet, Inc. v. General Motors Corp., 446 F.3d 1137, 1147 (11th Cir. 2006) ("Civil contempt may be imposed in an ordinary civil proceeding upon notice and an opportunity to be heard."). As part of that determination, plaintiff Jane Doe respectfully requests an opportunity to be heard directly by the Court (either in person or via telephone) so that the Court will have the benefit of her specific concerns in crafting appropriate sanctions and remedies to make her feel safe to return to her home and to prevent further intimidation at the hands of Epstein. + +Fourth, as part of the sanction for Epstein's civil contempt, the Court should expand its current protective order so that forbids Epstein or his agents from not only having any contact whatsoever, direct or indirect, with Jane Doe, but also with any of her family members or friends, as well as with any persons who have been identified by Jane Doe as possible witnesses in her case, without first seeking specific approval of the Court. + +Fifth, the Court should direct Epstein's legal counsel to file with the Court in advance of the mediation on Tuesday morning a certification that they have explained the requirements of all of these orders with him and have explained to him the serious consequences that could follow from of any additional violations of these orders. + +CASE NO: 08-CV-80893-MARRAMM + +Sixth, Epstein should be directed not to have any agents attempt to follow or surveil Jane Doe as she leaves the courthouse after the settlement conference on Tuesday or after any other court hearings or trial proceedings. + +Seventh this Court should initiate criminal contempt sanctions against Epstein for the violations of its two orders — and provide notice to Epstein that the criminal sanctions could include a possible term of imprisonment. Criminal contempt sanctions are appropriate here because "the criminal contemnor has done that which he has been commanded not to do. The criminal contemnor's disobedience is past, a completed act, adeed no sanction can undo. Accordingly, the criminal sanction operates not to coerce afuture act from the defendant for the benefit of the complainant, but to uphold the dignity of the law, by punishing the contemnor's disobedience." United Minor Workers of America v. Bagwell, 512 U.S. 821, 845 (1994) (internal citations omitted). The dignity of the law needs to be upheld; this Court need to act to insure Epstein understands that, despite his vast wealth, he remains equal to everyone else in the eyes of the law. In short, this Court needs to stop Epstein from flouting its orders and intimidating Jane Doe; + +Because the contempt took place outside the presence of the Court, the Court should proceed in nonsummary fashion. See Fed. R. Crim. P. 42(a); United States v. Baldwin, 770 F.2d 1550, 1553 (11th Cir. 1985). The procedures for such nonsummary criminal contempt are well settled. As the Eleventh Circuit has explained, "A federal court may punish contemptuous conduct that occurs outside its presence only after giving notice of the essential facts constituting the charged criminal contempt, + +CASE NO: 08-CV-80893-MARRal + +requesting that the contempt be prosecuted by an attorney for the government, and affording other procedural protections." Romero v. Drummond Co., Inc., 480 F.3d 1234, 1242-43 (1 1 th Cir. 2007). The Court should therefore begin the process by referring this matter to the U.S. Attorney's Office for the Southern District of Florida or, if that office declines to pursue the matter, such other attorney as may be appropriate. See Fed. R. Crim. P. 42(a)(2). + +Eighth, because Epstein's actions appear to implicate possible witness tampering, in violation of 18 U.S.C. § 1512(b), and possibly other federal offenses, the Court should additionally refer this matter to the U.S. Attorney's Office for the Southern District of Florida for a criminal investigation. + +Ninth, the Court should refer this matter to Palm Beach Circuit Court Judge Deborah Dale Pucillo's criminal division presiding over Epstein's criminal probation for consideration by her of whether Epstein has violated her order as well. + +Tenth, the Court should refer this matter to Epstein's probation officer for determination of any violations of his probation. + +Eleventh, the Court should request that Epstein pay a fine to Jane Doe's counsel in the amount of \$18,000 to cover any and all costs associated with relocating Jane Doe and keeping her safe through her trial date. + +# CONCLUSION + +The Court should hold a hearing on an emergency basis, find Epstein to be in contempt of the Court's orders, and impose sanctions and take other steps as outlined + +CASE NO: 08-CV-80893-MARRA + +by Jane Doe to secure her safety and to permit her to return to her home without harassment by Epstein. + +We respectfully request this Court to seal this Motion and all responses be SEALED. + +DATED: July 2, 2010 + +![]()![]()*and* + +Paul G. Cassell +Pro Hac Vice +332 S. 1400 E. +Salt Lake City, UT 84112 +Telephone: 801-585-5202 +Facsimile: 801-585-6833 +E-Mail: cassellp@law.utah.edu + +**CERTIFICATE OF SERVICE** + +I HEREBY CERTIFY that on July 2, 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 on 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 filed Notices of Electronic Filing. + +![]()CASE NO: 08-CV-80893-MARRa + +## SERVICE LIST + +Jane Doe v. Jeffrey Epstein United States District Court, Southern District of Florida + +Jack Alan Goldberger, Esq. Jgoldbergereaqwpa.com + +Robert D. Critton, Esq. rcrittonObciclaw.com + +Isidro Manual isidroaarciaabellsouth.net + +Michael James Pike MPikeebelclaw.com + +Paul G. Cassell cassello(&law.utah.edu + +**UNITED STATES DISTRICT COURT +Southern District of Florida** + +Case Number: 08-CV-80893-CIV-MARRA [REDACTED] + +JANE DOE + +Plaintiff + +v. + +JEFFREY EPSTEIN + +Defendant + +**CERTIFICATION OF EMERGENCY** + +I hereby certify that, as a member of the Bar of this Court, I have carefully examined this matter and it is a true emergency. + +I further certify that the necessity for this emergency hearing has not been caused by a lack of due diligence on my part, but has been brought about only by the circumstances of this case. The issues presented by this matter have not been submitted to the Judge assigned to this case or any other Judge or Magistrate Judge of the Southern District of Florida prior hereto. + +I further certify that I have made a bona fide effort to resolve this matter without the necessity of emergency action. + +Dated this   2   day of   JULY  , 2010       . + +Signature: + +![]()Printed Name: + +![]()Florida Bar Number: 542075 + +Telephone Number: 954-524-2820 + +===== + +**FOR CLERK'S OFFICE USE ONLY** + +I hereby certify that the Judge assigned to this case is unavailable for this emergency (a copy of notification to the Clerk is on file). In accordance with Local Rule 3.7, the Honorable \_\_\_\_\_ as randomly drawn from the Emergency Wheel. + +I hereby certify that the Judge randomly assigned to this emergency is unavailable due to \_\_\_\_\_ (A copy of notification to the Clerk is on file). In accordance with Local Rule 3.7, the Honorable \_\_\_\_\_ was randomly drawn from the Emergency Wheel. + +Dated this \_\_\_\_\_ day of \_\_\_\_\_, 20\_\_\_\_. + +**STEVEN M. 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1-05-000368 +PECIAL NOTES : +ocur To Date : 1/27/05 0000 +ay Of Week : Thursday +ommon/Location: 358 EL BRILLO WY +ity : PALM BEACH, FL +ocation Type : RESIDENCE-SINGLE FAMILY +at Assignment: DETECTIVE BUREAU +apt Class : SEXUAL BATTERY +ase Status : OPEN / ACTIVE +ipervisory Dt.: TRYLCH, JEFFREY 3/14/05 +itry Date : OREGERO, LAURA 4/06/05 +imes? : +ihicles? : +irrative? : +Occur From Date: 1/27/05 0000 +Report Date : 3/14/05 1600 +Map Reference : 10 +Report Officer : PAGAN, MICHELE +Case Status Dt : 3/14/05 +Property? : +Offenses? : +Related Cases? : + +\*\*\*\*\* V E H I C L E I N F O R M A T I O N # 1 \*\*\*\*\* +ase number : 1-05-000368 +ate Veh Type : +ike : +idel Name : +yle : +lor - Bottom : +N : +sposition : +rured by : +locked : +recovered : 0/00/00 +reet number : +ty : +covery code : +On Look Out?: +NCIC number : + +\*\*\*\*\* P E R S O N R E P O R T I N G I N F O - # 1 \*\*\*\*\* +se Number : 1-05-000368 +reet Number : [REDACTED] +ty : [REDACTED] +rth Date/Age : [REDACTED] +rupation : +ne Phone No. : [REDACTED] +c : : : : : Female +light : : : : : 0 +Employer? : +Oper Lic No. : [REDACTED] +Race : : : : : [REDACTED] +Height : : : : : 0 +Other Phone Nbr: + +\*\*\*\*\* S U S P E C T / A R R E S T E E I N F O R M A T I O N - # 1 \*\* +se Number : 1-05-000368 +reet Number : 12247 72ND CT NORTH +ty : [REDACTED] PALM BEACH, FL 334121460 +rth Date : 4/09/1986 18 +loyer? : +r Lic No. : R125320866290 FL +ier Phone Nbr: +: : : : : Female +mum Weight : 0 +Prompt valid in: [REDACTED] +Maximum Age : 18 +Occupation : +Home Phone No. : +Race : [REDACTED] +Minimum Height : 0 +Maximum Height : 0 + +ate: 7/19/06 PALM BEACH POLICE DEPARTMENT ime: 15:01:37 Page: 81 Incident Report Program: CMS301L + +kse No • 1-05-000368 (Continued) on my voice mail. Malt left her telephone number for a return call 561-662-3098. I left her a message to return call. + +Investigation Continues.. + +NARRATIVE Si Reported By: RECAREY, 2/21/06 Entered By.: ALTOMARO, NICKIE A. 2/22/06 + +On February 15, 2006, I made telephone contact with SIMI who provided directions to where I could locate her. Det Caristo and I res onded to 806 Old Dixie Hwy in Lake Park to meet with S Upon my arrival, I met with in the parking lot directly behind MARCO Auto Painting. She was advised I was there to speak with her about an ongoing investigation that concerned Jeffrey Epstein in Palm Beach. ipmeg stated she knows Epstein very well and did not want to speak with me about Mr. Epstein. She was very fond of Epstein and did not want to speak with me about anything concerning Jeffrey Epstein. I explained to her that she was seen at the house and I would like to speak with her. She stated she knew there was an investigation and that I had spoken with otherig ige and therefore I should know what happened at Epstein's house. ended the conversation and walked back into her boyfriends business, Blanton Automotive. Det Caristo and I left the area and returned to the police station. + +Investigation continues. + +NARRATIVE Reported By: RECAREY, 4/10/06 Entered By.: ALTOMARO, NICKIE A. 4/10/06 + +AGrand Jury Session was requested during the month of February 2006, in which all the girls that had been interviewed would have been called to testify before the Grand Jury to seek an indictment against Jeffrey Epstein. Due to subsequent meetings with the State Attorney's Office and Defense Attorney Alan Dershowitz the Grand Jury was postponed until a later time. Dershowitz had provided a package of material on the main victims in this case in which they appear on myspace.com and speak about alcohol use and some marijuana use. The State Attorney's Office wanted time to review the material. + +Irequested additional subpoenas from the State Attorney's Office in which I requested information from Dollar Rent a Car and Jet Aviation. The information requested from Dollar Rent a Car was for the rented vehicle by Alfredo Rodriguez while under the employ of Epstein for one of the victims. The other subpoena requested was for Jet Aviation for dates and times when Epstein's planes were in Palm Beach County. + +Icontinued to research other names that were acquired either from .nterviews or intelligence gathered during the investigation. I + +ate: 7/19/06 ime: 15:01:37 + +## PALM BEACH POLICE DEPARTMENT Incident Report + +Page: 82 Program: CM8301L + +►se **No • 1-05-000368 (Continued) located mmel Iresponded to ea inks** da, During the interview, stated she knew I would be speaking with her. elb. stated she was first introduced to Epstein when she turned eighteen years old. stated she was sure of her age as it was her senior year in She advised she was brought there to make money and was told she would have to provide amassage to this Palm Beach guy. She remembered she met Epstein and his assistant Sarah in the kitchen area. She stated she was taken by one of her friends, She stated she went upstairs with Sarah while Epstein got ready for the massage. He exited his bathroom naked and milmme turned around. Epstein asked her if being naked offended her. allialtstated it made her uncomfortable. Epstein then put on a towel and lay on the table. agmems stated she rubbed his back and feet. She stated she had no massage training or experience. astated during the massage, Epstein attempted to touch her buttocks. nulled away as he touched her buttocks. She told him again she was uncomfortable with him touching her. Epstein then cut the massage short and became upset with her. Epstein aid her 8200.00 for the massage and told her to leave the house. never returned to the house. She did advise of one time she went with allble however she waited in the car for Sas she did not want to go into the house. At the conclusion ofe visit with EPstein they left the area. INOMMillbstated she had heard from other girls that have gone to the house that Epstein now required them to do the massage naked and allow him to touch them in their private areas for monies. The interview was concluded as -did not have any other information to provide. + +Ithen learned from the original victim, the defense attorney had learned of her identity. I spoke with the father of the victim, who stated there has been a private investigator on his house photographing his family and chasing visitors who come to the house. He provided a Florida License of E79-4EH. This vehicle is registered to Ivan Robles of West Palm Beach. Robles is aprivate investigator intern who is licensed by the state. I informed the State Attorney's Office of the above information. + +Ireceived the Grand Jury subpoenas to be delivered to three victims for a Grand Jury session to be held on April 18, through April 20, 2006. + +Investigation continues. + +\*\*\*\*\*NARRATIVE # 42 Reported By: RECAREY, Ill, 4/14/06 Entered By.: ALTOMARO, A. 4/18/06 + +The Grand Jury Subpoenas were personally served to the individuals they were issued to. On April 5, 2006, at approximately 7:30 p.m., I oersonally served the parents ofillawho had informed me that the )rivate investigators were still photographing the family. On April + +## kte: 7/19/06 PALM BEACH POLICE DEPARTMENT Page: 83 Ime: 15:01:37 Incident Report Program: CMS301L + +'se No • 1-05-000368 (Continued) 10, 2006, at approximately 2:30 p.m., I servedflat her residence in The subpoena was given to her mother, IMMI, + +Ilearned through one of the victims OW that she was personally contacted through asource that has maintained contact with Epstein. The source assured she would receive monetary compensation for her assistance in not cooperating with law enforcement. Illipialso stated she was told, "Those who help him will be compensated and those who hurt him will be dealt with." I told...What tampering with a witness/victim is an arrestable offense and very serious. I asked her who approached her during this encounter. IMmooriginally was reluctant to provide the name of the person who approached her to offer her not to testify because she felt they were still friends. + +On April 11, 2006, Det Dawson and I traveled to Tallahassee, Florida ailli a and met with the victimAleallo identified #W/F, as the person who approached her in Palm Beach while lisre !!eMe during Spring Break in March 2006. so stated she did not want to pursue the intimidation charges on MOMS Swag concerned that the defense attorney was given acopy of the report as certain things she had told me in confidence were repeated to her by Beal. Prior to our departure, the victim was given acopy of her subpoena for the Grand Jury which was scheduled to commence April 18, 2006. + +Upon our return from Tallahassee, I notified the State Attorney's Office of what was told to me. I also notified them that the subpoenas were delivered to the witnesses and they would be calling for arrangements for the date and time needed for the Gland Jury. I spoke with ASA Weiss and informed her of the possible intimidation by the defense. + +On April 13, and April 14, 2006 I attempted contact on several occasions with ASA Weiss and ASA Belohlavic to ascertain when the victims needed to report for Grand Jury testimony. Messages were left on their voicemail. On April 17, 2006, during the hours of 9:00 am and 11:30 am, I again left messages for ASA Weiss and ASA Belohlavic for either of them to return my call as I had not heard from the State Attorney's Office as to the time and date of the Grand Jury. + +At approximately 12:30 pm, I went to the State Attorney's Office and located ASA Weiss and ASA Belohlavic in their offices. I entered ASA Belohlavic's office who informed me that she was going to return my call. She explained that an offer was made to the defense, Atty Guy Fronstin and Atty Alan Dershowitz. The offer is 1 count of Agg Assault with intent to commit afelony, five years probation, with adjudication withheld. Epstein would have to submit to psychiatric/sexual evaluation and no unsupervised visits with minors. + +When asked about the all the other victims, ASA Belohlavic stated that was the only offer made as to one victim, ASA Belohlavic cell phone rang and went to voice mail. She checked her voice mail end played the message on speaker. The caller identified himself as )ate: 7/19/06 rime: 15:01:37 + +. . + +# PALM BEACH POLICE DEPARTMENT Page: 84 Incident Report Program: CMS301L + +:ase No 1-05-000368 + +Atty (Continued) Guy Fronstin and acknowledged the deal made between them. Epstein, Fronstin stated in the message, he spoke with his client, Jeffrey jury as they and agreed would to the deal. Fronstin asked to call off the grand cause accept this deal. Belohlavic stated aprobable me know would as to be when needed to book Epstein in the'county jail and would let the deal and not it would be needed. I explained my disapproval of being consulted prior to the deal being offered. would However I expressed that was only my opinion and the final approval Reiter come from the chief of Police. She explained to have Chief call Barry Krisher about the deal. I left the area and deal returned offered. to the police station where I briefed the Chief about the + +stepmother Ichecked my voice mail messages and discovered amessage from Attorney's for the victimilla She was calling because the State they are needed Office still had not returned any of her calls as to when and left messages for this case. I then called ASA Belohlavic's office for her to call the victims on this case and explained to them what the State Attorney's Office had done. + +On April 17, 2006, at approximately 4:30 pm, State Attorney cancellation Investigator Tim Valentine called to officially notify me of the that had of the Grand Jury. He requested I contact the victims advised Valentine been served that to appear, to notify them of the cancellation. I the State Attorney's as this Grand Jury session was called based on Grand Jury Office decision to have the victims heard by the that I felt it was the States Attorney's Office they responsibility were to contact the victims and advise them of the reason no longer needed. + +NARRAT/VE 43 Reported By: RECAREY, 5/04/06 Entered By.: ALTOMARO, NICKIE A. 5/04/06 + +Office, As I had not received any contact from anyone at the State Attorney's submitted on them May 1, 2006, I prepared three arrest warrant requests and delivered to the State Attorney's Office. The packages were Belohlavek. to the Crimes against Children Unit in care of ASA Lana counts of Jeffrey Epstein's arrest warrant was requested for 4 of Lewd and Unlawful Sexual activity with certain minors and one count Lascivious Molestation. , Epstein's assistant's, the 1st degree arrest warrant request was or 4 counts of Principal in count of Principal Unlawful Sexual activity with certain minors and one in the 1st degree Lewd and Lascivious Molestation. arrest warrant request was for Lewd and Lascivious signed Acts on avictim under 16 years of age. The receipt of delivery was and brought back to the records division at the police department. + +!rom On May ASA 3, Daliah 2006, at approximately 2:54 pm, I received atelephone call Weiss on my cellular telephone. ASA Weiss advised she + +ate: 7/19/06 +ime: 15:01:37 + +PALM BEACH POLICE DEPARTMENT +Incident Report + +Page: 85 +Program: CMS301L + +ase No. . . : 1-05-000368 (Continued) +has been taken off the Jeffrey Epstein case because her husband is employed with Attorney Jack Goldberger. Attorney Goldberger is the attorney of record for Jeffrey Epstein. His previous attorney, Guy Fronstin, has been fired from representation. ASA Lana Belohlavek has been assigned the case. ASA Weiss stated she can no longer speak about the Epstein case with me. I thanked her for her telephone call. ASA Weiss further stated that ASA Belohlavek would be calling me. + +\*\*\*\*\* N A R R A T I V E # 44 \*\*\*\*\* +1 Reported By: RECAREY, [REDACTED] 5/15/06 +Entered By: ALTOMARO, NICKIE A. 5/15/06 + +On May 10, 2006, information was received that Epstein's associate, Leslie Wexner, The Limited Inc, CEO's, plane had arrived in West Palm Beach, PBIA. The plane, a Gulfstream 4 bearing a N900LS registration, was on the tarmac at Galaxy Aviation. As Epstein had recently acquired the services of a new attorney, and the fact that Epstein's house is currently under remodeling, it was believed that Epstein may be in Palm Beach. I conducted physical surveillance at the residence, 358 El Brillo Way. I observed a large construction crew conducting remodeling at the house. The contractor, David Norr, was observed driving a [REDACTED] Explorer, [REDACTED] in color. The vehicle has a Florida registration of F30QQF. Norr left Epstein's house and traveled north on County Road. Det Caristo and I conducted surveillance on Norr. Norr traveled to several construction sites and checked on certain jobs. Surveillance was discontinued on Norr and Det Caristo and I traveled to Galaxy Aviation. I observed the [REDACTED] plane with a blue stripe along the body and tail of the plane; the tail number was visible on the bottom of the tail, closer to the body of the plane. We maintained visual surveillance on the plane until 4:57 p.m., when a caravan of Cadillac Escalades drove onto the tarmac. We observed several people exit the vehicles and discovered that they were part of the executive team for Limited Inc. The executives were in Palm Beach County for an executive meeting for the day. They arrived in Palm Beach County on May 9, 2006 at 9:30 pm and were scheduled to leave on the 10th at 5:00 pm. + +On May 12, 2006, I met with ASA Lana Belohlavek at the State Attorney's Office. She explained that her boss, Barry Krischer, was requesting this case be taken to the Grand Jury again. I explained to her I had requested arrest warrants for Jeffrey Epstein, [REDACTED], and [REDACTED]. I asked that she either issue the warrants or direct file, as so much time has elapsed since the original request to the Grand Jury. I explained that the Palm Beach Police Department had concluded the case in December of 2005 and has been waiting for the case to go forward. Belohlavek stated the original offer was again offered to the new defense attorney. She was waiting for their answer by Friday May 19, 2006. She stated she would advise me of the answer. + +\*\*\*\*\* N A R R A T I V E # 45 \*\*\*\*\* +1 Reported By: RECAREY, [REDACTED] 6/05/06 + +## ----------------------------------------------------------------------------- ate: 7/19/06 PALM BEACH POLICE DEPARTMENT Page: 86 ime: 15:01:37 Incident Report Program: CMS301L + +ase No • 1-05-000368 + +Entered By.: ALTOMARO, NICKIE A. + +(Continued) + +6/06/06 + +On May 22, 2006, I received several phone calls throughout the day from Mrillawho stated he had been followed aggressively by a private investigator. MrillOstated that as he drove to and from work and running errands throughout the county, the same vehicle was behind him running other vehicles off the road in an attempt not to lose sight of Mr.linavehicle. + +I explained to him as Mr. Epstein had retained new legal council it was possible it would be new private investigators following him to observe his daily activities. I also explained to him that there was a meeting scheduled with ASA Lana Belohlavek and Attorney Jack Goldberger at Mr. Krischer's office scheduled on June 1, 2006 at 9:00 am. I attempted to call ASA Lana Belohlavek to inform her of the private investigators following Mrsehowever; she was on her vacation during the week of May 22 through May 30 2006. + +On May 23, 2006, I received other phone calls from Mr. and mrs.fewho advised they were able to acquire the private investigators license plate information. The subject following them was again driving very aggressively and caused Mrs. alto run off the road. mrsAllestated the vehicle is a Chevy Monte Carlo bearing Florida tag I35-XGA. The vehicle is Jared to Zachary Bechard of Jupiter Florida. Bechard is employed with Candor Investigations from Jupiter, Florida. Bechard is a licensed Private Investigator in the State of Florida. + +Since the discovery of the threat made against one of the victims in this case gm I requested subpoenas for all calls made to and received from 4IIIMOVOleduring the month of MarCh 2006 for her cell phone and home phone. I had confirmed with Florida State University the exact dates of Spring Break for 2006. The Spring Break was from March 4, 2006 through March 12, 2006. I received a subpoena from Sprint/Nextel with all calls made during the month of March 2006. I reviewed the 989 calls made and received during the month of March 2006. I observed on March 7, 2006, US made and received thirty five calls during that day. + +Date Time Seconds In/Out To/From 7-Mar-06 11:03 AM 492 Outbound 561XXXX 7-Mar-06 11:16 AM 6 Inbound 561XXXX 7-Mar-06 11:22 AM 887.2 Inbound 561XXXX 7-Mar-06 11:37 AM 48 Outbound 9178553363 7-Mar-06 11:39 AM 28.2 Inbound 2125356831 7-Mar-06 12:02 PM 727.2 Inbound 2125356831 + +the table reflects the date of the calls, time of day (EST), duration + +## tte: 7/19/06 PALM BEACH POLICE DEPARTMENT .me: 15:01:37 Incident Page: 87 Report Program: CMS301L + +.se No • 1-05-000368 (Continued) fromiONOMOMPphone. of call in seconds, inbound or outbound calls and calls made to or On March 7, 2006, at 11:03 am, Offillnade acall + +to the victimilftwhich The victim then returned lasted the 492seconds (8 minutes and 2 seconds). The victim call at 11:16 am which lasted 6 seconds. + +(14 minutes and then 6 made contact with at 11:22 am for 877.2 seconds with what the seconds). These sequences of calls were consistent victim had described to me on the date of the a intimidation. call to Immediately after speaking with the victim, illamakes , Epstein's assistant, which lasts for forty-eig number ie.,istered as leggP I Acall is then immediately received, a telephone located at to a Corporation affiliated with Jeffrey Epstein revealed 457 457 Madison Madison Ave in New York. An extensive computer check his corporations Ave is a business address in which Epstein has assigned to. Epstein had corporation attorney, Darren agent. Indyke, I also observed register the businesses and register himself as an New Epstein has his El Zorro Ranch Corporation, and the York Financial Strategy Group, Ghislaine Corporation, J Epstein and Company Finally, Strategy Group registered to this same address. corporate a number third call is received by at 12:02 pm from the same noted that there which lasts 12 minutes and 1 second. It should be the month of is no further contact with either the victim during further contact March with or April of 2006. i also noted that there was no remainder or Jeffrey Epstein during the of the month o rApril 2006. + +meeting on June that 1, 2006, occurred ASA Lana Belohlavek telephoned me to inform of the this case. with Atty. Jack Goldberger and her ref nce file on this She case advised she would make her determination pn whether to or not by Monday June 5, 2006. + +Inv Continues. + +NARRATIVE # 46 Reported By: RECAREY, 7/12/06 Entered By.: ALTOMARO, E A. 7/12/06 + +that On June the 29, case 2006, I had spoken to ASA Lana Belohlavic who informed me informed would be sent to the Grand Jury for charges. She the Epstein me case. that the grand jury would convene on July 19, 2006 to hear the determination Belohlavic stated State Attorney Barry Krisher made to go the Grand Jury to hear the case. + +inquired On July 12, about 2006, I spoke with Mrs./III mother of the victim, S who told we would the status of the case. I explained to her that I was 2006. She be going to the Grand Jury during the week of July 19, stated she had not been contacted as of yet by the State telephone Attorney's Office for any information. 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+Defendant. + +R + +The United States Attorney charges that: + +## COUNT + +In or around October 2005, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendant, F + +JEFFREY EPSTEIN, + +did intentionally harass another person, that is, Jane Doe #1, in an attempt to delay, prevent, and dissuade Jane Doe #1 from reporting to a law enforcement officer of the United States the commission of a federal offense; in violation of Title 18, United State Tode, Sections 1512(O2) and 2. + +## COUNT 2 + +In or around 2005, in the special territorial jurisdiction of the United States, that is, in an aircraft owned by a United States citizen while in flight over the high seas, and elsewhere, the defendant, + +JEFFREY EPSTEIN, + +did kno y commit a simple assault on a person who was over the age of 16 years, that is, S.R.; in viola • Title 18, United States Code, Section 113(aX5). + +IL ALEXANDER AC UNITED STATES ATTORNEY + +A. 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OF RA. MIAMI + +FILED by 1k D C INTAKE MAY - 1 2009 I STEVEN M....A/MORE J CLERK V.S. MST. CT + +COMPLAINT AND Defendant. DEMAND FOR JURY TRIAL + +# COMPLAINT AND DEMAND FOR JURY TRIAL + +Plaintiff, Jane Doe No. 102, brings this Complaint against Defendant, Jeffrey Epstein, and states as follows: + +### PARTIES. JURISDICTION. AND VENUE + +- 1. At all times material to this cause of action, Plaintiff, Jane Doe No. 102, was a resident of Palm Beach County, Florida. +- 2. This Complaint is brought under a fictitious name to protect the identity of Plaintiff, Jane Doc No. 102, because this Complaint makes sensitive allegations of sexual assault and abuse of a then minor. +- 3. At all times material to this cause of action, Defendant, Jeffrey Epstein, had a residence located at 358 El Brillo Way, Palm Beach, Palm Beach County, Florida. +- 4. Defendant, Jeffrey Epstein, is currently a citizen of the State of Florida, as he is currently incarcerated in the Palm Beach County Stockade. +- 5. At all times material to this cause of action, Defendant, Jeffrey Epstein, was an adult male born in 1953. + +6. This Court has jurisdiction over this action and the claims set forth herein pursuant to 18 U.S.C. § 2255. + +7. This Court has venue of this action pursuant to 28 U.S.C. § 1391(b), as a substantial part of the events giving rise to the claim occurred in this District. + +# STATEMENT OF FACTS + +8. At all relevant times, Defendant, Jeffrey Epstein, was an adult male, spanning the ages of 45 and 55 years old. Epstein is known as a billionaire financier and money manager with a secret clientele limited exclusively to billionaires. He is a man of tremendous wealth, power, and influence. He owns a fleet of aircraft that includes a Gulfstream IV, a helicopter, and a Boeing 727, as well as a fleet of motor vehicles. Until his incarceration, he maintained his principal place of residence in the largest home in Manhattan, a 51,000-square-foot eight-story mansion on the Upper East Side. Upon information and belief, he also owns a \$6.8 million mansion in Palm Beach, Florida, a \$30 million 7,500-acre ranch in New Mexico he named "Zorro," a 70-acre private island known as Little St. James in St.M, U.S. Virgin Islands, a mansion in London's Westminster neighborhood, and a home in the Avenue Foch area of Paris. The allegations herein concern Defendant's conduct while at his lavish homes and/or numerous other locations both nationally and internationally. + +9. Upon information and belief, Defendant has a sexual preference for underage minor girls. He engaged in a plan, scheme, or enterprise in which he gained access to countless vulnerable and relatively economically disadvantaged minor girls, and sexually assaulted, molested, and/or exploited these girls, and then gave them money. + +10. Beginning in or around 1998 through in or around September 2007, Defendant used his resources and his influence over vulnerable minor girls to engage in a systematic pattern of sexually exploitative behavior. + +II. Defendant's plan and scheme reflected a particular pattern and method. Defendant coerced and enticed impressionable, vulnerable, and relatively economically less fortunate minor girls to participate in various acts of sexual misconduct that he committed upon them. Defendant's scheme involved the use of underage girls, as well as other individuals, to recruit other underage girls. Upon information and belief, Defendant and/or an authorized agent would call and alert Defendant's assistants shortly before or after he arrived at his Palm Beach residence. His assistants would call economically disadvantaged and underage girls from West Palm Beach and surrounding areas who would be enticed by the money being offered and who Defendant and/or his assistants perceived as less likely to complain to authorities or have credibility issues if allegations of improper conduct were made. The then minor Plaintiff and other minor girls, some as young as 12 years old, were transported to Defendant's Palm Beach mansion by Defendant's employees, agents, and/or assistants in order to provide Defendant with "massages." + +12. Many of the instances of illegal sexual conduct committed by Defendant were perpetrated with the assistance, support, and facilitation of at least three assistants who helped him orchestrate this child exploitation enterprise. These assistants would often arrange times for underage girls to come to Defendant's residence, transport or cause the transportation of underage girls to Defendant's residence, escort the underage girls to the massage room where Defendant would be waiting or would enter shortly thereafter, urge the underage girls to remove their clothes, deliver cash from Defendant to the underage girls and/or their procurers at the conclusion of each "massage appointment," and, upon information and belief, take nude photographs and/or videos of the underage girls for Defendant with and/or without their knowledge. Defendant would pay the procurer of each girl's "appointment" hundreds of dollars. + +13. Epstein designed this scheme to secure a private place in Defendant's Palm Beach mansion where only persons employed and invited by Epstein would be present, so as to reduce the chance of detection of Defendant's sexual abuse and prostitution as well as to make it more difficult for the minor girls to flee the premises and/or to credibly report his actions to law enforcement or other authorities. The girls were usually transported by his employees, agents, and/or assistants or by a taxicab paid for by Defendant in order to make it difficult for the girls to flee his mansion. + +14. Upon arrival at Defendant's Palm Beach mansion, each underage victim would generally be introduced to one of Defendant's assistants, who would gather the girl's personal contact information. The minor girl would then be led up a flight of stairs to a room that contained a massage table and a large shower. The staircase leading to the room was plastered with nude photographs of young girls, including some photographs depicting two or more young girls engaged in lewd acts. Upon information and belief, Defendant, Jeffrey Epstein, had such photographs in each of his six homes and/or on his computers. + +IS. At times, if it was the girl's first "massage" appointment, another female would be in the room to "lead the way" until Defendant would have her leave. Generally, Defendant would start his massage wearing only a small towel, which eventually would be removed. Defendant and/or the other female would direct the girl to massage him, giving the minor girl specific instructions as to where and how he wanted to be touched, and then direct her to remove her clothing. He would then perform one or more lewd, lascivious, and sexual acts, including masturbation, fondling the minor's breasts and/or sexual organs, touching the minor's vulva, vagina, and/or anus with a vibrator and/or back massager and/or his fina(s) and/or his penis, digitally penetrating her vagina, performing intercourse, oral sex, and/or anal sex, and/or coercing or attempting to coerce the girl to engage in lewd acts and/or prostitution and/or + +enticing the then minor girl to engage in sexual acts with another female in Defendant's presence. The exact degree of molestation and frequency with which the sexual exploitations took place varied and is not yet completely known; however, Defendant committed such acts regularly on a daily basis and, in most instances, several times a day. In order to facilitate the daily exchanges of money for sexual assault and abuse, Defendant kept U.S. currency readily available. + +16. Defendant, Epstein, traveled to his mansion in Palm Beach for the purpose of luring minor girls to his mansion to sexually abuse and/or batter them. He used the telephone to contact these minor girls for the purpose of coercing them into acts of prostitution and to enable himself to commit sexual battery against them and/or acts of lewdness in their presence, and he conspired with others, including assistants and/or his driver(s) and/or pilot(s), and his socialite friend/partner, Ghislaine Maxwell, to further these acts and to avoid police detection. Defendant's systematic pattern of sexually exploitative behavior referred to in paragraph 10 and described in paragraphs 11 through the present paragraph occurred in all of Defendant's domestic and international residences and/or places of lodging and/or modes of transportation. + +17. Consistent with the foregoing plan and scheme, Defendant used his money, wealth, and power to unduly and improperly manipulate and influence the then minor Plaintiff. A vulnerable young girl, Plaintiff was working as a changing room assistant at The Mar-A-Lego Club in Palm Beach making approximately S9 an hour when she was first lured into Defendant's sexually exploitative world. In or about the summer of 1998, when Plaintiff was merely fifteen years old while attending to her duties at Mar-A-Lago, Plaintiff was recruited by Ghislaine Maxwell, who lived, traveled, socialized, and worked with Defendant. Ms. Maxwell asked Plaintiff if she was interested in learning massage therapy and earning a great deal of money while learning the profession. Plaintiff's father, who was a maintenance manager at The Mar-A- + +Lago Club, was not apprehensive because he felt comforted that an older woman had approached Plaintiff with this opportunity. As a result, Plaintiff's father dropped off Plaintiff at Defendant's mansion that same day. Ms. Maxwell met Plaintiff and her father outside of Defendant's Palm Beach mansion, where Ms. Maxwell assured the minor girl's father that Ms. Maxwell would provide transportation home for his teenaged daughter. Ghislaine Maxwell led Plaintiff up a flight of stairs to a spa room with a shower and a massage table. Defendant was lying naked on the massage table. Plaintiff was shocked, but, with no experience with massages, thought this could be massage therapy protocol. Ms. Maxwell then took off her own shirt and left on her underwear and started rubbing her breasts across Defendant's body, impliedly showing Plaintiff what she was expected to do. Ms. Maxwell then told Plaintiff to take off her clothes. The minor girl was apprehensive about doing this, but, in fear, proceeded to follow Ms. Maxwell by removing everything but her underwear. She was then ordered to remove her underwear and to straddle Defendant. The encounter escalated, with Defendant and Ms. Maxwell sexually assaulting, battering, exploiting, and abusing Plaintiff in various ways and in various locations, including the steam room and shower. At the end of this sexually exploitive abuse, Defendant and Ms. Maxwell giddily told Plaintiff to return the following day and told her she had "lots of potential." Defendant paid Plaintiff hundreds of dollars, told her it was for two hours of work, and directed one of his employees to drive her home. + +18. Defendant and/or his procurers thereafter lured the then minor Plaintiff to his Palm Beach mansion every day for the next two weeks in order to engage in a similar pattern of sexual exploitation. Defendant and/or his procurers arranged at the end of each incident the transportation and scheduling for the following day's appointment. Additionally, Defendant telephoned the minor Plaintiff himself and/or had Ms. Maxwell telephone Plaintiff to make arrangements. Plaintiff was often times driven to and from Epstein's mansion by Epstein + +himself or his driver. Alternatively, Defendant or Ms. Maxwell would arrange and pay for Plaintiff's transportation home by taxicab. + +19. During Plaintiff's second incident of being sexually exploited and assaulted by Defendant at Defendant's Palm Beach mansion, Defendant asked Plaintiff to quit her job at The Mar-A-Lego Club and travel with him to earn much more money while learning the massage profession. Thus, Plaintiff, an impressionable and vulnerable young girl of modest means, quit her job as a changing room assistant, was lured by Defendant, and continued to be victimized by Defendant, who immersed the minor Plaintiff into Defendant's lewd and abusive lifestyle. Under Defendant's dominion and control, Defendant continuously "groomed" the minor adolescent. Defendant's daily routine required the minor Plaintiff to perform sexually on Defendant multiple times per day and to provide Defendant massages multiple times per day. Plaintiff had absolutely no say as to when, how many times, or what was done during each sexual encounter. Often, Plaintiff was joined by Ms. Maxwell, Ms. Maxwell's assistant, and/or a countless array of young women who would be brought to one of Defendant's homes for the sexual trysts and then be sexually exploited by Defendant. + +20. The first time that Defendant transported Plaintiff to another state in order to engage in sexual acts with her occurred when she was merely fifteen years old and after only two weeks of daily sexually abusive encounters with Defendant. Defendant used his private jet to transport the minor Plaintiff to Manhattan, where he provided her with spending money and accommodations with him at his mansion. From the time that Plaintiff was 15 years old, Defendant abused her to serve his every sexual whim, obtaining and purchasing passports and whatever was needed for her to travel with him and/or for him. Defendant transported Plaintiff in his private jet to locations that included Palm Beach, New York City, Santa Fe, Los Angeles, San Francisco, St. Louis, and numerous other domestic destinations, as well as international + +destinations, including Europe, the Caribbean, and Africa. He provided accommodations with him in order to have her available to him at all times wherever he went, including while transporting the minor Plaintiff on his private jet. Each time they would travel to one of these destinations, the same pattern of sexual abuse would occur, often with a vast array of aspiring models, actresses, celebrities, and/or other females, including minors, from all over the world. Upon information and belief, Defendant transported minor girls from Turkey, the Czech Republic, Asia, and numerous other countries, many of whom spoke no English. To Plaintiff's knowledge, the only females specifically excluded from Defendant's sexual escapades were African-Americans. + +21. In addition to being continually exploited to satisfy Defendant's every sexual whim, Plaintiff was also required to be sexually exploited by Defendant's adult male peers, including royalty, politicians, academicians, businessmen, and/or other professional and personal acquaintances. Whenever Defendant transported Plaintiff with him in his private jet to any destination, Defendant would pay Plaintiff a flat rate per day while he and/or his abovementioned associates would sexually exploit and abuse minor Plaintiff. + +22. Most of these acts of abuse occurred during a time when Defendant knew that Plaintiff was approximately 15, 16, and 17 years old, and, after years of daily sexual exploitation, continued into her adulthood. Despite Defendant's stating shortly before Plaintiff's sixteenth birthday that he soon would have to trade her in because she was getting too old, Defendant continued to sexually exploit Plaintiff until she fled at age 19. Defendant's predilection for young girls was well known to those who regularly procured them for him and to his circle of friends. On one of Defendant's birthdays, a friend of Defendant sent him three 12-year-old girls from France who spoke no English for Defendant to sexually exploit and abuse. After doing so, they were sent back to France the next day. + +23. Any assertions by Defendant that he was unaware of the age of the then minor Plaintiff are belied by his own actions, and are rendered irrelevant by the provision of applicable federal statutes concerning the sexual exploitation and abuse of a minor child. Defendant, Jeffrey Epstein, at all times material to this cause of action, knew and should have known of Plaintiff's age of minority. Defendant and Ms. Maxwell acknowledged and celebrated Plaintiff's 16th birthday. Defendant's preference for underage girls was well-known to those who regularly procured them for him. + +24. As previously stated in paragraph 14, Defendant displayed nude photographs of underage girls throughout his homes in New York City, Palm Beach, Santa Fe, and the U.S. Virgin Islands. Plaintiff, Jane Doe No. 102, saw photographs of naked young girls in each of Defendant's homes, including a photograph of herself naked at Defendant's home in Palm Beach. When she asked Defendant about it, he stated dismissively that he had naked photographs of her in all of his homes. + +25. Upon information and belief, some of the photographs in Defendant's possession were taken with hidden cameras set up in his home in Palm Beach. On the day of his arrest, police found two hidden cameras and photographs of underage girls on a computer in Defendant's home. Upon information and belief, Defendant may have taken lewd photographs of Plaintiff, Jane Doe No. 102, with his hidden cameras and may have transported lewd photographs of Plaintiff (among many other victims) to his other residences and elsewhere using a facility or means of interstate and/or foreign commerce. In addition, while Plaintiff was a minor teenager and upon Ms. Maxwell's insistence after Ms. Maxwell rejected as inappropriate photographs that Plaintiff presented of herself fully clothed, Ms. Maxwell photographed Plaintiff naked in different sexually explicit positions. Ms. Maxwell then presented these nude photographs of Plaintiff to Defendant as a birthday present for Defendant from Ms. Maxwell. + +Upon information and belief, one or more nude photographs of Plaintiff that were taken when she was a minor were confiscated by the Palm Beach Sheriff's Office during its execution of a search warrant of Defendant's Palm Beach mansion on October 20, 2005. Upon information and belief, those photographs are still in the custody of law enforcement. + +26. It is virtually impossible to calculate the exact number of times that Defendant sexually exploited and abused Plaintiff. From the age of 15, Plaintiff was sexually exploited and abused by Defendant on a daily basis and, most often, multiple times each day. While some of the precise dates these acts occurred are unknown to Plaintiff, these dates are known to Defendant, as he is reported to have kept a written log of each instance in which he engaged in these lewd acts with then minor Plaintiff and others. Upon information and belief, these logs are also in the custody of law enforcement. + +27. In or around September 2002, Defendant purchased a commercial round-trip airline ticket, and provided a passport, U.S. currency, and accommodations for Plaintiff to fly to Thailand. While thousands of miles away from Defendant on this extended trip alone for the first time in more than four years, Plaintiff met, fell in love, and married a young man. She escaped from Defendant's abuse with the help and insistence of her new husband and, instead of returning to Defendant, boarded a plane to Australia with one suitcase. + +28. Since November 2002, Plaintiff has lived a modest life in Australia, while maintaining lines of communication with her family and without contact with Defendant or any of the people in his entourage. However, suddenly, in 2008, Plaintiff received numerous phone calls from one of Defendant's agents. During these phone calls to Plaintiff, he repeatedly asked whether she knew anything about the civil cases against Defendant, whether she knew any of the females who were proceeding with the civil suits, whether she was planning on filing suit, whether she was communicating and/or cooperating with anyone against Defendant, and whether + +she would return to the United States to testify. Terrified by Defendant's demonstrated ability to track her down on her changed cell phone number halfway across the world, Plaintiff attempted to reassure Defendant's agent that she would remain quiet. During the course of one of these phone calls from Defendant's agents, Defendant himself spoke on the phone, continued to question her intentions, and, upon being reassured by Plaintiff, thanked her for not getting involved. + +29. Around January 2009, Plaintiff received aletter from the United States Attorney's Office for the Southern District of Florida, informing her of her potential civil claims against Defendant under 18 U.S.C. § 2255. Plaintiff contacted undersigned counsel within days and diligently and repeatedly pursued a good faith viable settlement of her claims against Defendant. Unable to reach a settlement, this lawsuit followed. + +30. As a result of these encounters with Defendant, Plaintiff, Jane Doe No. 102, has in the past suffered, and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, separation from her family, and other damages associated with Defendant's controlling and manipulating her on adaily basis for years into aperverse and unhealthy way of life. + +31. Defendant, Jeffrey Epstein, committed the above-referenced acts upon Plaintiff in violation of federal statutes condemning the coercion and enticement of aminor to engage in prostitution or sexual activity, travel with intent to engage in illicit sexual conduct, sex trafficking of children, sexual exploitation of minor children, transport of visual depictions of a minor engaging in sexually explicit conduct, transport of child pornography, child exploitation enterprises, and other crimes, specifically including, but not limited to, those crimes designated + +in 18 U.S.C. § 2421, § 2422(a), § 2422(b), § 2423(a), § 2423(b), § 2423(e), § 2251, § 2252, § 2252A(a)(1), and § 2252A(gX1). + +32. In June 2008, after investigations by the Palm Beach Police Department, the Palm Beach State Attorney's Office, the Federal Bureau of Investigation, and the United States Attorney's Office for the Southern District of Florida, Defendant, Jeffrey Epstein, entered pleas of "guilty" to various Florida state crimes involving the solicitation of minors for prostitution and the procurement of minors for the purposes of prostitution in the Fifteenth Judicial Circuit in Palm Beach County, Florida. Defendant, Jeffrey Epstein, is in the same position as if he had been tried and convicted of the sexual offenses committed against Plaintiff and, as such, must admit liability unto Plaintiff, Jane Doe No. 102. Plaintiff hereby exclusively seeks civil remedies pursuant to 18 U.S.C. § 2255. + +### COUNT ONE (Cause of Action for Coercion and Enticement of Minor to Engage in Prostitution or Sexual Activity pursuant to 18 U.S.C. 6 2255 in Violation of 18 U.S.C. 5 2422(612 + +33. Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs I through 32 above. + +34. Defendant, Jeffrey Epstein, used a facility or means of interstate and/or foreign commerce to knowingly persuade, induce, entice, or coerce Jane Doe No. 102, when she was under the age of 18 years, to engage in prostitution and/or sexual activity for which any person can be charged with a criminal offense, or attempted to do so, pursuant to 18 U.S.C. § 2255 in violation of 18 U.S.C. § 2422(b). + +35. Plaintiff, Jane Doe No. 102, was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code. + +36. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, separation from her family, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to suffer these losses in the future. + +WHEREFORE, Plaintiff, Jane Doe No. 102, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. + +### COUNT TWO (Cause of Action for Transportation of Minor with Intent to Ensue in Criminal Sexual Activity pursuant to IS U.S.C. 6 2255 in Violation of 18 U.S.C. 6 2423(a)1 + +37. Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 32 above. + +38. Defendant, Jeffrey Epstein, knowingly transported then minor Plaintiff, Jane Doe No. 102, in interstate and/or foreign commerce, with the intent that Plaintiff engage in prostitution, or in any sexual activity for which any person can be charged with a criminal offense, in violation 18 U.S.C. § 2423(a). As previously stated in paragraphs 20, 21, and 27. Defendant transported Plaintiff, Jane Doe No. 102, across state lines and across international borders numerous times from the time that Plaintiff was merely 15 years old through adulthood with the primary intent of sexually exploiting her. + +39. Plaintiff, Jane Doe No. 102, was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code. + +40. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, separation from her family, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses, and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to suffer these losses in the future. + +WHEREFORE, Plaintiff, Jane Doe No. 102, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages. attorney's fees, costs of suit, and such other further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. + +#### COUNT THREE 'Cause of Action for Travel with Intent to Estate in Illicit Sexual Conduct Pursuant to 18 U.S.C. 6 2255 in Violation of 18 U.S.C. 8 24230)11 + +41. Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 32 above. + +42. Upon information and belief, Defendant, Jeffrey Epstein, traveled in interstate and/or foreign commerce with the intent to engage in illicit sexual conduct, as defined in 18 U.S.C. § 2423(f), with minor females, including the then minor Plaintiff, in violation of 18 U.S.C. § 2423(b). + +43. Plaintiff, Jane Doe No. 102, was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code. + +44. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, separation from her family, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to suffer these losses in the future. + +WHEREFORE, Plaintiff, Jane Doe No. 102, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, + +actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. + +#### COUNT FOUR (Cause of Action for Coercion and Enticement to Emmet in Prostitution or Sexual Activity pursuant to 18 U.S.C. 6 2255 in Violation of 18 U.S.C. 6 2422(all + +45. Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 32 above. + +46. Defendant, Jeffrey Epstein, knowingly persuaded, induced, enticed, and/or coerced Jane Doe No. 102 to travel in interstate and/or foreign commerce to engage in prostitution and/or sexual activity for which any person can be charged with a criminal offense, or attempted to do so, pursuant to 18 U.S.C. § 2255 in violation of 18 U.S.C. § 2422(a). + +47. Plaintiff, Jane Doe No. 102, was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code. + +48. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, separation from her family, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn + +income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to suffer these losses in the future. + +WHEREFORE, Plaintiff, Jane Doe No. 102, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. + +### COUNT FIVE (Cause of Action for Transportation with Intent to Ellefle in Criminal Sexual Activity pursuant to 18 V,S,C. 6 2255 in Violation of 18 U.S.C. 4.24211 + +49. Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 32 above. + +50. Defendant, Jeffrey Epstein, knowingly transported, or attempted to transport, Plaintiff, Jane Doe No. 102, in interstate and/or foreign commerce, with the intent that Plaintiff engage in prostitution and/or in any sexual activity for which any person can be charged with a criminal offense, in violation of 18 U.S.C. § 2421. As previously stated in paragraphs 20, 21, and 27, Defendant transported Plaintiff, Jane Doe No. 102, across state lines and across international borders numerous times from the time that Plaintiff was merely 15 years old through adulthood with the primary intent of sexually exploiting her. + +51. Plaintiff, Jane Doe No. 102, was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code. + +52. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, + +psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, separation from her family, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life for a minor. The then minor Plaintiff incurred medical and psychological expenses, and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to suffer these losses in the future. + +WHEREFORE, Plaintiff, Jane Doe No. 102, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. + +### COUNT SIX (Cause of Action for Sexual Exploitation of Children pursuant to 18 U.S.C. 6 2255 in Violation of 18 U.S.C. 5 22511 + +53. Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 32 above. + +54. Defendant, Jeffrey Epstein, knowingly persuaded, induced, enticed, or coerced the then minor Plaintiff to engage in sexually explicit conduct for the purpose of producing a visual depiction of such conduct, in violation of 18 U.S.C. § 2251. As previously stated in paragraphs 14, 24, and 25, Defendant kept and displayed a myriad of nude photographs of underage girls throughout his homes, including his homes in New York City, Palm Beach, Santa Fe, and the U.S. Virgin Islands. Plaintiff, Jane Doe No. 102, saw photographs of naked young girls in each of Defendant's homes, including a photograph of herself naked at Defendant's home in Palm + +Beach. Upon information and belief, many of the photographs in the possession of Defendant were taken with hidden cameras set up in his home in Palm Beach. On the day of his arrest, police found two hidden cameras and photographs of underage girls on a computer in Defendant's home. Upon information and belief, Defendant, Jeffrey Epstein, may have taken lewd photographs of Plaintiff, Jane Doe No. 102, with his hidden cameras and may have transported lewd photographs of Plaintiff (among many other victims) to his other residences and elsewhere using a facility or means of interstate and/or foreign commerce. Upon information and belief, one or more nude photographs of Plaintiff that were taken when she was a minor were confiscated by the Palm Beach Sheriff's Office during its execution of a search warrant of Defendant's Palm Beach mansion on October 20, 2005. Upon information and belief, those photographs are still in the custody of law enforcement. + +55. Plaintiff, Jane Doe No. 102, was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code. + +56. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, separation from her family, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn + +income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to suffer these losses in the future. + +WHEREFORE, Plaintiff, Jane Doe No. 102, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. + +# COUNT SEVEN ICause of Action for Transport of Visual Depiction of Minor Email:it in Sexually Explicit Conduct pursuant to 18 U.S.C. 4 2255 in Violation of 18 U.S.C. 8 2252(a)(1)1 + +57. Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 32 above. + +58. Defendant, Jeffrey Epstein, knowingly mailed, transported, shipped, or sent via computer and/or facsimile in or affecting interstate and/or foreign commerce at least one visual depiction of the minor Plaintiff engaging in sexually explicit conduct, in violation of 18 U.S.C. § 2252(a)( I ). As previously stated in paragraphs 14, 24, and 25, Defendant displayed a myriad of nude photographs of underage girls throughout his homes, including his homes in New York City, Palm Beach, Santa Fe, and the U.S. Virgin Islands. Plaintiff, Jane Doe No. 102, saw photographs of naked young girls in each of Defendant's homes, including a photograph of herself naked as a minor at Defendant's home in Palm Beach. As previously stated in paragraph 24, Defendant told Plaintiff that he had photographs of her naked in all of his homes. Upon information and belief, many of the photographs in the possession of Defendant were taken with hidden cameras set up throughout his home in Palm Beach. On the day of his arrest, police found two hidden cameras and nude photographs of underage girls on a computer in Defendant's home. Upon information and belief, Defendant, Jeffrey Epstein, may have taken lewd + +photographs of Plaintiff, Jane Doe No. 102, with his hidden cameras and may have transported lewd photographs of Plaintiff (among many other victims) to his other residences and elsewhere using a facility or means of interstate and/or foreign commerce. Upon information and belief, one or more nude photographs of Plaintiff that were taken when she was a minor were confiscated by the Palm Beach Sheriff's Office during its execution of a search warrant of Defendant's Palm Beach mansion on October 20, 2005. Upon information and belief, those photographs arc still in the custody of law enforcement. + +59. As previously stated in paragraph 23, any assertions by Defendant that he was unaware of the agc of the then minor Plaintiff are belied by his actions and rendered irrelevant by the provision of applicable federal and state statutes concerning the sexual exploitation and abuse of a minor child. Defendant, Jeffrey Epstein, at all times material to this cause of action, knew and should have known of Plaintiffs age of minority. Defendant's preference for underage girls was well-known to those who regularly procured them for him. + +60. Plaintiff, Jane Doe No. 102, was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code. + +61. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, separation from her family, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, and Plaintiff will in the future suffer additional medical and + +psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to suffer these losses in the future. + +WHEREFORE, Plaintiff, Jane Doe No. 102, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. + +#### COUNT EIGHT (Cause of Action for Transport of Child Pornoaranbv pursuant to 18 U.S.C. 5 2255 la Violation of 18 U.S.C. 5 2252A(a)(1)) + +62. Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs 1 through 32 above. + +63. Defendant, Jeffrey Epstein, knowingly mailed, transported, shipped, or sent via computer and/or facsimile in or affecting interstate and/or foreign commerce child pornography in violation of 18 U.S.C. § 2252A(a)( I ). + +64. Plaintiff, Jane Doe No. 102, was a victim of one or more offenses enumerated in 18 U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code. + +65. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, separation from her family, and other damages associated with Defendant's manipulating and + +leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to suffer these losses in the future. + +WHEREFORE, Plaintiff, Jane Doe No. 102, demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. + +#### COUNT NINE iCause of Action for Eneadne in a Child Exploitation Enterprise pursuant to 18 U.S,C. 7255 in Violation of 18 U.S.C. ti 22S2A(01 + +66. Plaintiff, Jane Doe No. 102, hereby adopts, repeats, realleges, and incorporates by reference the allegations contained in paragraphs I through 32 above and Counts One through Eight above. + +67. Defendant, Jeffrey Epstein, knowingly engaged in a child exploitation enterprise, as defined in 18 U.S.C. § 2252A(g)(2), in violation of 18 U.S.C. § 2252A(gX1). As more fully set forth above, Defendant engaged in actions that constitute countless violations of 18 U.S.C. § 1591 (sex trafficking of children), Chapter 110 (sexual exploitation of children in violation of 18 U.S.C. §§ 2251, 2252(aX1), and 2252(A)(a)(1)), and Chapter 117 (transportation for illegal sexual activity in violation of 18 U.S.C. §§ 2421, 2422, and 2423). As more fully set forth above in paragraphs 9 through 32, Defendant's actions involved countless victims and countless separate incidents of sexual abuse, which he committed against minors, including Plaintiff, in concert with at least three other persons. + +68. Plaintiff, Jane Doe No. 102, was a victim of one or more offenses enumerated in 18U.S.C. § 2255, and, as such, asserts a cause of action against Defendant, Jeffrey Epstein, pursuant to this Section of the United States Code. + +69. As a direct and proximate result of the offenses enumerated in 18 U.S.C. § 2255 being committed against the then minor Plaintiff by Defendant, Plaintiff has in the past suffered, and will in the future continue to suffer, physical injury, pain and suffering, emotional distress, psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, separation from her family, and other damages associated with Defendant's manipulating and leading her into a perverse and unhealthy way of life. The then minor Plaintiff incurred medical and psychological expenses, and Plaintiff will in the future suffer additional medical and psychological expenses. Plaintiff has suffered a loss of income, aloss of the capacity to earn income in the future, and a loss of the capacity to enjoy life. These injuries are permanent in nature, and Plaintiff will continue to suffer these losses in the future. + +WHEREFORE, Plaintiff, Jane Doe No. 102. demands judgment against Defendant, Jeffrey Epstein, for all damages available under 18 U.S.C. § 2255, including, without limitation, actual and compensatory damages, attorney's fees, costs of suit, and such other further relief as this Court deems just and proper, and hereby demands trial by jury on all issues triable as of right by a jury. + +Date: May 1, 2009 + +Pk Lit/4 -sttiiA-.6b . XK4,1E Robert C. Josefsba No. 04085 + +Katherine W. Ezell, Bar No. 114771 + +Podhurst 0rseck, P.A. + +25 West Flagler Street, Suite 800 + +Miami, Florida 33130 + +(305) 358-2800 + +(305) 358-2382 (fax) + +riosefsbergAvodhurst.com + +kezelMoocilturst.com + +Attorneys for Plaintiff- + +# DEMAND FOR JURY TRIAL + +Plaintiff demands to have her case tried before a jury. + +Lit e4+4('-f + +Robert C. Jose rg, Bar No. 04 56 + +Katherine W. Ezell, Bar No. 114771 + +Podhurst Orseck, P.A. + +25 West Flaglcr Street, Suite 800 + +Miami, Florida 33130 + +(305) 358-2800 + +(305) 358-2382 (fax) + +riosefsbera(cPpodhurst.com + +kezellavodhurst.cona + +Attorneys for Plaintiff + +The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.) **NOTICE: Attorneys MUST Indicate All Re-filed Cases Below.** + +**I. (a) PLAINTIFFS** + +Jane Doe No. 102 + +(b) County of Residence of First Listed Plaintiff West Palm Beach + (EXCEPT IN U.S. PLAINTIFF CASES) + +(c) Attorney's (Firm Name, Address, and Telephone Number) + +Robert C. Josefsberg, Esq./Katherine W. Ezell, Esq. + Podhurst Orseck, P.A. + 25 W. Flagler St., Suite 800 + Miami Fl 33130 + +(d) Check County Where Action Arose: MIAMI-DADE MONROE BROWARD PALM BEACH ST. LUCIE INDIAN CITY MIAMI-HOBE + +**DEFENDANTS** + +Jeffrey Epstein + +County of Residence of First Listed Defendant West Palm Beach + (IN U.S. PLAINTIFF CASES ONLY) + +NOTE: IN LAND CONDEMNATION CASES SEE LSD DIV. LOCATION OF THE TRACT INTAKE + +Attorneys (If Known) + +Jack A. Goldberger, Esq., Atterbury Goldberger, et al., 250 S. Australian Ave., #1400, West Palm Beach, PEN 1640 WHITE CT REC'D J. MARCHOBE + +**II. BASIS OF JURISDICTION** + +(Place an "X" in One Box Only) + +- 1 U.S. Government Plaintiff 3 Federal Question (U.S. Government Not a Party) +- 2 U.S. Government Defendant 4 Diversity (Indicate Citizenship of Parties in Item III) + +**III. CITIZENSHIP OF PRINCIPAL PARTIES** + +(Place an "X" in One Box for Plaintiff and One Box for Defendant) + +| Citizen of This State | PTF | DEF | PTF | DEF | +|-----------------------|-----|-----|---------------------------------------------------------------|-----| +| | 1 | 1 | Incorporated or Principal Place of Business In This State | 4 | +| | 2 | 2 | Incorporated and Principal Place of Business In Another State | 5 | +| | 3 | 3 | Foreign Nation | 6 | +| | | | | 6 | + +**IV. NATURE OF SUIT** (Place an "X" in One Box Only) + +| CONTRACT | TORTS | FORFEITURE/PENALTY | BANKRUPTCY | OTHER STATUTES | | | | | | | | | | | | | | | | | | | | | | | | | +|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------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+| 110 Insurance
120 Marine
130 Act
140 Negotiable Instrument
150 Recovery of Overpayment & Enforcement of Judgment
151 Medicare Act
152 Recovery of Defaulted Student Loans (Excl. Veterans)
153 Recovery of Overpayment of Veteran's Benefits
160 Stockholders' Suits
190 Other Contract
195 Contract Product Liability
196 Franchise | 310 Airplane
315 Airplane Product Liability
320 Assault, Libel & Slander
330 Federal Employers' Liability
340 Marine
345 Marine Product Liability
350 Motor Vehicle
355 Motor Vehicle Product Liability
360 Other Personal Injury | 362 Personal Injury - Med. Malpractice
365 Personal Injury - Product Liability
368 Asbestos Personal Injury Product Liability
370 Other Fraud
371 Truth in Lending
380 Other Personal Property Damage
385 Property Damage Product Liability | 610 Agriculture
620 Other Food & Drug
625 Drug Related Seizure of Property 21 USC 88
630 Liquor Laws
640 R.R. & Truck
650 Airline Regs.
660 Occupational Safety/Health
690 Other | 422 Appeal 28 USC 158
423 Withdrawal 28 USC 157
PROPERTY RIGHTS
820 Copyrights
830 Patent
840 Trademark 		420 Appeal 28 USC 158
423 Withdrawal 28 USC 157
PROPERTY RIGHTS
820 Copyrights
830 Patent
840 Trademark 		470 Racketer Influenced and Corrupt Organizations
480 Consumer Credit
490 Cable/Sat TV
810 Selective Service
850 Securities/Commodities/Exchange
875 Customer Challenge 12 USC 3410
890 Other Statutory Actions
891 Agricultural Acts
892 Economic Stabilization Act
893 Environmental Matters
894 Energy Allocation Act
895 Freedom of Information Act
900 Appeal of Fee Determination Under Equal Access to Justice
950 Constitutionality of State Statutes
REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS LABOR SOCIAL SECURITY
210 Land Condemnation
220 Foreclosure
230 Rent Lease & Ejectment
240 Torts to Land
245 Tort Product Liability
290 All Other Real Property 		441 Voting
442 Employment
443 Housing/Accommodations
444 Welfare
445 Amer. w/Disabilities - Employment
446 Amer. w/Disabilities - Other
440 Other Civil Rights 		510 Motions to Vacate Sentence
530 General
535 Death Penalty
540 Mandarmus & Other
550 Civil Rights
555 Prison Condition 		710 Fair Labor Standards Act
720 Labor/Mgmt. Relations
730 Labor/Mgmt. Reporting & Disclosure Act
740 Railway Labor Act
790 Other Labor Litigation
791 Empl. Ret. Inc. Security Act 		861 HIA (1395ff)
862 Black Lung (923)
863 DIWC/DIWW (405(g))
864 SSID Title XVI
865 RSI (405(g))
870 Taxes (U.S. Plaintiff or Defendant)
871 IRS—Third Party 26 USC 7609
CHECK IF THIS IS A CLASS ACTION UNDER F.R.C.P. 23 Re-filed-(see VI below) Reinstated or Reopened Transferred from another district (specify) Multidistrict Litigation Appeal to District Judge from Magistrate Judgment
| PROPERTY RIGHTS | | 820 Copyrights
830 Patent
840 Trademark | 420 Appeal 28 USC 158
423 Withdrawal 28 USC 157
PROPERTY RIGHTS
820 Copyrights
830 Patent
840 Trademark 		470 Racketer Influenced and Corrupt Organizations
480 Consumer Credit
490 Cable/Sat TV
810 Selective Service
850 Securities/Commodities/Exchange
875 Customer Challenge 12 USC 3410
890 Other Statutory Actions
891 Agricultural Acts
892 Economic Stabilization Act
893 Environmental Matters
894 Energy Allocation Act
895 Freedom of Information Act
900 Appeal of Fee Determination Under Equal Access to Justice
950 Constitutionality of State Statutes
| PROPERTY RIGHTS | | 820 Copyrights
830 Patent
840 Trademark | 470 Racketer Influenced and Corrupt Organizations
480 Consumer Credit
490 Cable/Sat TV
810 Selective Service
850 Securities/Commodities/Exchange
875 Customer Challenge 12 USC 3410
890 Other Statutory Actions
891 Agricultural Acts
892 Economic Stabilization Act
893 Environmental Matters
894 Energy Allocation Act
895 Freedom of Information Act
900 Appeal of Fee Determination Under Equal Access to Justice
950 Constitutionality of State Statutes | REAL PROPERTY | CIVIL RIGHTS | PRISONER PETITIONS | LABOR | SOCIAL SECURITY | 210 Land Condemnation
220 Foreclosure
230 Rent Lease & Ejectment
240 Torts to Land
245 Tort Product Liability
290 All Other Real Property | 441 Voting
442 Employment
443 Housing/Accommodations
444 Welfare
445 Amer. w/Disabilities - Employment
446 Amer. w/Disabilities - Other
440 Other Civil Rights | 510 Motions to Vacate Sentence
530 General
535 Death Penalty
540 Mandarmus & Other
550 Civil Rights
555 Prison Condition | 710 Fair Labor Standards Act
720 Labor/Mgmt. Relations
730 Labor/Mgmt. Reporting & Disclosure Act
740 Railway Labor Act
790 Other Labor Litigation
791 Empl. Ret. Inc. Security Act | 861 HIA (1395ff)
862 Black Lung (923)
863 DIWC/DIWW (405(g))
864 SSID Title XVI
865 RSI (405(g))
870 Taxes (U.S. Plaintiff or Defendant)
871 IRS—Third Party 26 USC 7609 | CHECK IF THIS IS A CLASS ACTION UNDER F.R.C.P. 23 | Re-filed-(see VI below) | Reinstated or Reopened | Transferred from another district (specify) | Multidistrict Litigation | Appeal to District Judge from Magistrate Judgment | +| PROPERTY RIGHTS | | | | | | | | | | | | | | | | | | | | | | | | | | | | | +| 820 Copyrights
830 Patent
840 Trademark | 420 Appeal 28 USC 158
423 Withdrawal 28 USC 157
PROPERTY RIGHTS
820 Copyrights
830 Patent
840 Trademark 		470 Racketer Influenced and Corrupt Organizations
480 Consumer Credit
490 Cable/Sat TV
810 Selective Service
850 Securities/Commodities/Exchange
875 Customer Challenge 12 USC 3410
890 Other Statutory Actions
891 Agricultural Acts
892 Economic Stabilization Act
893 Environmental Matters
894 Energy Allocation Act
895 Freedom of Information Act
900 Appeal of Fee Determination Under Equal Access to Justice
950 Constitutionality of State Statutes
| PROPERTY RIGHTS | | 820 Copyrights
830 Patent
840 Trademark | 470 Racketer Influenced and Corrupt Organizations
480 Consumer Credit
490 Cable/Sat TV
810 Selective Service
850 Securities/Commodities/Exchange
875 Customer Challenge 12 USC 3410
890 Other Statutory Actions
891 Agricultural Acts
892 Economic Stabilization Act
893 Environmental Matters
894 Energy Allocation Act
895 Freedom of Information Act
900 Appeal of Fee Determination Under Equal Access to Justice
950 Constitutionality of State Statutes | | | | | | | | | | | | | | | | | | | | | | | | +| PROPERTY RIGHTS | | | | | | | | | | | | | | | | | | | | | | | | | | | | | +| 820 Copyrights
830 Patent
840 Trademark | 470 Racketer Influenced and Corrupt Organizations
480 Consumer Credit
490 Cable/Sat TV
810 Selective Service
850 Securities/Commodities/Exchange
875 Customer Challenge 12 USC 3410
890 Other Statutory Actions
891 Agricultural Acts
892 Economic Stabilization Act
893 Environmental Matters
894 Energy Allocation Act
895 Freedom of Information Act
900 Appeal of Fee Determination Under Equal Access to Justice
950 Constitutionality of State Statutes | | | | | | | | | | | | | | | | | | | | | | | | | | | | +| REAL PROPERTY | CIVIL RIGHTS | PRISONER PETITIONS | LABOR | SOCIAL SECURITY | | | | | | | | | | | | | | | | | | | | | | | | | +| 210 Land Condemnation
220 Foreclosure
230 Rent Lease & Ejectment
240 Torts to Land
245 Tort Product Liability
290 All Other Real Property | 441 Voting
442 Employment
443 Housing/Accommodations
444 Welfare
445 Amer. w/Disabilities - Employment
446 Amer. w/Disabilities - Other
440 Other Civil Rights | 510 Motions to Vacate Sentence
530 General
535 Death Penalty
540 Mandarmus & Other
550 Civil Rights
555 Prison Condition | 710 Fair Labor Standards Act
720 Labor/Mgmt. Relations
730 Labor/Mgmt. Reporting & Disclosure Act
740 Railway Labor Act
790 Other Labor Litigation
791 Empl. Ret. Inc. Security Act | 861 HIA (1395ff)
862 Black Lung (923)
863 DIWC/DIWW (405(g))
864 SSID Title XVI
865 RSI (405(g))
870 Taxes (U.S. Plaintiff or Defendant)
871 IRS—Third Party 26 USC 7609 | | | | | | | | | | | | | | | | | | | | | | | | | +| CHECK IF THIS IS A CLASS ACTION UNDER F.R.C.P. 23 | Re-filed-(see VI below) | Reinstated or Reopened | Transferred from another district (specify) | Multidistrict Litigation | Appeal to District Judge from Magistrate Judgment | | | | | | | | | | | | | | | | | | | | | | | | + +**VI. RELATED/RE-FILED CASE(S).** + +(See instructions second page): JUDGE Kenneth A. Marra a) Re-filed Case YES NO b) Related Cases YES NO + +DOCKET NUMBER See Attached + +**VII. CAUSE OF ACTION** Cite the U.S. Civil Statute under which you are filing and Write a Brief Statement of Cause (Do not cite jurisdictional statutes unless diversity): + 18 U.S.C. 2255 (Predicate Statutes 18 U.S.C. 2422(b), 2423(b), 2423(c), 2251, 2252, 2252A(a)(1), 2252A(g)(1)) + LENGTH OF TRIAL via 4 days estimated (for both sides to try entire case) + +**VIII. REQUESTED IN COMPLAINT:** CHECK IF THIS IS A CLASS ACTION UNDER F.R.C.P. 23 DEMANDS \$ CHECK YES only if demanded in complaint: JURY DEMAND: Yes No + +ABOVE INFORMATION IS TRUE & CORRECT TO THE BEST OF MY KNOWLEDGE SIGNATURE OF ATTORNEY OF RECORD: *Katherine W. Ezell* DATE *5/1/09* + FOR OFFICE USE ONLY AMOUNT *4350.20* RECEIPT # *91000030* + +*05/01/09* + +### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA WEST PALM BEACH DIVISION + +# ATTACHMENT TO CIVIL COVER SHEET + +FOR: Jane Doe 102,v. 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LARIMORE
CLERK U.S. DIST. CT.
S.D. OF FLA. - W.P.B. | | + +UNITED STATES OF AMERICA + +## CRIMINAL COMPLAINT + +vs. + +ALFREDO RODRIGUEZ, + +CASE NUMBER: 09-8308-LRJ + +Defendant. + +I, the undersigned complainant, being duly sworn, state the following is true and correct to the best of my knowledge and belief. + +From at least as early as January 18, 2007, through on or about November 3, 2009, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendant, + +**ALFREDO RODRIGUEZ,** + +did corruptly conceal a record, document, or other object, with the intent to impair the object's availability for use in an official proceeding and otherwise corruptly obstructed or impeded an official proceeding, in violation of Title 18, United States Code, Section 1512(c). + +I further state that I am a Special Agent with the Federal Bureau of Investigation, and that this Complaint is based on the following facts: + +Please see attached Affidavit + +Continued on the attached and made a part hereof. + +![]()Sworn to before me, and subscribed in my presence, upon my finding of probable cause. + +December / , 2009 at West Palm Beach, Florida +Date City and State + +![]()![]() + +## AFFIDAVIT + +I, Christina J. Pryor, being duly sworn, do state and attest as follows: + +1. I am a Special Agent with the Federal Bureau of Investigation (FBI) and have been so employed for three (3) months. I am currently assigned to the Safe Streets Task Force, Miami Field Division, FBI Squad P13-2. Prior to joining the Miami Field Division, 1 attended the FBI Academy in Quantico, Virginia, for five (5) months where I received training in federal criminal laws and investigation techniques, including the laws related to obstruction of justice. + +2. This affidavit is based upon my own personal knowledge of the facts and circumstances surrounding the investigation, and information provided to me by other law enforcement officers. This affidavit does not purport to contain all the information known to me about this case but addresses only that information necessary to support a finding of probable cause for the issuance of a criminal complaint charging Alfredo Rodriguez with obstruction of official proceedings, in violation of Title 18, United States Code, Section 1512(c). + +3. On October 27, 2009, agents of the FBI met with and interviewed a cooperating witness ("CW"). The CW reported that, while conducting discovery in a pending civil case before the United States District Court for the Southern District of Florida, he came into contact with Alfredo Rodriguez ("Rodriguez"), who was a subpoenaed witness in the civil case. + +4. Rodriguez had been interviewed by FBI agents on January 18, 2007, in connection with a federal criminal investigation into the sexual exploitation of minors. Prior to being interviewed by FBI, Rodriguez had also been contacted and interviewed by local police detectives, and had been asked to produce documents related to the criminal investigation. The civil litigation involving the CW related to civil damages claims made by victims of the criminal activity that formed the basis of the state and federal criminal investigations. + +5. The CW explained to agents that Rodriguez had been deposed under oath on two occasions. The first deposition occurred on July 27, 2009, and the second deposition was conducted on August 9, 2009. In connection with those depositions, Rodriguez was served with a subpoena duces tecum that called for the production of several types of documentary evidence. The CW was present for both depositions and Rodriguez testified that he had no documents responsive to the subpoena duces tecum. + +6. In August 2009, after the conclusion of the second deposition, the CW received a phone call from Rodriguez. Rodriguez informed the CW that he had additional information that he had not previously disclosed to any law enforcement agency or any of the civil attorneys. Rodriguez described the information as, the Holy Grail or Golden Nugget and explained that he had compiled lists of additional victims in the case and their contact information. Rodriguez explained that the information contained hundreds of additional victims and their phone numbers from diverse geographic locations, including New York, New Mexico, and Paris, France. + +7. Rodriguez asked the CW to pay him \$50,000.00 and, in return, Rodriguez would turn over the documents relating to the victims. In his initial and subsequent + +communications with Rodriguez, the CW explained to Rodriguez that he was under subpoena to turn over such information and that it would be illegal for Rodriguez to demand money for turning over the information. Rodriguez persisted that he would only turn over the information in his possession in exchange for \$50,000.00. + +8. On October 28, 2009, in a consensually-monitored phone call, the CW telephoned Rodriguez. Rodriguez again indicated that he would not turn over the information relating to the additional victims without monetary compensation. Rodriguez was told that an associate of the CW would be in touch with him regarding the information and exchange. The associate that the CW referred to was, in fact, an undercover employee (UCE) of the FBI. + +9. On October 29, 2009, the FBI UCE contacted Rodriguez via telephone. Rodriguez again explained that he would only turn over the information in exchange for monetary compensation. The UCE advised Rodriguez that it would take several days to acquire the funds and that once the funds were obtained, he/she would contact Rodriguez. During the conversation, Rodriguez admitted that he knew that the information was relevant to the FBI's criminal investigation and was called for by the investigation. Rodriguez explained that he had not turned over the information to the FBI because: (1) it was his "property" and he should be compensated for it; and (2) he was afraid that the target of the investigation would make him "disappear" or otherwise harm him, and the information was his "insurance policy." + +10. On November 2, 2009, the UCE made contact with Rodriguez via telephone. + +In that conversation, Rodriguez and the UCE continued the discussion regarding the purchase of the documents and scheduled a meeting for the following day. + +11. On November 3, 2009, Rodriguez met with the UCE at a predetermined location. During the meeting, Rodriguez produced a small bound book and several sheets of legal pad paper containing hand written notes. Rodriguez explained that he had taken the bound book from his former employer's residence while employed there in 2004 to 2005 and that the book had been created by persons working for his former employer. Rodriguez discussed in detail the information contained within the book, and identified important information to the UCE. In addition, Rodriguez admitted he had previously lied to FBI. Rodriguez asked the UCE about the \$50,000.00, took possession of the money, and began counting it. + +12. Rodriguez was then detained for Obstruction of Official Proceedings, Title 18, U.S. Code, Section 1512(c), and questioned. After Miranda warnings were administered by agents, Rodriguez waived his rights and signed a written waiver of those rights. Rodriguez admitted that he had the documents and book in his possession and had never turned them over to local law enforcement or the FBI. In addition, Rodriguez advised he had witnessed nude girls whom he believed were underage at the pool area of his former employer's home, knew that his former employer was engaging in sexual contact with underage girls, and had viewed pornographic images of underage girls on computers in his employer's home. Rodriguez was then released from custody for further investigation. + +13. The items that Rodriguez had attempted to sell to the UC for \$50,000.00 + +were reviewed by an agent familiar with the underlying criminal investigation. As Rodriguez had described, the items contained information material to the underlying investigation that would have been extremely useful in investigating and prosecuting the case, including the names and contact information of material witnesses and additional victims. Had those items been produced in response to the inquiries of the state law enforcement officers or the FBI Special Agents, their contents would have been presented to the federal grand jury. + +Based upon the foregoing, your affiant believes that probable cause exists to believe that, from at least as early as January 18, 2007 through on or about November 3, 2009, in Palm Beach County, in the Southern District of Florida, and elsewhere, Alfredo Rodriguez did corruptly conceal a record, document, or other object, with the intent to impair the object's availability for use in an official proceeding and otherwise corruptly obstructed or impeded an official proceeding, in violation of Title 18, United States Code, Section 1512(c). + +FURTHER YOUR AFFIANT SAYETH NAUGHT. + +CH A J. P YO CI 444 ENT FEDERAL BUREAU OF VES ATION + +Sworn to and subscribed before me this day of December, 2009. + +A R. JOHNSO UNITED STAT GISTRATE JUDGE + +**UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF FLORIDA** + +Case No. 09-8308-LRJ + +**UNITED STATES OF AMERICA** + +vs. + +**ALFREDO RODRIGUEZ,** + +Defendant. +\_\_\_\_\_/ + +**CRIMINAL COVER SHEET** + +1. 1. Did this matter originate from a matter pending in the Northern Region of the United States Attorney's Office prior to October 14, 2003? \_\_\_ Yes \_\_X No +2. 2. Did this matter originate from a matter pending in the Central Region of the United States Attorney's Office prior to September 1, 2007? \_\_\_ Yes \_\_X No + +Respectfully submitted, + +JEFFREY H. SLOMAN +ACTING UNITED STATES ATTORNEY + +By: + +![]()A. [REDACTED] VILLAFANA +Assistant United States Attorney +Florida Bar No. 0018255 +500 East Broward Boulevard, 7th Floor +Ft Lauderdale, FL 33394 +Telephone: 954-660-5946 +Facsimile: 954-356-7230 +[REDACTED] \ No newline at end of file diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821242/EFTA02821242.metadata.json b/marker2/court-redacted-v-epstein-81111/EFTA02821242/EFTA02821242.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..cdefb78bc8ef8a2862b3f9241fa05dbdbe1e1400 --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821242/EFTA02821242.metadata.json @@ -0,0 +1,402 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-redacted-v-epstein-81111/EFTA02821242.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", 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08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092, + +#### PLAINTIFF JANE DOE NO. 4'S MOTION FOR SANCTIONS AND MOTION FOR PROTECTIVE ORDER AND INCORPORATED MEMORANDUM OF LAW + +Plaintiff, Jane Doe No. 4, by and through undersigned counsel, hereby files this Motion for Sanctions and Motion for Protective Order and Incorporated Memorandum of Law, and states as follows: + +I. By now, this Court is familiar with Jeffrey Epstein's practice of intimidating and harassing his victims, as well as the Plaintiffs' level of fear of Jeffrey Epstein. See, e.g. Plaintiffs Jane Doe No. 101 and Jane Doe No. 102's Motion for No-Contact Order (D.E. 113); Plaintiffs Jane Does 2-7's Response to Defendant's Motion to Compel and/or Identify Plaintiffs in the Style of this Case (D.E. 144); Plaintiffs Jane Does' 2-7 Motion for Protective Order and Incorporated Memorandum of Law (D.E. 223); Plaintiffs Jane Doe Nos. 2-8's Motion for Protective Order as to Jeffrey Epstein's Attendance at Deposition of Plaintiffs, and Incorporated Memorandum of Law (D.E. 292); Affidavit of Dr. Kliman (D.E. 223, Exh. A). + +2. On September 16, 2009, Jeffrey Epstein's conduct reached a new low when he recklessly violated (i) this Court's No-Contact Order dated July 31, 2009; and (2) a written stipulation between the parties that Jeffrey Epstein would not attend the deposition of Jane Doe No. 4 or be seen by Jane Doe No. 4 while attending her deposition. + +3. Prior to the deposition of Jane Doe No. 4, the Plaintiffs filed a Motion for Protective Order to preclude Jeffrey Epstein from attending the depositions of the Plaintiffs. The Motion was filed for the specific purpose of preventing Jeffrey Epstein from intimidating or harassing the Plaintiffs as he has repeatedly done in the past. As the Motion had not been adjudicated prior to the deposition of Jane Doe No. 4, Plaintiff's counsel stipulated with defense counsel that "Jeffrey Epstein will not attend the deposition of Jane Doe No. 4." It was further stipulated that Jeffrey Epstein may listen to the deposition by telephone or view a videofeed of the deposition, but under no circumstances was he to be seen by our client while attending the deposition. (See Exhibit "C", email of September 15, 2009). These were express conditions agreed to by counsel before Jane Doe No. 4 would appear for deposition on September 16, 2009. + +4. The deposition of Jane Doe No. 4 was scheduled for 1:00 p.m. on September 16, 2009 at 350 Australian Ave South, Suite 115, West Palm Beach, Florida. + +5. At approximately 1:00 p.m. on September 16, 2009, Jane Doe No. 4 and her counsel were walking in the lobby of 350 Australian Ave South, Suite 115, West Palm Beach, Florida, toward the ground-floor conference room where her deposition was to be held.' Just a + +Defendant's counsel set the deposition of Jane Doe No. 4 for the same office building where Jeffrey Epstein has an office. + +few feet away from this conference room, Jeffrey Epstein crossed paths with Jane Doe No. 4. Jeffrey Epstein stopped walking and began staring at her. He intimidated her until she began to cry. Jeffrey Epstein made no immediate attempt to walk away from our client. Instead, he stopped and continued to stare at her until she ran away. Jeffrey Epstein was accompanied by what appeared to be his bodyguard. See Declaration of Adam Horowitz, counsel for Jane Doe No. 4, Exhibit "A". + +6. Jane Doe No. 4 became an emotional wreck upon being stared at by Jeffrey Epstein, whom she believed she would not encounter. After attempting to console his client, Plaintiff's counsel cancelled the deposition after a brief discussion with defense counsel about the events that occurred in the lobby. See Transcript of Deposition of Jane Doe No. 4, Exhibit + +7. Jeffrey Epstein's contact with and intimidation of Jane Doe No. 4 is in direct violation of this Court's No-Contact Order dated July 31, 2009. In that Order, this Court stated that Jeffrey Epstein shall have no "direct or indirect contact" with the Plaintiffs. (D.E. 238). + +8. The July 31, 2009 Order mirrored the June 30, 2008 criminal sentence entered by Palm Beach Circuit Court Judge Deborah Dale Pucillio, wherein she instructed Jeffrey Epstein that he shall have "no direct or indirect contact" with the Plaintiffs. (D.E. 238) + +9. There can be no doubt that Jeffrey Epstein knew where Jane Doe No. 4 would he at 1 p.m. on September 16, 2009. Of all of the places he could have been, he chose to be at the location of her deposition in flagrant disregard of two (2) No-Contact Orders and the stipulation of the parties in this case. Even worse, when he saw Jane Doe No. 4, he chose to stop and stare her down to the point of intimidation until she began to cry and flee. + +10. This Court has discretion to enter a protective order to protect a party from annoyance, embarrassment or oppression. Fed.R.Civ.P. 26(c). In this regard, the Court has discretion for cause shown to, inter alia, designate the persons who may attend depositions, and specify the time and place of discovery. Fed.R.Civ.P. 26(c)(1)(A) and (E). Additionally, this Court has authority to sanction a party for civil contempt for violating the terms of a court order. See Sizzler Family Steak Houses v. Western Sizzlin Steak House. Inc., 793 F.2d 1529, 1534-35 (11th Cir. 1986) (attorneys' fees may be awarded for civil contempt in failure to comply with court order). + +II. Jeffrey Epstein is a felon and registered sex offender. Judicial oversight, at Jeffrey Epstein's expense, is required to keep his conduct under control. + +12. Given Jeffrey Epstein's violation of this Court's No-Contact Order and the written stipulation of the parties, appropriate sanctions and other relief are necessary to compensate Plaintiff Jane Doe No. 4 and prevent future misconduct by Defendant Epstein. + +WHEREFORE, Plaintiff, Jane Doe No. 4, respectfully requests (1) an award of sanctions, including attorneys' fees and costs reasonably and necessarily incurred by Plaintiff due to Defendant's non-compliance with the Court's No-Contact Order; (2) an Order excusing Jane Doe No. 4 from her deposition on September 16, 2009, due to Defendant's violation of the No-Contact Order and defense counsel's breach of his promise to Plaintiff's counsel that Defendant would not be seen at Plaintiff's deposition; (3) an order directing that any depositions of Plaintiffs in the future be at a court reporter's office selected by Plaintiffs' counsel; (4) appointment of a special to preside at Plaintiffs' depositions and control the proceeding, to be paid for by Defendant; and (5) all other relief as this Court deems just and appropriate. + +# CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1.A.3 + +Undersigned counsel has conferred with Defendant's counsel in a good faith effort to resolve the issues raised in this motion, and has been unable to do so. + +Dated: September 17, 2009. Respectfully submitted, + +By: s/ Adam D. Horowitz 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 + +# CERTIFICATE OF SERVICE + +I hereby certify that on September 17, 2009, 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. + +/s/ Adam D. Horowitz + +## SERVICE LIST DOE vs. JEFFREY EPSTEIN United States District Court, Southern District of Florida + +Jack Alan Goldberger, Esq. ieoldberger@agwpa.com + +Robert D. Critton, Esq. rcritton@bciclaw.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@bciclaw.com + +Paul G. Cassell cassellp@law.utah.edu + +Richard Horace Willits lawyerwillits@aol.com + +Robert C. Josefsberg rjosefsberg@podhurst.com + +## 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, + +## DECLARATION OF ADAM D. HOROWITZ + +- 1. My name is Adam D. Horowitz. I am an attorney for Jane Doe No. 4. +- 2. The deposition of Jane Doe No. 4 was scheduled for September 16, 2009 at 1:00 p.m. at 350 Australian Ave. South, Suite 115, West Palm Beach, Florida. On the day before the deposition, the undersigned and counsel for Jeffrey Epstein entered into a written stipulation in which it was agreed that "Jeffrey Epstein will not attend tomorrow's deposition of Jane Doe No. 4 (in the absence of a court order permitting him to attend)." It was further agreed that Jeffrey Epstein may listen in to the deposition by telephone or view a videofeed of the deposition, but under no circumstances would he "be seen by our client." +- 3. While Jane Doe No. 4 and I were in the lobby of 350 Australian Ave South at approximately 1:00 p.m. for her deposition on September 16, 2009, we crossed paths with Jeffrey Epstein and someone who appeared to be his bodyguard. Jeffrey Epstein stopped + +![](_page_6_Picture_12.jpeg) + +walking and began to stare at and intimidate Jane Doe No. 4. Jane Doe No. 4 was terrified, began crying and ran outside the building. Jeffrey Epstein smirked at her and walked away. + +4. As a result of this incident, Jane Doe began crying uncontrollably and was unable to proceed with her deposition. + +Under penalties of perjury I declare that I have read the foregoing Declaration and the facts stated in it are true. + +Dated: September 17, 2009 + +![]()UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF FLORIDA + +CASE NO. 08-CV-80119-MARRA/[REDACTED] + +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 +-----/ + +DEPOSITION OF JANE DOE #4 + +Wednesday, September 16, 2009 +1:03 - 1:08 p.m. + +250 Australian Avenue South +Suite 115 +West Palm Beach, Florida 33401 + +Reported By: +Cynthia [REDACTED], RPR, FPR +Notary Public, State of Florida +Prose Court Reporting + +![](_page_8_Picture_30.jpeg) + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +APPEARANCES: + +On behalf of the Plaintiff: + +ADAM D. HOROWITZ, ESQUIRE MERMELSTEIN & HOROWITZ, P.A. 18205 Biscayne Boulevard Suite 2218 Miami, Florida 33160 Phone: 305.931.2200 + +On behalf of the Defendant: + +ROBERT D. CRITTON, JR., ESQUIRE MARK T. LUTTIER, ESQUIRE BURMAN, CRITTON, LUTTIER & COLEMAN, LLP 303 Banyan Boulevard Suite 400 West Palm Beach, Florida 33401 Phone: 561.842.2820 + +On behalf of Jeffrey Epstein: + +JACK ALAN GOLDBERGER, ESQUIRE ATTERBURY, GOLDBERGER & WEISS, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, Florida 33401-5012 Phone: 561.659.8300 + +On behalf of LM and EW: + +WILLIAM J. BERGER, ESQUIRE ROTHSTEIN, ROSENFELDT, ADLER 401 East Las Olas Boulevard Suite 1650 Fort Lauderdale, Florida 33301 Phone: 954.522.3456 + +On behalf of CMA: + +JACK P. , ESQUIRE SEARCY, DENNEY, SCAROLA, BARNHART & SHIPLEY, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 + +APPEARNCES CONTINUED... + +On behalf of BB: + +ADAM J. LANGINO, ESQUIRE +LEOPOLD KUVIN +2925 PGA Boulevard +Suite 200 +Palm Beach Gardens, Florida 33410 +Phone: 561.515.1400 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +#### PROCEED I NG S + +MR. HOROWITZ: Adam Horowitz, counsel for Plaintiff, Jane Doe 4. + +MR. CRITTON: Cindy, what time is it? + +THE COURT REPORTER: It is 1:03. + +MR. BERGER: William J. Berger for LM and EW. + +MR. NM: Jack... for CMA. + +MR. LANGINO: Adam Langino from Leopold Kuvin on behalf of BB. + +MR. LUTTIER: Mark Luttier on behalf of Burman, Critton, Luttier & Coleman for the Defendant. + +MR. CRITTON: Robert Critton on behalf of Defendant, Jeffrey Epstein. + +MR. HOROWITZ: This is Adam Horowitz. We're canceling today's deposition. Before appearing here today, we had astipulation with Defense counsel that Mr. Jeffrey Epstein, the Defendant, would not be here. He would not cross paths with our client. + +And immediately as we were approaching the deposition room, he made face-to-face contact with our client. He was just feet away from + +1 2 her and intimidated her, and for that reason we're not going forward. + +3 4 5 6 7 8 9 10 11 MR. CRITTON: I didn't see any contact because I, obviously, was not out there. We started at about -- when you came in it was approximately 1:03. Mr. Epstein has an office here at the Florida Science Foundation. Had you been here at 1:00, your paths never would have crossed because Mr. Epstein was leaving the building. I instructed him to leave the building so that he would not be here. + +12 13 14 He was going to appear by way of Skype so that he could be on avideo camera so that he could see this. + +15 (Mr. Goldberger entered the room.) + +16 17 18 19 20 21 MR. CRITTON: Had you been here on time, and not faulting, Iam just saying had you been here on time at 1:00, as everyone else seemed to be here at least get here before you did, Adam, you and your client, your paths never would have crossed. + +22 23 24 25 Idirected Mr. Epstein to leave the building so he would not be here so that there would be no way that your paths could have crossed. It was neither my intent nor was it + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +my client's intent specifically, because I also advised him that he was not to cross paths, not to have any contact with your client, and certainly by our agreement not to be here today for the deposition. + +MR. HOROWITZ: And at approximately 1:00 is exactly when my client crossed paths with Jeffrey Epstein. And not only did he cross paths but he proceeded to stare her down just feet away from her. For that reason she became an emotional wreck and cannot proceed with the deposition. She's simply not in an emotional state to do so. + +And in addition Mr. Epstein violated the agreement between counsel that he would not cross paths or come into contact with our client. And it will be also for the criminal court judge to decide whether he has violated a no-contact order. I have nothing else to say. + +MR. CRITTON: Again I instructed Mr. Epstein to leave the building so absolutely no contact could occur between he and Mr. Horowitz and his client nor anyone else. Until the court, until either Judge Marra or Judge ruled on the issue as to whether + +or not he could appear at the depositions of not only Jane Doe 4 but any other individuals, so you do what you need to do. + +MR. HOROWITZ: Off the record. + +(The Deposition was concluded.) + +#### CERTIFICATE + +STATE OF FLORIDA COUNTY OF PALM BEACH + +I, Cynthia , Registered Professional Reporter and Florida Professional Reporter, State of Florida at large, certify that I was authorized to and did stenographically report the foregoing proceedings and that the transcript is atrue and complete record of my stenographic notes. + +Dated this 16th day of September, 2009. + +Cynthia , RPR, FPR + +#### Adam Horowitz + +From: Adam Horowitz Sent: Tuesday, September 15, 2009 11:43 AM To: 'Michael J. Pike'; 'Robert D. Critton Jr.' Cc: Stuart Mermelstein Subject: Jane Does v. Epstein + +Please allow this to confirm that Jeffrey Epstein will not attend tomorrow's deposition of Jane Doe No. 4 (in the absence of a Court order permitting him to attend). We understand you may wish to have your client listen in by telephone or view a videofeed of the deposition, but will not be seen by our client. + +Regards, + +Adam D. 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09-81092, + +### PLAINTIFF JANE DOE NO. 3's MOTION FOR SANCTIONS, MOTION FOR PROTECTIVE ORDER, AND INCORPORATED MEMORANDUM OF LAW + +Plaintiff, Jane Doe No. 3, by and through undersigned counsel, hereby files Motion for Sanctions, Motion for Protective Order, and Incorporated Memorandum of Law, and states as follows: + +I. Plaintiffs in these cases have previously brought to this Court's attention Jeffrey Epstein's pattern of intimidating and harassing his victims, as well as the Plaintiffs' fear of Jeffrey Epstein. See e.g., Plaintiffs Jane Doe No. 101 and Jane Doe No. 102's Motion for No-Contact Order (D.E. 113); Plaintiffs Jane Does 2-7's Response to Defendant's Motion to Compel and/or Identify Plaintiffs in the Style of this Case (D.E. 144); Plaintiffs Jane Does' 2-7 Motion for Protective Order and Incorporated Memorandum of Law (D.E. 223); Plaintiffs Jane Doe Nos. 2-8's Motion for Protective Order as to Jeffrey Epstein's Attendance at Deposition of Plaintiffs, and Incorporated Memorandum of Law (D.E. 292); Affidavit of Dr. Kliman (D.E. 223, Exh. A); Jane Doe No. 4's Motion for Sanctions and Motion for Protective Order (D.E. 306); Order, dated October 23, 2009 (D.E. 369) (forbidding Epstein from attending Jane Doe No. 4's deposition); Omnibus Order (forbidding Epstein's attorneys from repetitive and abusive questioning during Plaintiffs' depositions) (D.E. 433). + +2. Jane Doe No. 4 previously brought to this Court's attention that Epstein attended her deposition in violation of this Court's No-Contact Order (D.E. 238), a nearly identical No-Contact Order entered by the Court in Epstein's criminal prosecution, and a stipulation between the parties that Epstein would not appear at her deposition. + +3. Yet again, on November 24, 2009, Defendant Epstein flagrantly violated multiple Orders of this Court when he deliberately presented himself at the location of Jane Doe No. 3's medical examination pursuant to Fed.R.Civ.P. 35 (the "IME"). At that time, he terrorized Jane Doe No. 3 by crossing paths with her in a place and at a time when he must have known that his presence was forbidden by Court Order. + +4. Epstein's counsel served the Notice of Jane Doe No. 3's IME on October 30, 2009. The Notice included the date and location of Jane Doe No. 3's IME, 250 S. Australian Avenue, West Palm Beach. The Notice stated that the IME would start at 9 am and last until approximately 5:30 p.m. A Court Order required the Plaintiff to submit to eight hours of evaluation. Jane Doe No. 3 was the fifth plaintiff to undergo her IME. All of the previous IMEs lasted until later than 6:15 p.m. Therefore, Epstein and his counsel knew where Jane Doe No. 3 would be on November 24, 2009, and that she would be there between 9:00 am and sometime around 6:15 p.m. Epstein, therefore, must have known that there was a fair chance he would + +encounter Jane Doe No. 3 on November 24, 2009, at the address where his attorney had scheduled the IME. + +5. On November 5, 2009, this Court entered a Joint Agreed Order, which stated that "Defendant Jeffrey Epstein will not attend the IMEs or make himself seen by Plaintiffs on the date of their IMEs." (D.E. 401) (emphasis added). It was Epstein's responsibility to ensure his compliance with this Order. The Order further provided that the IMEs of Jane Doe Nos. 2-8 would take place at a "mutually agreeable location," and not at the office of Epstein's counsel. + +6. Pursuant to the November 5, 2009 Order, Jane Doe No. 3 appeared at her IME. During a brief recess in the IME, Jane Doe No. 3 and her attorney were outside the office building where the IME was taking place, 250 S. Australian Ave., West Palm Beach.' As in the other Plaintiffs' IMEs that took place over a two-week period, Jane Doe No. 3 took a short break approximately every two hours when it was time to change the videotape in the camera recording the IME.2 It was during the last break of the day that Defendant Epstein crossed paths with Jane Doe No. 3, in violation of multiple Court Orders. + +7. While Jane Doe No. 3 and her counsel, Jessica Arbour, were sitting on a bench just outside the foyer of the office building, Defendant Epstein exited the building. When he encountered Jane Doe No. 3 and her attorney, he made no attempt to stop, change his direction, or return to the building without Jane Doe No. 3 seeing him, despite having ample opportunity to avoid them. See Affidavit of Jessica Arbour, attached as Exhibit "A". + +This is the same building where Defendant Epstein crossed paths with Jane Doe No. 4 on the date of her deposition. (See D.E. 306). + +2 At the beginning of each IME, the Defendant's expert advised all of the Plaintiffs, including Jane Doe No. 3, that she was allowed to take "smoke breaks" any time she would like. + +8. Epstein crossed in front of Jane Doe No. 3, approximately 5-7 feet from her. Jane Doe No. 3 immediately reacted in a terrified, emotional manner that included screaming and crying. Her attorney physically removed her from Defendant Epstein's vicinity and into the safety of the building's lobby. Jane Doe No. 3's reaction was so emotional that the security guard on duty and several onlookers appeared quite concerned. Exh. "A" 7-11). + +9. Epstein does not dispute that he encountered Jane Doe No. 3 and her attorney. See Exhibit B. He does not dispute that he recognized them. + +10. Jane Doe No. 3 was eventually calmed enough to be taken back to the office where her IME was being conducted, but was too distraught to continue her IME. At that point, Jane Doe No. 3's counsel terminated the IME. + +II. At no time were Plaintiff or her counsel made aware that Defendant Epstein would be in the building when any of the Plaintiffs would be present for their IMEs. Indeed, Plaintiffs reasonably expected that this Court's prior orders and the threat of sanctions would be a sufficient deterrent to keep Epstein away. + +12. Defendant Epstein's ostensible full-time employer, the Florida Science Foundation, is no longer located in the building where the IMEs took place. The company was administratively dissolved several months ago, approximately the same time that his courtordered work-release program with the foundation ended. As a result, it would appear that Epstein had no legitimate purpose in the building at 250 S. Australian Ave. on November 24, 2009. Indeed, he was dressed in an oversized sweatsuit that would not be appropriate for any professional environment. (Arbour Aff., Exh. "A", 114). The reason for his presence in the building has never been explained to Jane Doe No. 3's counsel. + +13. In addition to violating the Agreed Order (D.E. 401), Epstein's conduct recklessly or intentionally violated (i) this Court's No-Contact Order dated July 31, 2009 (D.E. 238), in which he was specifically instructed to have no "direct or indirect contact" with Jane Doe No. 3 or any other plaintiff; and (2) the July 31, 2008, no-contact Order entered by the Court in his criminal matter arising from the sexual assaults of numerous underage girls, including Jane Doe No. 3. The July 31, 2009 Order mirrored the June 30, 2008 criminal sentence entered by Palm Beach Circuit Court Judge Deborah Dale Pucillio, wherein she instructed Jeffrey Epstein that he shall have "no direct or indirect contact" with the Plaintiffs. (D.E. 238). + +14. Jane Doe No. 3 agrees to attend the remaining two hours of her IME in order to comply fully with this Court's Order on the IME length. However, a protective order specifically barring the continuation of the 1ME from occurring anywhere not previously agreed upon by Plaintiff's counsel is necessary to ensure that Defendant Epstein will not be given another opportunity to traumatize Jane Doe No. 3. Given the violation of the prior Orders as well as a prior similar incident at the deposition of Jane Doe No. 4, a more drastic measure is now necessary to protect Jane Doe No. 3 from Epstein. + +15. Furthermore, Jane Doe No. 3 seeks sanctions against Defendant Epstein for the violation of not one, but three court orders designed to protect Plaintiffs from the exact conduct in which Defendant Epstein engaged. This Court has authority to sanction a party for civil contempt for violating the terms of a court order. See Sizzler Family Steak Houses v. Western Sizzlin Steak House. Inc., 793 F.2d 1529, 1534-35 (11th Cir. 1986) (attorneys' fees may be awarded for civil contempt in failure to comply with court order). Additionally, sanctions for violation of multiple court orders are an appropriate exercise of judicial oversight. + +16. Given Jeffrey Epstein's violation of this Court's No-Contact Order and the Agreed Order, appropriate sanctions and other relief are necessary to compensate Plaintiff Jane Doe No. 3. + +17. Prior to filing this Motion, Plaintiff's counsel conferred with Jeffrey Epstein's counsel in an attempt to reach an agreement as to the relief requested. No agreement was reached. + +WHEREFORE, Plaintiff, Jane Doe No. 3, respectfully requests (1) an award of sanctions, including attorneys' fees and costs reasonably and necessarily incurred by Plaintiff due to Defendant Jeffrey Epstein's violation of the Court's No-Contact Order (D.E. 238) and Agreed Order (D.E. 401); (2) an Order requiring that the remaining two hours of Jane Doe No. 3's IME take place at a mutually agreeable location in a city other than West Palm Beach, with Defendant Epstein responsible for all costs above and beyond those originally contemplated by this Court in its Nov. 5 Order; and (3) all other relief as this Court deems just and appropriate. + +# CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.I.A.3 + +Undersigned counsel has conferred with Defendant's counsel in a good faith effort to resolve the issues raised in this motion, and has been unable to do so. + +Dated: January 4, 2010 Respectfully submitted, + +By: s/ Adam D. Horowitz 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 + +### CERTIFICATE OF SERVICE + +I hereby certify that on January 4, 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. + +/s/ Adam D. Horowitz + +## SERVICE LIST DOE vs. JEFFREY EPSTEIN United States District Court, Southern District of Florida + +Jack Alan Goldberger, Esq. igoldberger@agwpa.com + +Robert D. Critton, Esq. rcritton@bciclaw.com + +James brad@pathtojustice.com + +Isidro Manuel isidrogarcia@bellsouth.net + +Jack jph@searcylaw.com U + +Katherine Warthen Ezell KEzell@podhurst.com + +Michael James Pike MPike@bciclaw.com + +Paul G. Cassell cassellp@law.utah.edu + +Richard Horace Willits Iawyerwillits@aol.com + +Robert C. 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Epstein is a registered sex offender, who should not have contact with any of the victims of his sexual assaults — including M.J.. Moreover, in a prior court case quite similar to M.J.'s, Epstein has directly harassed victims of his abuse through the device of sending "private investigators" to do his harassment. Accordingly, the Court should forbid any such direct or indirect contact without prior approval of the Court. + +### BACKGROUND + +### Previous Protective Orders + +Epstein has pled guilty to state sex charges on June 30, 2008. When he pled guilty before Palm Beach Circuit Court Judge Deborah Dale Pucillo, she ordered Epstein "not to have any contact, direct or indirect" with any victims. She also expressly + +stated that her no-contact order applied to "all of the victims." The relevant transcripts are attached as Exhibit 1. + +To avoid any uncertainty about the scope of this state court order, several of the plaintiff/victims with other suits pending against Epstein before this Court filed a motion for an order prohibiting defendant or his agents from communicating with them directly or indirectly. (Case No. 9:08-cv-80119, DE 113.) Exhibit 2. Epstein opposed these requests as "needless, unwarranted and excessive." DE 127 at 5. Exhibit 3 This Court, however, firmly overruled Epstein's objections. On July 31, 2009, this Court (Marra, J.) entered its own no-contact order (in addition to the state court order), ruling: + +In light of Defendant's response to Plaintiff's motion for no contact order, suggesting that the state court's order only applies to some victims and that parties are always allowed to contact each other directly, the Court finds it necessary to state clearly that Defendant is under this court's order not to have direct or indirect contact with any plaintiffs, regardless of the intended scope of the state court court's order. + +Order, Case No. 9:08-cv-80119, DE 238, at 4-5 (emphasis added). Exhibit 4 + +As one of the victim's (Jane Doe's) case approached trial, this Court ordered Jane Doe to attend a settlement conference on July 6, 2010. Jane Doe had concerns that the upcoming settlement conference, demanded by Epstein, was going to be used to harass and intimidate her. See Plaintiff Jane Doe's Motion for Modification of Magistrate Judge Palermo's Order Schedule settlement Conference, Case No. 9:08-cv-80893, DE 187. Exhibit 5. After a response from Epstein (DE 191), the Court modified its order regarding the settlement conference to avoid harassment of Jane Doe. Significantly, in the final paragraph, the Court (Palermo, J.), starkly commanded: + +The parties are instructed not to communicate, speak or harass one another in any way. Any violation of this Order will not be tolerated. The parties are instructed to GOVERN THEMSELVES ACCORDINGLY. + +Case no. 9:08-cv-80893, DE 193 at 2 (italic added, capitalization in original). Exhibit 6 + +### Intimidating Activities Against Jane Doe on the Evening of July 1, 2010 + +In spite of three court orders forbidding contact and harassment of victims including Jane Doe, the plaintiff in case No. 9:08-cv-80893 -- Epstein showed his unwillingness to follow the rules. On the evening of July 1, 2010, sometime after the issuance of Judge Palermo's order, Jane Doe left her house to go to the store and noticed a car (Infiniti SUV, license tag T-KNOLZ) following her everywhere she went. Feeling frightened, she pulled into a driveway in a nearby neighborhood at one point to allow the car to proceed past her, but the car pulled into the neighborhood and stopped nearby. It was clear the person in the car was following her and was intentionally making his presence known. Jane Doe pulled out of the driveway and headed home, with this other car tailing close behind. Once Jane Doe arrived to her house, she went inside and the person following in the Infiniti parked across the street outside her home. Jane Doe called her attorney expressing her fear and asking what could be done to protect her. She observed that the car kept creeping closer to her home every once in awhile. + +This intimidation of Jane Doe was so serious that, alerted by Jane Doe's counsel, a retired police officer called the police. The police responded to Jane Doe's home and confronted the man in the car. The man told the police that he was "private investigator." However he would not tell the police who had hired him, only that he was + +hired to "watch" Jane Doe. The name of the investigator appears to be Thaddeus Knowles. The police reported these facts to Jane Doe, but advised her that they did not have a legal basis to order him to leave the public street. + +Counsel for Jane Doe then arranged for the retired police officer to go to Jane Doe's home. This retired officer arrived at Jane Doe's home at approximately 10 p.m. He immediately saw a car parked 25 feet from Jane Doe's home, facing her home. He also observed the purported "private investigator" in the car intermittently flashing his high beam lights into Jane Doe's home. The investigator was also intermittently attempting to videotape anyone inside the home. The retired police officer took videotapes of the investigator lighting up the interior of the home with his high beam lights, and also took photographs of this harassing action as well. The videotape and photographs could be provided quickly to the Court upon request. + +After consulting with Jane Doe, the retired police officer determined that Jane Doe felt like a prisoner in her own home and that she believed her physical safety was threatened if she remained there. She further believed that this intimidation was being orchestrated by defendant Epstein. Jane Doe was not involved in other litigation and is not aware of any other person who would want to do something like this to her. Also, in the previous 48 hours, Jane Doe had received telephone calls from two ex-boyfriends that investigators were at their homes, knocking on their doors and trying to talk to them about Jane Doe — apparently because of this case. + +In light of Jane Doe's concerns, the retired police officer believed that it was best to take Jane Doe from her home. He advised Jane Doe to pack a suitcase and leave the home with him. + +At approximately 10:30 p.m., the retired police officer then took Jane Doe in his car and pulled up next to the "private investigator." The retired police officer advised the investigator that Jane Doe was leaving the home to go to another location and that he should not attempt to follow them. Nonetheless, the investigator attempted to follow the retired police officer as they drove away from Jane Doe's home. The retired police officer then took evasive action and was able to elude his pursuer. + +As a result of these activities, Jane Doe felt very threatened. She knew that she was followed for much of the day. She also knew that this was not surreptitious surveillance by someone who was trying to discovery something about her, but rather quite visible surveillance by someone whose manifest intent was to make sure that she knew she was being followed. Thus, when she pulled over, he pulled over; when she parked, he parked visibly close by. The only reason for such activities could be to intimidate her on the eve of the court-ordered mediation. It may also be worth noting that Jane Doe was a petite young woman, physically smaller and younger than the male private investigator who has been following her. + +Jane Doe went into the protective custody of her attorneys and was hidden at a secure location. On the afternoon of Friday, July 2, 2010 (shortly before the 4th of July weekend), Jane Doe filed a Emergency Motion for A Hearing, Finding That Epstein is in Civil Contempt of the Court's Two Orders Forbidding Harassment and Indirect Contact, + +For Appropriate Sanctions and Additional Remedies Including Referral for Criminal Contempt. Case No. 9:08-Cv-80893, Exhibit 7. + +## Other Intimidation of Victims and Witnesses By Epstein + +The Court should be aware that the intimidation of Jane Doe was not the first time Epstein used scare tactics to intimidate victims and witnesses. Indeed, as the Court is aware, despite numerous civil suits being filed against Epstein for sexual abuse, none of the victims in those cases have felt able to proceed to trial. Counsel for Jane Doe have been advised that many of these victims were afraid to take their cases all the way to trial. + +In determining where to enter a protective order, this Court can consider all of the circumstances, including other documented examples of harassment by Epstein:' + +Previous use of "investigators" to scare witnesses: The use of "investigators" to aggressively harass his victims is not new to Epstein, as investigators have in the past aggressively followed key witnesses to intimidate and scare them. See Palm Beach Police Incident Report at p. 86 (Complete Incident Report attached as Exhibit 8). + +Victim-to-victim communication: One of Epstein's sexual abuse victims was relayed a message from another victim speaking on Epstein's behalf regarding the criminal investigation of Epstein in 2006: "Those who help will be compensated and those who hurt will be dealt with." See Palm Beach Police Department Incident Report, page 83. + +' The Federal Rules of Evidence do not apply to this motion and, in any event, the federal rules authorize the Court to consider other bad acts in reaching a conclusion about disputed events. See Fed. R. Evid. 404(b). + +Witness tampering during the federal investigation: During the FBI investigation of his sexual abuse of young girls, Epstein intimidated and harassed other possible witnesses against him -- namely , Leslie Groff and Indeed, this intimidation was so serious that federal prosecutors prepared draft federal charges against him for witness tampering charges. (attached as Exhibit 9). Ultimately, for reasons that are unclear, these charges were not filed. + +Threats Against Jane Doe 102 Epstein has even tracked down adverse witnesses as far away as Australia in the past to send the message not to testify against him regarding his illegal sexual exploits. See Complaint of Jane Doe 102 v. Epstein (attached as Exhibit 10). + +Threats Against Alfredo Rodriguez: Jane Doe is not the only person to have received this impression that she is at risk if she does not accede to Epstein's demands. The Court is familiar with Alfredo Rodriguez, an employee of Epstein who kept a "black book" of the names of minor girls Epstein' was sexually abusing. See Criminal Complaint, U.S. v. Rodriguez, No. 9:10-CR-80015-KAM (DE 3) Exhibit 11. Rodriguez stated that he was afraid that Jeffrey Epstein would make him "disappear" unless he had an "insurance policy" (i.e., the black book). Id. at 3. + +"Accidentally" Encountering a Victim on the Way to a Deposition. + +During civil litigation of other cases brought against Jeffrey Epstein by other Epstein victims, Epstein himself attempted to intimidate those victims whenever he got the chance. At the deposition of one of his victims who proceeded civilly against Epstein under the pseudonym Jane Doe #4, Epstein intentionally crossed paths with the + +victim and stared her down as an attempt to intimidate her. (DE 306 in case 08-80119, attached at Ex. 12). On November 5, 2009, Epstein again appeared in the location where one of his victims, this time Doe #3. Jane Doe #3, was present for her 8 hour psychological IME. Epstein knew at that time that Jane Doe #3 was already emotionally fragile and suffering through a grueling psychological examination and he chose to exacerbate her condition by suddenly appearing within feet of her. See Ex. 13. Each of these encounters occurred despite the court's elaborate procedures to prevent these encounters and irrespective of the various court orders in place warning Epstein against this behavior. + +# LEGAL MEMORANDUM + +The Court can consider all of the foregoing information as circumstantial evidence pointing to only one conclusion: that defendant Epstein — a registered sex offender with vast financial resources — may well try to intimidate M.J. during this lawsuit. The Court should accordingly enter a protective order barring direct or indirect contact by Epstein with M.J., including contact by purported "private investigators" without approval by the Court. + +It is clear that the intent of Palm Beach circuit Court Judge Deborah Dale Pucillo was to keep Epstein from having any contact with "all" of his victims, and she barred both "direct or indirect" contact. Epstein, however, has obviously absurdly narrow interpretations of these orders to engage in threats and harassment. + +In a case similar to this one, Judge Marra entered a no-contact order, barring Epstein from having any direct or indirect contact with the victims. Order, Case No. + +9:08-cv-80119, DE 238, at 4-5 (emphasis added). Epstein, however, ridiculously interpreted that order as allowing him to send private investigators to Jane Doe's home late at night and terrorize her. Accordingly, to avoid any such harassment in this case, the Court's order should make clear that it extends to "private investigators" unless Epstein obtains permission for investigation after notice to M.J. and a hearing. + +## CONCLUSION + +Harassment of plaintiffs who have filed civil suits — particularly civil suits alleging sexual assaults — strikes at the very heart of the legal system. Harassment may prevent a victim from obtaining justice in Court. This Court should not pretermit any such behavior by Epstein. The Court should enter an order barring Epstein from having any direct or indirect contact with M.J., including contact through "private investigators," without first obtaining leave of the Court after notice to and a hearing with M.J.. + +### POSITION OF THE PARTIES + +M.J. has conferred with Counsel for defendant Epstein and understands that defendant Epstein objects to all these requests. + +DATED: November 11, 2010 + +Respectfully Submitted, + +JAFFE, WEISSING, , FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 Florida Bar No.: 542075 E-mail: brad@pathtojustice.com + +#### CERTIFICATE OF SERVICE + +I HEREBY CERTIFY that on November 11, 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 on 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 filed Notices of Electronic Filing. + +> s/ J. J. + +### SERVICE LIST + +M.J. v. Jeffrey Epstein United States District Court, Southern District of Florida + +Lilly Ann E. Kni ht Helaine S. Goodner + +BURNETT PA Espirito Santo Plaza, le Floor 1395 Brickell Avenue Miami. 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+JEFFREY EPSTEIN, + +Defendant + +JANE DOE NO. 4, + +CASE NO: 08-CV-80380-MARRA/ [REDACTED] + +Plaintiff + +vs. + +JEFFREY EPSTEIN, + +Defendant + +\_\_\_\_\_/ + +JANE DOE NO. 5, + +CASE NO: 08-CV-80381-MARRA/[REDACTED] + +Plaintiff + +vs. + +JEFFREY EPSTEIN, + +Defendant + +\_\_\_\_\_/ + +JANE DOE NO. 6. + +CASE NO: 08-CV-80994-MARRA/[REDACTED] + +Plaintiff + +vs. + +JEFFREY EPSTEIN, + +Defendant + +\_\_\_\_\_/ + +JANE DOE NO. 7, + +CASE NO: 08-CV-80993-MARRA/[REDACTED] + +Plaintiff + +vs. + +JEFFREY EPSTEIN, + +Defendant + +CASE NO: 08-CV-80811-MARRA + +C.M.A., + +Plaintiff + +vs. + +JEFFREY EPSTEIN, + +Defendant + +JANE DOE, CASE NO. 08-CV-80893-CIV-MARRA/ + +Plaintiff, + +Vs. + +JEFFREY EPSTEIN, et al. + +Defendant. + +DOE II, CASE NO: 09-CV-80469-MARRA + +Plaintiff + +vs. + +JEFFREY EPSTEIN, et al. + +Defendants. + +JANE DOE NO. 101, CASE NO: 09-CV-80591-MARRa + +Plaintiff + +vs. + +JEFFREY EPSTEIN, + +Defendant + +JANE DOE NO. 102, CASE NO: 09-CV-80656-MARRa + +Plaintiff + +vs. + +JEFFREY EPSTEIN, + +Defendant + +### PLAINTIFF JANE DOE'S MOTION TO COMPEL ANSWERS TO PLAINTFF'S FIRST REQUEST FOR PRODUCTION + +Plaintiff Jane Doe, hereby moves this Court for an order compelling defendant, Jeffrey Epstein, to answer her first request for production or, in the alternative, to prove that his invocation of his Fifth Amendment privilege is proper. Jane Doe also requests production of a privilege log. + +Jane Doe has propounded 16 requests for production, including such straightforward requests as requests for production of: + +Request No. 1: Copies of all telephone records; + +Request No. 2: Photos of the inside of your home located at 358 El Brillo Way, Palm Beach, Florida, that depict the room(s) where massages took place (including massage table). + +Request No. 10: Correspondence between Epstein and federal prosecutors; + +Request No. 12: Personal tax returns; + +Request No. 13: Photocopies of Epstein's passport; + +Request No. 14: A statement of net worth; and + +Request No. 16: Medical records. + +In response to each and every one of these requests, Epstein has given the following response (with only minor variations here and there): + +Defendant is asserting his U.S. constitutional privileges. I intend to respond to all relevant questions regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution. + +This Court should order Epstein to provide all of the requested information or, in the alternative, prove that his Fifth Amendment invocations are valid. It is for the court, not the claimant, to determine whether the hazard of incrimination is justified. United States v. Argomaniz, 925 F.2d 1349, 1355 (11th Cir. 1991). "A court must make a particularized inquiry, deciding, in connection with each specific area that the + +questioning party wishes to explore, whether or not the privilege is well-founded." Id. Typically this is done in an in camera proceeding wherein the person asserting the privilege is given the opportunity "to substantiate his claims of the privilege and the district court is able to consider the questions asked and the documents requested by the summons." Id. + +Here Epstein has made boilerplate invocation of the Fifth Amendment to each and every request propounded by Jane Doe, including for example the request for correspondence with federal prosecutors and for production of federal tax returns. This obviously is not a request with Fifth Amendment implications, as the information has already been fully disclosed to the Government. + +For all these reasons, the Court should compel Epstein to answer the requests or provide a particularized justification for his Fifth Amendment invocation with regard to each request. + +Epstein's "cut and paste" response to the request for production also blatantly disregards the requirements for invoking privilege under the Court's local rules. Local rule 26.1.G very specifically requires the preparation of a privilege log with respect to all documents and oral communications (among other things) that are withheld on the basis of privilege. Epstein has failed to prepare such a log, making it impossible for Jane Doe to effectively challenge his generic assertions. Indeed, with respect to a few requests, Epstein has stated: "Further, the request may include information subject to work product or an attorney-client privilege." Of course, the whole purpose of forcing a defendant to prepare a privilege log is to force the defendant to decide whether or not + +information is privileged. An assertion that something "may" be privileged is obviously woefully deficient. The Local Rules do not permit this tactic, and Epstein should be (at a minimum) promptly required to produce a privilege log. + +For all these reasons, the Court should compel Epstein to provide a privilege log and to answer the interrogatories or provide a particularized justification for his Fifth Amendment invocation with regard to each request. + +It should be noted that (with minor exceptions) the only grounds on which Epstein can refuse to answer the request for production is proof of a valid Fifth Amendment privilege. This the only objection Epstein has asserted (with minor exceptions). As a result, any other objections to production are deemed waived. See Local Rule 26.1G.3.(a) ("Any ground [for an objection] not stated in an objection within the time provided by the Federal Rules of Civil Procedure, or any extensions thereof, shall be waived."). + +# SPECIFIC REQUESTS FOR PRODUCTION + +For the convenience of the court — and in compliance with Local Rule 26.1 H (party filing motion to compel shall list specific requests in succession) — Jane Doe's requests for production and Epstein's objections are as follows: + +Request No. 1: Copies of all telephone records in your or your attorney's possession from 2002 through 2005 that in any way relate to you (including all phone lines owned by you or that were used to contact girls for the purposes of scheduling massages for you.) + +Defendant is asserting his U.S. constitutional privileges. I intend to respond to all relevant questions regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective + +representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution. + +Request No. 2: All massage appointment books, diaries, computer calendars or scheduling entities, scheduling books or any other writing or correspondence that contains the names of any of the girls that were called, contacted, scheduled or who otherwise went to your home located at 358 El Brillo Way, Palm Beach, Florida, for the purpose of giving you a massage. + +Defendant is asserting his U.S. constitutional privileges. I intend to respond to all relevant questions regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution. + +Request No. 3: Any and all documentation in your possession that contains Plaintiff's name or that refers to Plaintiff, directly or indirectly, (includes e-mails, letters, message pads, diaries, appointment books, computer print outs). + +Defendant is asserting his U.S. constitutional privileges. I intend to respond to all relevant questions regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution. + +Request No. 4: Any and all photos, videos, downloaded digital prints or any other visual depiction of Plaintiff, or of any other known or suspected minor females introduced to you, directly or indirectly, by Plaintiff. + +Defendant is asserting his U.S. constitutional privileges. I intend to respond to all relevant questions regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution. + +Request No. 5: Photos of the inside or your home located at 358 El Brillo Way, Palm Beach, Florida, that depict the room(s) where the massages too place (including massage table). + +Defendant is asserting his U.S. constitutional privileges. I intend to respond to all relevant questions regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution. + +Request No. 6: Any and all documentation of cancelled checks or evidence of payment to Plaintiff of any kind and for any reason whatsoever. + +Defendant is asserting his U.S. constitutional privileges. I intend to respond to all relevant questions regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution. + +Request No. 7: All discovery information obtained by you or your attorneys as a result of the exchange of discovery in the State criminal case against you or the Federal investigation against you. + +Defendant is asserting his U.S. constitutional privileges. I intend to respond to all relevant questions regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution. In addition to and without waiving his constitutional privileges, the information sought is privileged and confidential, and inadmissible to the terms of the deferred prosecution agreement, Federal Rule of Evidence 410 and 408, and § 90.410, Fla. Stat.1 Further, the request may including information subject to work product or an attorney-client privilege. + +Request No. 8: All financial documents evidencing asset transfers from 2005 to present for you personally or any company or corporation owned by you. + +Defendant is asserting his U.S. constitutional privileges. I intend to respond to all relevant questions regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution. + +--- + +1 Jane Doe does not intend to use these materials to draw a forbidden inference of guilt from the mere fact that information was provided to law enforcement officials as part of plea discussions, but rather for other purposes. These materials are also quite clearly likely to lead to the discovery of other admissible evidence, as they relate to the same subject matter as this lawsuit. To the extent that Epstein relies on the non-prosecution agreement, nothing in that agreement bars *discovery* of information relevant to this lawsuit. + +Request No. 9: Any documents or other evidentiary materials provided to local, state, or federal law enforcement investigators or local, state or federal prosecutors investigating your sexual activities with minors. + +Defendant is asserting his U.S. constitutional privileges. I intend to respond to all relevant questions regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution. In addition to and without waiving his constitutional privileges, the information sought is privileged and confidential, and inadmissible pursuant to the terms of the deferred prosecution agreement, Fed. Rule of Evidence 410 and 408, and § 90.410, Fla. Stat.2 Further, the request may include information subject to work product or an attorney-client privilege. + +Request No. 10: All correspondence between you and your attorneys and state or federal law enforcement or prosecutors (includes, but not limited to, letters to and from the States Attorney's office or any agents thereof). + +Defendant is asserting his U.S. constitutional privileges. I intend to respond to all relevant questions regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution. In addition to and without waiving his constitutional privileges, the information sought is privileged and confidential, and inadmissible pursuant to the terms of the deferred prosecution agreement, + +--- + +2 Jane Doe does not intend to use these materials to draw a forbidden inference of guilt from the mere fact of plea discussions, but rather for other purposes. These materials are also likely to lead to the discovery of other admissible evidence. To the extent that Epstein relies on the non-prosecution agreement, nothing in that agreement bars discovery of information relevant to this lawsuit. + +Fed. Rule of Evidence 410 and 408, and § 90.410, Fla. Stat. 3 Further, the request may include information subject to work product or an attorney-client privilege. + +Request No. 11: Any and all documents reflecting your current net worth. + +Defendant is asserting his U.S. constitutional privileges. I intend to respond to all relevant questions regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution. + +Request No. 12: Personal tax returns for all years from 2002 through the present. + +Defendant is asserting his U.S. constitutional privileges. I intend to respond to all relevant questions regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution; overly broad. + +Request No. 13: A photocopy of your passport, including any supplemental pages reflecting travel to locations outside the 50 United States between 2002 and 2008, including any documents or records regarding plane tickets, hotel receipts, or transportation arrangements. + +--- + +3 Jane Doe does not intend to use these materials to draw a forbidden inference of guilt from the mere fact of correspondence in connection with plea discussions, but rather for other purposes. These materials are also likely to lead to the discovery of other admissible evidence. To the extent that Epstein relies on the non-prosecution agreement, nothing in that agreement bars *discovery* of information relevant to this lawsuit. + +Defendant is asserting his U.S. constitutional privileges. I intend to respond to all relevant questions regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution. In addition to and without waiving his constitutional protections and privileges, the scope of information is so overbroad that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence; compiling such information over a six year period would be unduly burdensome and time consuming.4 + +Request No. 14: A sworn statement of your net worth (including a detailed financial statement depicting all current assets and liabilities). + +Defendant is asserting his U.S. constitutional privileges. I intend to respond to all relevant questions regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution. + +Request No. 15: All financial statements or affidavits produced by you for any reason, to any person, company, entity or corporation since 2005. + +Defendant is asserting his U.S. constitutional privileges. I intend to respond to all relevant questions regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United + +--- + +4 Jane Doe believes that Epstein used overseas travel as a means of obtaining underage girls for sexual purposes and for avoiding criminal prosecution for such activities. Also, providing a copy of a passport is hardly "burdensome." Also, given the fact that Epstein is likely to have used the services of a travel agent or another intermediary, it should not be difficult for him to provide evidence of his overseas travels from such intermediaries. + +States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution; overly broad. + +Request No. 16: All medical records of Defendant Epstein from Dr. Stephan Alexander. + +Defendant is asserting his U.S. constitutional privileges. I intend to respond to all relevant questions regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution. + +# CONCLUSION + +For all these reasons, the Court should compel Epstein to answer the request for production, or provide a particularized justification for his Fifth Amendment invocation with regard to each request. Epstein should also be required to provide a privilege log. Counsel for Jane Doe have conferred with opposing counsel on the issues raised in this motion, and no resolution was possible. + +DATED July 20, 2009 Respectfully Submitted, + +s/ J. ROTHSTEIN ROSENFELDT ADLER Las Olas City Centre 401 East Las Olas Blvd., Suite 1650 Fort Lauderdale, Florida 33301 Telephone (954) 522-3456 Facsimile (954) 527-8663 Florida Bar No.: 542075 E-mail: bedwards@rra-law.com + +and + +Paul G. Cassell Pro Hac Vice 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: 801-585-5202 Facsimile: 801-585-6833 E-Mail: cassellp@law.utah.edu + +### CERTIFICATE OF SERVICE + +I HEREBY CERTIFY that on July 20, 2009, 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 on 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 filed Notices of Electronic Filing. + +> s/ J. + +**SERVICE LIST** +**Jane Doe v. Jeffrey Epstein** +**United States District Court, Southern District of Florida** + +Jack Alan Goldberger, Esq. +[Jgoldberger@agwpa.com](mailto:Jgoldberger@agwpa.com) + +Robert D. Critton, Esq. +[rcritton@bclclaw.com](mailto:rcritton@bclclaw.com) + +Isidro Manual [REDACTED] +[isidrogarcia@bellsouth.net](mailto:isidrogarcia@bellsouth.net) + +Jack [REDACTED] +[iph@searcylaw.com](mailto:iph@searcylaw.com) + +Katherine Warthen Ezell +[KEzell@podhurst.com](mailto:KEzell@podhurst.com) + +Michael James Pike +[MPike@bclclaw.com](mailto:MPike@bclclaw.com) + +Paul G. Cassell +[cassellp@bclclaw.com](mailto:cassellp@bclclaw.com) + +Richard Horace Willits +[lawyerswillits@aol.com](mailto:lawyerswillits@aol.com) + +Robert C. Josefsberg +[rjosefsberg@podhurst.com](mailto:rjosefsberg@podhurst.com) + +Adam D. Horowitz +[ahorowitz@sexabuseattorney.com](mailto:ahorowitz@sexabuseattorney.com) + +Stuart S. Mermelstein +[ssm@sexabuseattorney.com](mailto:ssm@sexabuseattorney.com) + +William J. 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+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, JEFFREY EPSTEIN'S RESPONSE IN OPPOSITION TO PLAINTIFF'S, JANE DOE, MOTION TO COMPEL RESPONSE TO PLAINTIFF'S REQUEST FOR PRODUCTION IDE 971, WITH INCORPORATED MEMORANDUM OF LAW + +Defendant, JEFFREY EPSTEIN, hereby files his Response in Opposition to Plaintiffs, JANE DOE, Motion to Compel Response to Plaintiff's Request for Production IDE 97J (Consolidated Case No. 08-C1V-80119 IDE 194)). + +#### I. Procedural Background + +Plaintiff's Motion to Compel is filed at DE (97). The Motion to Compel was voluminous and orders had been entered by this court (DE 242 and 293) addressing other 5th Amendment issues; therefore, the undersigned counsel endeavored to eliminate certain requests outlined in Plaintiffs Motion to Compel. As a result, a Joint Notice of Agreement was entered advising the court that several of the requests had been addressed by counsel alleviating the court from having to rule on same. (DE 316). + +Defendant filed his Rule 4 Appeal (DE 282) and his Supplementary Brief (DE 283), which address several of the .5111 Amendment arguments applicable to the requests outlined + +Page No. 2 + +herein. Portions of DE 282 and 283 were provided to the court in camera pursuant to the court's order (DE 242). Therefore, for the Court's ease of reference and in an attempt to maintain brevity, Defendant hereby incorporates those arguments and case law as if fully set forth herein. + +Significantly, these cases have been consolidated for discovery. Therefore, consistent rulings should apply. In making those rulings, this Court must continue to recognize that the allegations in the related cases cannot be forgotten. (Lg., see DE 242 and 293, p.5-6). Production of information in one case could provide a link in the chain of evidence used to prosecute Epstein for a crime or provide an indirect link to incriminating evidence in another case. Id. and infra. + +The Request for Production and the responses thereto are attached as Composite Exhibit "A". + +# I. The Requests For Production, Argument And Memorandum Of Law + +## a. Request Number 5 + +Request No. 5: Photos of the inside of your home located at 358 El Brillo Way, Palm Beach, Florida, that depict the room(s) where the massages took place (including massage table). + +Response: Defendant asserts his U.S. constitutional privileges. I intend to produce all relevant documents regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select, authenticate, and produce documents relevant to this lawsuit without waiving my Fifth Amendment rights and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution. + +In Jane Doe No. 2 v. Epstein, Case No. 80119, the Magistrate Judge found, "[l]n 2008, Epstein entered into a Non-Prosecution Agreement ("NPA") with the United States Attorney General's Office for the Federal Southern District of Florida ("USAO") and the State Attorney's + +Office for Palm Beach County. Under the terms of the NPA, any criminal prosecution against Epstein is deferred as long as he abides by the certain terms and conditions contained therein. If at any time the USAO's Office has reason to believe Epstein is in breach of the Agreement, it need only provide Epstein's counsel with notice of the breach and then move forward with Epstein's prosecution. Accordingly, the undersigned would agree with Epstein ... that the fact there exists a NPA does not mean that Epstein is free from future criminal prosecution, and that in fact, `the threat of prosecution is real, substantial and present.'" See August 4, 2009 Order (DE 242) and September 9, 2009 Omnibus Order (DE 293); and Manson v. United States 244 U.S. 362, 365 (1917). Moreover, as this court knows, the NPA only defers prosecution in the Southern District of Florida, not other districts. Therefore, Epstein is "confronted by a substantial and `real,' and not merely trifling or imaginary, hazard[] of incrimination" when it comes to Plaintiff's discovery requests. United States v. Anfelbaum, 445 U.S. 115, 128 (1980). + +The Fifth Amendment serves as a guarantee against testimonial compulsion and provides, in relevant part, that "[njo person...shall be compelled in any Criminal Case to be a witness against himself." (DE 242, p.5); see also Edwin v. Price, 778 F.2d 668, 669 (11th Cir. 1985) (citing Lefkowitz v. Turley, 414 U.S. 70, 77 (1973)). The privilege is accorded liberal construction in favor of the right and extends not only to answers that would support a criminal conviction, but extends also to those answers which would furnish a link in the chain of evidence needed to prosecute the claimant for a crime. See Hoffman v. United States, 341 U.S. 479, 486 (1951). Information is protected by the privilege not only if it would support a criminal conviction, but also in those instances where "the responses would merely `provide a lead or clue' to evidence having a tendency to incriminate." See United States v. Neff, 315 F.2d 1235, + +1239(9th Cir.), cert denied, 447U.S. 925 (1980); Blau v. United States 340U.S. 159 (1950); SEC v Leach, 156F.Supp.2d 491, 494 (ED. PA. 2001). + +Moreover, the act of production itself may implicitly communicate statements and, for this reason, the Fifth Amendment privilege also encompasses the circumstances where the act of producing documents in response to a subpoena or production request has a compelled testimonial aspect. See United States v. Hubbell, 530U.S. 27, 35-36 (2000). Thus, where the existence or location of the requested documents are unknown, or where production would "implicitly authenticate" the requested documents (as requested by Plaintiff here), the act of producing responsive documents is considered testimonial and is protected by the Fifth Amendment. aes In re Grand Jury Subpoena, 1F.3d 87, 93 (2nd Cir. 1993). + +Here, Plaintiffs overly broad request seeks photos of the inside of Epstein's home. Moreover, it seeks to compel Epstein into implicitly admitting that there were rooms within his house where "the massages took place" and into selecting such rooms and even the alleged massage table. Any compelled "production" by Epstein would violate his Fifth Amendment rights in that he is implicitly being asked to authenticate same i.e., given the nature of the request, Epstein's selection and production of photos would constitute compelled testimonial admissions that "the massages" took place in a given room on agiven table etc. . . . The requested information could potentially provide a`lead or clue' or alink in the chain of evidence having a tendency to incriminate Epstein and would threaten to invade his privilege against being required to produce and/or testify. Rudy-Glanzer v. Glanzer, 232F.3d 1258, 1263 (9th Cir. 2000)(the "privilege" against self-incrimination does not depend upon the likelihood, but upon the possibility of prosecution and also covers those circumstances where the disclosures + +would not be directly incriminating, but could provide an indirect link to incriminating evidence). + +In Jane Doe No. 2 v. Epstein, the Court sustained Epstein's Fifth Amendment objections to interrogatories: asking Epstein to identify all employees who performed work inside his Palm Beach residence and all other employees who came to the residence, asking Epstein to identify any who gave or were asked to give him massages, requesting information regarding the identity of persons who provided transportation services, seeking a list of Epstein's employees' telephone numbers, asking Epstein to identify any persons or witnesses who have knowledge or are in possession of physical evidence pertaining to the events in question, seeking information related to alleged sexual abuse or misconduct on a minor, and seeking the facts on upon which Epstein relies to support pleading denials and affirmative defenses. See (DE 242). + +If the Fifth Amendment protects Epstein from disclosing the identity of any person who has knowledge or are in possession of physical evidence (i.e. photographs, videos, written statements, etc.) pertaining the alleged events in question, it follows that Epstein's production himself of photographs of the same or related subjects would also violate his Fifth Amendment rights. Stated differently, if Epstein can properly invoke his Fifth Amendment right to not identify a person who may have a photograph or physical evidence pertaining to the alleged events, how can Epstein be required to produce the requested photographs? He cannot. + +For these reasons, Epstein's justified concern with regard to answering the above request and the resulting waiver of his Fifth Amendment Privilege in this regard and/or providing selfincriminating information is substantial, real and not merely imaginative. Accordingly, based on the facts and circumstances of this case, and under applicable law, Defendant's assertion of the + +Page No. 6 + +protections afforded under the 5th, 6th, and 14'h Amendments of the United States Constitution are required to be upheld. + +## b. Requests Numbers 7,9 and 10 + +Request No. 7: All discovery information obtained by you or your attorneys as a result of the exchange of discovery in the State criminal case against you or the Federal investigation against you. + +Request No. 9: Any documents or other evidentiary materials provided to local, state, or federal law enforcement investigators or local, state or federal prosecutors investigating your sexual activities with minors. + +Request No. 10: All correspondence between you and your attorneys and state or federal law enforcement or prosecutors (includes, but not limited to, letters to and from the State Attorney's office or any agents thereof). + +Response to Request Numbers 7, 9 and 10: Defendant is asserting specific legal objections to the production request as well as his U.S. constitutional privileges. I intend to produce all relevant documents regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select, authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution. In addition to and without waiving his constitutional privileges, the information sought is privileged and confidential, and inadmissible pursuant to the terms of the deferred prosecution agreement, Fed. Rule of Evidence 410 and 408, and §90.410, Ha. Stat. Further, the request may include information subject to work product or an attorney-client privilege. + +As discussed in the supporting memorandum herein, it is well settled that the Fifth Amendment privilege against self-incrimination also encompasses situations as here where the act of production itself involves a testimonial compulsion. Hubbell, supra. In responding to each request, Epstein would be compelled admit that such documents existed, admit that the documents were in his possession or control, and were authentic. In other words, the very act of production of the category of documents requested would implicitly communicate "statements of fact." Hubbell, supra; Hoffman, supra. The act of production might not only provide evidence + +to support a conviction, but also a link in the chain of evidence for prosecution. See supra. Such compulsion to produce is the same as being compelled to testify. The acts of Epstein in being required to produce the requested documents imply assertions of fact — admitting the documents exist, admitting the documents are in his possession or control, and admitting the documents are authentic. Again, in reading each of the production requests, it is clear that the very act of production of such documents could implicate Epstein of a crime. See supra, same argument on Sal Amendment applies. + +Moreover, the production of such discovery information may lead to the identity of witnesses that could testify against Epstein and those that may have knowledge or are in possession of evidence that could be used against Epstein. This court has already ruled that Epstein can properly invoke his Fifth Amendment right to sr j identify a person who may have a photograph or physical evidence pertaining to the alleged events. (DE 242). Moroever, the requested information could encompass documents identifying Epstein's whereabouts, schedules, calendars etc . . . Requiring Epstein to provide responses would in essence be compelling him to provide assertions of fact that could incriminate him under 18 U.S.C. §2422(b) and 18 U.S.C. §2423(b) and other federal violations discussed, in camera, at DE 282 and 283. As stated infra, the court has already ruled on this issue. See DE 242 and 293. Epstein should not be required to produce information in any State or Federal Agencies' possession, especially when doing so would violate his constitutional rights. + +Notably, this court has already ruled on a similar request in 80119 whereby the Plaintiffs, Jane Doe 2-7, asked the following: + +Request No. 1. The list provided to you by the U.S. Attorney of individuals whom the U.S. Attorney was prepared to name in an Indictment as victims of an offense by Mr. Epstein enumerated in 18 U.S.C. §2255. + +> Request No. 2. All documents referring or relating to the United States' agreement with Defendant to defer federal prosecution subject to certain conditions, including without limitation, the operative agreement between Defendant and the United States and all amendments, revisions and supplements thereto. + +> Request No. 3. All documents referring or relating to Defendant's agreement with the State of Florida on his plea of guilty to violations of Florida Criminal Statutes, including without limitation, the operative plea agreement and any amendments, revisions and supplements thereto. + +> Request No.4. All documents obtained in discovery or investigation relating to either the Florida Criminal Case or the Federal Criminal Case, including without limitation, documents obtained from any federal, state, or local law enforcement agency, the State Attorney's office and the United States Attorney's office. + +The court specifically held at p.17 of its Order at DE 242 that "[d]efendant's Motion as it relates to Production request number(s) 1, 2, 3, 4. . . is [granted]. The very act of producing documents in response to these requests is testimonial in nature, in that by production, Epstein would be implicitly communicating 'statements of fact,' to which the fifth Amendment privilege may be validly asserted . Hubbell, 530 U.S. at 35-36. Not only do the subject requests involve 'statements of fact,' given the nature of the allegations against Epstein, they could also serve as links in the chain of evidence needed for prosecution. As such, Epstein's fifth Amendment Privilege assertion as it relates to these requests is sustained." That same ruling should apply to the above requests. + +### The Requests Seek Attorney-Client And Work-Product Privileged Material And Rules 408 And 410, Fed. Evid. And \$90.410, Fla. Stat., Preclude Production of the Material + +Next, a reading of the particular discovery requests reveals that they encompass attorneyclient and work-product privileged material. As this court has already ruled (DE 242), Epstein cannot be compelled to create a privilege log because that would be tantamount to compelled testimony to which Defendant's constitutional protections apply. Any exchange of information with federal authorities was done in the context of discussions that are in essence immunized under the provisions of FRE 410 in order to encourage the resolution of pending investigations + +Page No. 9 + +without trials. FRE 410(4) is particularly directed to communications in matters which, like Epstein's, did not result in a plea of guilty to any federal charge. Fla. Stat. §90.410 provides parallel protections in state criminal matters. To the extent Epstein's counsel provided the authorities with any information it cannot, by the terms of that rule, be used in subsequent litigation as same is work-product. Likewise, the information received from the federal authorities, if any, as part of a give and take, is also subject to FRE 410. Finally, the purposes of FRE 408 provide further protection for both state and federal interchanges of information. If Epstein is compelled to produce this information, not only will it violate his Fifth Amendment privilege, but it will also result in an open-ended waiver of his attorney-client and work-product privileges. + +Additionally, Request Numbers 7, 9 and 10 all pertain to the State Criminal Proceeding and the Federal Investigation by the USAO. Therefore, the requests concern the negotiation(s) and eventual entering into of aPlea and the negotiation(s) and eventual entering into the NPA. Request Numbers 9 and 10 are so broad that production would encompass any information, assuming it exists, provided by Epstein's attorneys to local, state or federal prosecutors in the Southern District and/or outside of the Southern District in connection with Epstein's alleged sexual activities. Likewise, all the requests, as worded, seek production of information in connection with "compromise negotiations." Federal Evidence Rules 408 and 410 and Florida Statute §90.410 prevent the production of such material. The full text of Federal Evidence Rules 408and 410, and Florida Statute §90.410 is found at footnote 1 and is incorporated herein. + +Relevancy and Its Limits + +Clearly, discovery in criminal cases is not congruent with discovery in civil cases. Here, the information requested involves negotiations with the State and the USAO and their investigation. + +If the USAO cannot be compelled to release its investigation(s) and related work-product, how + +(a) Prohibited uses.--Evidence of the following is not admissible on behalf of any party, when offered to prove liability for, invalidity of, or amount of a claim that was disputed as to validity or amount, or to impeach through a prior inconsistent statement or contradiction: + +(1) furnishing or offering or promising to furnish--or accepting or offering or promising to accept--a valuable consideration in compromising or attempting to compromise the claim; and + +(2) conduct or statements made in compromise negotiations regarding the claim, except when offered in a criminal case and the negotiations related to a claim by a public office or agency in the exercise of regulatory, investigative, or enforcement authority. + +(b) Permitted uses.--This rule does not require exclusion if the evidence is offered for purposes not prohibited by subdivision (a). Examples of permissible purposes include proving a witness's bias or prejudice; negating a contention of undue delay; and proving an effort to obstruct a criminal investigation or prosecution. + +#### CREDIT(S) + +(Pub.L. 93.595, § I, Jan. 2, 1975, 88 Stat. 1933; Apr. 12, 2006, eft Dec. 1, 2006). + +## Rule 410. Inadmissibility of Pleas, Plea Discussions, and Related Statements + +Except as otherwise provided in this rule, evidence of the following is not, in any civil or criminal proceeding, admissible against the defendant who made the plea or was a participant in the plea discussions: + +(I) a plea of guilty which was later withdrawn; + +(2) a plea of nolo contendere; + +(3) any statement made in the course of any proceedings under Rule I I of the Federal Rules of Criminal Procedure or comparable state procedure regarding either of the foregoing pleas; or + +(4) any statement made in the course of plea discussions with an attorney for the prosecuting authority which do not result in a plea of guilty or which result in a plea of guilty later withdrawn. + +However, such a statement is admissible (i) in any proceeding wherein another statement made in the course of the same plea or plea discussions has been introduced and the statement ought in fairness be considered contemporaneously with it, or (ii) in a criminal proceeding for perjury or false statement if the statement was made by the defendant under oath, on the record and in the presence of counsel. + +#### Florida Evidence Code + +### 90.410. Offer to plead guilty; nolo contendere; withdrawn pleas of guilty + +Evidence of a plea of guilty, later withdrawn; a plea of nob contendere; or an offer to plead guilty or nolo contendere to the crime charged or any other crime is inadmissible in any civil or criminal proceeding. Evidence of statements made in connection with any of the pleas or offers is inadmissible, except when such statements are offered in a prosecution under chapter 837. + +can Epstein be compelled to disclose same in violation of his constitutional rights and his attorney-client and work-product privileges? He cannot. The protections afforded by these evidentiary rules provide that such documents are not subject to discovery. + +Moreover, any information exchanged by Epstein's attorneys and the State was exchanged pursuant to Fla.R.Crim.P. §3.220 and is therefore protected under that Rule. Further, the information is "work-product" information. See id. and 14B Fla. Jur.2d Criminal Law §1412. + +## Third Party Privacy Rights + +Here, the requests also seek information that may violate others third-party privacy rights. As noted by the United States Supreme Court in Eisenstadt v. Baird, 405 U.S. 438, 454, 92 S.Ct. 1029, 1038, at fn. 10 (1972): + +In Stanley, 394 U.S., at 564, 89 S.Ct., at 1247, the Court stated:`(A)Iso fundamental is the right to be free, except in very limited circumstances, from unwanted governmental intrusions into one's privacy." The makers of our Constitution undertook to secure conditions favorable to the pursuit of happiness. They recognized the significance of man's spiritual nature, of his feelings and of his intellect. They knew that only a part of the pain, pleasure and satisfactions of life are to be found in material things. They sought to protect Americans in their beliefs, their thoughts, their emotions, and their sensations. They conferred, as against the Government, the right to be let alone-the most comprehensive of rights and the right most valued by civilized man.' [Citations omitted]. + +The fundamental right of privacy is not only guaranteed under by the Fourteenth Amendment of the United States Constitution, but also under the Constitution of the State of Florida, Art. I, Sect. 23. As summarized by the Florida Supreme Court in Shaktman v. State, 553 So.2d 148, 150-51 (Fla. 1989): + +The right of privacy, assured to Florida's citizens, demands that individuals be free from uninvited observation of or interference in those aspects of their lives which fall within the ambit of this zone of privacy unless the intrusion is warranted by the necessity of a compelling state interest. In an opinion which predated the adoption of section 23, the First District aptly characterized the nature of this right. + +A fundamental aspect of personhood's integrity is the power to control what we shall reveal about our intimate selves, to whom, and for what purpose. + +Bryon, Harless, Schaffer, Reid & Assocs., Inc. v. State ex rel, Schellenberg 360 So.2d 83, 92 (Fla. 1st DCA 1978), quashed and remanded on other grounds, 379 So.2d 633 (Fla.1980). Because this power is exercised in varying degrees by differing individuals, the parameters of an individual's privacy can be dictated only by that individual. The central concern is the inviolability of one's own thought, person, and personal action. The inviolability of that right assures its preeminence over "majoritarian sentiment" and thus cannot be universally defined by consensus. + +(Emphasis added). + +Clearly, the nature of the questions and production requests identified would require Epstein to produce information that may identify third parties (that could also testify against him) and necessarily thwart such individuals' rights to assert their constitutional right of privacy as guaranteed under the United States and Florida Constitutions. See generally Eisenstadt v. Baird, supra at 454-455 (the right encompasses privacy in one's sexual matters and is not limited to the marital relationship). + +Accordingly, based on the facts and circumstances of this case, and under applicable law, Defendant's assertion of the protections afforded under the 5th, 6th, and 14th Amendments of the United States Constitution are required to be upheld. + +**c. Requests Numbers 8, 11, 12, 14 and 15** + +**Request No. 8:** All financial documents evidencing asset transfers from 2005 to the present for you personally or any company or corporation owned by you. + +**Request No. 11:** Any and all documents reflecting your current net worth. + +**Request No. 12:** Personal tax returns for all years from 2002 through the present. + +**Request No. 14:** A sworn statement of your net worth (including a detailed financial statement depicting all current assets and liabilities). + +Page No. 13 + +Request No. 15: All financial statements or affidavits produced by you for any reason, to any person, company, entity or corporation since 2005. + +Response to Request Numbers : Defendant is asserting specific legal objections to the production request as well as his U.S. constitutional privileges. I intend to produce all relevant documents regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select, authenticate, and produce documents relevant to this lawsuit without waiving my Fifth Amendment constitutional rightsand I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution; overly broad. + +As set forth in more detail in DE 282 and 283, which were provided to the court in camera, Epstein cannot provide answers/responses to questions relating to his financial history and condition without waiving his Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. The requests are unreasonable, overbroad, confidential, proprietary in nature and seek information that is neither relevant to the subject matter of the pending action nor does it appear to be reasonably calculated to lead to the discovery of admissible evidence. The information sought is privileged and confidential, and inadmissible pursuant to the terms of the NPA and, Fed. Rule of Evidence 410 and 408, and Fla. Stat. 90.410. See supra for argument. + +Responding to the above financial requests would require Epstein to identify information regarding matters as set forth in more detail in DE 282 and 283, which were provided to the Court in camera. Producing the specified information would result in testimonial disclosures that would communicate statements of fact. Again, the information sought relates to potential federal claims of violations. See DE 282 and 283, in camera. Production would therefore constitute a testimonial admission of the genuineness, the existence, and Epstein's control of such records, + +Page No. 14 + +and thus presents areal and substantial danger of self-incrimination in this case, in other related cases and as well in areas that could result in criminal prosecution. See generally Hoffman v United States, 341U.S. 479, 486 (1951) and United States v. Hubbell, 530U.S. 27, 36, 120 S.Ct. 2037, 2043 (2000). + +The Fifth Amendment is asafe harbor for all citizens, including those who are innocent of any underlying offense. This request, if answered, may result in compelled production and/or testimonial communications from Epstein regarding his financial status and history and would require him to waive his right to decline to respond to other inquiries related to the same subject matter. Responding to this and other related inquiries would have the potential to provide alink in achain of information and/or leads to other evidence or witnesses that would have the specific risk of furthering an investigation against him and therefore are protected from compulsion by Epstein's constitutional privilege. + +Accordingly, any compelled testimony that provides a"lead or clue to a source of evidence of such [a] crime" is protected by Fifth Amendment. SEC v Leach, 156F.Supp.2d 491, 494(E.D. PA. 2001). See supra. Questions seeking "testimony" regarding names of witnesses, leads to phone or travel records, or financial records that would provide leads to tax or money laundering or unlicensed money transmittal investigations are protected. See also Hoffman v United States, 341U.S. 479, 486 (1951)("the right against self-incrimination may be invoked if the answer would furnish alink in the chain of evidence needed to prosecute for a crime"). + +In addition to the above argument, the specific information requested in request number 12as to personal tax returns also seeks information that is confidential and protected by federal law, 26 U.S.C. §6103. + +To the extent Plaintiff claims she needs the requested information concerning asset transfers based on her unsupported presumption that Epstein is fraudulently transferring assets, same is premature and unsupported by the law for the reasons set forth in Epstein's Memorandum of Law in Opposition to Plaintiffs Motion for Injunction Restraining Fraudulent Transfer of Assets (DE 198). + +### d. Requests Numbers 13 and 16 + +Request No. 13: Aphotocopy of your passport, including any supplemental pages reflecting travel to locations outside the 50 United States between 2002 and 2008, including any documents or records regarding plane tickets, hotel receipts, or transportation arrangements. + +Response: Defendant asserts his U.S. constitutional privileges. I intend to produce all relevant documents regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select, authenticate, and produce documents relevant to this lawsuit without risking waiver of my Fifth Amendment rights and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution. In addition to and without waiving his constitutional protections and privileges, the scope of information is so overbroad that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence; compiling such information over asix year period would be unduly burdensome and time consuming. + +Request No. 16: Alexander. All medical records of Defendant Epstein from Dr. Stephan + +Response: Defendant is asserting specific legal objections to the production request as well as his U.S. constitutional privileges. I intend to produce all relevant documents regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select, authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my + +> constitutional rights, would be unreasonable, and would therefore violate the Constitution. + +As to Request Number 13, Defendant has already provided this court with sufficient argument at DE 282 and DE 283 detailing why the production of information showing Epstein's whereabouts could provide a link in the chain of evidence regarding: (a) Epstein's air travel within the United States and Foreign Territories; (b) Epstein's communications with others relating to or referring to females coming into the United States from other countries; and (c) Epstein's personal calendars and schedules. Given that the essential proof of an allegation of 18 U.S.C. 2423(b) would include travel records, schedules regarding trips and locations, flight records, calendars, and transportation arrangements, the court found that Epstein had made a more particularized showing because producing such information "could reveal the availability to him and/or use by him of interstate facilities and thus would constitute a link in the chain of evidence that could potentially expose [Epstein) to the dangers of self incrimination." (DE 293, p.6) + +Here, Plaintiff's request for Epstein's passport "reflecting travel to locations outside the 50 United States between 2002 and 2008, including any documents or records regarding plane tickets, hotel receipts, or transportation arrangements" is no different from the requests this Court has already ruled upon and sustained Epstein's Fifth Amendment privilege in response thereto. (DE 292). In summary, this court reasoned that: + +"[i]n this and the other civil actions, Plaintiff's allege that Epstein violated certain federal and state criminal statutes in an attempt to make claims against Epstein ranging from sexual battery to intentional infliction of emotional distress. The lynchpin for the exercise of federal criminal jurisdiction under 18 U.S.C. §2422(b), which figures in some of the complaints filed, is `the use of any facility or means of interstate or foreign commerce' and the analogous essential element of 18 U.S.C. §2423(b), which also figures in some of the Complaints, is `travel[s] in interstate commerce or travels into the United States or . . . travels in foreign commerce.' Accordingly, requiring Epstein to provide responses. . .would in + +> essence be compelling him to provide assertions of fact, thereby admitting that such documents existed and further admitting that the documents in his possession or control were authentic. + +Based upon the arguments set forth in DE 283 (which is incorporated herein), this Court sustained Epstein's Fifth Amendment Privilege. That same ruling should apply here as Jane Doe's request is identical to the requests already ruled on by this court. (DE 293). + +As to Plaintiff's request for Epstein's medical records, Dr. Stephen Alexander was hired as an expert consultant by Epstein's attorneys in the underlying criminal matter. Therefore, any information provided to Dr. Stephen Alexander or any information provided by the experts to Epstein's attorneys is protected by the attorney-work product and attorney-client privileges, Fla.R.Civ.P.1.280, 19 Fla. Jur.2d, Discovery and Depositions, §89, and Fed.R.Civ.P. 26(b)(3). + +19A Fla. Jur.2d, Discovery and Depositions, §89, provides: + +[a] party may discover facts known or opinions held by an expert who has been retained or specially employed by another party in anticipation of litigation or preparation for trial and who is not expected to be called as awitness at trial, only as provided in...Rule of Civil Procedure 11.360 (b)(1)1, governing the report of an examining physician" /which is not applicable in the instant matter], "or upon ashowing of exceptional circumstances under which it is impracticable for the party seeking discovery to obtain facts or opinions on the same subject by other means. The statutory protection has been extended both to the facts known or opinions held by non-witness experts retained or specially employed by a party in anticipation of litigation and to their identities. Thus, absent a showing of exceptional circumstances, a litigant is not required to disclose the names and specialties of experts retained but not expected to testify at trial. Accordingly, a discovery order ordering adefendant to disclose the names of any persons who have examined, evaluated, or reviewed the defendant's records improperly compels the defendant to divulge the names of experts consulted for trial but not intended to be called to testify at trial where such information is protected by the work-product privilege and where the state makes no showing of exceptional circumstances. + +Id.; see also Carrero v. Homes. Inc. 667 So. 2d 1011 (Fla. 4th DCA 1996); Myron By and Through Brock v. Doctors General, Ltd., 573 So. 2d 34 (Fla. 4th DCA1990); see also 14B Fla.Jur.2d , Criminal Law, §1412. + +In addition to the foregoing privileges, in the Court's prior order (DE 242), it found that Epstein's Health Insurance Portability and Accountability Act ("HIPAA") objections were "unfounded as the requests [i.e., the interrogatory] seek only the identification of Epstein's healthcare providers." Here, however, a request for production is at issue, not an interrogatory. Therefore, Epstein's HIPAA rights should be upheld. v. Woodford, 2007 WL 309485 (E.D. Cal. 2007), (p. 9)(HIPPA institutes procedural safeguards to protect the privacy of an individual's medical information and history). In the context of HIPAA, Courts have recognized three methods of health care discovery (assuming it's relevant) in civil litigation: (1) Obtaining a patient authorization that complies with the requirements and criteria, tailored to the specific case, of HIPAA as set forth in 45 C.F.R. §164.508; (2) Court Order, which also complies with the requirements of HIPAA ensuring that the privacy and confidentiality of the information is protected; and (3) Subpoena or discovery request, which again comply with the strictures of HIPAA, including that the person whose records are being sought has been given proper notice. ss& Handbook of Federal Civil Discovery And Disclosure (2d Edition), Chap. 18, Sect. A - Health Insurance Portability and Accountability Act (HIPAA), §18.3 — Discovery of health care information in civil litigation; and Graham v. Dacheikh, 991 So.2d 932, at fn. 3 (2d DCA Fla. 2008)("Even under HIPAA, ..., if the records are produced during normal discovery they are typically produced in a manner that restricts the persons who may access the documents and requires their return at the end of the litigation. See 45 C.F.R. §164.512(e)."). + +Federal Rule of Evidence 401 provides that - "'Relevant evidence" means evidence having any tendency to make the existence of any fact that is of consequence to the determination of the action more probable or less probable than it would be without the evidence." Pursuant to Rule 26(b)(1), the scope of discovery is as follows — + +Unless otherwise limited by court order, the scope of discovery is as follows: Parties may obtain discovery regarding any nonprivileged matter that is relevant to any party's claim or defense--including the existence, description, nature, custody, condition, and location of any documents or other tangible things and the identity and location of persons who know of any discoverable matter. For good cause, the court may order discovery of any matter relevant to the subject matter involved in the action. Relevant information need not be admissible at the trial if the discovery appears reasonably calculated to lead to the discovery of admissible evidence. All discovery is subject to the limitations imposed by Rule 26(bX2XC). + +Plaintiff's requests is further barred by under Fed. Evid. Rule 501 and §90.503, Fla.R.Evid. Rule 501 provides — + +Except as otherwise required by the Constitution of the United States or provided by Act of Congress or in rules prescribed by the Supreme Court pursuant to statutory authority, the privilege of a witness, person, government, State, or political subdivision thereof shall be governed by the principles of the common law as they may be interpreted by the courts of the United States in the light of reason and experience. However, in civil actions and proceedings. with respect to an element of a claim or defense as to which State law supplies the rule of decision, the privilege of a witness, person. government, State, or political subdivision thereof shall be determined in accordance with State law. + +(Emphasis added). + +Plaintiff alleges diversity jurisdiction, and thus, state law of Florida controls application of the privilege. Plaintiff claims - Count I —"Sexual Battery Upon a Minor," Count II — "Cause of Action Pursuant to 18 USC §2255," Count III — "Intentional Infliction of Emotional Distress," Count IV — "Civil Remedy for Criminal Practices" and Count VI — "Cause of Action Pursuant to Florida Statute 796.09 Against Defendant, Jeffrey Epstein". Erie R.Co. v. Tompkins, 58 S.Q. 817 (1938). Accordingly, the privileges recognized under state law apply to this action under Rule 501. See, es., 1550 Brickell Associates v. O.B.E. Ins. Co., 253 F.R.D. 697, 699 (S.D. Fla. 2008)("Attorney-client privilege is governed by state law in diversity actions."). + +§90.503(2), Fla. Stat., provides — + +(2) A patient has a privilege to refuse to disclose, and to prevent any other person from disclosing, confidential communications or records made for the purpose of diagnosis or treatment of the patient's mental or emotional condition, including alcoholism and other drug addiction, between the patient and the psychotherapist, or persons who are participating in the diagnosis or treatment under the direction of the psychotherapist. This privilege includes any diagnosis made, and advice given, by the psychotherapist in the course of that relationship. + +As summarized in C.L. v. Judd, 993 So.2d 991, 995 (2d DCA Fla. 2007): + +Under the psychotherapist-patient privilege, a patient has a privilege to refuse to disclose confidential information or records made for the purpose of diagnosis or treatment of mental conditions, including any diagnoses made by the psychotherapist. § 90.503(2), Fla. Stat. (2005); see Pauker v. Olson, 834 So.2d 198, 200 (Fla. 2d DCA 2002). The psychotherapist-patient privilege does not apply: (1) during involuntary commitment proceedings, (2) when there is a court-ordered mental examination, or (3) when the patient raises and relies on the issue of his or her mental condition in litigation as part of any claim or defense. § 90.503(4); Roberson, 884 So.2d at 980; State v. Famiglietti, 817 So.2d 901, 903 (Fla. 3d DCA 2002). The privilege does not allow the invasion of a patient's privileged communications with his or her psychotherapist. Roberson, 884 So.2d at 979. + +Significantly, Epstein has not placed his medical history at issue. In Breeden v. , 859 So. 2d 1276 (Fla. 4th DCA 2003), the court quashed an order compelling production of mental health records in a medical malpractice suit involving a failed ankle surgery finding that patient's mental health was irrelevant to claims asserted. See also Pusateri v. Fernandez, 707 So. 2d 892, 893 (Fla. 2d DCA 1998) (quashing order directing physicians to produce patient's medical record as the records were not relevant to any pending claim or defense nor were reasonably calculated to lead to the discovery of admissible evidence); Fla. Dept. of Corrections v. Abril, 969 So. 2d 201, 205-06 (Fla. 2007) (noting that "Florida has a long tradition of recognizing the privacy interests of patients in confidential medical records."); and State v. Cashner, 819 So. 2d 227, 229 (Fla. 4th DCA 2002) (holding that since "the compelled disclosure of a patient's medical records encroaches upon a patient's right to privacy, the state must demonstrate it has a compelling interest in the information contained in those records."). Plaintiff must also show + +that the requested information is relevant to the disputed issues of the underlying action. S Young Circle Garage. LLC. v. Koppel, 916 So. 2d 22 (Fla. 4th DCA 2005); see also Equitable Life Assurance Society of the United States v. Daisy Worldwide, Inc., 702 So. 2d 263 (Fla. 3d DCA 1997). Plaintiff has failed to meet this burden and, in doing so, has also failed to show any substantial need for the documents + +If this court orders production of the requested information (which it should not), an in camera inspection should be had to determine, as to each document, whether Fla. Stat. §39.204 is applicable. See DE 242, p.15; Carson v. 466 So.2d 1188, 1192 (Fla. 4th DCA 1985); and Doherty v. John Doe No. 22, 957 So.2d 1267 (4th DCA 2007). A reading of these cases clearly establishes that Fla. Stat. §39.204 does not provide Plaintiff with a carte blanche access to Defendant's medical history, especially those of non-testifying consulting experts. + +Wherefore, Epstein respectfully requests that this Court issue and order: + +- a. finding that the danger Epstein faces by being forced to respond to the above requests is substantial and real, and not merely trifling or imaginary; +- b. sustaining Epstein's Fifth Amendment Privilege and other delineated constitutional privileges as it relates to the above requests and denying Plaintiff's Motion in that regard; and + - c. for such other and further relief as this Court deems just and proper. + +Respect ?.' .mitted, + +B + +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 served this + +day on all counsel of record identified on the following Service List in the manner specified by CM/ECF on this \_\_\_ day of October, 2009 + +Respectfully submitted, + +![]()ROBERT D. CRITTON, JR., ESQ. + +Florida Bar No. 224162 + +[rcrit@bclclaw.com](mailto:rcrit@bclclaw.com) + +MICHAEL J. PIKE, ESQ. + +Florida Bar #617296 + +[mpike@bclclaw.com](mailto: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/[REDACTED]** + +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](mailto:ssm@sexabuseattorney.com) + +[ahorowitz@sexabuseattorney.com](mailto:ahorowitz@sexabuseattorney.com) + +*Counsel for Plaintiffs* + +*In related Cases Nos. 08-80069, 08-80119, 08-* + +*80232, 08-80380, 08-80381, 08-80993, 08-* + +*80994* + +Richard Horace Willits, Esq. + +Richard H. Willits, P.A. + +2290 10th Avenue North + +Suite 404 + +Lake Worth, FL 33461 + +Brad [REDACTED], Esq. + +Rothstein Rosenfeldt Adler + +401 East Las Olas Boulevard + +Suite 1650 + +Fort Lauderdale, FL 33301 + +Phone: 954-522-3456 + +Fax: 954-527-8663 + +[bedwards@rra-law.com](mailto:bedwards@rra-law.com) + +*Counsel for Plaintiff in Related Case No. 08-* +*80893* + +Paul G. Cassell, Esq. + +*Pro Hac Vice* + +332 South 1400 E, Room 101 + +Salt Lake City, UT 84112 + +801-585-5202 + +801-585-6833 Fax + +[cassellp@law.utah.edu](mailto:cassellp@law.utah.edu) + +*Co-counsel for Plaintiff Jane Doe* + +561-582-7600 Fax: 561-588-8819 Counsel for Plaintiff in Related Case No. 08- 80811 reelrhw@hotmail.com + +Jack Scarola, Esq. Jack P.. Esq. Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 561-686-6300 Fax: 561-383-9424 isxAsearcylaw.com iph@searcvlaw.com Counsel for Plaintiff C.. + +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. 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 + +Isidro M. Esq. Waw arm, P.A. itira Street, Suite 900 West Palm Beach, FL 33401 561-832-7732 561-832-7137 F isidrogarcia@bellsouth.net Counsel for Plaintiff in Related Case No. 08- 80469 + +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 rjosefsberg@oodhurst.com kezell@podhurst.com Counsel for Plaintiffs in Related Cases Nos. 09-80591 and 09-80656 + +Jack Alan Goldberger, Esq. 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Jeffrey Epstein's response (DE 339 in consolidated case no. 08-CIV-80119) to her motion to compel answers to her first request for production. Epstein should be compelled to provide the requested information, because it is not properly subject to a Fifth Amendment invocation. + +# SPECIFIC REQUESTS FOR PRODUCTION + +# Request No. 5. + +Jane Doe withdraws this request. + +# Requests No. 7, 9 and 10 + +Request No. 7: All discovery information obtained by you or your attorneys as a result of the exchange of discovery in the State criminal case against you or the Federal investigation against you. + +Defendant is asserting his U.S. constitutional privileges. I intend to respond to all relevant questions regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution. In addition to and without waiving his constitutional privileges, the information sought is privileged and confidential, and inadmissible to the terms of the deferred prosecution agreement, Federal Rule of Evidence 410 and 408, and § 90.410, Fla. Stat. Further, the request may include information subject to work product or an attorney-client privilege. + +Request No. 9: Any documents or other evidentiary materials provided to local, state, or federal law enforcement investigators or local, state or federal prosecutors investigating your sexual activities with minors. + +Defendant is asserting his U.S. constitutional privileges. I intend to respond to all relevant questions regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution. In addition to and without waiving his constitutional privileges, the information sought is privileged and confidential, and inadmissible pursuant to the terms of the deferred prosecution agreement, Fed. Rule of Evidence 410 and 408, and § 90.410, Fla. Stat.1 Further, the request may include information subject to work product or an attorney-client privilege. + +Request No. 10: All correspondence between you and your attorneys and state or federal law enforcement or prosecutors (includes, but not limited to, letters to and from the States Attorney's office or any agents thereof). + +Defendant is asserting his U.S. constitutional privileges. I intend to respond to all relevant questions regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution. In addition to and without waiving his constitutional privileges, the information sought is privileged and confidential, and inadmissible pursuant to the terms of the deferred prosecution agreement, Fed. Rule of Evidence 410 and 408, and § 90.410, Fla. Stat. Further, the request may include information subject to work product or an attorneyclient privilege. + +# Reply to Epstein's Response: + +These requests simply seek information that the federal government gave to Epstein in the course of its plea discussions with him. Remarkably, Epstein claims that these materials — which started in the government's possession -- are now somehow transformed and given Fifth Amendment protection by his mere receipt of them. The Fifth Amendment does not work such alchemy. + +It is true, of course, that the Fifth Amendment covers situations where the act of producing documents has "communicative aspects of its own, wholly aside from the contents of the papers produced." Fisher v. United States, 425 U.S. 391, 410 (1976). But this "act of production" doctrine has stringent limits. It does not extend, for example, to a claim by a taxpayer that he would incriminate himself by producing his accountant's work papers. As the Supreme Court has explained, the government's awareness of these documents was "a foregone conclusion" and therefore their production could be required: + +It is doubtful that implicitly admitting the existence and possession of the papers rises to level of testimony within the protection of the Fifth Amendment. The papers belong to the accountant, were prepared by him, and are the kind usually prepared by an accountant working on the tax returns of his client. Surely the Government is in no way relying on the "truthtelling" of the taxpayer to prove the existence of . . . the documents. The existence and location of the papers are a foregone conclusion. + +Fisher, 425 U.S. at 410 (emphasis added). + +Courts applying this "foregone conclusion" standard to various fact patterns have asked whether the government was aware of the documents' existence apart from any actions of the defendant. Thus, United States v. Hubbell, 530 U.S. 27 (2000), rejected the Government's argument that it was a foregone conclusion that the defendant possessed "ordinary business records." The Court noted that the government had no "prior knowledge" of these records: + +Whatever the scope of this "foregone conclusion" rationale, the facts of this case plainly fall outside of it. While in Fisher the Government already knew that the documents were in the attorney's possession and could independently confirm their existence and authenticity through the accountants who created them, here the Government has not shown that it had any prior knowledge of either the existence or the whereabouts of the 13,120 pages of documents ultimately produced by respondent. + +Id. at 44 (emphasis added). + +In this case, of course, the government's "prior knowledge" of the documents that Jane Doe seeks is obviously and undeniably a foregone conclusion. The government itself gave Epstein the documents! Therefore, there is no plausible argument that, in producing these documents to Jane Doe, Epstein will somehow be incriminating himself by disclosing to the government something that it does not already know. The government clearly has prior knowledge of documents that it gave to Epstein. Here, + +then, the "existence and location of the documents . . . are a 'foregone conclusion' and [Epstein] . . . adds little or nothing to the sum total of the Government's information by conceding that he in fact has the documents." In re Grand Jury Subpoena, Dated April 18, 2003, 383 F.3d 905, 910 (9th Cir. 2004). + +The D.C. Circuit has recently refused to extend the act of production doctrine to facts very similar to those here. In United States v. Ponds, 454 F.3d 313 (D.C. Cir. 2006), federal prosecutors sought information about possible crimes committed by a defense attorney in the course of representing a defendant in a federal case. The prosecutors subpoenaed the attorney to produce all correspondence between him and courts and prosecutors in that case. In summarily rejecting an argument that producing the documents would somehow fall within the act of production doctrine of the Fifth Amendment, the D.C. Circuit explained that "the government must have known of the existence of documents . . . because it was a party to that correspondence." Id. at 325. The Circuit further explained that the government's subpoena need not "name every scrap of paper that is produced. Because the government already had sufficient knowledge about the . . . [case-related] documents, . . . [the defense attorney] was simply surrendering them, not testifying, by complying with those demands in the subpoena." Id. Other cases similarly reject attempts to use an act of production shield to turning over documents whose existence is known to the government or is a foregone conclusion. See, e.g. In re Grand Jury Subpoena Duces Tecum Dated Oct 29, 1992, 1 F.3d 87, 93 (2d Cir. 1993) (rejecting act of production argument because compliance with subpoena requiring production of a personal calendar "would require mere + +surrender of the calendar, and not testimony" (internal quotation omitted)); United States v. Clark, 847 F.2d 1467, 1473 (10th Cir. 1988) (accounting records not subject to act of production protection; in producing records the defendant would not "authenticate the documents as being his own or being accurate"); Securities and Exchange Commission v. First Jersey Securities, Inc., 843 F.2d 74, 76 (2d Cir. 1988) (rejecting act of production argument regarding bank records because "everybody knew that they existed"); ]"); United States v. Lang, 792 F.2d 1235, 1242 (4th Cir. 1986) (rejecting act of production argument regarding bank records because an IRS agent "had been given access to and has examined some or all of the records" and thus the defendants "act of producing those records would add little or nothing to the sum total of the Government's knowledge of the existence and location of the summoned records"). + +Rather than discuss specific case law about the act of production doctrine, Epstein retreats into mere generalities. Thus, he asserts that giving to Jane Doe the discovery produced by the government might disclose witnesses helpful to Jane Doe. Epstein's Resp. at 7. But this assertion badly confuses how the Fifth Amendment works. Of course, the government's documents have information that might be harmful to Epstein's claims of innocence; presumably that is why the government was showing him the documents in the first place to convince him to plead guilty to a crime. But it is a "settled proposition that a person may be required to produce specific documents even though they contain incriminating assertions of fact or belief . . . ." United States v. Hubbell, 530 U.S. 27, 35 (2000). The only question here is whether turning over the government's own documents to Jane Doe somehow forces Epstein to provide + +"testimony" to the government — something forbidden by the Fifth Amendment. Epstein has no such viable claim here. + +Epstein also argues that the magistrate judge's earlier omnibus order (doc. # 339 in case no. 9:08-CV-80119) requires that request for production be denied. This is untrue for several reasons. First, the earlier requests that were apparently denied2 were broader than the narrow requests made by Jane Doe. The earlier requests included, for example, a request for all documents "relating to" the federal non-prosecution agreement (Production Request No. 2), all documents "relating to" Epstein's Florida guilty plea (Production Request No. 3), and all documents obtained in "investigation relating to" either the federal or state criminal investigations. See Epstein's Resp. at 8 (quoting those requests). Such overbroad requests might require Epstein to effectively make "use of the content of his mind" in identifying which documents were responsive. See Hubbell, 530 U.S. at 43. But here Jane Doe has propounded far narrower requests that do not require any mind to pick and choose. Indeed, Jane Doe's request is significantly narrower that other requests that the United States Supreme Court and other courts have upheld. See, e.g., Fisher v. United States, 425 U.S. 391, 394 (1976) (rejecting Fifth Amendment challenge to subpoena requesting "accountant's workpapers pertaining to Dr. E.J. Mason's books and records of 1969, 1970, and 1971); United States v. Ponds, 454 F.3d 313, 325 (D.C. Cir. 2006) (rejecting Fifth Amendment challenge to subpoena requesting "[a]ny and all correspondence between the Law + +2 The magistrate judge's order on this point actually states that it was Epstein's motion to quash that was "denied." See Order at 17 ("Defendant's Motion as it relates to Pnxluction Requests 1. 2. 3. 4. 6. R. 14. 15. 16. 17. and 20 is denied." (emphasis added)). Read in context, it appears that the magistrate judge intended to state that the defendant's motion was granted. + +Offices of Navron Ponds [the defendant] and courts and prosecutors in the matter of U.S. v. Jerome Harris" (internal bracketing omitted)); United States v. Clark, 847 F.2d 1467, 1473 (10th Cir. 1988) (rejecting Fifth Amendment challenge to subpoena requesting "all records pertaining to the performance of any accounting service by [one named person to another named person. + +The magistrate judge's earlier order is also not controlling here for a second reason. That order was entered in a case that has been consolidated with Jane Doe's case for discovery purposes. But Jane Doe was not a party to the earlier ruling and did not have the opportunity to provide briefing and argument before the magistrate judge ruled. In this case, of course, Jane Doe has had that opportunity and has now provided recent precedents clearly dictating that her specific motion should be granted. See, e.g., United States v. Ponds, 454 F.3d 313, 325 (D.C. Cir. 2006) (Fifth Amendment privilege does not extend to correspondence to which the government was a party). + +Epstein also argues some sort of attorney-client or work-product privilege bars production of the documents. This argument is frivolous. The attorney-client privilege, for example, extends only to a "confidential communication" made in the course of "rendition of legal services to the client." Fla. Stat. Ann. § 90.502(2). Documents given by the government to Epstein are obviously not confidential communications within the sense of the attorney client privilege. Similarly, the documents are not work product, because they do not involve any creation by Epstein's attorneys. See, e.g., Balboa v. State, 446 So.2d 1134, 1135 (Fla. App. 1984) ("opinions, theories, or conclusions of attorneys are privileged, but statements of witnesses to attorneys are not"). + +Epstein finally claims that the information is protected by Federal Rules of Evidence 408 and 410, regarding settlement discussions and plea negotiations. Those federal rules3 have no bearing Jane Doe's requests for production number 7 and 9, which seek respectively discovery provided by the government and "evidentiary materials" provided by the government. These are simply not "offers to compromise," Fed. R. Evid. 408, or "plea discussions," Fed. R. Evid. 410, to which the rules apply. + +While Rules 408 and 410 do not covers requests number 7 and 9, they potentially cover Jane Doe's request number 10, seeking correspondence regarding the plea discussions in this case. These rules, however, provide no valid basis for resisting Jane Doe's discovery requests. Discovery is, of course, permitted "regarding any nonprivileged matter that is relevant" to Jane Doe's claims. Fed. R. Civ. P. 26(b)(1) (emphasis added). The Rules of Evidence regarding settlement discussions do not create any privileges. It is possible that Epstein may argue that these rules ultimately bar the use of certain evidence at trial. If these arguments are made, Jane Doe will respond in due course.4 But under the discovery rules "[r]elevant information need not be admissible at the trial if the discovery appears reasonably calculated to lead to the discovery of admissible evidence." Fed. R. Civ. P. 26(b). Thus, discovery is "construed broadly to encompass any matter that bears on, or that reasonably could lead to + +3 Epstein also cites several analogous state rules of evidence, which are likewise inapplicable for the reasons explained regarding the federal rule. + +Both rules contains exemptions, allowing such evidence to be used to prove such things as "state of mind," "bias and prejudice," or other things apart from mere liability for the matter under discussion. See, e.g., United States v. Peed, 714 F.2d 7, 9-10 (4th Cir. 1983) (admitting defendant's offer to return missing properly because it appeared motivated by purpose of persuading victim to drop criminal charges rather than to compromise civil claim). The Florida rules that Epstein cites, even though not applicable in this federal case, are also subject to similar exemptions. + +another matter that could bear on any issue that is or may be in the case." Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340, 352 (1978). The correspondence with the government agencies may well point Jane Doe in the direction of admissible evidence, and therefore Epstein should be compelled to provide the correspondence sought in request number 10. + +In a last desperate attempt to thwart production, Epstein appeals to "third-party privacy rights." Epstein's Resp. at 11. Given the extent to which Epstein's hired investigators have concluded interrogations of anyone even remotely connected with this case, this appeal to privacy interests rings rather hollow. In any event, it is odd to think that the privacy rights of these third persons do not interfere with Epstein himself (a convicted sex offender) reviewing these materials but forbid equal viewing by attorneys for a victim who was victimized by him. In any event, none of the authorities cited by Epstein are remotely similar to the case at hand. Epstein's argument should therefore be rejected summarily. + +# Requests No. 8, 11, 14, and 15 + +Request No. 8: All financial documents evidencing asset transfers from 2005 to present for you personally or any company or corporation owned by you. + +Defendant is asserting his U.S. constitutional privileges. I intend to respond to all relevant questions regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution. + +Request No. 11: Any and all documents reflecting your current net worth. + +Defendant is asserting his U.S. constitutional privileges. I intend to respond to all relevant questions regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution. + +Request No. 14: A sworn statement of your net worth (including a detailed financial statement depicting all current assets and liabilities). + +Defendant is asserting his U.S. constitutional privileges. I intend to respond to all relevant questions regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution. + +Request No. 15: All financial statements or affidavits produced by you for any reason, to any person, company, entity or corporation since 2005. + +Defendant is asserting his U.S. constitutional privileges. I intend to respond to all relevant questions regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my + +constitutional rights, would be unreasonable, and would therefore violate the Constitution; overly broad. + +# Reply to Epstein's Response: + +Epstein's main argument to turning over financial records is that he has explained in two sealed documents (doc. #282 and doc. #283) why producing financial records would incriminate him. Of course, because these documents are sealed, Jane Doe has no way of determining one way or other whether Epstein's assertions are true. Jane Doe therefore respectfully asks the Court to make its determination of the issue, mindful of the fact that it is proceeding without the benefit of an adversarial presentation from Jane Doe. + +If the Court concludes that the materials in DE 282 and DE 283 do demonstrate that Epstein would incriminate himself by discussing his assets — and, in particular, his recent transfers of assets to overseas locations and elsewhere — then the Court should consider the information in deciding whether to grant Jane Doe's motion for Preliminary Injunction Restraining Fraudulent Transfer of Assets [DE165], for reasons that Jane Doe explains in her concurrently-filed Notice that Additional Evidence of Epstein's Fraudulent Asset Transfers Will Be Filed shortly and Motion for Consideration by the Court of Materials in DE 282 and DE 283 in Determining Motion for Appointment of a Receiver. + +Epstein's other generic objections are makeweight and should be rejected. The financial records are relevant to a variety of issues in the case, including Jane Doe's efforts to show a conspiracy and to obtain punitive damages. + +### Request No. 12: + +Request No. 12: Personal tax returns for all years from 2002 through the present. + +Defendant is asserting his U.S. constitutional privileges. I intend to respond to all relevant questions regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution; overly broad. + +# Reply to Epstein's Response: + +Epstein's refusal to turn over his filed tax returns is absurd. For all the reasons explained earlier in connection with Requests 7, 9 and 10, the government (i.e., the IRS) already has a copy of these returns. Therefore, it can hardly be incriminating for Epstein to produce them. + +There is an additional, independent reason for rejecting Epstein's refusal to produce his tax returns. Tax records, including in particular filed tax returns, are "required records" that are not covered by the Fifth Amendment. See, e.g., Rajah v. Mukasey, 544 F.3d 427, 442 (2nd Cir. 2008) (". . . a taxpayer's W-2 forms are required records not subject to the Fifth Amendment because they are a mandatory part of a civil regulatory regime . . "); In re Doe, 711 F.2d 1187, 1191 (2d Cir. 1983) ("we have little difficulty applying the required records exception to the W-2 . . . forms" and ordering production of W-2 forms over Fifth Amendment objection); In re Doe, 97 F.R.D. 640, 644-45 (S.D.N.Y. 1982) (ordering production of physician's W-2 forms as required + +records); In re Grand Jury Empanelled March 19, 1989, 541 F.Supp. 1, 3 (D.N.J. 1981). (ordering the production of tax returns and W-2 statements to a grand jury), aff'd, 680 F.2d 327, 336 n. 15 (3rd Cir. 1982) ("[W]e affirm that those subpoenaed documents in the appellee's possession which are required either to be kept by law or to be disclosed to a public agency should be produced for the grand jury's inspection."), aff'd in part, rev'd in part on other grounds sub nom. United States v. Doe, 465 U.S. 605, 608 n.3 (1984). Of course, in all these cases, tax returns were ordered produced even though a federal statute (cited by Epstein) makes tax returns "confidential." See 26 U.S.C. § 6103. In all these cases, the confidentiality of provided by the IRS statute was obviously and properly overridden by the discovery procedures found in Fed. R. Civ. P. 26. + +Request No. 13: A photocopy of your passport, including any supplemental pages reflecting travel to locations outside the 50 United States between 2002 and 2008, including any documents or records regarding plane tickets, hotel receipts, or transportation arrangements. + +Defendant is asserting his U.S. constitutional privileges. I intend to respond to all relevant questions regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution. In addition to and without waiving his constitutional protections and privileges, the scope of information is so overbroad that it seeks information that is neither relevant nor reasonably calculated to lead + +to the discovery of admissible evidence; compiling such information over a six year period would be unduly burdensome and time consuming.5 + +# Reply to Epstein's Response: + +Here again, Epstein has no good basis for refusing to turn over something that the government is aware of and has inspected. Epstein has had to produce his passport to government immigration agents whenever he leaves or enters the United States. There is no valid Fifth Amendment basis for refusing the same opportunity to Jane Doe. + +In addition, like income tax records, a passport is a "required record" for which no Fifth Amendment privilege is available. See Rajah v. Mukasey, 544 F.3d 427, 442 (2nd Cir. 2008) ("Just as a taxpayer's W-2 forms are required records not subject to the Fifth Amendment because they are a mandatory part of a civil regulatory regime, so too are the passports . . at issue in the current case"). + +# Request No. 16. + +Request No. 16: All medical records of Defendant Epstein from Dr. Stephan Alexander. + +Defendant is asserting his U.S. constitutional privileges. I intend to respond to all relevant questions regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my + +5 Jane Doe believes that Epstein used overseas travel as a means of obtaining underage girls for sexual purposes and for avoiding criminal prosecution for such activities. Also, providing a copy of a passport is hardly "burdensome." Also, given the fact that Epstein is likely to have used the services of a travel agent or another intermediary, it should not be difficult for him to provide evidence of his overseas travels from such intermediaries. + +constitutional rights, would be unreasonable, and would therefore violate the Constitution. + +### Reply to Epstein's Response: + +Epstein claims, but does not prove, that he has hired Dr. Stephen Alexander as an expert witness in this case. He contends that he is therefore no obligated to turn over Dr. Alexander's records. + +Jane Doe understands that Dr. Alexander was Epstein's physician before this litigation ever started. Therefore, as to all records before such hiring, there is no protection. Even after such hiring, it would be Epstein's burden to show that certain medical examinations were done for purposes of litigation to prove work-product protection — a burden Epstein has not attempted to meet. + +Epstein also notes that the Health Insurance Portability and Accountability Act ("HIPAA") requires that records be disclosed in civil discovery only under an order insuring confidentiality. Jane Doe has no objection to such a confidentiality order. Finally, Epstein argues that some of the records may be protected by the Florida doctorpatient privilege. Fla. Stat. § 90.503(2). Epstein, however, is required to demonstrate that the elements of the privilege are satisfied on a document-by-document basis. Epstein has failed to do this and the documents should therefore be produced (or, in the alternative, Epstein should make an in camera submission showing how each document is privileged). + +# CONCLUSION + +For all these reasons, the Court should compel Epstein to answer the requests for production discussed above. + +DATED October 16, 2009 + +Respectfully Submitted, + +s/ [REDACTED] J. [REDACTED] +[REDACTED] J. [REDACTED] + +ROTHSTEIN ROSENFELDT ADLER +Las Olas City Centre +401 East Las Olas Blvd., Suite 1650 +Fort Lauderdale, Florida 33301 +Telephone (954) 522-3456 +Facsimile (954) 527-8663 +Florida Bar No.: 542075 +E-mail: bedwards@rra-law.com + +and + +Paul G. Cassell +Pro Hac Vice +332 S. 1400 E. +Salt Lake City, UT 84112 +Telephone: 801-585-5202 +Facsimile: 801-585-6833 +E-Mail: cassellp@law.utah.edu + +**CERTIFICATE OF SERVICE** + +I HEREBY CERTIFY that on October 16, 2009 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 on 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 filed Notices of Electronic Filing. + +s/ [REDACTED] J. [REDACTED] +[REDACTED] J. [REDACTED] + +**SERVICE LIST** + +**Jane Doe v. Jeffrey Epstein** +**United States District Court, Southern District of Florida** + +Jack Alan Goldberger, Esq. +[Jgoldberger@agwpa.com](mailto:Jgoldberger@agwpa.com) + +Robert D. Critton, Esq. +[rcritton@bclclaw.com](mailto:rcritton@bclclaw.com) + +Isidro Manual [REDACTED] +[isidrogarcia@bellsouth.net](mailto:isidrogarcia@bellsouth.net) + +Jack [REDACTED] [REDACTED] +[iph@searcylaw.com](mailto:iph@searcylaw.com) + +Katherine Warthen Ezell +[KEzell@podhurst.com](mailto:KEzell@podhurst.com) + +Michael James Pike +[MPike@bclclaw.com](mailto:MPike@bclclaw.com) + +Paul G. Cassell +[cassellp@bclclaw.com](mailto:cassellp@bclclaw.com) + +Richard Horace Willits +[lawyerswillits@aol.com](mailto:lawyerswillits@aol.com) + +Robert C. Josefsberg +[rjosefsberg@podhurst.com](mailto:rjosefsberg@podhurst.com) + +Adam D. Horowitz +[ahorowitz@sexabuseattorney.com](mailto:ahorowitz@sexabuseattorney.com) + +Stuart S. Mermelstein +[ssm@sexabuseattorney.com](mailto:ssm@sexabuseattorney.com) + +William J. Berger +[wberger@rra-law.com](mailto:wberger@rra-law.com) \ No newline at end of file diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821323/EFTA02821323.metadata.json b/marker2/court-redacted-v-epstein-81111/EFTA02821323/EFTA02821323.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e442abeb6d70d45d6dddc32fbf0298943b4f797b --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821323/EFTA02821323.metadata.json @@ -0,0 +1,1021 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-redacted-v-epstein-81111/EFTA02821323.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 18, + "chars": 33267, + "elapsed_seconds": 11.01, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": 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b/marker2/court-redacted-v-epstein-81111/EFTA02821341/EFTA02821341.md new file mode 100644 index 0000000000000000000000000000000000000000..e0f61e1f8934f25a0ddcad969d20d98d189d0a27 --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821341/EFTA02821341.md @@ -0,0 +1,81 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA + +JANE DOE, CASE NO. 08-CV-80893-CIV-MARRA/ + +Plaintiff, + +Vs. + +JEFFREY EPSTEIN, et al. + +Defendant. + +Related Cases: + +08-80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 + +## PLAINTIFF JANE DOE'S NOTICE OF 90 DAYS EXPIRING ON MOTIONS TO COMPEL + +Plaintiff, Jane Doe, pursuant to Local Rule 7.1.B.3, to give notice that more than 90 days have elapsed on three pending motions regarding her case (No. 9:08-CV-80893-KAM). Because these motions are discovery motions, they were filed in the consolidated case (9:08-cv-80119-KAM) pursuant to this Court's consolidation order. + +1. On July 10, 2009, Jane Doe filed (1) a Motion to Compel Responses to Plaintiff's Request for Production (dkt. #194 in 9:08-cv-80119-KAM), (2) a Motion to Compel Responses to Plaintiff's Request for Production (dkt. #195), and (3) a Motion to Compel Answers to Plaintiff's Interrogatories (dkt. #196). + +CASE NO: 08-CV-80119-MARRA + +2. After defendant Epstein received an extension, he filed responses/objections to all three of these motions on October 6, 2009 (dkts. #339, 342, 343). + +3. Jane Doe filed her reply to these responses on October 16, 2009 (dkts. #354, 355, and 356). + +4. More than 90 days has now elapsed since the filing of those replies (and, in addition, since the filing of the original motions). For the reasons offered in her pleadings, Jane Doe respectfully requests that her motions be granted. + +DATED: January 22, 2010 + +Respectfully Submitted, + +AFFE, WEISSING, , FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 Florida Bar No.: 542075 E-mail: brad@pathtojustice.com + +and + +Paul G. Cassell Pro Hac Vice 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: 801-585-5202 Facsimile: 801-585-6833 E-Mail: cassellp@law.utah.edu + +CASE NO: 08-CV-80119-MARRA + +## CERTIFICATE OF SERVICE + +I HEREBY CERTIFY that on January 22, 2010 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 on 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 filed Notices of Electronic Filing. + +> s/ J. + +## SERVICE LIST + +Jane Doe v. Jeffrey Epstein United States District Court, Southern District of Florida + +Jack Alan Goldberger, Esq. Jaoldberaer@aqwpa.com + +Robert D. Griffon, Esq. rcritton@bcIclaw.com + +Isidro Manual isidrogarcia@bellsouth.net + +Jack iph@searcvlaw.com • + +Katherine Warthen Ezell KEzell@podhurst.com + +Michael James Pike MPike@bciclaw.com + +Paul G. Cassell cassellp@bcIclaw.com + +Richard Horace Willits lawyerswillits@aol.com + +CASE NO: 08-CV-80119-MARRA/[REDACTED] + +Robert C. Josefsberg +[rjosefsberg@podhurst.com](mailto:rjosefsberg@podhurst.com) + +Adam D. Horowitz +[ahorowitz@sexabuseattorney.com](mailto:ahorowitz@sexabuseattorney.com) + +Stuart S. Mermelstein +[ssm@sexabuseattorney.com](mailto:ssm@sexabuseattorney.com) + +William J. Berger +[wberger@rra-law.com](mailto:wberger@rra-law.com) \ No newline at end of file diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821341/EFTA02821341.metadata.json b/marker2/court-redacted-v-epstein-81111/EFTA02821341/EFTA02821341.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..edd4f6cc1cf856845c8a37e592c63e6e4fffb786 --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821341/EFTA02821341.metadata.json @@ -0,0 +1,253 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-redacted-v-epstein-81111/EFTA02821341.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 4, + "chars": 3278, + "elapsed_seconds": 3.08, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF FLORIDA", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 201.96000000000004, + 70.47 + ], + [ + 410.520751953125, + 70.47 + ], + [ + 410.520751953125, + 99.54998779296875 + ], + [ + 201.96000000000004, + 99.54998779296875 + ] + ] + }, + { + "title": "PLAINTIFF JANE DOE'S NOTICE OF 90 DAYS EXPIRING \nON MOTIONS TO COMPEL", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 143.20800000000003, + 387.18 + ], + [ + 469.3027648925781, + 387.18 + ], + [ + 469.3027648925781, + 417.17999267578125 + ], + [ + 143.20800000000003, + 417.17999267578125 + ] + ] + }, + { + "title": "CERTIFICATE OF SERVICE", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 225.216, + 123.12 + ], + [ + 387.0013122558594, + 123.12 + ], + [ + 387.0013122558594, + 138.91998291015625 + ], + [ + 225.216, + 138.91998291015625 + ] + ] + }, + { + "title": "SERVICE LIST", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 261.936, + 316.71000000000004 + ], + [ + 350.1988220214844, + 316.71000000000004 + ], + [ + 350.1988220214844, + 332.04998779296875 + ], + [ + 261.936, + 332.04998779296875 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 48 + ], + [ + "Line", + 23 + ], + [ + "Text", + 10 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 64 + ], + [ + "Line", + 30 + ], + [ + "Text", + 9 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 69 + ], + [ + "Line", + 33 + ], + [ + "Text", + 12 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 3, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 10 + ], + [ + "PageFooter", + 4 + ], + [ + "PageHeader", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02821341" + } +} \ No newline at end of file diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821345/EFTA02821345.md b/marker2/court-redacted-v-epstein-81111/EFTA02821345/EFTA02821345.md new file mode 100644 index 0000000000000000000000000000000000000000..11bb4c55026b62dc9eb54cc389413ab1bf300494 --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821345/EFTA02821345.md @@ -0,0 +1,97 @@ +#### 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, 08-80380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 + +### OMNIBUS ORDER + +THIS CAUSE is before the Court on the following motions: (1) Plaintiffs Motion to Compel Answers to Plaintiff's First Request for Production(D.E. #194 and #210); (2) Plaintiff's Motion to Compel Answers to Plaintiff's First Request for Admissions (D.E. #195 and #211); and, (3) Plaintiff's Motion to Compel Answers to Interrogatories (D.E.#196 and #212). + +In this case, which has been consolidated for purposes of discovery, Plaintiffs are former under-age girls who allege they were sexually assaulted by Defendant, Jeffrey Epstein ("Epstein"), at his Palm Beach mansion home. The scheme is alleged to have taken place over the course of several years in or around 2004-2005, when the girls in question were approximately 16 years of age. As part of this scheme, Epstein, with the help of his assistant allegedly lured economically disadvantaged minor girls to his homes in Palm beach, New York and St. with the promise of money in exchange for a massage. Epstein purportedly transformed the massage into a sexual assault. The three-count Complaint alleges sexual assault and battery (Count I), intentional infliction of emotional distress (Count II), and, coercion and enticement to sexual activity in violation of 18 U.S.C. §2422 (Count III). + +In 2008, Epstein entered into a Non-Prosecution Agreement with the United States Attorney General's Office for the Federal Southern District of Florida and the State Attorney's Office for Palm Beach County. Under the terms of the Non-Prosecution Agreement, any criminal prosecution against Epstein is deferred as long as he abides by the certain terms and conditions contained therein. If at any time the United States Attorney's Office has reason to believe Epstein is in breach of the Agreement, it need only provide Epstein's counsel with notice of the breach and then move forward with Epstein's prosecution. Accordingly, the mere fact the Govemment and Epstein have entered into a Non-Prosecution Agreement does not mean that Epstein is free from future criminal prosecution. + +In each of these motions Plaintiff Jane Doe seeks to compel answers to certain requests for admissions, interrogatories and requests for production that were propounded on Defendant Epstein. Defendant has responded by asserting several objections, the primary one of which is an assertion of his Fifth Amendment privilege. + +The Fifth Amendment serves as a guarantee against testimonial compulsion and provides, in relevant part, that TO person...shall be compelled in any Criminal Case to be a witness against himself." Id. In practice, the Fifth Amendment's privilege against selfincrimination "permits a person not to answer official questions put to him in any other proceeding, civil or criminal, formal or informal, where the answers might incriminate him in future criminal proceedings." Edwin v. Price, 778 F.2d 668, 669 (11th Cir. 1985)(citing Lefkowitz v. Turley, 414 U.S. 70, 77 (1973)). The privilege is accorded "liberal construction in favor of the right it was intended to secure," Hoffman v. United States, 341 U.S. 479, 486 (1951), and extends not only to answers that would in themselves support a criminal conviction, but extends also to those answers which would furnish a link in the chain of evidence needed to prosecute the claimant for a crime. Id.; Blau v. United States, 340 U.S. 159 (1950). Thus, information is protected by the privilege not only if it would support a criminal conviction, but also in those instances where "the responses would merely 'provide a lead or clue' to evidence having a tendency to incriminate." United States v. Neff, 615 F.2d 1235, 1239 (9th Cir.), cert. denied, 447 U.S. 925 (1980). + +The Fifth Amendment's privilege against self-incrimination comes into play only in those instances where the witness has "reasonable cause to apprehend danger from a direct answer." Hoffman, 341 U.S. at 486 (citing Mason v. United States, 244 U.S. 362, 365 (1917)). "The claimant must be 'confronted by substantial and 'real,' and not merely trifling or imaginary, hazards of incrimination." United States v. Apfelbaum, 445 U.S. 115, 128 (1980). + +When the Fifth Amendment privilege is raised as a bar to discovery, a blanket refusal to answer questions or to produce documents is improper. Anqlada v. Sprague, 822 F.2d 1035, 1037 (11th Cir. 1987). Instead, the privilege must be asserted in response to a particular question, and in each instance the burden is on the claimant to justify invocation of the privilege. Id. Once a particularized showing has been made, lijt is for the court to decide whether a witness' silence is justified and to require him to answer if it clearly appears to the court that the witness asserting the privilege is mistaken as to its validity." In re Morganroth, 718 F.2d 161, 166-67 (6th Cir. 1983). In making this determination the judge is instructed to view the facts and evidence presented on a caseby-case basis, and "must be governed as much by his perception of the peculiarities of the case, as by the facts actually in evidence." Hoffman, 341 U.S. at 487. + +The law is well established that the Fifth Amendment privilege may not apply to specific documents "even though they contain incriminating assertions of fact or belief, because the creation of those documents was not 'compelled' within the meaning of the privilege." United States v. Hubbell, 530 U.S. 27, 35-36 (2000). However, in certain instances, "'the act of production' itself may implicitly communicate 'statements of fact.'" Id. For this reason the Fifth Amendment privilege also encompasses the circumstance where the act of producing documents in response to a subpoena or production request has a compelled testimonial aspect Id. Thus, in those instances where the existence and/or location of the requested documents are unknown, or where production would "implicitly authenticate" the requested documents, the act of producing responsive documents is considered testimonial and is protected by the Fifth Amendment. In re Grand Jury Subpoena, 1 F.3d 87, 93 (2d Cir. 1993); see also Fisher v. United States, 425 U.S. 391, 410 (1976)(issue expressed as whether compliance with a document request or subpoena "tacitly conceded" the item's authenticity, existence or possession by the defendant). + +The Court begins with an analysis of the Fifth Amendment privilege as applied to each request or category of requests. In the event the Court determines that a certain request does not infringe upon Epstein's Fifth Amendment privilege, Epstein's additional objections to that request shall be addressed. Where appropriate, the Court looks to Epstein's Response Memorandum for more particularized objections, rather than relying solely on Epstein's objections as initially stated, which in some cases are less specific in nature. + +The Admission Requests at issue herein, Request Numbers 1-9 and 21-23, all essentially seek admissions relating to the same general subject matter, namely, Defendant's financial history: Epstein's net worth (Requests 1-5, and 23); fraudulent conveyances (Requests 6, 9, 21 and 22); real estate ownership (Requests 7-8). Epstein argues, and this Court agrees, that to force him to respond to these requests would involve compelled statements that could reasonably furnish a link in the chain of evidence needed to prosecute Epstein in future criminal proceedings or even support a criminal conviction. Accordingly, Epstein's objection to responding to these requests on the basis of his Fifth Amendment Right against self incrimination is upheld and Plaintiff's Motion is denied. + +As noted previously, the Fifth Amendment privilege against self incrimination is accorded "liberal construction," Hoffman, 341 U.S. at 486, and extends not only to answers that would in themselves support a criminal conviction, but extends also to those answers which would furnish a link in the chain of evidence needed to prosecute the claimant for a crime. Id. Thus to be afforded protection, the answer need not necessarily be enough to support a criminal conviction; it is enough if the response merely provides a lead or clue to evidence having a tendency to incriminate. Neff, 615 F.2d at 1239. + +In asserting his Fifth Amendment privilege, Epstein expresses a concern that these requests for admissions, if answered, may result in compelled testimonial communications from Epstein regarding his financial status and history and would require him to waive his right to decline to respond to other inquiries related to the same subject matter in this case, the related cases and those matters outlined in Epstein's in camera submissions at D.E. #s 282 and 283. Given the allegations raised in the various Complaints and the elements required to convict Epstein of a crime, and considering the background facts underlying the case, these concerns are reasonable, real and not unjustified. It goes without saying that being forced to admit, deny and/or identify the existence of the information sought by virtue of an admission or denial is tantamount to forcing testimonial disclosures that would communicate statements of fact. Finding that such admissions or denials present a real and substantial danger of self-incrimination in this case, in other related cases, and relative to potential federal claims of violations, the Court concludes the subject requests are subject to Epstein's assertion of his Fifth Amendment privilege against self incrimination. + +# INTERROGATORY REQUESTS + +The interrogatories at issue here fall into three general categories: contention-type interrogatories seeking information such as the facts upon which Defendant relies in support of his affirmative defenses and pleading allegations and the anticipated testimony of certain witnesses (Interrogatories 12 and 23); financial history information such as what assets Epstein has, where such assets are located, and whether such assets have been transferred or fraudulently concealed (Interrogatories 2-7 and 13-15); and one identity information interrogatory seeking the names, addresses and phone numbers of Epstein's current accountants, financial planners or money managers (Interrogatory 17). For the following reasons Epstein's objections on the basis of his Fifth Amendment privilege against self-incrimination are upheld and Plaintiff's Motion to Compel the subject Interrogatory Requests is denied. + +As with the Admission Requests, Epstein argues, and this Court agrees, that to force Epstein to answer the above-stated Interrogatories would involve compelled statements that could reasonably furnish a link in the chain of evidence needed to prosecute Epstein in future criminal proceedings or even support a criminal conviction. Asking Epstein to identify persons or witnesses who may have knowledge of the events in question, to state the facts upon which he relies in support of his affirmative defenses, and to give an accounting of all of his assets and list all actions taken by him and those retained by him with reference to those assets, would violate the Fifth Amendment in that Epstein would be forced to incriminate himself in the commission of crimes. Further, such an order would constitute compelled testimonial admissions that could potentially provide a link in the chain of evidence having a tendency to incriminate Epstein and would threaten to invade his privilege against being required to produce or testify. Rudy-Glanzer v. Glanzer, 232 F.3d 1258, 1263 (991 Cir. 2000). Accordingly, finding the sought after information would result in testimonial disclosures that would communicate statements of fact which in turn would present a real and substantial danger of self-incrimination in this case and other related cases as well as in areas that could result in criminal prosecution, Epstein's objection to responding to these requests on the basis of his Fifth Amendment privilege against self incrimination is upheld and Plaintiffs Motion is denied. + +## PRODUCTION REQUESTS + +The production requests at issue here fall into four general categories: requests for documents the federal government gave to Epstein in the course of its plea discussions with him (Requests 7, 9 and 10); requests for financial information documents (Requests 8, 11, 14 and 15); requests for personal tax returns from 2002 to the present and for a copy of Epstein's passport (Requests 12 and 13); and Epstein's medical records from Dr. Stephen Alexander (Request 16). Each of these categories of requests shall be addressed in turn. + +Plaintiffs Motion to Compel as it relates to the first category of documents, consisting of documents the federal government gave to Epstein in the course of its plea discussions with him (Requests 7, 9 and 10), is granted. The law is well established that the Fifth Amendment privilege against self-incrimination does not extend to documents whose existence is known to the government or is a foregone conclusion. Fisher, 425 U.S. at 410; United States v. Hubbell, 530 U.S. 27, 44 (2000); United States v. Ponds, 454 F.3d 313, 325 (D.C. Cir. 2006). Thus, while the Fifth Amendment covers situations where the act of producing documents has "communicative aspects of its own wholly aside from contents of the papers produced" Fisher, 425 U.S. at 410, the doctrine does not apply where the government has "prior knowledge of either the existence or the whereabouts of the...documents ultimately produced... ." Hubbell, 530 U.S. at 44. + +Requests 7, 9 and 10 seek production of documents the govemment itself gave to Epstein, making the government's prior knowledge of the documents sought an obvious and undeniable "foregone conclusion." As such, Epstein can not reasonably and in good faith argue that in producing these documents to Plaintiff he will somehow be incriminating himself. In re Grand Jury Subpoena, 383 F.3d 905, 910 (9th Cir. 2004) (noting there can be no self-incrimination by production where the "existence and location of the documents ... are a 'foregone conclusion' and [the claimant] ... adds little or nothing to the sum total of the Government's information by conceding that he in fact has the documents."). + +In an attempt to get around this settled principle of law, Epstein argues that forcing him to give Plaintiff the discovery produced by the government would implicate the Fifth Amendment in that such production might disclose witnesses helpful to Plaintiff. Epstein Resp., p.7. This argument misses the point. As Plaintiff correctly observes, the question is not whether the government's documents have information that might be harmful to Epstein's defense, indeed, a reasonable presumption would be that the documents do contain information harmful to Epstein and that is precisely why the government was showing Epstein the documents in the first place; Instead, the only pertinent question is whether turning over the government's documents to Plaintiff somehow forces Epstein to provide 'testimony' to the government in contravention of the privilege against self incrimination guaranteed by the Fifth Amendment. This question can only reasonably be answered in the negative. + +Also without merit is Epstein's argument that these requests are the same requests the undersigned previously found subject to the Fifth Amendment. Epstein Resp., pp.7-8. This is not the case. The earlier requests referenced by Epstein were significantly broader than the narrow requests at issue here, including for example, a request for all documents "relating to" the federal non-prosecution agreement, all documents "relating to" Epstein's Florida guilty plea, and all documents obtained in "investigation relating to" either the federal or state criminal investigations. These requests would have required Epstein to pick and choose which documents were responsive and in this way force Epstein to effectively make "use of the content of his mind," an action that would undeniably implicate the Fifth Amendment. See Hubbell, 530 U.S. at 43. + +Epstein also raises objections on the basis of the work product doctrine and the attorney client privilege. objections on the basis of the attorney client privilege and the work product doctrine are rejected out of hand. The attorney-client privilege protects "confidential communications" between a lawyer and his client for the purpose of obtaining legal advice. Fisher v. United States, 425 U.S. 391, 403 (1976); U.S. v. Schaltenbrand, 930 F.2d 1554, 1562 (11th Cir.), cert. denied, 112 S.Ct. 640 (1991); In re Grand Jury Subpoena (Bierman), 788 F.2d 1511, 1512 (11th Cir. 1986). Under the rule, only material involving confidential communications between the attorney and the client which fall within the purview of the privilege are rendered immune from discovery. Fisher, 425 U.S. at 403. The documents at issue here were given by the Government to Epstein, and as such are clearly not confidential communications protected by the attorney client privilege. The work product doctrine, which protects from disclosure documents and tangible things prepared in anticipation of litigation by or for a party or by or for that party's attomey acting for his client, Fed. R. Civ. P. 26(b)(3)'; In re Grand Jury Proceedings, 601 F.2d 162, 171 (5th Cir. 1979), is also not implicated as the subject documents were not created by Epstein's attorneys. Id. + +Finally, Epstein argues the information sought is protected from disclosure by Rules 408 and 410 of the Federal Rules of Evidence governing the admission into evidence of documents involving settlement discussions and plea negotiations. Plaintiffs acknowledge that Request Number 10 might, at some point, be implicated by the Rule, but they are correct when they avail themselves of the broad federal discovery rules and argue that the information sought, while it may ultimately be barred from use at trial, is nonetheless subject to disclosure at the instant discovery stage. See Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340, 352 (1978). Accordingly, Epstein is ordered to produce the documents subject to these Requests within ten (10) days from the date hereof. + +Plaintiffs Motion to Compel as it relates to the second category of documents, financial information documents (Requests 8,11,14 and 15), is denied on the basis of the Fifth Amendment. In sustaining Epstein's Fifth Amendment privilege, the Court has considered the facts alleged in the Complaints, the elements needed to convict Epstein of + +Rule 26(b)(3) was adopted in 1970 to codify the holding in Hickman v. Taylor, 329 U.S. 495 (1947). + +a crime, the particularized showing made in Epstein's Response Brief and in camera submission, and drawn upon the Court's knowledge of the cases at issue. On this basis the Court finds the privilege raised as to these Requests valid, and asserted by Epstein only with reference to "genuinely threatening questions." United States v. Goodwin, 625 F.2d 693, 701 (5th Cir. 1980). + +In ruling as it does, the Court finds that ordering Epstein to produce the information sought, information which relates to potential violations of federal law and claims, constitutes testimonial disclosures that would communicate statements of fact and present a real and substantial danger of self-incrimination in both this case and other related cases that could result in criminal prosecution. Fisher, 425 U.S. at 410 (noting that the Fifth Amendment covers situations where the act of producing documents has "communicative aspects of its own wholly aside from contents of the papers produced"). The danger Epstein faces by being forced to testify in this instance is "substantial and real, and not merely trifling or imaginary' as required. Apfelbaum, 445 U.S. 128. Accordingly, finding the subject requests involve compelled statements that would furnish a link in the chain of evidence needed to convict Epstein of a crime, the Court finds Epstein's Fifth Amendment privilege claim validly asserted. Accordingly, Epstein's objection is sustained and he need not produce documents subject to these Requests. + +The third category of documents requested consists of Epstein's personal tax returns for the year 2002 through the present (Request No. 12) and a copy of Epstein's U.S. Passport (Request No. 13). Plaintiffs' Motion as it relates to both these requests is granted. Once again, the Fifth Amendment privilege against self-incrimination does not extend to documents whose existence is known to the government or is a foregone conclusion. Fisher, 425 U.S. at 410; Hubbell, 530 U.S. at 44; Ponds, 454 F.3d at 325 (D.C. Cir. 2006). In this instance the Government, namely the IRS, already has Epstein's tax returns, so it can hardly be incriminating for Epstein to produce them. Id. The same is true of Epstein's U.S. Passport. Since Epstein is required to show his Passport to Government officials every time he travels outside the United States, the Government undeniably has "prior knowledge" of the Passport's existence, and its whereabouts is a "foregone" conclusion. Hubbell, 530 U.S. at 44. + +Even more persuasive is the fact that tax records and passports, considered by the courts to be "required records," are as a matter of law deemed not subject to Fifth Amendment protection. See, e.q., Rajah v. Mukasey, 544 F.3d 427, 442 (2d Cir. 2008)("Just as a taxpayer's W-2 forms are required records not subject to the Fifth Amendment because they are a mandatory part of a civil regulatory regime, so too are the passports...at issue in the current case."); In re Doe, 711 F.2d 1187, 1191 (2d Cir. 1983)(ordering production of W-2 forms over Fifth Amendment objection on grounds of required records exception); In re Doe, 97 F.R.D. 640, 644-45 (S.D. N.Y. 1982)(same). + +Epstein's reliance on 26 U.S.C. §6103, governing the confidentiality of tax returns, does little to aid Epstein's cause. The same federal statute Epstein cites was cited by the claimant of the privilege in the cases referred to above and in each of them the court's ruled that the confidentiality provided by the IRS statute was properly overridden by the broad federal discovery rules. Id. Accordingly, Epstein's Fifth Amendment claim of privilege as it relates to these Requests is rejected and Epstein has ten (10) days from the date hereof to provide the discovery subject to these Requests. + +The last category of documents concern Epstein's medical records from Dr. Stephen Alexander (Request 16). Epstein raises several objections to this category of Requests from relevancy concerns to privilege claims. Because Plaintiff has failed to articulate any reasonable basis for obtaining the documents in question, Plaintiffs' Motion as it relates to this request is denied. While the scope of discovery is broad, it is not without limits. Washington v. & Williamson Tobacco, 959 F.2d 1566, 1570 (11th Cir. 1992). Indeed the 2000 Amendment to Rule 26 has effectively limited the scope of discoverable information to those matters which are relevant to a claim or defense in the lawsuit. Dellacasa, LLC v. John Moriarty & Ass. Of Florida, Inc., 2007 WL 4117261 at \*3 (S.D. Fla. 2007). Courts have long held that "[w]hile the standard of relevancy [in discovery] is a liberal one, it is not so liberal as to allow a party to 'roam in the shadow zones of relevancy and to explore matter which does not presently appear germane on the theory that it might conceivably become so.' " Food Lion, Inc. v. United Food & Commercial Workers Intern. Union, 103 F.3d 1007, 1012-13 (C.A. D.C. 1997)(quoting Broadway and Ninety Sixth Street Realty Co. v. Loew's Inc., 21 F.R.D. 347, 352 (S.D. N.Y. 1958)); Donahay v. Palm Beach Tours & Transp., Inc., 2007 W.L. 1119206 at \*1 (S.D. Fla. 2007). Accordingly, Plaintiffs' Motion as it relates to Request No. 16 is denied. Epstein has raised detailed objections to the request, among other things calling into question the relevancy of his medical condition in this case where, according to him, he has not placed his medical condition at issue. This particular objection was met by Plaintiffs with silence. In light of the objection made by Epstein, Plaintiffs were obligated to come back in their reply and articulate some rational basis for seeking the records requested. Having failed in this regard, Plaintiffs' Motion as it relates to Request No. 16 is denied and Epstein need not produce documents responsive to this request. + +In accordance with the above and foregoing, it is hereby + +ORDERED AND ADJUDGED as follows: + +(1) Plaintiff's Motion to Compel Answers to Plaintiff's First Request for Production (D.E. #194 and #210) is GRANTED IN PART AND DENIED IN PART in accordance with the terms herein; + +(2) Plaintiffs Motion to Compel Answers to Plaintiff's First Request for Admissions (D.E. #195 and #211) is DENIED; and, + +(3) Plaintiffs Motion to Compel Answers to Interrogatories (D.E.#196 and #212) is DENIED. + +DONE AND ORDERED this February 4, 2010, in , at West Palm Beach, Florida. + +> 40-7 LINNEA R. J UNITED STA ON ES MAGISTRATE JUDGE + +CC: The Honorable Kenneth A. 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2010 (DE 462) + +Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through his undersigned attorneys, and Pursuant to Rule 4, Review and Appeal — Southern District, and other applicable rules as well as this court's discretion, respectfully moves this Court for an extension of time in which to ". . . file with the Clerk of the Court, and serve of all parties written objections which shall specifically set forth the order, or part thereof, appealed from [and] aconcise statement of the alleged error in the [] ruling, and statutory, rule, or case authority, in support of defendant's position." As good cause in support of granting the motion, Defendant states: + +1. This court entered an order (DE 462) stating that Epstein must provide documents responsive to request to numbers 7, 9, 10, 12, and 13 within 14 days from the date of said order. Federal Rule 4 allows for an appeal to be filed within 14 days of said order + +2. Based upon the timing of the order to produce documents and the 14 day time period allowed for the filing of an Appeal, there remains aconflict as to the timing of both. Defendant needs an extension of time as aresult of said timing conflict, and for additional the reasons set forth below. + +3. Defendant seeks to appeal, pursuant to Rule 4, those portions of the order which specifically address the above requests for production. Given the breadth of the 5th Amendment addressing the above requests and the fact that the order does not address various issues in the Response (including relevance), the Defendant respectfully requests an additional 15 days from February 18, 2010 within which to "file with the Clerk of the Court, and serve of all parties written objections which shall specifically set forth the order, or part thereof, appealed from [and] aconcise statement of the alleged error in the [J ruling, and statutory, rule, or case authority, in support of defendant's position." As such, Defendant requests that the due date effectively be moved to August 31, 2009. + +4. The undersigned, Michael J. Pike, has a special set hearing in front of the Honorable Elizabeth Metzgen in Stuart, Florida on February 9, 2010. In addition, the undersigned, Robert D. Critton, Jr., Esq., is scheduled for various depositions in these related matters. + +5. This request is not made to delay and will not prejudice any of the parties. + +6. While this request is within the sound discretion of the court pursuant to Rule 4, the undersigned has consulted with opposing counsel and he has not agreed. + +Wherefore, the undersigned respectfully requests the relief sought herein, and for such other and further relief as this court deems just and proper. + +# Local Rule 7.1 Statement + +Counsel for the movant conferred by telephone with counsel or the Plaintiff and Counsel for Plaintiff is not in agreement with the requested e + +> By: ROBERT ON, JR. Florida #2241.2 MICHAEL J. PIKE, ESQ. Florida Bar #617296 + +### Certificate of Service + +I HEREBY 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 electronic mail (e-mail) on this 9th day of February, 2010. + +Respectfully s + +By: ROBERT . C1ZT FQN, JR., ESQ. Florida g r No. 224162 rcrit@bciclaw.com MICHAEL J. PIKE, ESQ. Florida Bar #617296 mpikeAbciclaw.com BURMAN, CRITTON, LUTTIER & COLEMAN 303 Banyan Blvd., 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 E Case No. 08-CV-80119-MARRA/ + +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](mailto:ssm@sexabuseattorney.com) +[ahorowitz@sexabuseattorney.com](mailto:ahorowitz@sexabuseattorney.com) + +*Counsel for Plaintiffs* +*In related Cases Nos. 08-80069, 08-80119,* +*08-80232, 08-80380, 08-80381, 08-80993,* +*08-80994* + +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](mailto:jagesq@bellsouth.net) + +*Counsel for Defendant Jeffrey Estein* + +[REDACTED], Jaffe, Weissing, [REDACTED] Fistos +& Lehrman, PL +425 N. Andrews Avenue +Suite 2 +Fort Lauderdale, FL 33301 +Phone: 954-524-2820 +Fax: 954-524-2822 +[brad@pathtojustice.com](mailto:brad@pathtojustice.com) +*Counsel for Plaintiff in Related Case No.* +*08-80893* + +Paul G. Cassell, Esq. +*Pro Hac Vice* +332 South 1400 E, Room 101 +Salt Lake City, UT 84112 +801-585-5202 +801-585-6833 Fax +[cassellp@law.utah.edu](mailto:cassellp@law.utah.edu) + +*Co-counsel for Plaintiff Jane Doe* + +Isidro M. [REDACTED] Esq. +[REDACTED] Law Firm, P.A. +224 Datura Street, Suite 900 +West Palm Beach, FL 33401 +561-832-7732 +561-832-7137 F + +[isidrogarcia@bellsouth.net](mailto:isidrogarcia@bellsouth.net) +*Counsel for Plaintiff in Related Case No.* +*08-80469* \ No newline at end of file diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821359/EFTA02821359.metadata.json b/marker2/court-redacted-v-epstein-81111/EFTA02821359/EFTA02821359.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..bba6bc3e5080e2596b3b074b1658065f3479cff4 --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821359/EFTA02821359.metadata.json @@ -0,0 +1,276 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-redacted-v-epstein-81111/EFTA02821359.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": 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+Plaintiff, + +vs. + +JEFFREY EPSTEIN, et al. + +Defendant. + +Related Cases: + +08-80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 + +## PLAINTIFF JANE DOE'S OBJECTION TO EXTENSION OF TIME TO FILE APPEAL AND, IN THE ALTERNATIVE, REQUEST FOR DIRECTION TO EPSTEIN TO BEGIN ASSEMBLING MATERIALS + +Plaintiff, Jane Doe, respectfully files this Objection to Defendant's Motion for Extension of Time (dkt. #464). + +Epstein is apparently requesting an additional 15 days from February 18, 2010, to file an objection to an order from the magistrate judge that he produce documents that were provided to him by the Government during the discovery phase of the criminal case. As the magistrate judge concluded, any purported Fifth Amendment objection to producing such documents is utterly groundless. The Fifth Amendment protects a defendant from revealing things to the Government that it does not know. The Government obviously knows what is in the documents that it gave to him. Therefore, there is no legitimate Fifth Amendment objection to such production. + +CASE NO: 08-CV-80119-MARRA/ + +In addition, 15 days on top of the already prescribed 10 days to appeal is an excessively long period of time. As the Court is aware, the discovery period prescribed in this case will soon draw to a close. Jane Doe needs the documents produced quickly and in a timely fashion so that she can pursue any leads revealed in them during the discovery period. + +In the alternative, if the Court grants any extension of time to file an appeal, Jane Doe respectfully requests that the extension order also include a direction to Epstein to fully assemble all of the required documents so that, if Epstein's appeal is rejected, the documents can be produced to Jane Doe without any further delay. + +DATED: February 9, 2010 + +Respectfully submitted, + +AFFE, WEISSING, , FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 Florida Bar No.: 542075 E-mail: brad@pathtojustice.com + +and + +Paul G. Cassell Pro Hac Vice 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: 801-585-5202 Facsimile: 801-585-6833 E-Mail: cassellp@law.utah.edu + +CASE NO: 08-CV-80119-MARRA + +## CERTIFICATE OF SERVICE + +I HEREBY CERTIFY that on February 9, 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 on 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 filed Notices of Electronic Filing. + +> s/ J. J. + +CASE NO: 08-CV-80119-MARRA/[REDACTED] + +**SERVICE LIST** + +**Jane Doe v. Jeffrey Epstein** +**United States District Court, Southern District of Florida** + +Jack Alan Goldberger, Esq. +[Jgoldberger@agwpa.com](mailto:Jgoldberger@agwpa.com) + +Robert D. Critton, Esq. +[rcritton@bclclaw.com](mailto:rcritton@bclclaw.com) + +Isidro Manual [REDACTED] +[isidrogarcia@bellsouth.net](mailto:isidrogarcia@bellsouth.net) + +Jack [REDACTED] [REDACTED] +[iph@searcylaw.com](mailto:iph@searcylaw.com) + +Katherine Warthen Ezell +[KEzell@podhurst.com](mailto:KEzell@podhurst.com) + +Michael James Pike +[MPike@bclclaw.com](mailto:MPike@bclclaw.com) + +Paul G. Cassell +[cassellp@bclclaw.com](mailto:cassellp@bclclaw.com) + +Richard Horace Willits +[lawyerswillits@aol.com](mailto:lawyerswillits@aol.com) + +Robert C. Josefsberg +[rjosefsberg@podhurst.com](mailto:rjosefsberg@podhurst.com) + +Adam D. Horowitz +[ahorowitz@sexabuseattorney.com](mailto:ahorowitz@sexabuseattorney.com) + +Stuart S. Mermelstein +[ssm@sexabuseattorney.com](mailto:ssm@sexabuseattorney.com) \ No newline at end of file diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821363/EFTA02821363.metadata.json b/marker2/court-redacted-v-epstein-81111/EFTA02821363/EFTA02821363.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..cc94b466ab0f0d13cdefda56b406d09a16abde3c --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821363/EFTA02821363.metadata.json @@ -0,0 +1,257 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-redacted-v-epstein-81111/EFTA02821363.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 4, + "chars": 3937, + "elapsed_seconds": 5.25, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF FLORIDA", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 200.73600000000002, + 71.0675048828125 + ], + [ + 410.520751953125, + 71.0675048828125 + ], + [ + 410.520751953125, + 99.54998779296875 + ], + [ + 200.73600000000002, + 99.54998779296875 + ] + ] + }, + { + "title": "PLAINTIFF JANE DOE'S OBJECTION TO EXTENSION OF TIME TO FILE APPEAL \nAND, IN THE ALTERNATIVE, REQUEST FOR DIRECTION TO EPSTEIN TO BEGIN \nASSEMBLING MATERIALS", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 74.66399999999999, + 387.98999999999995 + ], + [ + 538.5600000000001, + 387.98999999999995 + ], + [ + 538.5600000000001, + 430.67999267578125 + ], + [ + 74.66399999999999, + 430.67999267578125 + ] + ] + }, + { + "title": "CERTIFICATE OF SERVICE", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 225.82799999999997, + 136.89000000000001 + ], + [ + 387.0013122558594, + 136.89000000000001 + ], + [ + 387.0013122558594, + 152.41998291015625 + ], + [ + 225.82799999999997, + 152.41998291015625 + ] + ] + }, + { + "title": "SERVICE LIST", + "heading_level": null, + "page_id": 3, + "polygon": [ + [ + 261.324, + 110.16000000000003 + ], + [ + 347.616, + 110.16000000000003 + ], + [ + 347.616, + 124.74 + ], + [ + 261.324, + 124.74 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 54 + ], + [ + "Line", + 26 + ], + [ + "Text", + 10 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 65 + ], + [ + "Line", + 31 + ], + [ + "Text", + 8 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 29 + ], + [ + "Line", + 13 + ], + [ + "Text", + 3 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 3, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 26 + ], + [ + "PageFooter", + 4 + ], + [ + "PageHeader", + 2 + ], + [ + "SectionHeader", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02821363" + } +} \ No newline at end of file diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821367/EFTA02821367.md b/marker2/court-redacted-v-epstein-81111/EFTA02821367/EFTA02821367.md new file mode 100644 index 0000000000000000000000000000000000000000..8b0b3a0e6bad0acddaf45f64e4462464fa996c82 --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821367/EFTA02821367.md @@ -0,0 +1,39 @@ +## 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, 08-80380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 + +## ORDER + +THIS CAUSE is before the Court upon Defendant Jeffrey Epstein's "Motion for an Extension Directed to the Court Pursuant to Rule 4, Review and Appeal - Southern District, In Connection with this Court's Order Dated February 4, 2010 (DE 462)." See DE 464. In his Motion, Defendant seeks additional time to file an appeal of Magistrate Judge February 4, 2010 Order compelling production of certain documents within 14 days from the date of that Order. Upon consideration of the motion, response (DE 465), and reply (DE 466), it is hereby + +ORDERED AND ADJUDGED that Defendant's Motion for an Extension (DE 462) is GRANTED IN PART AND DENIED IN PART as follows: + +(1) The deadline for Defendant to file an appeal of Magistrate Judge February 4, 2010 Order is extended to Friday, February 26, 2010. + +(2) In the event that Magistrate Judge February 4, 2010 Order is affirmed on + +appeal, Defendant will have three (3) business days from the date of this Court's order to produce the documents at issue. + +DONE AND ORDERED in at West Palm Beach, Palm Beach County, + +Florida, this 11' day of February, 2010. + +rz + +KENNETH A. 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MOTION FOR RECONSIDERATION AND/OR REQUEST FOR RULE 4 REVIEW AND APPEAL OF PORTIONS OF THE MAGISTRATE'S ORDER DATED FEBRUARY 4.2010 (DE 462). WITH INCORPORATED OBJECTIONS AND MEMORANDUM OF LAW + +Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through his undersigned attorneys, hereby files his Motion for Reconsideration and/or for Request Rule 4 Review and Appeal of Portions of the Magistrate's Order (DE 462) pursuant to Rule 60, Fed.R.Civ.P. Rule 4, Rule 4(c) and Fed. R. Civ. P. 53(e). In support, Epstein states: + +### L Procedural Background + +Plaintiff's Motion to Compel is filed at DE (194). Defendant's Response in Opposition is filed at DE (339), and the arguments set forth therein are incorporated herein by reference as if completely set forth herein as each apply to request numbers 10, 12 and 13. + +Significantly, these cases have been consolidated for discovery. Therefore, consistent rulings must apply. In making those rulings, this Court must continue to recognize that the allegations in the related cases cannot be forgotten. DE 242, 293, and 462). + +Production of information in one case could provide a link in the chain of evidence used to prosecute Epstein for a crime or provide an indirect link to incriminating evidence in another case and in another jurisdiction. Id. and *infra*. + +The Request for Production and the responses thereto are attached as **Composite Exhibit "A"**. + +## **II. The Fifth Amendment** + +The Fifth Amendment serves as a guarantee against testimonial compulsion and provides, in relevant part, that "[n]o person...shall be compelled in any Criminal Case to be a witness against himself." (DE 242, p.5); see also Edwin v. Price, 778 F.2d 668, 669 (11th Cir. 1985) (citing Lefkowitz v. Turley, 414 U.S. 70, 77 (1973)). The privilege is accorded liberal construction in favor of the right and extends not only to answers that would support a criminal conviction, but extends also to those answers which would furnish a link in the chain of evidence needed to prosecute the claimant for a crime. See Hoffman v. United States, 341 U.S. 479, 486 (1951). Information is protected by the privilege not only if it would support a criminal conviction, but also in those instances where "the responses would merely 'provide a lead or clue' to evidence having a tendency to incriminate." See United States v. Neff, 315 F.2d 1235, 1239 (9th Cir.), cert denied, 447 U.S. 925 (1980); Blau v. United States, 340 U.S. 159 (1950); SEC v Leach, 156 F.Supp.2d 491, 494 (E.D. PA. 2001). + +Moreover, the act of production itself may implicitly communicate statements and, for this reason, the Fifth Amendment privilege also encompasses the circumstances where the act of producing documents in response to a subpoena or production request has a compelled testimonial aspect. See United States v. Hubbell, 530 U.S. 27, 35-36 (2000). Thus, where the existence or location of the requested documents are unknown, or where production would + +“implicitly authenticate” the requested documents, the act of producing responsive documents is considered testimonial and is protected by the Fifth Amendment. See In re Grand Jury Subpoena, 1 F.3d 87, 93 (2nd Cir. 1993); Rudy-Glanzer v. Glanzer, 232 F.3d 1258, 1263 (9th Cir. 2000)(the “privilege” against self-incrimination does not depend upon the likelihood, but upon the possibility of prosecution and also covers those circumstances where the disclosures would not be directly incriminating, but could provide an indirect link to incriminating evidence). + +### **III. The Requests For Production, Argument And Memorandum Of Law** + +#### **a. Requests Numbers 7, 9 and 10** + +**Request No. 7:** All discovery information obtained by you or your attorneys as a result of the exchange of discovery in the State criminal case against you or the Federal investigation against you. + +**Request No. 9:** Any documents or other evidentiary materials provided to local, state, or federal law enforcement investigators or local, state or federal prosecutors investigating your sexual activities with minors. + +**Request No. 10:** All correspondence between you and your attorneys and state or federal law enforcement or prosecutors (includes, but not limited to, letters to and from the State Attorney’s office or any agents thereof). + +**Response to Request Numbers 7, 9 and 10:** Defendant is asserting specific legal objections to the production request as well as his U.S. constitutional privileges. I intend to produce all relevant documents regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select, authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution. In addition to and without waiving his constitutional privileges, the information sought is privileged and confidential, and inadmissible pursuant to the terms of the deferred prosecution agreement, Fed. Rule of Evidence 410 and 408, and §90.410, Fla. Stat. Further, the request may include information subject to work product or an attorney-client privilege. + +In light of the Court's Order and the Reply which further defines exactly what Plaintiff seeks (DE 354, p. 3), Epstein is now permitted to cautiously elaborate on his responses. + +As to Request Number 7, Epstein and his attorneys do not have any "discovery information" provided to them by the federal government.' + +As to Request Number 9, Epstein has not been given any evidentiary materials or evidentiary documents by the federal government. + +Request No. 10 contravenes the critical public policy of encouraging the resolution of criminal prosecutions without trial and the concomitant understanding that defendants will be considerably more likely to engage in full and discussions with the government if they need not fear that statements they or their counsel make to government prosecutors will be used against them to their detriment. The critical importance of plea bargaining to the criminal justice system has long been recognized. "[W]hatever might be the situation in an ideal world, the fact is that the guilty plea and the often concomitant plea bargain are important components of this country's criminal justice system. Properly administered, they can benefit all concerned." Bordenkircher v. Haves, 434U.S. 357, 361-62 (1978), quoting Blackledge v. Allison, 431U.S. 63, 71 (1977). To encourage defendants to participate in the plea negotiation process, rules have developed to prohibit admission into evidence against the defendant of any and all statements he or his counsel acting on his behalf makes to government prosecutors during the plea negotiation process. This confidentiality protection is embodied in both Fed. R. Evid. 410 and Fed. R. Crim. P. 11(f). While these rules by their express terms refer only to admissibility of evidence, the + +As set forth infra, the federal government provided Epstein with the NPA and the list attached thereto. The NPA is now apublic document and the list, pursuant to Brad Edward's Agreement with Judge J. Colbath, remains confidential. + +2FRE 410(4) is particularly directed to communications in matters which, like Epstein's, did not result in aplea of guilty to ayt federal charge. Fla. Stat. §90.410 provides parallel protections in state criminal matters. + +purposes and policies underlying these rules in instructive in this context, in which acivil plaintiff seeks discovery of documents falling within the scope of these two rules. + +Rule 410 was created to promote active plea negotiations and plea bargains, which our Supreme Court has acknowledged are "important components of this country's criminal justice system.". . . Our Court of Appeals has held that "in order for plea bargaining to work effectively and fairly, adefendant must be free to negotiate without fear that this statements will later be used against him.". Indeed, absent the protection of Rule 410, "the possibility of self-incrimination would discourage defendants from being completely candid and open during plea negotiations." + +US\_"2.A.I. 534 F.Supp.2d 63, 66-67 (D.D.C. 2008), quoting United States v. 617 F.2d 677, 683 (D.C.Cir. 1980). See Lg., United States v. Mezzanatto, 513U.S. 196, 205, 207 (1995)(purpose of the rules is to encourage plea bargaining, and rules "creat[e], in effect, a privilege of the defendant," quoting 2 J. Weinstein & M. Berger, Weinstein's Evidence ¶410[05] at 410-43 (1994)); United States v. Barrow, 400F.3d 109, 116 (2d Cir. 2005)("The underlying purpose of Rule 410 is to promote plea negotiations by permitting defendants to talk to prosecutors without sacrificing their ability to defend themselves if no disposition agreement is reached"); Fed. R. Crim. P. 11, Advisory Committee Notes, 1979 Amendment ("the purpose of Fed. R. Ev. 410 and Fed. R. Crim. P. 11(e)(6) [now Rule 11(f)] is to promote the unrestrained candor which produces effective plea discussions").3 + +Additional illustration of the high degree of confidentially accorded settlement negotiations is found in Fed. R. Evid. 408, which precludes the introduction into evidence communications made during settlement negotiations. The purposes underlying Rule 408 are essentially the same as those underlying Rules 11(0 and 410: "to encourage non-litigious solutions to disputes." Reichenbach v. a, 528 F.2d 1072, 1074 (11th Cir. 1976). See, Lg., Stockman v. Oakcrest Dental Center, P.C., 480 F.3d 791, 805 (6th Cir. 2007)("the purpose underlying Rule 408 . . . is the promotion of the public policy favoring the compromise and settlement of disputes that would otherwise be discouraged with the admission of such evidence"); Bankcard America, Inc. v. Universal Bancard Systems, Inc., 203F.3d 477, 483 (7th Cir. 2000)("Because settlement talks might be chilled if such discussions could later be used as admissions of liability at trial, the rule's purpose is to encourage settlements"); In re A.H. Robins Co Inc., 197 B.R. 568, 572 (E.D.Va. 1994)("Rule 408 aims to settlement discussions in an individual lawsuit, and therefore insulates the particular parties to asettlement discussion from possible adverse consequences of their and open statements"). So crucial is this policy of confidentiality to the functioning of our federal court system that some courts have held that communications falling within the parameters of Rule 408 are covered by asettlement privilege which insulates them not just from admission into evidence but from discovery as well. See, Lg., Goodyear Tire & Rubber Co. v. Chiles Power Supply, Inc., 332F.3d 976, 979-983 (6th Cir. 2003). + +Given the powerful and long-standing policy of according confidentiality to settlement negotiations in both the civil and criminal context, civil plaintiffs should, at a minimum, be required to demonstrate real and concrete need for the material. They should not be permitted to rummage through such sensitive documents based on nothing more than a vague and contentless statement that the materials are "likely to lead to the discovery of other admissible evidence." Motion to Compel at 12 n.3, which is all that plaintiff offers as to Request No. 10. This is particularly so given the reality that parties often take positions or offer potential compromise solutions during plea negotiations which are inconsistent with the litigation strategy they will pursue if the case goes to trial. As one court has explained in the civil context: + +There exists a strong public interest in favor of secrecy of matters discussed by parties during settlement negotiations. . . . The ability to negotiate and settle acase without trial fosters amore efficient, more cost-effective, and significantly less burdened judicial system. . . . Parties must be able to abandon their adversarial tendencies to some degree. They must be able to make hypothetical concessions, offer creative quid pro quos, and generally make statements that would otherwise belie their litigation efforts. + +Goodyear Tire, 332F.3d at 980. The same is no less true in the plea negotiation context. The free availability in discovery to civil plaintiffs of communications made during the plea negotiation process has profound potential to chill I. and open communications during that process so crucial to the functioning of the criminal justice system in any criminal case which has potential to become acivil or regulatory matter as well. Such defendants will be loath to be fully forthcoming during plea discussions or communications and indeed, if the potential civil or regulatory consequences are sufficiently severe, may decline to enter into plea negotiations at all, if they must fear that their communications will be made available to civil plaintiffs in discovery, thus entirely defeating both the purpose and spirit of Rules 410 and 11(f). + +In addition, the communications made during the plea negotiation process contain fact and opinion attorney work product of both Mr. Epstein's attorneys and government attorneys. Particularly given the strong public policy in favor of confidentiality of plea/settlement negotiations, the disclosure of such information should be treated as falling within the selective waiver provisions of Fed. R. Evid. 502 and not be treated as an open-ended waiver of the attorney-client and work product privileges. + +The correspondence in question contained what would constitute paradigm opinion work product with the single caveat that the opinions of each counsel, Epstein's and the United States Attorney's were exchanged with each other pursuant to the overall expectation that they were safeguarded from disclosure by the policies of confidentiality that protect communications during settlement and plea negotiations. The requested communications include the views of + +Page No. 8 + +Epstein's counsel in the criminal case regarding why a federal prosecution was inappropriate, why the federal statutes did not fit the alleged offense conduct, why certain of the alleged victims were not credible. It also includes Epstein's counsel's views on the limits and inapplicability of certain elements of 18 U.S.C. §2255, one of the principal causes of action in the Jane Doe cases. This opinion work product should not be disclosed when it was incorporated into heartland plea negotiations that are accorded protection under the federal rules of evidence. It is the disclosure of such legal opinions — and not just their admissibility — that should be protected from a civil discovery request that lacked any statement as to why this information was even nereqsary to the fair litigation of the civil cases. + +Concomitantly, to the extent that the request is now limited to communications from the Government to Epstein, see DE 54, pgs 3 and 8, the narrowed request implicate the same concerns for the opinions, the work product, and the expectation of privacy of the United States Attorney or Assistant United States Attorney who authored the many letters received by counsel for Epstein. As such, to the extent that the Court is considering affirming any part of the Magistrate-Judge's opinion allowing request 10 that would result in the required disclosure of communications from the Government counsel to Epstein, that notice be provided to the United States Attorney so they may intervene to protect their opinion work product, assert their rights to confidentiality under FRE 408 and 410, and assert where appropriate their interests in grand jury secrecy and in the privacy rights of their witness who in at least one document are identified. The defendant requests that if the Court were considering allowing the disclosure of any portion of the communications sent by Epstein to the Government which are within the original request for production but apparently not plaintiff's latest filing, DE 354, pg 3, the Court first consider + +Page No. 9 + +permitting the defendant to provide a privilege log that would identify specific portions of the correspondence that contains the opinion work product of counsel for Epstein + +Here, the information requested involves negotiations with the USAO and its investigation. If the USAO cannot be compelled to release its investigation(s) and related work-product, how can Epstein be compelled to disclose same in violation of his constitutional rights? He cannot. Rules 11(f), 408, and 410 all counsel strongly against the discoverability of such documents. The court, is requested to reverse the Magistrate-Judge's order as to paragraph 10. Alternatively, the Court is requested to permit a privilege log that would be filed by Epstein's counsel – and if they so desire the Government – particularizing the prejudice to their work product and to the values otherwise protected by FRE 408 and 410 on a document by document basis + +Epstein also continues to maintain that the requested correspondence is protected under the Fifth Amendment, as it could furnish a link in the chain of evidence needed to prosecute him for a crime or provide the federal government with information that provides a lead or clue to evidence having a tendency to incriminate Epstein. See infra; Hoffman v. United States, 341 U.S. at 486; United States v. Neff, 315 F.2d at 1239; Blau v. United States, 340 U.S. at 159; and SEC v Leach, 156 F.Supp.2d at 494. + +As this court has recognized, the threat of criminal prosecution is real and present as Epstein remains under the scrutiny of the USAO, which is explained and/or acknowledged in the Court's Orders (DE 242 and 462). As this Court knows, Epstein entered into a Non-Prosecution Agreement ("NPA") with the USAO for the Federal Southern District of Florida. However, the NPA does not provide Epstein with any protection from criminal investigation or prosecution in other than in the Southern District of Florida. As the court has acknowledged in its orders (e.g., + +DE 462), complaints in these related matters allege that Epstein both resided in and allegedly engaged in illegal sexual conduct in districts outside the Southern District of Florida, and that he allegedly lured economically disadvantaged girls to homes other than in Palm Beach. Thus, the fact that there exists a NPA does not mean that Epstein is free from a reasonable fear of future criminal prosecution. In fact, this court acknowledged that "[t]he danger Epstein faces by being forced to testify in this case is substantial and real, and not merely trifling or imaginary as required." (DE 242, p. 10). + +As such, in the event Epstein is required to produce information provided to him by the federal government — or provided by Epstein to the Government - that information could provide a link in the chain of evidence needed to prosecute Epstein of a crime outside the protections of the NPA. Given the nature of the allegations, to wit, a scheme and plan of sexual misconduct, this court should find it entirely reasonable for Epstein to assert his Fifth Amendment privilege as to request Number 10, especially since it is broad enough to encompass information that could violate Epstein's Fifth Amendment Privileges. Hubbell, supra. In responding to the request, Epstein would be compelled admit that such documents exist, admit that the docwnents were in his possession or control, and were authentic. In other words, the very act of production of the category of documents requested would implicitly communicate "statements of fact." Hubbell,supra; Hoffman,supra. + +Moreover, the production of such information may lead to the identity of witnesses that could testify against Epstein and those that may have knowledge or are in possession of evidence that could be used against Epstein in another district. This court has already ruled that Epstein can properly invoke his Fifth Amendment right to fat identify a person who may have a photograph + +Page No. 11 + +or physical evidence pertaining to the alleged events. (DE 242). For these reasons, Epstein's justified concern with regard to answering the above request and the resulting waiver of his Fifth Amendment Privilege in this regard and/or providing self-incriminating information is substantial, real and not merely imaginative. + +### Third Party Privacy Rights And Judge Jeffrey's Colbath's Order + +The Magistrate's Order does not consider the privacy rights of other alleged victims. As this Court knows full well, attached to the NPA is a list which delineates alleged victims. Once the NPA was made public, Judge Colbath, with the agreement of the Palm Beach Post, Brad ██████████, Esq. and Spencer Kuvin, Esq. agreed that the "list" would remain private. As such, Request for Production Number 10 seeks information that may violate others third-party privacy rights in that certain names may be mentioned in correspondence, including those on the "list." As noted in Eisenstadt v. Baird, 405 U.S. 438, 454, 92 S.Ct. 1029, 1038, at fn. 10 (1972): + +In Stanley, 394 U.S., at 564, 89 S.Ct., at 1247, the Court stated: (A) lso fundamental is the right to be free, except in very limited circumstances, from unwanted governmental intrusions into one's privacy." The makers of our Constitution undertook to secure conditions favorable to the pursuit of happiness. They recognized the significance of man's spiritual nature, of his feelings and of his intellect. They knew that only a part of the pain, pleasure and satisfactions of life are to be found in material things. They sought to protect Americans in their beliefs, their thoughts, their emotions, and their sensations. They conferred, as against the Government, the right to be let alone-the most comprehensive of rights and the right most valued by civilized man.' [Citations omitted]. + +The fundamental right of privacy is not only guaranteed under by the Fourteenth Amendment of the United States Constitution, but also under the Constitution of the State of Florida, Art. I, Sect. 23. As summarized by the Florida Supreme Court in Shaktman v. State, 553 So.2d 148, 150-51 (Fla. 1989): + +The right of privacy, assured to Florida's citizens, demands that individuals be free from uninvited observation of or interference in those aspects of their lives which fall within the ambit of this zone of privacy unless the intrusion is + +Page No. 12 + +warranted by the necessity of a compelling state interest. In an opinion which predated the adoption of section 23, the First District aptly characterized the nature of this right. + +A fundamental aspect of personhood's integrity is the power to control what we shall reveal about our intimate selves, to whom, and for what purpose. + +Bryon, Harless, Schaffer, Reid & Assocs., Inc. v. State ex rel, Schellenberg 360 So.2d 83, 92 (Fla. 1st DCA 1978), quashed and remanded on other grounds, 379 So.2d 633 (Fla.1980). Because this power is exercised in varying degrees by differing individuals, the parameters of an individual's privacy can be dictated only by that individual. The central concern is the inviolability of one's own thought, person, and personal action. The inviolability of that right assures its preeminence over "majoritarian sentiment" and thus cannot be universally defined by consensus. + +(Emphasis added). + +Clearly, the nature of the question would require Epstein to produce information that may identify third parties (including alleged victims), which would necessarily thwart such individuals' rights to assert their constitutional right of privacy as guaranteed under the United States and Florida Constitutions. See generally Eisenstadt v. Baird, supra at 454-455 (the right encompasses privacy in one's sexual matters and is not limited to the marital relationship). The Magistrate's Order did not address this issue. + +Federal law provides crime victims with rights similar to those afforded by the Florida constitution which includes, but is not limited to, "the right to reasonable, accurate, and timely notice of any public court. . . proceeding involving the crime. . . ." "the right not to be excluded from any public court proceeding. . . ." and "the right to be heard." 15 Fla. Jur.2d Crim.Proc. §1839; Fla. Stat. 960.0021. Based upon the foregoing, any alleged victim that may be identified in any of the requested information must first be notified, which means that this court must, at the very least, conduct an in camera inspection of any and all information to determine which alleged victim must be placed on notice that their identity may be revealed or redact their names + +Page No. 13 + +in camera. See also Fla. Stat. §794.03, §794.024 and §794.026. The right to privacy encompasses at least two different kinds of interests, the individual interests of disclosing personal matters and the interest in independence in making certain kinds of important decisions. Favalora v. Sidawav, 966 So.2d 895 (Fla. Leh DCA 2008). + +Accordingly, based on the facts and circumstances of this case, and under applicable law, Defendant's assertion of the protections afforded under the 5th, 6th, and 14'h Amendments of the United States Constitution are required to be upheld. In addition, this Court must address the privacy rights of others as outlined above. + +## b. Request Number 12 + +Request No. 12: Personal tax returns for all years from 2002 through the present. + +Response to Request Numbers : Defendant is asserting specific legal objections to the production request as well as his U.S. constitutional privileges. I intend to produce all relevant documents regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select, authenticate, and produce documents relevant to this lawsuit without waiving my Fifth Amendment constitutional rights and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution; overly broad. + +As set forth in more detail in DE 282 and 283, which were provided to the court in camera, Epstein cannot provide answers/responses to questions relating to his financial history and condition without waiving his Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution, which includes his tax returns. Asking for Epstein's personal tax returns is financial in nature and it is confidential, proprietary and seeks information much of which is neither relevant to the subject matter of the pending action nor does it appear to be + +Page No. 14 + +reasonably calculated to lead to the discovery of admissible evidence. Importantly, the Magistrate did not make a ruling on relevancy as to the personal tax returns, and the Plaintiff has not met the burden of establishing a "compelling need" for the tax returns. + +Producing the specified information, in full, would result in testimonial disclosures that would communicate statements of fact and would require Epstein to produce the returns and thereby "stipulate" to their genuiness, their existence, his control of the records, and their authenticity as his executed tax returns even though his possession of such records are by no means aforegone conclusion. Again, the information sought relates to potential federal claims of violations. See DE 282 and 283, in camera. Production would therefore constitute a testimonial admission of the genuineness, the existence, and Epstein's control of such records, and thus presents areal and substantial danger of self-incrimination in this case, in other related cases and as well in areas that could result in criminal prosecution. See generally Hoffman v United States 341U.S. at 486; United States v. Hubbell, 530U.S. at 36 and United States v. Apfelbaum, 445U.S. at 128. + +The Court's order seems to hone in on the "required records" exception for the proposition that, as a matter of law, Epstein's personal tax returns must be produced because they are allegedly a mandatory part of acivil regulatory scheme and have assumed some public aspect. (DE 462, p.12) However, "required records" are ordinarily records collected by highly regulated business (e.g., physicians) wherein the records themselves have assumed public aspects which render them analogous to public documents. See In re Dr. John Doe, 97F.R.D. 640, 641- 643(S.D.N.Y. 1982). Usually, these documents are known to more than the filer and the agency in which the document(s) were filed (i.e., known to other persons of the general public). Id. Even though the IRS may have certain returns, they remain confidential under 26 U.S.C. §6103 + +from any disclosures and are therefore different than a regulated/public record that can be accessed by the public. In Trudeau v. New York State Consumer Protection Bd., 237F.R.D. 325 (N.D.N.Y. 2006), the court maintained that "[r]outine discovery of tax returns is not the rule but rather the exception." Id. at 331. The Court went on to note that [f]or nearly the pastthirty-five years, tax returns have been considered `confidential,' pursuant to 26 U.S.C. §6103." Id. Because of the principle of confidentiality, it further noted, "courts in the Second Circuit have found personal financial information to be presumptively confidential or cloaked with a qualified immunity," and must, therefore, "balance the countervailing policies of liberal discovery set forth in the Federal Rules of Civil procedure against maintaining the confidentiality of such documents." Id. + +To achieve that balance, courts in the Second Circuit have developed a"more stringent" standard than that set forth in the rules. To order disclosure of tax returns, acourt must find that "the requested tax information is relevant to the subject matter of the action" and that "there is a compelling need for this information because the information contained therein is not otherwise readily available." Id. The Magistrate's Order makes no such finding in the instant matter. In fact, the burden of showing compelling need is on the party seeking discovery, but once a compelling need has been found, the party whose tax return information has been requested has the burden to "provide alternative sources for this sensitive information. Id. If the requested information is available from alternate sources, disclosure should not be compelled. Potential alternate sources to which the court pointed were gathering the information through deposition or disclosure in an affidavit by the requested party of net worth, wealth, and income. Id. at 331-32. 5.0 Barton v. Cascade Regional Blood Services, 2007WL 2288035 (W.D.Wash. 2007)("Tax returns are confidential communications between the taxpayer and the government[citing + +§6103] and although not privileged from discovery there is a recognized policy against unnecessary public disclosure The Court finds no compelling need which overcomes this recognized policy"). Courts have broadly construed these provisions to embody a general federal policy against indiscriminate disclosure of tax returns from any source. Federal Say. & Loan Ins. Corp. v. Knew, 55F.R.D. 514-15 (N.D. Ill. 1972)("it is the opinion of this court that [§6403] reflect[s] avalid public policy against disclosure of income tax returns. This policy is grounded in the interest of the government in full disclosure of all the taxpayer's income which thereby maximizes revenue. To indiscriminately compel ataxpayer to disclose this information merely because he has become a party to alawsuit would undermine this policy"); see also Premium Service Corp. v. Sperry & Hutchinson Co., 511F.2d 225, 229 (9th Cir. I975)(would have been appropriate for district court to quash subpoena for tax returns based on the "primacy" of the "public policy against unnecessary disclosure [of tax returns] arises from the need, if tax laws are to function properly, to encourage taxpayers to file complete and accurate returns"). + +In Pendlebury v. Starbucks Coffee Co., 2005WL 2105024 at \*2 (S.D. Fla. 2005), the court agreed that "[i]ncome tax returns are highly sensitive documents" and that courts should be reluctant to order disclosure during discovery. Citing, Natural Gas Pipeline Co. of Am. v. Energy Gathering, Inc., 2F.3d 1397, 1411 (5th Cir. 1993); DeMasi v. Weiss, Inc., 669F.2d 114, 119-20 (3d Cir. 1982)(noting existence of public policy against disclosure of tax returns); Premium Serv. Cora. v. Sperry & Hutchinson Co. 511F.2d 225, 229 (91h Cir. 1975). The court in Pendlebury agreed that parties seeking the production of tax returns must demonstrate (1) relevance of the tax returns to the subject matter of the dispute and (2) a compelling need for the tax returns exists because the information contained therein is not otherwise available. Id. at \*2; see also Dunkin Donuts, Inc. v. Mary's Donuts, Inc., 2001WL 34079319 (S.D. Fla. 2001); + +Ila v. Hallaarten & Co., 34F.R.D. 482, 483-84 (S.D.N.Y. 1964). Thus, before the Court can order production of the requested returns in this matter, the Plaintiff must satisfy the "relevance" and "compelling need" standards. The Magistrate's Order fails to address the "relevancy" standard and Plaintiff fails to provide same with supporting argument and case law, and the Plaintiff fails to delineate any "compelling need" or availability of networth from other sources (e.g., a stipulation as to net worth, which is certainly an alternative means). To the extent that the Court determines that the tax returns are relevant and that there is a compelling need for at least their disclosure of Epstein's wealth for punitive damage purposes, Epstein would agree to stipulate, through his attorneys, that he has anet worth of over \$50,000,000. Such a stipulation more than satisfies any necessity for the disclosure of the tax returns or any additional net worth information. + +This court already ruled in DE 462 that Epstein is not required to produce his financial history information to the extent same seeks to identify Epstein's assets, where such assets are located and whether such assets have been transferred. Id. Moreover, the names and addresses of his accounts, financial planners and money managers were also sustained pursuant to the Fifth Amendment. Id. Therefore, to the extent this court orders production of tax returns and to the extent Epstein's personal tax returns contain such information, same should be redacted and subject to heightened confidentiality. However, this can only be done subsequent to an in camera hearing wherein this court can make a ruling on relevancy, production, redaction and confidentiality; but only after the Plaintiff shows a compelling need. + +Furthermore, Epstein's complicated business transactions have no relevancy to this lawsuit and, therefore, evidence of same should not be produced. The Fifth Amendment is asafe harbor for all citizens, including those who are innocent of any underlying offense. This request, + +if answered, may result in compelled production and/or testimonial communications from Epstein regarding his financial status and history and would require him to waive his right to decline to respond to other inquiries related to the same subject matter. Responding to this and other related inquiries would have the potential to provide alink in achain of information and/or leads to other evidence or witnesses that would have the specific risk of furthering an investigation against him and therefore are protected from compulsion by Epstein's constitutional privilege. + +Accordingly, any compelled testimony that provides a"lead or clue to a source of evidence of such [a] crime" is protected by Fifth Amendment. SEC v Leach, 156F.Supp.2d at 494. Questions seeking "testimony" regarding names of witnesses, leads to phone or travel records, or financial records that would provide leads to tax or money laundering or unlicensed money transmittal investigations are protected. See also Hoffman vUnited States, 341U.S. 479, 486(1951)("the right against self-incrimination may be invoked if the answer would furnish a link in the chain of evidence needed to prosecute for a crime"). + +# c. Request Number 13 + +Request No. 13: Aphotocopy of your passport, including any supplemental pages reflecting travel to locations outside the 50 United States between 2002 and 2008, including any documents or records regarding plane tickets, hotel receipts, or transportation arrangements. + +Response: Defendant asserts his U.S. constitutional privileges. I intend to produce all relevant documents regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select, authenticate, and produce documents relevant to this lawsuit without risking waiver of my Fifth Amendment rights and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution. In addition to and without waiving his constitutional protections + +> and privileges, the scope of information is so overbroad that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence; compiling such information over asix year period would be unduly burdensome and time consuming. + +As to Request Number 13, Defendant provided this court with sufficient argument at DE 282and DE 283 detailing why the production of information showing Epstein's whereabouts could provide alink in the chain of evidence regarding: (a) Epstein's air travel within the United States and Foreign Territories; (b) Epstein's communications with others relating to or referring to females coming into the United States from other countries; and (c) Epstein's personal calendars and schedules. Given that the essential proof of an allegation of 18 U.S.C. 2423(b) would include travel records, schedules regarding trips and locations, flight records, calendars, and transportation arrangements, the court found that Epstein had made amore particularized showing because producing such information "could reveal the availability to him and/or use by him of interstate facilities and thus would constitute alink in the chain of evidence that could potentially expose [Epstein] to the dangers of self incrimination." (DE 293, p.6) See infra, regarding private aircraft. + +The Magistrate's Order (DE 462) provides that Epstein's Fifth Amendment privilege does not extend to his passport because its existence is known to the government or is a "foregone conclusion." Id. at p. 11. First, the magistrate's order presupposes that Epstein has all his passports from 2002 up through to the current date and that the government has an exact copy of same. Second, the Order presupposes that U.S. Customs and Border Patrol ("CPB") keeps a record and/or has maintained records of Epstein's travel and whereabouts from 2002 up through to the current date. Third, assuming Epstein traveled internationally, the Order presupposes that the CPB has records of all of Epstein's destinations and that other countries have shared that information with the CBP. + +For instance, CBP now offers "Global Entry" to enter the United States by kiosk. However, it is unclear whether the Global Entry kiosk records and copies the pages of a traveler's destinations outside of the United States, or does it simply record exit from and entry back into the United States?5 Moreover, it is unclear whether CBP maintains the Sample Customs Declaration Form for any period of time, which form sets out (i.e., if filled out) the countries visited by atraveler.6 This Court cannot Compel Epstein to produce information in violation of his Fifth Amendment by simply stating that Epstein's passport is "known to the government" or is a "forgone conclusion." In fact, from the websites listed herein, any CBP documents or forms filled out by atraveler take on acomplete different form when compared to an original passport, which is initially issued with blank pages. This Court would be hardpressed to find that the CBP has an exact copy of every page of every traveler's passport. Obviously, this would create more document management than CBP anticipates on its website. + +Moreover, pursuant to 19 C.F.R. §122.2, pilots of private aircraft are required to electronically transmit passenger and crew manifest information for all flights arriving into and/or departing out of the United States. As this court knows, Mr. has conducted extensive discovery, has questioned individuals as to whether Epstein owns private aircraft and has obtained certain flight manifests. Arguably, if such a procedure were followed in Epstein's case pursuant to 19 C.F.R. §122.2, then Epstein's passport would arguably take on a substantially different form when compared to the information maintained by the CBP (i.e., information that was electronically transferred). Under that circumstance, CLIP would not have an exact copy of Epstein's passports. Accordingly, the assumptions made in the Magistrate's Order have serious Fifth Amendment implications in that the exact information sought is not + +hturJ/www.customsgov/xviewv/traventrusted traveler/global entry/ + +6 chg httn://www.customs,gpv/xo/cgov/trave vacation/sample declaration form.xml + +"known to the government" and is not a "forgone conclusion" in that the government is not likely to have an exact copy of Epstein's passports. + +Again, Plaintiff's request for Epstein's passport"reflecting travel to locations outside the 50United States between 2002 and 2008, is no different from the requests this Court has already ruled upon and sustained Epstein's Fifth Amendment privilege in response thereto. (DE 292). + +In summary, this court reasoned that: + +"[On this and the other civil actions, Plaintiff's allege that Epstein violated certain federal and state criminal statutes in an attempt to make claims against Epstein ranging from sexual battery to intentional infliction of emotional distress. The lynchpin for the exercise of federal criminal jurisdiction under 18 U.S.C. §2422(b), which figures in some of the complaints filed, is `the use of any facility or means of interstate or foreign commerce' and the analogous essential element of 18 U.S.C. §2423(b), which also figures in some of the Complaints, is `travel[s] in interstate commerce or travels into the United States or . . . travels in foreign commerce.' Accordingly, requiring Epstein to provide responses. . .would in essence be compelling him to provide assertions of fact, thereby admitting that such documents existed and further admitting that the documents in his possession or control were authentic. + +As such, if you believe Plaintiff's footnote 4 at (DE 210), responding to this request could very well implicate Epstein's Fifth Amendment privilege. The allegations of Epstein's use of interstate commerce and travel and any compelled production is clearly aviolation of Epstein's Fifth Amendment rights' Based upon the arguments set forth in DE 283 (which is incorporated herein), this Court sustained Epstein's Fifth Amendment Privilege. That same ruling should apply here. (DE 293). If not, this court may be requiring Epstein to produce a log of his travels, which this Court already sustained under the Fifth Amendment. + +Plaintiff must also show that the requested information is relevant to the disputed issues of the underlying action. See Young Circle Garage, LLC. v. Koppel, 916So. 2d 22 (Fla. 4th DCA + +Once again, a ruling on these issues cannot be made in a vacuum. This court must, as it has done in the past, consider the other related cases and the allegations made therein when considering whether a response to a particular discovery requests would implicate Epstein's Fifth Amendment rights. leg DEs 242, 283 and 462. + +Page No. 22 + +2005); see also Equitable Life Assurance Society of the United States v. Daisy Worldwide, Inc., 702So. 2d 263 (Ha. 3d DCA 1997). Plaintiff has failed to meet this burden and, in doing so, has also failed to show any substantial need for the documents. + +Wherefore, Epstein respectfully requests that this Court issue and order: + +- a. finding that the danger Epstein faces by being forced to testify in this case relative to the above requests is substantial and real, and not merely trifling or imaginary; +- b. sustaining Epstein's Fifth Amendment Privilege as it relates to the above requests and denying Plaintiff's Motion in that regard; +- c. reversing and/or revising the Magistrate's Order (DE 462) relative to Request Numbers 10, 12 and 13 and entering an amended order sustaining Epstein's objections to the Magistrate's Order as to those specific requests and not requiring him to produce information relative to same; and/or +- d. remanding this appeal to the Magistrate-Judge for her reconsideration of these portions of her order; +- e. alternatively, if this court rules that any of the information requested herein is relavent, it shall only do so after an in camera hearing and only after this court ensures that each and every documents produced is the subject of a heightenedconfidentality order; + - f. for such other and further relief as this Court deems just and proper. + +Respectfully ted, + +E, ESQ. 296 + +## Certificate of Service + +IHEREBY CERTIFY that atrue 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 at day of February 2010. + +Respectfully s + +By: + +ROB T TTON, JR., ESQ. + +Florida Bar N . 224162 + +rcri cla + +MICHAEL J. PIKE, ESQ. + +Florida Bar #617296 + +muike@bc1claw.com + +BURMAN, CR1TTON, 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 E • + +Case No. 08-CV-80119-MA + +Stuart S. Mermelstein, Esq. Adam D. Horowitz, Esq. Mennelstein & Horowitz, P.A. 18205 Biscayne Boulevard Suite 2218 Miami, FL 33160 305-931-2200 Fax: 305-931-0877 ssmalsexabuseattorney.com + +, Jaffe, Weissing, Fistos & Lehnnan, PL 425 N. Andrews Avenue Suite 2 Fort Lauderdale, FL 33301 Phone: 954-524-2820 Fax: 954-524-2822 brad(apatinqj ustice.com Counsel for Plaintiff in Related Case No. 08- + +[ahorowitz@sexabuseattorney.com](mailto:ahorowitz@sexabuseattorney.com) + +80893 + +*Counsel for Plaintiffs* + +*In related Cases Nos. 08-80069, 08-80119, 08-80232, 08-80380, 08-80381, 08-80993, 08-80994* + +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](mailto:jagesq@bellsouth.net) + +*Counsel for Defendant Jeffrey Estein* + +Paul G. Cassell, Esq. +*Pro Hac Vice* +332 South 1400 E, Room 101 +Salt Lake City, UT 84112 +801-585-5202 +801-585-6833 Fax + +[cassellp@law.utah.edu](mailto:cassellp@law.utah.edu) + +*Co-counsel for Plaintiff Jane Doe* + +Isidro M. [REDACTED], Esq. + +[REDACTED] Law Firm, P.A. +224 Datura Street, Suite 900 +West Palm Beach, FL 33401 +561-832-7732 +561-832-7137 F + +[isidrogarcia@bellsouth.net](mailto:isidrogarcia@bellsouth.net) + +*Counsel for Plaintiff in Related Case No. 08-80469* + +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 + +[rjosefsberg@podhurst.com](mailto:rjosefsberg@podhurst.com) + +[kezell@podhurst.com](mailto:kezell@podhurst.com) + +*Counsel for Plaintiffs in Related Case* + +*pledge* +*3/23* + +**UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF FLORIDA** + +CASE NO: 08-CV-80893-MARRA/ [REDACTED] + +JANE DOE, + +Plaintiff + +vs. + +JEFFREY EPSTEIN, + +Defendant + +**PLAINTIFF'S FIRST REQUEST FOR PRODUCTION TO DEFENDANT** + +COMES NOW the Plaintiff, JANE DOE, by and through her undersigned counsel, pursuant to Fed.R.Civ.P. 34 and S.D. Fla. 26.1G., and requests the Defendant, Jeffrey Epstein, to produce the original or best copy of the items listed hereinbelow, at the offices of the Plaintiff's undersigned counsel, for inspection and/or copying within thirty (30) days of service. + +**PRELIMINARY STATEMENT** + +1. These requests for production are deemed continuing. Pursuant to Rule 26(e) of the Federal Rules of Civil Procedure and applicable law, if any information sought by said requests for production is not learned until after they are answered, or if any answers for any reason should later become incorrect, there shall be a continuing duty on the party answering said requests to supplement or change answers previously submitted. + +**DEFINITIONS AND INSTRUCTIONS** + +- 1. **Communication.** The term "communication" means the transmittal of information (in the form of facts, ideas, inquiries or otherwise). +- 2. **Document.** The term "document" is defined to be synonymous in meaning and equal in scope to the usage of this term in Federal Rule of Civil Procedure 34(a), including, without limitation, electronic or computerized data compilations. A draft or non-identical copy is a separate document within the meaning of this term. + +**"A"** +*cc: R [unclear], DJ* +*disc* +EFTA02821393 + +1. 3. **Identify (with respect to person).** When referring to a person, "to identify" means to give, to the extent known, the person's full name, present or last known address, and when referring to a natural person, additionally, the present or last known place of employment. Once a person has been identified in accordance with this subparagraph, only the name of the person need be listed in response to subsequent discovery requesting the identification of that person. +2. 4. **Identify (with respect to documents).** When referring to documents, "to identify" means to give, to the extent known, the (i) type of documents; (ii) general subject matter; (iii) date of the document; and (iv) author(s), addressee(s) and recipient(s). +3. 5. **Parties.** The terms "plaintiff" and "defendant" as well as a party's full or abbreviated name or a pronoun referring to a party means the party and, where applicable, its officers, directors, employees, partners, corporate parent, subsidiaries or affiliates. This definition is not intended to impose a discovery obligation on any person who is not a party to the litigation. +4. 6. **Person.** The term "person" is defined as any natural person or any business, legal or governmental entity or association. +5. 7. **Concerning.** The term "concerning" means relating to, referring to, describing, evidencing or constituting. +6. 8. **All/Each.** The terms "all" and "each" shall be construed as all and each. +7. 9. **And/Or.** The connectives "and" and "or" shall be construed either disjunctively or conjunctively as necessary to bring within the scope of the discovery request all responses that might otherwise be construed to be outside of its scope. +8. 10. **Number.** The use of the singular form of any word includes the plural and vice versa. +9. 11. **Refer/Relate to.** "Refer" or "relate to" means to make a statement about, discuss, describe, reflect, constitute, identify, deal with, consist of, establish, comprise, list, evidence, substantiate or in any way pertain, in whole to in part, to the subject. +10. 12. As used herein the singular shall include the plural, the plural shall include the singular, and the masculine, feminine and neuter shall include each of the other genders. + +**DOCUMENTS REQUESTED** + +1. 1. Copies of all telephone records in your or your attorneys' possession from 2002 - 2005 that in any way relate to you (including all phone lines owned by you or that were used to contact girls for the purposes of scheduling massages for you). + +2. All massage appointment books, diaries, computer calendars or scheduling entries, scheduling books or any other writing or correspondence that contains the names of any of the girls that were called, contacted, scheduled, or who otherwise went to your home located at 358 El Brillo Way, Palm Beach, Florida, for the purpose of giving you amassage. + +3. Any and all documentation in your possession that contains Plaintiffs name or that refers to Plaintiff, directly or indirectly, (includes emails, letters, message pads, diaries, appointment books, computer print outs). + +4. Any and all photos, videos, downloaded digital prints or any other visual depiction of Plaintiff, or of any other known or suspected minor females introduced to you, directly or indirectly, by Plaintiff. + +5. Photos of the inside of your home located at 358 El Brillo Way, Palm Beach, Florida, that depict the room(s) where the massages took place (including massage table). + +6. Any and all documentation of cancelled checks or evidence of payment to Plaintiff of any kind and for any reason whatsoever. + +7. All discovery information obtained by you or your attorneys as aresult of the exchange of discovery in the State criminal case against you or the Federal investigation against you. + +8. All financial documents evidencing asset transfers from 2005 to the present for you personally or any company or corporation owned by you. + +9. Any documents or other evidentiary materials provided to local, state, or federal law enforcement investigators or local, state or federal prosecutors investigating your sexual activities with minors. + +10. All correspondence between you or your attorneys and state or federal law enforcement or prosecutors (includes, but is not limited to, letters to and from the State Attorney's office or any agents thereof). + +11. Any and all documents reflecting your current net worth. + +12. Personal tax returns for all years from 2002 through the present. + +13. A photocopy of your passport, including any supplemental pages reflecting travel to locations outside the 50 United States between 2002 and 2008, including any documents or records regarding plane tickets, hotel receipts, or transportation arrangements. + +14. A sworn statement of your net worth (including adetailed financial statement depicting all current assets and liabilities). + +15. All financial statements or affidavits produced by you for any reason, to any person, company, entity or corporation since 2005. + +16. All medical records of Defendant Epstein from Dr. Stephan Alexander. + +## CERTIFICATE OF SERVICE + +WE HEREBY CERTIFY that atrue and correct copy of the above and foregoing has been provided via United States mail to the following addressees, this 23day of March, 2009. + +Robert D. Critton, Jr., Esquire Michael J. Pike, Esquire Burman, Critton, Luttier & Coleman, LLP 515 North Flagler Drive Suite 400 West Palm Beach, Florida 33401 rcrit@bc1claw.com mpike©bciclaw.com + +Jack Alan Goldberger, Esquire +Atterbury, Goldberger & Weiss, P.A. +250 Australian Avenue South +Suite 1400 +West Palm Beach, Florida 33401 +[jagesq@bellsouth.net](mailto:jagesq@bellsouth.net) + +Michael R. Tein, Esquire +██████████ Tein, P.L. +3059 Grand Avenue +Suite 340 +Coconut Grove, Florida 33133 +[tein@lewistein.com](mailto:tein@lewistein.com) + +Respectfully Submitted, + +THE LAW OFFICE OF BRAD ██████████ & +ASSOCIATES, LLC + +By: + +![]()Brad ██████████ Esquire +Attorney for Plaintiff +Florida Bar No. 542075 +2028 ██████████ Street +Suite 202 +Hollywood, Florida 33020 +Telephone: 954-414-8033 +Facsimile: 954-924-1530 +E-Mail: [be@bradedwardslaw.com](mailto:be@bradedwardslaw.com) + +Paul G. Cassell +Attorney for Plaintiff +Pro Hac Vice +332 S. 1400 E. +Salt Lake City, UT 84112 +Telephone: 801-585-5202 +Facsimile: 801-585-6833 +E-Mail: [cassellp@law.utah.edu](mailto:cassellp@law.utah.edu) + +**JANE DOE,** + +### **UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA** + +**CASE NO.: 08-CIV- 80893 — MARRAlla** + +**Plaintiff,** + +**v.** + +**JEFFREY EPSTEIN,** + +**Defendant.** + +### **DEFENDANT'S RESPONSE & OBJECTIONS TO PLAINTIFF'S FIRST REQUEST FOR PRODUCTION (dated 03123109)** + +**Defendant, JEFFREY EPSTEIN, ('EPSTEIN"), by and through his undersigned attorneys, pursuant to Fed.R.Civ.P., 34, and S.D. Fla. 26.1.G., serves his response to Plaintiff JANE DOE's First Request For Production, dated March 23, 2009.** + +**Request No. 1: Copies of all telephone records in your or your attorneys' possession from 2002 through 2005 that in any way relate to you (including all phone lines owned by you or that were used to contact girls for the purposes of scheduling massages for you.)** + +**Response: Defendant asserts his U.S. constitutional privileges. I intend to produce all relevant documents regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select, authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution.** + +**Request No. 2: All massage appointment books, diaries, computer calendars or scheduling entities, scheduling books or any other writing or correspondence that contains the names of any of the girls that were called, contacted, scheduled or who** + +otherwise went to your home located at 358 El Brillo Way, Palm Beach, Florida, for the purpose of giving you a massage. + +**Response:** Defendant asserts his U.S. constitutional privileges. I intend to produce all relevant documents regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select, authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution. + +**Request No. 3:** Any and all documentation in your possession that contains Plaintiff's name or that refers to Plaintiff, directly or indirectly, (includes e-mails, letters, message pads, diaries, appointment books, computer print outs). + +**Response:** Defendant asserts his U.S. constitutional privileges. I intend to produce all relevant documents regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select, authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution. + +**Request No. 4:** Any and all photos, videos, downloaded digital prints or any other visual depiction of Plaintiff, or of any other known or suspected minor females introduced to you, directly or indirectly, by Plaintiff. + +**Response:** Defendant asserts his U.S. constitutional privileges. I intend to produce all relevant documents regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select, authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution. + +**Request No. 5:** Photos of the inside of your home located at 358 El Brillo Way, Palm Beach, Florida, that depict the room(s) where the massages took place (including massage table). + +**Response:** Defendant asserts his U.S. constitutional privileges. I intend to produce all relevant documents regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select, authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution. + +**Request No. 6:** Any and all documentation of cancelled checks or evidence of payment to Plaintiff of any kind and for any reason whatsoever. + +**Response:** Defendant asserts his U.S. constitutional privileges. I intend to produce all relevant documents regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select, authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution. + +**Request No. 7:** All discovery information obtained by you or your attorneys as a result of the exchange of discovery in the State criminal case against you or the Federal investigation against you. + +**Response:** Defendant is asserting specific legal objections to the production request as well as his U.S. constitutional privileges. I intend to produce all relevant documents regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select, authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution. In addition to and without waiving his constitutional privileges, the information sought is privileged and confidential, and inadmissible + +pursuant to the terms of the deferred prosecution agreement, Fed. Rule of Evidence 410and 408, and §90.410, Fla. Stat. Further, the request may include information subject to work product or an attorney-client privilege. + +Request No. 8: All financial documents evidencing asset transfers from 2005 to the present for you personally or any company or corporation owned by you. + +Response: Defendant is asserting specific legal objections to the production request as well as his U.S. constitutional privileges. I intend to produce all relevant documents regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select, authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution. + +Request No. 9: Any documents or other evidentiary materials provided to local, state, or federal law enforcement investigators or local, state or federal prosecutors investigating your sexual activities with minors. + +Response: Defendant is asserting specific legal objections to the production request as well as his U.S. constitutional privileges. I intend to produce all relevant documents regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select, authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution. In addition to and without waiving his constitutional privileges, the information sought is privileged and confidential, and inadmissible pursuant to the terms of the deferred prosecution agreement, Fed. Rule of Evidence 410and 408, and §90.410, Fla. Stat. Further, the request may include information subject to work product or an attorney-client privilege. + +Request No. 10: All correspondence between you and your attorneys and state or federal law enforcement or prosecutors (includes, but not limited to, letters to and from the State Attorney's office or any agents thereof). + +**Response:** Defendant is asserting specific legal objections to the production request as well as his U.S. constitutional privileges. I intend to produce all relevant documents regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select, authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution. In addition to and without waiving his constitutional privileges, the information sought is privileged and confidential, and inadmissible pursuant to the terms of the deferred prosecution agreement, Fed. Rule of Evidence 410 and 408, and §90.410, Fla. Stat. Further, the request may include information subject to work product or an attorney-client privilege. + +**Request No. 11:** Any and all documents reflecting your current net worth. + +**Response:** Defendant asserts his U.S. constitutional privileges. I intend to produce all relevant documents regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select, authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution. + +**Request No. 12:** Personal tax returns for all years from 2002 through the present. + +**Response:** Defendant asserts his U.S. constitutional privileges. I intend to produce all relevant documents regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select, authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution; overly broad. + +**Request No. 13:** A photocopy of your passport, including any supplemental pages reflecting travel to locations outside the 50 United States between 2020 and 2008, + +including any documents or records regarding plane tickets, hotel receipts, or transportation arrangements. + +**Response:** Defendant asserts his U.S. constitutional privileges. I intend to produce all relevant documents regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select, authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution. In addition to and without waiving his constitutional protections and privileges, the scope of information is so overbroad that it seeks information that is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence; compiling such information over a six year period would be unduly burdensome and time consuming. + +**Request No. 14:** A sworn statement of your net worth (including a detailed financial statement depicting all current assets and liabilities). + +**Response:** Defendant asserts his U.S. constitutional privileges. I intend to produce all relevant documents regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select, authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution. + +**Request No. 15:** All financial statements or affidavits produced by you for any reason, to any person, company, entity or corporation since 2005. + +**Response:** Defendant asserts his U.S. constitutional privileges. I intend to produce all relevant documents regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select, authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution; overly broad. + +Request No. 16: All medical records of Defendant Epstein from Dr. Stephan Alexander. + +Response: Defendant is asserting specific legal objections to the production request as well as his U.S. constitutional privileges. I intend to produce all relevant documents regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select, authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution. + +## Certificate of Service + +WE HEREBY CERTIFY that a true copy of the f Mail and facsimile to the following addressees this regoing has been sent via U.S. day of May, 2009. + +Brad NM Esq. Rothstein Rosenfeldt Adler 401 East Las Olas Boulevard Suite 1650 Fort Lauderdale, FL 33301 Phone: 954-522-3456 Fax: 954-527-8663 bedwards rra-law.com Counsel for Plaintiff Paul G. Cassell, Esq. Pro Hac Vice 332 South 1400 E, Room 101 Salt Lake City, UT 84112 801-585-5202 801-585-6833 Fax cassellg law.utah.edu Co-counsel for Plaintiff + +Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 561-659-8300 561-835-8691 Fax jagescabellsouth.net Co-Counsel for Defendant Jeffrey Epstein + +Respectfully subm + +By: ROBERT D. RITTON, JR., ESQ. + +Florida Bar No. 224162 + +[rcrit@bclclaw.com](mailto:rcrit@bclclaw.com) + +BURMAN, CRITTON, LUTTIER & COLEMAN + +515 N. 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/dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821406/EFTA02821406.md @@ -0,0 +1,276 @@ +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA + +JANE DOE, CASE NO. 08-CV-80893-CIV-MARRA/ + +Plaintiff, + +Vs. + +JEFFREY EPSTEIN, et al. + +Defendant. + +Related Cases: + +08-80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 + +#### PLAINTIFF JANE DOE'S RESPONSE TO DEFENDANT'S MOTION FOR RECONSIDERATION AND/OR REQUEST FOR RULE 4 REVIEW AND APPEAL + +Plaintiff, Jane Doe, hereby files this response to defendant Jeffrey Epstein's Motion for Reconsideration and/or Request for Rule 4 Review and Appeal of Portions of Magistrate's Order (dkt. #477). The motion should be denied in its entirety. As the magistrate judge correctly found, defendant Epstein has no valid Fifth Amendment objection to refusing to turn over materials and information already in the Government's possession. Moreover, the other objections that he raises were never presented to the magistrate judge and, in any event, are without merit. + +## PROCEDURAL BACKGROUND + +On July 20, 2009, Jane Doe filed a straightforward motion for production of various materials, including documents provided to Epstein as part of discovery from state and federal prosecutors in the criminal cases against him, his recent tax returns, and his passport (dkt. #210). Epstein obtained an extension of time in which to respond + +and, two-and-a-half months later, on October 6, 2009, Epstein filed an objection to producing these items primarily on Fifth Amendment grounds (dkt. #339). On October 16, 2009, Jane Doe filed a reply in support of her motion (dkt. #354). On January 22, 2010, Jane Doe filed a notice that more than 90 days had elapsed since the filing of her motion (dkt. #453). + +On February 4, 2010, the magistrate judge granted in part Jane Doe's motion to compel, specifically ruling that Epstein had to produce the discovery provided to him by state and federal prosecutors, his recent tax returns, and his passport (dkt. #462). The magistrate judge explained that the requests "seek production of documents the government itself gave to Epstein, making the government's prior knowledge of the documents sought an obvious and undeniable 'foregone conclusion.' As such, Epstein cannot reasonably and in good faith argue that in producing these documents to Plaintiff he will somehow be incriminating himself." Id. at 8. + +Epstein then obtained extension of time in which to file an appeal, ultimately filing an appeal of the magistrate decision on February 26, 2010 - some seven months after Jane Doe's initial request had been made (dkt. #477). + +## EPSTEIN POSSESSES MATERIALS RESPONSIVE TO JANE DOE'S REQUESTS + +At the outset, it is worth briefly addressing what appears to be an effort by Epstein to obfuscate the fact that he possesses documents and other materials relevant to the discovery requests for production. Jane Doe made request for materials relating to the criminal charges against Epstein, his recent tax returns, and his passports. The three discovery requests regarding Epstein's criminal charges are: + +Request No. 7: All discovery information obtained by you or your attorneys as a result of the exchange of discovery in the State criminal case against you or the Federal investigation against you. + +Request No. 9: Any documents or other evidentiary materials provided to local, state, or federal law enforcement investigators or local, state or federal prosecutors investigating your sexual activities with minors. + +Request No. 10: All correspondence between you and your attorneys and state or federal law enforcement or prosecutors (includes, but not limited to, letters to and from the States Attorney's office or any agents thereof). + +In his appeal pleading to this Court, Epstein has now made the following representations: + +As to Request No. 7, Epstein and his attorneys do not have any 'discovery information' provided to them by the federal government. + +As to Request No. 9, Epstein has not been given any evidentiary materials or evidentiary documents by the federal government. + +Defendant's Motion for Reconsideration and/or Request for Rule 4 Review and Appeal, dkt. #477, at 4 (hereinafter "Epstein's Appeal"). Jane Doe does not take these representations to mean that Epstein possesses no information responsive to these requests. If this were the case, Epstein could have avoided seven months of litigation by simply explaining that to the Court (and Jane Doe) at the outset. Rather, Epstein seems to be playing semantic games. With regard to discovery request no. 7, Epstein represents only that he has no discovery information from the federal government — not contesting the obvious fact (as Jane Doe has been reliably informed) that he received significant discovery in connection with the state criminal charges to which he pled guilty. With regard to discovery request no. 9, Epstein represents only that he has not been given evidentiary documents by the federal government — again not contesting the obvious fact (as Jane Doe has been reliably informed) that he received documents and + +other materials, including correspondence, from both the state and federal authorities working on his case. If Epstein is going to continue to mince words in this fashion, Jane Doe asks that he clearly explain to the Court in any reply pleading what materials responsive to the requests for production he possesses so that the Court may make an informed ruling.' + +## ARGUMENT + +#### I. THE MAGISTRATE JUDGE PROPERLY ORDERED EPSTEIN TO PRODUCE DISCOVERY AND OTHER MATERIALS FROM THE CRIMINAL CASE. + +The magistrate judge ordered Epstein to produce materials responsive to requests no. 7, no. 9, and no. 10 — all materials relating to the criminal cases against Epstein. This order should be affirmed. + +### A. The "Purpose" of the Federal Rules of Evidence Regarding Settlement Discussions Does Not Provide any Basis for Resisting Discovery + +The main argument that Epstein makes before the Court now against this request for production is that it would supposedly violate the purpose underlying the Rules of Evidence that limit the use at trial of certain evidence regarding settlement discussions. This argument should be rejected for numerous reasons. + +First, it is important to understand that argument is being raised against the backdrop of a sustained (and thus far successful) effort by Epstein to prevent Jane Doe from obtaining any documentary discovery from him regarding this case. As the Court is well aware from the pleadings in this and related cases, through a battery of attorneys + +It is also important to note that Jane Doe's discovery requests date back to last July. Jane Doe assumes that Epstein has not destroyed or otherwise dispossessed himself of any materials responsive to the requests since that time. Jane Doe also assumes that Epstein will give the discovery requests their reasonable and ordinary understanding, rather than some strained interpretation. + +Epstein has raised numerous objections to providing discovery to Jane Doe and other plaintiffs. Epstein has also "taken the Fifth" with regard to all substantive questions propounded to him about his sexual abuse of young girls. Jane Doe's efforts to obtain the materials involved in this motion are hardly gilding the lily — if she receives them, they would be the first substantive materials that she has obtained from Epstein in this case. + +Second, Epstein's argument about the confidentiality of settlement discussions only pertains to Jane Doe's discovery Request No. 10, which seeks correspondence with the Government.2 It has no application to her discovery Requests Nos. 7 and 8 regarding documents and other materials provided by state and federal prosecutors during the criminal cases against Epstein. Accordingly, those two requests should be summarily granted. + +Third, Epstein's argument before this Court regarding settlement discussion confidentiality is an entirely new argument from the one that he presented to the magistrate judge. Before the magistrate judge, Epstein's argument was that producing the correspondence with the Government would violate his Fifth Amendment privilege against Self-Incrimination. See Defendant Jeffrey Epstein's Response in Opposition to Plaintiff's, Jane Doe's, Motion to Compel Response to Plaintiff's Request for Production (dkt. # 339), at 6-8 (hereinafter cited as "Epstein's Response in Opposition") (raising Fifth Amendment "act of production" argument). It was only at the tail-end of his memorandum that Epstein even mentioned issues regarding the settlement + +2 The request covers correspondence with "state or federal law enforcement or prosecutors." For convenience, the request will be described as being for correspondence with "the Government." + +discussions. His argument tersely asserted that "a reading of the particular discovery requests reveals that they encompass attorney-client and work-product privileged material." Epstein's Response in Opposition at 8. Id. The argument then concluded with the claim that the federal rules of evidence "prevent the production of such material." Id. at 9. + +The magistrate judge had no difficulty in dispatching not only the Fifth Amendment claims (discussed below) but also the arguments that Epstein presented regarding the alleged attorney-client and work-product privilege. The magistrate judge rejected "out of hand" any claim by Epstein regarding attorney-client privilege because issues discussed with the Government could hardly be viewed as "'confidential communications' between a lawyer and his client for the purpose of obtaining legal advice." Omnibus Order, dkt. #462, at 9. And with regard to the Federal Rules of Evidence relating to settlement discussions, the magistrate judge noted that the rules apply only to the trial — not the earlier discovery phase of a civil case. Id. at 10. + +Rather than contest these uncontrovertable propositions before this Court, Epstein advances a new set of attacks on producing the correspondence. He now contends that production would "contravene the critical public policy" that allows plea bargaining of criminal charges. Epstein's Appeal at 4. He then dives into what he alleges is the "purpose of the rules" and claims that this purpose will be violated if he is required to produce his correspondence with the Government. Id. at 5. In support of his argument, he cites a series of cases that discuss confidentiality generally (but not discovery issues). + +Epstein never presented this argument to the magistrate judge. Nor did Epstein cite any of the supporting cases that he now cites to this Court to the magistrate judge. Accordingly, this Court should not consider this new argument being presented to it for the first time. As the Eleventh Circuit has explained, "Systemic efficiencies would be frustrated and the magistrate judge's role reduced to that of a mere dress rehearser if a party were allowed to feint and weave at the initial hearing, and save its knockout punch for the second round." v. McNeil, 557 F.3d 1287, 1292 (111h Cir. 2009). + +Four, in any event, far from being a knockout punch, Epstein's argument is meritless. As is readily apparent, Epstein is making an argument based on what he alleges to be good "public policy." Epstein's Appeal at 4. But in approving the Rules of Civil Procedure, Congress has already made a different determination about the appropriate policy to follow during discovery. The Rules of Civil Procedure permit discovery, of course, "regarding any nonprivileged matter that is relevant" to Jane Doe's claims. Fed. R. Civ. P. 26(b)(1) (emphasis added). The Rules of Evidence regarding settlement discussions (rules 410 and 408) do not create any privileges. It is possible that Epstein may ultimately argue that these rules exclude certain evidence at trial. If he makes these arguments, Jane Doe will respond in due course.3 But under the discovery rules "[r]elevant information need not be admissible at the trial if the discovery + +3 Both rules contains exemptions, allowing such evidence to be used to prove such things as "state of mind," "bias and prejudice," or other things apart from mere liability for the matter under discussion. See, e.g., United States v. Peed, 714 F.2d 7, 9-10 (4th Cir. 1983) (admitting defendant's offer to return missing property because it appeared motivated by purpose of persuading victim to drop criminal charges rather than to compromise civil claim). The Florida rule that Epstein cites, even though not applicable in this federal case, are also subject to similar exemptions. Once Jane Doe has an opportunity to review the materials that Epstein provides, she believes that she will be able to provide multiple permissible grounds for believing that the correspondence falls comfortably within the exemptions. + +appears reasonably calculated to lead to the discovery of admissible evidence." Fed. R. Civ. P. 26(b). Thus, discovery is "construed broadly to encompass any matter that bears on, or that reasonably could lead to another matter that could bear on any issue that is or may be in the case." Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340, 352 (1978). The correspondence with the government agencies may well point Jane Doe in the direction of admissible evidence, and therefore Epstein should be compelled to provide the correspondence sought in request number 10. + +Fifth, even if Rule 410 and 408 could be viewed restricting discovery in civil cases, they are entirely inapplicable to this particular case. Rule 410 is the specific rule covering plea bargaining in criminal cases. It makes inadmissible against a defendant "any statement made in the course of plea discussions with an attorney for the prosecuting authority which do not result in a plea of guilty . . . ." Fed. R. Evid. 410(4) (emphasis added). Of course, in this case the discussions that Epstein had with prosecutors did "result in a plea of guilty" -- therefore Rule 410 is by its own terms completely irrelevant to correspondence by Epstein involving a ultimate guilty plea. + +Rule 408 does not cover criminal plea bargaining, but is a general rule that covers settlement discussions in civil cases. See B. MUELLER & LAIRD C. KIRKPATRICK, EVIDENCE 246 (3d ed. 2003) (Federal Rule of Evidence "408 is intended to apply to settlement negotiations in civil cases as indicated by the reference to compromising a 'claim' rather than a `charge.' Plea bargaining in criminal cases is addressed by [Federal Rule of Evidence) 410."). Therefore, Epstein simply cannot rely on Rule 408 as basis for refusing to produce materials connected with plea bargaining. + +For all these reasons Epstein's argument that it would contravene public policy to order him to produce his correspondence with the Government should be rejected. + +#### B. The Fifth Amendment Privilege Against Self-Incrimination Does Not Provide any Basis for Resisting Discovery of Materials Already Seen By the Government. + +Epstein also half-heartedly continues to press the argument that the magistrate judge emphatically rejected: that producing materials that the Government has disclosed during the plea discussions would violate the Fifth Amendment. Epstein's Appeal at 9-11. His argument to this Court is little more than a "cut-and-paste" of the pleading he filed with the magistrate judge, not even bothering with any revision to discuss the analysis of or cases cited by the magistrate judge. + +The magistrate judge rejected Epstein's Fifth Amendment argument because "requests 7, 9, and 10 seek production of documents the government itself gave Epstein, making the government's prior knowledge of the documents sought an obvious and undeniable 'foregone conclusion.' As such, Epstein cannot reasonably and in good faith argue that in producing these documents to Plaintiff he will somehow be incriminating himself." Omnibus Order at 8. The magistrate judge cited as supporting authority In re Grand Jury Subpoena, 383 F.3d 905, 910 (9th Cir. 2004) (noting there can be no self-incrimination by production where the 'existence and location of the documents . .. are a 'foregone conclusion' and [the claimant] . . .adds little or nothing to the sum total of the Government's information by conceding that he in fact has the documents."). + +Rather than address this analysis, Epstein maintains that producing the items "could furnish a link in the chain of evidence needed to prosecute him for a crime." + +Epstein's Appeal at 9. This claim is remarkable, because Epstein is arguing that the materials at issue — which started in the government's possession -- are now somehow transformed and given Fifth Amendment protection by his mere receipt of them. The Fifth Amendment does not work such alchemy. + +It is true, of course, that the Fifth Amendment covers situations where the act of producing documents has "communicative aspects of its own, wholly aside from the contents of the papers produced." Fisher v. United States, 425 U.S. 391, 410 (1976). But this "act of production" doctrine has stringent limits. It does not extend, for example, to a claim by a taxpayer that he would incriminate himself by producing his accountant's work papers. As the Supreme Court has explained — and the magistrate judge properly recognized -- the government's awareness of these documents was "a foregone conclusion" and therefore their production could be required: + +It is doubtful that implicitly admitting the existence and possession of the papers rises to level of testimony within the protection of the Fifth Amendment. The papers belong to the accountant, were prepared by him, and are the kind usually prepared by an accountant working on the tax returns of his client. Surely the Government is in no way relying on the "truthtelling" of the taxpayer to prove the existence of . . . the documents. The existence and location of the papers are a foregone conclusion. + +Fisher, 425 U.S. at 410 (emphasis added). + +Courts applying this "foregone conclusion" standard to various fact patterns have asked whether the government was aware of the documents' existence apart from any actions of the defendant. Thus, United States v. Hubbell, 530 U.S. 27 (2000), rejected the Government's argument that it was a foregone conclusion that the defendant possessed "ordinary business records." The Court noted that the government had no "prior knowledge" of these records: + +CASE NO: 08-CV-80119-MARRA/[REDACTED] + +Whatever the scope of this "foregone conclusion" rationale, the facts of this case plainly fall outside of it. While in *Fisher* the Government already knew that the documents were in the attorney's possession and could independently confirm their existence and authenticity through the accountants who created them, here the Government has not shown that it had *any prior knowledge* of either the existence or the whereabouts of the 13,120 pages of documents ultimately produced by respondent. + +*Id.* at 44 (emphasis added). + +In this case, of course, the government's "prior knowledge" of the documents that Jane Doe seeks is obviously and undeniably a foregone conclusion. *The government itself gave Epstein the documents!* Therefore, there is no plausible argument that, in producing these documents to Jane Doe, Epstein will somehow be incriminating himself by disclosing to the government something that it does not already know. The government clearly has prior knowledge of documents that *it* gave to Epstein. Here, then – as the magistrate judge properly held relying on an instructive Ninth Circuit opinion (not discussed by Epstein) -- the "existence and location of the documents . . . are a 'foregone conclusion' and [Epstein] . . . adds little or nothing to the sum total of the Government's information by conceding that he in fact has the documents." *In re Grand Jury Subpoena, Dated April 18, 2003*, 383 F.3d 905, 910 (9th Cir. 2004). + +The D.C. Circuit has recently refused to extend the act of production doctrine on facts very similar to those here. In *United States v. Ponds*, 454 F.3d 313 (D.C. Cir. 2006), federal prosecutors sought information about possible crimes committed by a defense attorney in the course of representing a defendant in a federal case. The prosecutors subpoenaed the attorney to produce all correspondence between him and courts and prosecutors in that case. In summarily rejecting an argument that producing the documents would somehow fall within the act of production doctrine of the Fifth + +Amendment, the D.C. Circuit explained that "the government must have known of the existence of documents . . . because it was a party to that correspondence." Id. at 325. The Circuit further explained that the government's subpoena need not "name every scrap of paper that is produced. Because the government already had sufficient knowledge about the . . . [case-related] documents, . . . [the defense attorney] was simply surrendering them, not testifying, by complying with those demands in the subpoena." Id. Other cases similarly reject attempts to use an act of production shield to turning over documents whose existence are known to the government or is a foregone conclusion. See, e.g. In re Grand Jury Subpoena Duces Tecum Dated Oct 29, 1992, 1 F.3d 87, 93 (2d Cir. 1993) (rejecting act of production argument because compliance with subpoena requiring production of a personal calendar 'Would require mere surrender of the calendar, and not testimony" (internal quotation omitted)); United States v. Clark, 847 F.2d 1467, 1473 (10th Cir. 1988) (accounting records not subject to act of production protection; in producing records the defendant would not "authenticate the documents as being his own or being accurate"); Securities and Exchange Commission v. First Jersey Securities, Inc., 843 F.2d 74, 76 (2d Cir. 1988) (rejecting act of production argument regarding bank records because "everybody knew that they existed"). + +## C. The Attorney-Client Privilege and Work-Product Doctrines Are Not Applicable to the Discovery Requests. + +Although his appeal memorandum is not entirely clear, Epstein also seems to be arguing some sort of attorney-client or work-product privilege bars production of the documents. As the magistrate judge found in rejecting this claim "out of hand," + +Omnibus Order at 9, any such argument is frivolous. As the magistrate judge explained, "The attorney-client privilege protects 'confidential communications' between a lawyer and his client for the purpose of obtaining legal advice." Id. There is nothing confidential about materials being exchanged between Epstein and government prosecutors — regardless of whether the materials or correspondence were being sent from the prosecutors to Epstein or from Epstein to the prosecutors." Epstein does not even acknowledge — much less attempt to refute - the magistrate judge's reasoning for ordering Epstein to produce these materials + +# D. The Privacy Rights of Third Parties are Not Implicated By The Magistrate Judge's Order. + +In a last attempt to thwart production, Epstein appeals to "third-party privacy rights." Epstein's Appeal at 11. Given the extent to which Epstein's hired investigators have interrogated anyone even remotely connected with this case, this appeal to privacy interests rings rather hollow. In any event, it is odd to think that the privacy rights of these third persons do not interfere with Epstein himself (a convicted sex offender) reviewing these materials but forbid equal viewing by attorneys for a victim who was victimized by him. None of the authorities cited by Epstein are remotely + +Jane Doe's request No. 10 sought "NW correspondence between you and your attorneys and state or federal law enforcement or prosecutors (includes, but not limited to, letters to and from the State Attorney's office or any agents thereof)" (emphasis added). In a cryptic sentence in his appeal, Epstein states "to the extent that the request is now limited to communications from the Government to Epstein, see DE 54, pgs 3 and 8, the narrowed request implicate[s] the same concerns for the opinions, the work product, and the expectation of privacy of the United States Attorney . . . ." Epstein's Appeal at 8. It's hard to understand what Epstein means by this sentence. The cited docket entry — DE 54 — has nothing to do with the discovery request at hand. Perhaps this sentence is simply a mistaken remnant of a botched "cut and paste" from another pleading in another case where docket entry 54 would be relevant. In any event, to be clear, Jane Doe has not "narrowed" her request to only one-half of the relevant correspondence and thus the magistrate judge's order is not limited to one-half of the correspondence. + +similar to the case at hand. They all involved third parties asserting their own rights. Epstein simply lacks "standing" to raise the interests of third parties. + +And, of course, Jane Doe's counsel are aware of the limits restricting use of information provided in discovery to matters pertaining to the litigation. Jane Doe's counsel understands very well that the names of minor sexual assault victioms should remain confidential, and there is no intent to compromise that the confidentiality of these girls. Therefore, Epstein's argument should be rejected summarily. + +## II. THE MAGISTRATE JUDGE PROPERLY ORDERED EPSTEIN TO PRODUCE HIS RECENT TAX RETURNS. + +The magistrate judge also ordered Epstein to produce his recent tax returns. Before the magistrate judge, Epstein raised a Fifth Amendment objection to this production. The magistrate judge rejected Epstein's argument for three reasons. First, "the Government, namely the IRS, already has Epstein's tax returns, so it can hardly be incriminating for Epstein to produce them." Omnibus Order at 12. Second, the magistrate judge found "[e]ven more persuasive . . . the fact that tax records and passports, considered by the courts to be 'required records,' are as a matter of law not subject to Fifth Amendment protection." Omnibus Order at 12 (citing Rajah v. Mukasey, 544 F.3d 427, 442 (2d Cir. 2008)); In re Doe, 711 F.2d 1187, 1191 (2d Cir. 1983); In re Doe, 97 F.R.D. 640, 644-45 (S.D.N.Y. 1982)). Third, the magistrate judge concluded that any confidentiality of tax records "was properly overridden by the broad federal discovery rules." Omnibus Order at 12. + +Before this Court, Epstein continues to push his Fifth Amendment argument, citing general Fifth Amendment cases. He does not dispute, however, that numerous + +CASE NO: 08-CV-80119-MARRA/[REDACTED] + +cases have found no Fifth Amendment protection for tax returns – as the magistrate judge specifically noted in rejecting Epstein's argument. *See, e.g., Rajah v. Mukasey*, 544 F.3d 427, 442 (2nd Cir. 2008) (". . . a taxpayer's W-2 forms are required records not subject to the Fifth Amendment because they are a mandatory part of a civil regulatory regime . . . "); *In re Doe*, 711 F.2d 1187, 1191 (2d Cir. 1983) ("we have little difficulty applying the required records exception to the W-2 . . . forms" and ordering production of W-2 forms over Fifth Amendment objection); *In re Doe*, 97 F.R.D. 640, 644-45 (S.D.N.Y. 1982) (ordering production of physician's W-2 forms as required records); *In re Grand Jury Empanelled March 19, 1989*, 541 F.Supp. 1, 3 (D.N.J. 1981). (ordering the production of tax returns and W-2 statements to a grand jury), *aff'd*, 680 F.2d 327, 336 n. 15 (3rd Cir. 1982) ("[W]e affirm that those subpoenaed documents in the appellee's possession which are required either to be kept by law or to be disclosed to a public agency should be produced for the grand jury's inspection."), *aff'd in part, rev'd in part on other grounds sub nom. United States v. Doe*, 465 U.S. 605, 608 n.3 (1984). Nor does Epstein contest the magistrate judge's observation that, given the Government already possesses the tax returns, "it can hardly be incriminating for Epstein to produce them." Omnibus Order at 12. + +Epstein does not tarry long on these fundamental problems, moving quickly to the claim that even if the Fifth Amendment does not bar production of the tax returns, he is entitled to claim the benefits of some "more stringent" standard for production than would otherwise apply to discovery. Epstein's Appeal at 15. The authority for this claim is said to be *Trudeau v. New York State Consumer Protection Bd.*, 237 F.R.D. 325 (N.D.N.Y. 2006), which reviews some decisions from within the Second Circuit and + +discusses a "compelling need" standard that apparently applies in the Northern District of New York. Epstein's Appeal at 15-16. + +Epstein's claim suffers from two fundamental problems. First, Epstein simply never argued to the magistrate judge that he was entitled to a more stringent standard of review. Rather, his argument to the magistrate judge was exclusively a Fifth Amendment argument. Epstein's Response in Opposition at 13-15. Here again, in the interests of judicial efficiency, this Court should not consider new arguments advanced for the first time on appeal from a magistrate judge. v. McNeil, 557 F.3d 1287, 1292 (11th Cir. 2009) ("a district court has discretion to decline to consider a party's argument when that argument was not first presented to the magistrate judge"). + +Second, whatever may be the law in the Northern District of New York about discovery of tax returns there, the law in the Eleventh Circuit is that tax returns are subject to ordinary discovery principles. Although Epstein's failure to raise the issue below prevented Magistrate Judge from reviewing the issue in this case, the state of the law in the Eleventh Circuit was recently and carefully reviewed by Magistrate Judge in another case. In United States v. Certain Real Property known as and Located at 6469 Polo Pointe Way, Delray Beach, Fla., 444 F.Supp.2d 1258, 1263 -1264 (S.D.Fla.,2006), he explained that this claim of a higher standard had been rejected by Maddow v. Procter & Gamble Co., Inc., 107 F.3d 846, 853 (11th Cir.1997): + +Despite the fact that some Courts within the Southern District of Florida have required a compelling need prior to ordering disclosure of tax records, the Eleventh Circuit declined to adopt such a position. In Maddow, 107 F.3d at 853, the defendants requested plaintiffs' tax returns and sent an interrogatory seeking detailed attorney fee arrangement + +information. Although the plaintiffs objected to the tax return request on privilege and relevance grounds, they provided W-2 and 1099 forms to document their earnings. The district court found that the tax records would contain relevant information not contained within the supplied forms, and ordered the plaintiffs to pay three thousand dollars (\$3,000.00) in attorney's fees for not complying with the discovery request. See Id. + +On appeal, in affirming the district court's order compelling production of the tax records, the Court stated, "[t]he court's decision to compel discovery was not an abuse of discretion: both items of information are arguably relevant to the case." Id. However, the Court reversed the district court's imposition of sanctions, finding that the plaintiffs were substantially justified in relying on out-of-circuit district court caselaw in support of their contention that a compelling need had to be shown prior to ordering disclosure, where there was no in-circuit caselaw regarding the disclosure of tax records. See Id. It should be noted that while the Court recognized that cases requiring a compelling need to be shown prior to ordering disclosure of tax records [existed], the Eleventh Circuit did not adopt such approach. See Id. + +U.S. v. Certain Real Property known as and Located at 6469 Polo Pointe Way, Delray Beach, Fla., 444 F.Supp.2d 1258, 1263 -1264 (S.D.Fla. 2006). This Court should likewise follow the Eleventh Circuit's ruling in Maddow and treat the tax return information as discoverable under ordinary standards. See also Shearson Lehman Hutton v. Lambros, 135 F.R.D. 195, 198 (M.D.Fla.1990) (ordering disclosure of tax returns because such information was relevant to the parties claims and defenses, reasoning that the quasi-privilege for tax returns had not been expressly recognized within the Circuit); Weiner v. Bache Halsey Stuart, Inc., 76 F.R.D. 624, 627 (S.D.Fla.1977) (holding that no privilege attaches to tax returns and that their discoverability turns on relevance); MCI Worldcom Network Servs., Inc. v. Von Behren Elec., Inc., No. 1:00CV3311JTC, 2002 WL 32166535, at \*4 (N.D.Ga. May 21, 2002) (same) (citing Shearson Lehman Hutton, Inc., 135 F.R.D. at 198). + +Finally, for the sake of completeness, Jane Doe could easily satisfy even a more stringent standard for obtaining Epstein's tax returns. Even courts in New York would order production of tax returns in discovery where "(1) it clearly appears that they are relevant to the subject matter of the action, and (2) a compelling need is shown because the information contained therein is not otherwise available." Dunkin' Donuts, Inc. v. Mary's Donuts, Inc., 2001 WL 34079319 at \*2 (S.D.Fla.) (S.D.Fla.,2001) (citing v. Hallgarten & Co., 34 F.R.D. 482; 483-84 (S.D.N.Y.1964)). + +Epstein's tax returns are clearly relevant to Jane Doe's case for numerous reasons. First, a theory of Jane Doe's case is that Epstein used his wealth and power to lure economically disadvantaged minor girls to his homes in Palm Beach, New York and St. where they were sexually assaulted. Epstein's tax returns will help establish the imbalance of economic power that was at the heart of his ability to pressure them into being sexually assaulted. + +Second, Jane Doe is seeking not only compensatory damages but also punitive damages. Epstein's income in recent years is plainly relevant to the size of the punitive damage award that the jury will need to impose to sufficiently punish him and insure that he does not continue the same crimes in the future. Indeed, Epstein appears to concede that his tax returns are relevant to this issue, offering to stipulate that "he has a net worth of over \$50,000,000." Epstein's Appeal at 17. Of course, this stipulation should have been presented in the first instance to the magistrate judge rather than to this Court on appeal. In any event, Jane Doe is entitled to argue for punitive damages based on Epstein's full net worth, not some conservative calculation of a figure that is lower by some undetermined amount. Jane Doe believes in good faith that Epstein's + +net worth is substantially more than \$50 million (he has been routinely described in the media as a "billionaire") and is entitled to pursue discovery to confirm her belief. + +Third, Jane Doe's counsel continue to receive disturbing reports that Epstein is moving all of his assets overseas in an effort to defeat collection of any judgment that Jane Doe and other plaintiffs may obtain. As the Court is aware, Jane Doe even filed a motion for (among other things) a restraining order forbidding Epstein from making fraudulent transfers of his assets (dkt. #165). The Court ultimately denied that motion, primarily on grounds that while Epstein had taken the Fifth when asked about his fraudulent transfers, Jane Doe lacked affirmative evidence that such transfers were taking place. Order, dkt. #400, at 3.5 Epstein's tax returns may help to provide the affirmative evidence (or lead to affirmative evidence) that such fraudulent transfers are taking place. Cf. Epstein's Appeal at 17 (conceding that his tax returns will reveal "complicated business transactions"). + +Fourth, Jane Doe has alleged and found some limited evidence suggesting that Epstein is using "modeling agencies" as a means of luring young, under-aged girls to him for sexual purposes. Epstein's tax returns may reveal the existence and location of such modeling agencies. + +Fifth, Jane Doe is currently facing Epstein's motion for summary judgment on her count that alleges a violation of 18 U.S.C. § 2255, which in turn incorporates sexual + +5 Jane Doe was able to produce evidence that Epstein had fraudulent transferred the title to several of his vehicle to third parties in an effort to conceal his ownership of these assets. The Court concluded that these frauds were "de minimis" given Jane Doe's allegation that Epstein was a "billionaire." Order at 3. Epstein's tax returns are also relevant to these issues, since they may show additional assets that have been fraudulently titled and may shed light on the true status of his finances. Moreover, if Epstein's net worth is "only" \$50 million, than it would appear that Epstein had an obligation to call this fact to the attention of the Court at the time that it ruled in his favor based on the fact that he was an alleged billionaire. + +assault and child abuse statutes that require a federal nexus (i.e., use of a means of interstate communication). Yet Epstein has filed two in camera pleadings with this Court that appear to detail how his financial information may be relevant to such federal nexus issues. See dkt. #282 and #283 (in camera pleadings). The tax returns may help Jane Doe establish the interstate nexus to Epstein's offenses.6 + +The second prong of the heightened test would require Jane Doe to establish that "the information contained therein [in the tax returns] is not otherwise available." Dunkin' Donuts, Inc. v. Mary's Donuts, Inc., 2001 WL 34079319, at \*2 (S.D. Fla. 2001). Here again, this prong is easily satisfied. Epstein has taken the Fifth on answering (among other things) all financial questions propounded to him and has otherwise thus far thwarted discovery by Jane Doe and other plaintiffs on financial issues as well as all other issues in this case. See, e.g., dkt. #462. While it is clear that Jane Doe will be entitled to an adverse inference as to all issues where Epstein has elected to obstruct discovery through his blanket 51h amendment invocation, Jane Doe anticipates that Epstein will attempt to dilute the impact of such an inference at trial. Therefore, Jane Doe should not be left only with evidence deduced from adverse inferences, and she is deserving of all corroborating documentation that is not blocked by assertions of the 5th amendment. Clearly the tax returns are a way in which Jane Doe can get supporting evidence as to Epstein's finances. Epstein does not argue otherwise. For all these reasons, the magistrate judge properly ordered Epstein to produce his recent tax returns. + +6 Of course, there are no Fifth Amendment concerns raised by production of tax records already in the Government's possession, for the reasons explained earlier. + +## III. THE MAGISTRATE JUDGE PROPERLY ORDERED EPSTEIN TO PRODUCE HIS GOVERNMENT-ISSUED PASSPORT. + +The magistrate judge also required Epstein to produce to Jane Doe his passport (a document obviously issued by the Government). Epstein argued to the magistrate judge that producing the passport might constitute "a link in the chain of evidence" that could tie him to various federal crimes. Epstein's Opposition at 16. The magistrate judge rejected this argument for two reasons. First, the magistrate judge reasoned that "Epstein is required to show his Passport to Government officials every time he travels outside the United States, [so] the Government undeniably has 'prior knowledge' of the Passport's existence, and its whereabouts is a 'foregone' conclusion." Omnibus Order at 12 (citing Hubbell, 530 U.S. at 44). Second, the magistrate judge concluded that the passport was a "required record" to which the Fifth Amendment privilege cannot be properly invoked. Omnibus Order at 12 (citing and quoting Rajah v. Mukasey, 544 F.3d 427, 442 (2d Cir. 2008) ("Just as a taxpayer's W-2 forms are required records not subject to the Fifth Amendment because they are a mandatory part of a civil regulatory regime, so too are the passports . . . at issue in the current case."). + +Rather than respond to the magistrate judge's analysis and to the cited cases, Epstein (once again) raises a new set of arguments. Epstein initially claims that he is entitled to invoke a Fifth Amendment privilege for his passport unless Jane Doe can show "that the government has an exact copy of same." Omnibus Order at 19 (emphasis in original). Epstein further contends that "the Order presupposes that the [Customs and Border Patrol] has records of all of Epstein's destinations and that other countries have shared the information with the CPB." Epstein's Appeal at 19. + +Here again, this Court should reject Epstein's argument because he failed to present it to the magistrate judge. The Court should be particularly reluctant to venture into the argument that he raises, because it involves certain evidentiary issues about the nature of the Customs and Border Patrol records -- evidentiary issues that were not litigated below. See v. McNeil, 557 F.3d 1287, 1292 (11th Cir. 2009) ("[t]o require a district court to consider evidence not previously presented to the magistrate judge would effectively nullify the magistrate judge's consideration of the matter and would not help to relieve the workload of the district court") (internal quotation omitted). + +Even if the Court decides to review Epstein's claim, the claim is without merit. The controlling case law does not require that the Government have "an exact copy" of the records (as Epstein now argues), but only that the "existence" of the records be a "foregone conclusion" (as the magistrate judge found). For example, in the Hubbard case cited by the magistrate judge, the Supreme Court explained that in an earlier case (Fisher v. United States) it had rejected a taxpayer's efforts to invoke a Fifth Amendment privilege against producing "working papers prepared by the taxpayers' accountants that the IRS knew were in the possession of the taxpayers' attorneys." Hubbell, 530 U.S. at 44-45 (citing Fisher v. United States, 425 U.S. 391, 394 (1976)). While the Government did not have an exact copy of these records (or even any copy for that matter), the Supreme Court rejected a Fifth Amendment invocation because: + +It is doubtful that implicitly admitting the existence and possession of the papers rises to the level of testimony within the protection of the Fifth Amendment. . . . The existence and location of the papers are a foregone conclusion and the taxpayer adds little or nothing to the sum total of the Government's information by conceding that he in fact has the papers. + +Hubbell, 530 U.S. at 44 (quoting Fisher v. United States, 425 U.S. at 411). In line with Fisher, dozens of cases implicitly hold that the Government need not have a copy of records in order to defeat a Fifth Amendment privilege. See, e.g., Rajah v. Mukasey, 544 F.3d 427, 442 (2d Cir. 2008) (ordering production of passports without requiring showing that Government had exact copy of those passports). + +As the magistrate judge held, a second reason for rejecting Epstein's attempt to invoke the Fifth Amendment before producing his passport is that the passport is a "required record" for which the Fifth Amendment is simply inapplicable. The magistrate judge cited Rajah v. Mukasey, 544 F.3d 427, 442 (2d Cir. 2008), which specifically held that "[j]ust as a taxpayer's W-2 forms are required records not subject to the Fifth Amendment because they are a mandatory part of a civil regulatory regime, so too are the passports . . . at issue in the current case." Epstein does not respond to this doctrine — or offer any case law in response. + +In addition to Rajah v. Mukasey, the magistrate judge could also have cited authority from this Court which specifically adopted that case. In United States v. , 595 F.Supp.2d 1312, 1318 (S.D.Fla. 2009), this Court quoted from and adopted Rajah's conclusion that passports are not protected by the Fifth Amendment. Id. at 1318 ("'the Fifth Amendment does not protect [persons] either from being forced to turn over their passports") (quoting with approval Rajah). This Court went on to explain that, notwithstanding the Fifth Amendment, the Government "may require disclosure of information where the area of inquiry is regulatory rather than criminal, where the field subject to the disclosure obligation is not permeated with criminal statutes, and where there is a substantial non-prosecutorial interest served by the + +CASE NO: 08-CV-80119-MARRA/[REDACTED] + +reporting regime." [REDACTED], 595 F.Supp.2d at 138 (*citing Rajah v. Mukasey*, 544 F.3d 427, 442 (2d Cir.2008)). *See also United States v. McDowell*, 250 F.3d 1354, 1362 (11th Cir.2001) (Fifth Amendment rights are generally diminished in the context of border crossings). All these rationales apply here. Epstein's passport is simply a government-issued record that he must present whenever he enters this country. The only information disclosed on the passport is stamps placed on it by the United States government or other governments. And, of course, all of this information is reviewed by government agents whenever Epstein crosses a border. In these circumstances, there is plainly no Fifth Amendment privilege for Epstein to invoke. + +Finally, Epstein contends that Jane Doe needs to show some kind of "substantial need" for his passport. Epstein's Appeal at 22. This argument was not presented to the magistrate judge and is also frivolous. The discovery rules do not require a request be predicated on a "substantial need" but only that it be "reasonably calculated to lead to the discovery of admissible evidence." Fed. R. Civ. P. 26(b)(1). As Epstein concedes, Jane Doe has been pursuing discovery in this case regarding flight manifests and other international travel by Epstein. *Id.* at 20. Clearly the passport is relevant to this line of inquiry. It is also relevant to supporting Jane Doe's theory that Epstein has brought minor girls into this country to satisfy his sexual appetite for underage girls. + +### CONCLUSION + +The magistrate judge carefully considered Epstein's arguments against producing certain materials and, for three particular categories – criminal discovery, tax returns, and a passport – required that Epstein producing them. The magistrate judge + +properly analyzed the issues and the ruling requiring Epstein to produce the materials should be affirmed. + +Epstein should also be directed to produce the materials within three days, as this Court has indicated would be the requirement upon affirmance of the magistrate judge's order. Dkt. #468 at 1-2 ("In the event that Magistrate Judge February 4, 2010 Order is affirmed on appeal, Defendant will have three (3) business days from the date of this Court's order to produce the documents at issue.") + +DATED: March 10, 2010 + +Respectfully Submitted, + +JAFFE, WEISSING, , FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 Florida Bar No.: 542075 E-mail: brad@pathtojustice.com + +and + +Paul G. Cassell Pro Hac Vice 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: 801-585-5202 Facsimile: 801-585-6833 E-Mail: cassellp@law.utah.edu + +CASE NO: 08-CV-80119-MARRA/[REDACTED] + +**CERTIFICATE OF SERVICE** + +I HEREBY CERTIFY that on March 10, 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 on 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 filed Notices of Electronic Filing. + +s/ [REDACTED] J. [REDACTED] +[REDACTED] J. [REDACTED] + +**SERVICE LIST** + +**Jane Doe v. Jeffrey Epstein** +**United States District Court, Southern District of Florida** + +Jack Alan Goldberger, Esq. +[Jgoldberger@agwpa.com](mailto:Jgoldberger@agwpa.com) + +Robert D. Critton, Esq. +[rcritton@bclclaw.com](mailto:rcritton@bclclaw.com) + +Isidro Manual [REDACTED] +[isidrogarcia@bellsouth.net](mailto:isidrogarcia@bellsouth.net) + +Jack [REDACTED] +[iph@searcylaw.com](mailto:iph@searcylaw.com) + +Katherine Warthen Ezell +[KEzell@podhurst.com](mailto:KEzell@podhurst.com) + +Michael James Pike +[MPike@bclclaw.com](mailto:MPike@bclclaw.com) + +Paul G. Cassell +[cassellp@law.utah.edu](mailto:cassellp@law.utah.edu) + +Richard Horace Willits +[lawyerswillits@aol.com](mailto:lawyerswillits@aol.com) + +Robert C. Josefsberg +[rjosefsberg@podhurst.com](mailto:rjosefsberg@podhurst.com) + +CASE NO: 08-CV-80119-MARRA/[REDACTED] + +Adam D. Horowitz +[ahorowitz@sexabuseattorney.com](mailto:ahorowitz@sexabuseattorney.com) + +Stuart S. Mermelstein +[ssm@sexabuseattorney.com](mailto:ssm@sexabuseattorney.com) \ No newline at end of file diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821406/EFTA02821406.metadata.json b/marker2/court-redacted-v-epstein-81111/EFTA02821406/EFTA02821406.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..a6c0be3c5a1fd179df62db9973fc6c9980366ffc --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821406/EFTA02821406.metadata.json @@ -0,0 +1,1312 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-redacted-v-epstein-81111/EFTA02821406.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 27, + "chars": 48720, + "elapsed_seconds": 10.78, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF FLORIDA", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 200.73600000000002, + 49.41 + ], + [ + 410.520751953125, + 49.41 + ], + [ + 410.520751953125, + 78.17999267578125 + ], + [ + 200.73600000000002, + 78.17999267578125 + ] + ] + }, + { + "title": "PLAINTIFF JANE DOE'S RESPONSE TO DEFENDANT'S MOTION FOR \nRECONSIDERATION AND/OR REQUEST FOR RULE 4 REVIEW AND APPEAL", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 85.68, + 366.93 + ], + [ + 527.2614135742188, + 366.93 + ], + [ + 527.2614135742188, + 395.4200134277344 + ], + [ + 85.68, + 395.4200134277344 + ] + ] + }, + { + "title": "PROCEDURAL BACKGROUND", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 214.812, + 601.02 + ], + [ + 397.52557373046875, + 601.02 + ], + [ + 397.52557373046875, + 615.9200134277344 + ], + [ + 214.812, + 615.9200134277344 + ] + ] + }, + { + "title": "EPSTEIN POSSESSES MATERIALS RESPONSIVE \nTO JANE DOE'S REQUESTS", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 162.18, + 550.8000000000001 + ], + [ + 450.7528381347656, + 550.8000000000001 + ], + [ + 450.7528381347656, + 580.6800079345703 + ], + [ + 162.18, + 580.6800079345703 + ] + ] + }, + { + "title": "ARGUMENT", + "heading_level": null, + "page_id": 3, + "polygon": [ + [ + 268.668, + 247.86 + ], + [ + 344.1871643066406, + 247.86 + ], + [ + 344.1871643066406, + 262.67999267578125 + ], + [ + 268.668, + 262.67999267578125 + ] + ] + }, + { + "title": "I. 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0000000000000000000000000000000000000000..ead6761de20309fd7a07f7fbe992ea518327e7ea --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821433/EFTA02821433.md @@ -0,0 +1,50 @@ +## 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, 08-80380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 + +## OMNIBUS ORDER + +THIS CAUSE is before the Court on Defendant Epstein's Motion For Reconsideration and/or Request for Rule 4 Review and Appeal of Portions of the Magistrate's Order Dated February 4, 2010 (D.E. #477); and Defendant's Motion for Reconsideration and/or Request for Rule 4 Review and Appeal of Magistrate's Order Dated March 4, 2010 (D.E. #488). For the following reasons said Motions are viewed by this Court as requests for reconsideration and are denied. Should Defendant wish to file a formal appeal to the District Court with regard to this Order and/or any or both of the underlying Orders, Defendant may do so within ten (10) days from the date hereof. + +In the first Motion (D.E.#477) Epstein seeks reversal of certain portions of the undersigned's Order entered February 4, 2010 which granted in part and denied in part Jane Doe's Motion to Compel production of various materials filed July 20, 2009. Specifically Epstein takes issue with that portion of the Order which compelled production of discovery from state and federal prosecutors in the criminal case against him, his recent tax returns, and his passport. The Court stands behind each of these decisions for the reasons stated in its Order and is not persuaded by any of Epstein's arguments to the contrary. + +The first category of documents (Requests 7, 9, and 10 ) consist of documents the government itself gave to Epstein. Epstein's primary objection was based on the Fifth Amendment, which the undersigned overruled on the basis of the "foregone conclusion" doctrine, which provides there can be no self-incrimination by production where the "existence and location of the documents...are a 'foregone conclusion' and [the claimantl...adds little or nothing to the sum total of the Government's information by conceding that he in fact has the documents." In re Grand Jury Subpoena, 383 F.3d 905, 910 (91" Cir. 2004). Other objections raised by Epstein included attorney-client, work product, and privacy concerns, each of which were also addressed and rejected. Epstein's final argument, raised now for the first time, concerns settlement discussion confidentiality. Because Epstein never presented this argument to the undersigned, it is inappropriate to raise it now for the first time. + +v. McNeil, 557 F.3d 1287, 1292 (11th Cir. 2009). Even were the Court to consider the argument on its merits, for the reasons explained in Jane Doe's Response Memorandum (D.E. #485), pp.4-9, the Court finds said argument without merit. + +The second and third category of documents concern production of Epstein's recent tax returns and passport. The undersigned likewise finds no basis for reversal of this decision. Rajah v. Mukasey, 544 F.3d 427, 442 (2d Cir. 2008)(noting that tax records and passports which are considered by the courts to be "required records," are as a matter of law not subject to Fifth Amendment protection). Epstein cites certain cases from the Second Circuit which provide for a "compelling need" standard to obtain tax returns. This claim of a higher standard applying to tax returns, however, has been rejected in the Eleventh Circuit. See Maddow v. Proctor & Gamble Co., Inc., 107 F.3d 846, 853 (11th Cir. 1997); United States v. Certain Real Property Known as and Located at 6469 Polo Pointe Way, 444 F.Supp.2d 1258, 1263-1264 (S.D. Ha. 2006). Accordingly, Epstein's Motion for reconsideration is denied. + +In the second Motion (D.E. #488) Epstein seeks reversal of a portion of the undersigned's Order entered March 4, 2010. The March 4, 2010 Order concerns Defendant's blanket assertion of the Fifth Amendment privilege in response to Plaintiff's interrogatories and production requests seeking net worth discovery. The Order upheld each of Epstein's objections except for those raised in response to Production Request Number 1 seeking all federal and state tax returns, including all W-2 forms and 1099 forms and schedules for the five year period from 2003-2008. Epstein's objections in this regard were the same objections raised in response to the same request contained in Jane Doe's July 20, 2009 Request for Production, which this Court ordered previously ordered produced over Epstein's objections and a request for reconsideration. + +The same reasons set forth above in connection with the undersigned's February 4, 2010 Order denying Epstein's request to reconsider her decision compelling production of his tax returns apply equally here, and shall not be repeated. Suffice it to say that for those reasons, Epstein's Motion for Reconsideration of the Order entered March 4, 2010, is denied. In accordance with the above and foregoing, it is hereby, + +ORDERED AND ADJUDGED as follows: + +(1) Defendant Epstein's Motion For Reconsideration and/or Request for Rule 4 Review and Appeal of Portions of the Magistrate's Order Dated February 4, 2010 (D.E. #477) is DENIED. Should Defendant wish to file a formal appeal to this Order and/or to the underlying February 4, 2010 Order, Defendant may do so within ten (10) days from the date hereof; and + +(2) Defendant's Motion for Reconsideration and/or Request for Rule 4 Review and Appeal of Magistrate's Order Dated March 4, 2010 (D.E. #488) is DENIED. Should Defendant wish to file a formal appeal to this Order and/or to the + +underlying March 4, 2010 Order, Defendant may do so within ten (10) days from the date hereof . + +**DONE AND ORDERED** this April 1, 2010, in [REDACTED], at West Palm Beach, Florida. + +![]()\_\_\_\_\_ +LINNEA R. [REDACTED] +UNITED STATES MAGISTRATE JUDGE + +CC: The Honorable Kenneth A. 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Rule 4, Rule 4(c) and Fed. R. Civ. P. 53(e). In support, Epstein states: + +**I. Introduction** + +The Fifth Amendment serves as a guarantee against testimonial compulsion and provides, in relevant part, that "[n]o person...shall be compelled in any Criminal Case to be a witness against himself." (DE 242, p.5); see also Edwin v. Price, 778 F.2d 668, 669 (11th Cir. 1985) (citing Lefkowitz v. Turley, 414 U.S. 70, 77 (1973)). The privilege is accorded liberal construction in favor of the right and extends not only to answers that would support a criminal conviction, but extends also to those answers which would furnish a link in the chain of evidence + +needed to prosecute the claimant for a crime. See Hoffman v. United States, 341 U.S. 479, 486 (1951). Information is protected by the privilege not only if it would support a criminal conviction, but also in those instances where "the responses would merely `provide a lead or clue' to evidence having a tendency to incriminate." See United States v. Neff, 315 F.2d 1235, 1239 (9th Cir.), cert denied, 447 U.S. 925 (1980); Blau v. United States, 340 U.S. 159 (1950); SEC v Leach, 156 F.Supp.2d 491, 494 (E.D. PA. 2001). Add new case from my e-mail of yesterday: (Court in Englebrick v Worthington Industries Inc 670 F Supp2d 1048 (CD Cal, 2009) rejected motion to compel in helpful language: "A valid assertion of the privilege does not require an imminent criminal prosecution or investigation: 'The right to assert one's privilege against self-incrimination does not depend upon the likelihood, but upon the possibility of prosecution' cite omitted ...a possibility of prosecution exists where the witness has not received a grant of immunity, the statute of limitations has not run, double jeopardy does not apply, and there are no other concrete indications that criminal prosecution is barred. See also Belmonte v Lawson, 750 F. Supp. 735, 739 (E.D. Va. 1990)("Courts should avoid engaging in crystal ball forecasts about what a prosecutor may or may not do...). + +Significantly, these cases have been consolidated for discovery. Therefore, consistent rulings must apply. In making those rulings, this Court must continue to recognize that the allegations in the related cases cannot be forgotten. (Eg., see DE 242, 293). Production of information in one case could provide a link in the chain of evidence used to prosecute Epstein for a crime or provide an indirect link to incriminating evidence in another case and in another jurisdiction. Id. and infra. + +Moreover, in addition to the testimonial privilege discussed herein, the Fifth Amendment includes an act of production which encompasses circumstances highly relevant to certain of the discovery requests at issue where the act of producing documents in response to a subpoena or production request has a compelled testimonial aspect in that it would constitute an implied admission as to the defendant's possession or control of the requested documents, as to their authenticity, and as to the defendant's selection of them as meeting the requests for production. See United States v. Hubbell 530 U.S. 27, 35-36 (2000). Thus, where the existence or location of the requested documents are unknown, or where production would "implicitly authenticate" the requested documents, the act of producing responsive documents is considered testimonial and is protected by the Fifth Amendment. See In re Grand Jury Subpoena, 1 F.3d 87, 93 (2nd Cir. 1993); Rudy-Glanzer v. Glanzer, 232 F.3d 1258, 1263 (9th Cir. 2000)(the "privilege" against self-incrimination does not depend upon the likelihood, but upon the possibility of prosecution and also covers those circumstances where the disclosures would not be directly incriminating, but could provide an indirect link to incriminating evidence). + +In addition, several of the requests outlined below implicate Federal Rules of Evidence 408, 410 and 502, and the confidentiality protections intrinsic to federal tax returns that would be unavailable under 26 U.S.C. 6103 even if a subpoena is served upon the IRS. Furthermore, + +### II. Procedural Background + +Epstein filed his Motions for Reconsideration or, Alternatively, Rule 4 Appeal, at DE 477 and 488. However, this court entered an order (DE 513) allowing for Consolidated Rule 4 Appeals relative to the above docket entries. + +### (a) Jane Doe + +Plaintiff, Jane Doe's Motion to Compel is filed at DE (194). Defendant's Response in Opposition is filed at DE (339), and the arguments set forth therein are incorporated herein by reference as if completely set forth herein as each apply to request numbers 10, 12 and 13. + +## (b) Jane Does 2-8 + +Plaintiffs, Jane Doe 2-8s' Motion to Compel is filed at DE (333). Defendant's Response in Opposition is filed at DE (390) and the arguments set forth therein are incorporated herein by reference as if completely set forth herein as each apply to request number 1 of Plaintiff's First request to produce Net Worth Discovery. + +The Request for Production and the responses thereto are attached as Composite Exhibits "A" and "B". + +# III. The Requests For Production, Araument And Memorandum Of Law + +# a. Jane Doe - Requests Numbers 7, 9 and 10 + +Request No. 7: All discovery information obtained by you or your attorneys as a result of the exchange of discovery in the State criminal case against you or the Federal investigation against you. + +Request No. 9: Any documents or other evidentiary materials provided to local, state, or federal law enforcement investigators or local, state or federal prosecutors investigating your sexual activities with minors. + +Request No. 10: All correspondence between you and your attorneys and state or federal law enforcement or prosecutors (includes, but not limited to, letters to and from the State Attorney's office or any agents thereof). + +Response to Request Numbers 7, 9 and 10: Defendant is asserting specific legal objections to the production request as well as his U.S. constitutional privileges. I intend to produce all relevant documents regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select, authenticate, and produce documents relevant to this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution. In addition to and without waiving his constitutional privileges, the information sought is privileged and confidential, and inadmissible pursuant to the terms of the deferred prosecution agreement, Fed. Rule of Evidence 410 and 408, and §90.410, Fla. Stat. Further, the request may include information subject to work product or an attorney-client privilege. It appears there is now a direct conflict with what Jane Doe requests (see e.g., DE 354, p. + +3). In short, Plaintiff is fast and loose in her argument regarding what she seeks (i.e., she states in no uncertain terms (DE 354, p.3) that she seeks information that the Federal government gave to Epstein. However, in her Reply to the Response in Opposition, she now seeks everything that the government gave to Epstein's lawyers and what his lawyers gave to the Federal government (i.e., the full breadth of the requests). The far broader ambit of the requests implicates whether the Plaintiff is seeking just the communications provided by USA() to Epstein's counsel or all Epstein's counsel's communications with, ems., the USAO, the State Attorneys' Office or any other local, state or Federal law enforcement. If Jane Doe seeks "all" communications, it deeply implicates the work product of Epstein's lawyers. If Plaintiff seeks just the communication provided by the USAO or the State Attorney, it deeply implicates the work product of the USAO and the State Attorney negotiating and communicating with Epstein's counsel which include, but are not limited to, information that resulted in a plea and information that did NOT result in a plea and information that may have resulted in the entering of the Non-Prosecution Agreement ("NPA"). Either way, the requests deeply implicate the protections and policies of FRE 408, 410 and 502 as more fully set forth infra. + +Before this limitation was made by Plaintiff, Epstein argued in his response in opposition (DE 339, p.7-8) that these requests are the same type requests the court found subject to the Fifth Amendment. With the limitation made by Plaintiff and her counsel in the Reply, the court ruled "[t]hat the earlier requests referenced by Epstein were significantly broader than the narrow + +Page No. 6 + +requests at issue here, including for example, a request for all documents `relating to' the federal non—prosecution agreement, and all documents `relating to' either the federal or state criminal investigations. These requests would have required Epstein to pick and choose which documents were responsive and in this way force Epstein to use to effectively make `use of the content his mind,' an action that would undeniably implicate the Fifth Amendment." (DE 462, p.9) Clearly the instant requests are exactly the same type of broad requests this court has already ruled upon. Had the Plaintiff not limited the scope of the requests in her Reply (DE 354, p.3), the court would not have labeled these requests as "narrow" because these requests now seek all information related to the federal non—prosecution agreement and all documents relating to either the federal or state criminal investigations, which clearly require Epstein to effectively make use of the content his mind to determine what is and what is not responsive to these broad requests. + +As a result of the limitation made by Plaintiff in her Reply (DE 354) and as a result of this court's Order (DE 462), Epstein responded - "[a]s to Request Number 7, Epstein and his attorneys do not have any "discovery information" provided to them by the federal government and [a]s to Request Number 9, Epstein has not been given any evidentiary materials or evidentiary documents by the federal government." (DE 477) Certainly, these responses were not intended to "gild the lily" as Plaintiff contends nor are they misleading. Despite what the interrogatory sought, Plaintff chose to limit same in her Reply to only what the Federal Government gave Epstein, and that is exactly how the Magistrate interpreted same. The responses were made based upon Plaintiffs limitation in what she sought from Epstein and because this court entered an Order based upon that limitation. Had the limitation not been made, neither this court nor Epstein would have been misled down this primrose path. + +Page No. 7 + +Nonetheless, Plaintiff now seeks to obtain the full breadth of information sought under request numbers 7, 9 and 10. However, that argument shall meet a short death in that Plaintiff herself limited the scope of the requests in her Reply and failed to timely file her own Rule 4 Appeal after the court entered its order at DE 462, which adopted Plaintiff 's limited scope of the requests (which Plaintiff now wishes to change). See S.D. Fla., Rule 4(a)(1), Mag. J. 2009. If the court made a mistake in adopting the limited scope of the requests (which it did not), Plaintiff should have timely appealed, which she did not. As such, Plaintiff's requested relief in this regard should be denied. + +Next, the Magistrate's order as to Request No.: 10 must be reversed because it contravenes critical public policy of encouraging resolution of criminal prosecutions without trial and the concomitant understanding that defendants will be considerably more likely to engage in full and discussions with the government if they need not fear that statements they or their counsel make to government prosecutors will be used against them to their detriment. The policies behind FRE 408, 410 and 502 provide this court with a basis for sustaining Epstein's objections to Request No.: 10. For instance, the critical importance of plea bargaining to the criminal justice system has long been recognized. "[W]hatever might be the situation in an ideal world, the fact is that the guilty plea and the often concomitant plea bargain are important components of this country's criminal justice system. Properly administered, they can benefit all concerned." Bordenkircher v. Haves, 434 U.S. 357, 361-62 (1978), quoting Blackledge v. Allison, 431 U.S. 63, 71 (1977). To encourage defendants to participate in the plea negotiation process, rules have developed to prohibit admission into evidence against the defendant of any and all statements he or his counsel acting on his behalf makes to government prosecutors during the plea negotiation process. This confidentiality protection is embodied in both Fed. R. Evid. 410 and Fed. R. Crim. + +Page No. 8 + +P. 11(0. While these rules by their express terms refer only to admissibility of evidence, the purposes and policies underlying these rules is instructive in this context, in which a civil plaintiff seeks discovery of documents falling within the scope of these two rules. + +Rule 410 was created to promote active plea negotiations and plea bargains, which our Supreme Court has acknowledged are "important components of this country's criminal justice system.". . . Our Court of Appeals has held that "in order for plea bargaining to work effectively and fairly, a defendant must be free to negotiate without fear that this statements will later be used against him.". Indeed, absent the protection of Rule 410, "the possibility of self-incrimination would discourage defendants from being completely candid and open during plea negotiations." + +S.E.C. v. , 534 F.Supp.2d 63, 66-67 (D.D.C. 2008), quoting United States v. 617 F.2d 677, 683 (D.C.Cir. 1980). See, , United States v. Mezzanatto, 513 U.S. 196, 205, 207 (1995)(purpose of the rules is to encourage plea bargaining, and rules "creat[e], in effect, a privilege of the defendant," quoting 2 J. Weinstein & M. Berger, Weinstein's Evidence ¶410[05] at 410-43 (1994)). United States v. Barrow, 400 F.3d 109, 116 (2d Cir. 2005)("The underlying purpose of Rule 410 is to promote plea negotiations by permitting defendants to talk to prosecutors without sacrificing their ability to defend themselves if no disposition agreement is reached"); Fed. R. Crim. P. 11, Advisory Committee Notes, 1979 Amendment ("the purpose of Fed. R. Ev. 410 and Fed. R. Crim. P. 11(e)(6) [now Rule 11(f)] is to promote the unrestrained candor which produces effective plea discussions"),I + +Additional illustration of the high degree of confidentially accorded settlement negotiations is found in Fed. R. Evid. 408, which precludes the introduction into evidence + +FRE 410(4) is particularly directed to communications in matters which, like Epstein's, did not result in a plea of guilty to an federal charge. Fla. Stat. §90.410 provides parallel protections in state criminal matters. Epstein pled guilty to Fla. Stat. 796.07(2)(f), Unlawful to Solicit, Induce, Entice, or Procure Another to Commit Prostitution, Lewdness or Assignation, and Fla. Stat. 796.03, Procuring Person Under Age of 18 For Prostitution. Therefore, in the event this court orders production of said correspondence, then it must first hold an in camera inspection to determine what, if any, documents are related to the foregoing pleas and what documents are not. Along those same lines, an in camera inspection must be had in an effort to redact any information that may violate third-party privacy rights or information that would implicate Epstein's Fifth Amendment rights. agg infra. + +Page No. 9 + +communications made during settlement negotiations. The purposes underlying Rule 408 are essentially the same as those underlying Fed. R. Crim, P. 11(0 and 410: "to encourage nonlitigious solutions to disputes." Reichenbach v. 528 F.2d 1072, 1074 (11th Cir. 1976). See, Lg., Stockman v. Oakcrest Dental Center P.C., 480 F.3d 791, 805 (6th Cir. 2007)("the purpose underlying Rule 408 . . . is the promotion of the public policy favoring the compromise and settlement of disputes that would otherwise be discouraged with the admission of such evidence"); Bankcard America, Inc. v. Universal Bancard Systems, Inc., 203 F.3d 477, 483 (7th Cir. 2000)("Because settlement talks might be chilled if such discussions could later be used as admissions of liability at trial, the rule's purpose is to encourage settlements"); In re A.H. Robins Co., Inc., 197 B.R. 568, 572 (E.D.Va. 1994)("Rule 408 aims to settlement discussions in an individual lawsuit, and therefore insulates the particular parties to a settlement discussion from possible adverse consequences of their and open statements"). So crucial is this policy of confidentiality to the functioning of our federal court system that some courts have held that communications falling within the parameters of Rule 408 are covered by a settlement privilege which insulates them not just from admission into evidence but from discovery as well. See, Lg, Goodyear Tire & Rubber Co. v. Chiles Power Supply, Inc., 332 F.3d 976, 979-983 (6th Cir. 2003). + +Given the powerful and long-standing policy of according confidentiality to settlement negotiations in both the civil and criminal context, civil plaintiffs should, at a minimum, be required to demonstrate real and concrete need for the material. They should not be permitted to rummage through such sensitive documents based on nothing more than a vague and contentless statement that the materials are "likely to lead to the discovery of other admissible evidence." Motion to Compel at 12 n.3, which is all that plaintiff offers as to Request No. 10. This is + +Page No. 10 + +particularly so given the reality that parties often take positions or offer potential compromise solutions during plea negotiations which are inconsistent with the litigation strategy they will pursue if the case goes to trial. As one court has explained in the civil context: + +There exists a strong public interest in favor of secrecy of matters discussed by parties during settlement negotiations. . . . The ability to negotiate and settle a case without trial fosters a more efficient, more cost-effective, and significantly less burdened judicial system. . . . Parties must be able to abandon their adversarial tendencies to some degree. They must be able to make hypothetical concessions, offer creative quid pro quos, and generally make statements that would otherwise belie their litigation efforts. + +Goodyear Tire, 332 F.3d at 980. The same is no less true in the plea negotiation context particularly where a central component of the discussions and negotiations between counsel for Epstein and counsel for the USAO was to reach an agreement on conditions relating to 18 USC 2255 including certain waivers and other obligations of Epstein's NPA. The plaintiffs have contended that such provisions relating to 2255 are civil in nature, thus squarely implicating FRE 408 protections. The free availability in discovery to civil plaintiffs of communications made during the plea negotiation process has profound potential to chill and open communications during that process so crucial to the functioning of the criminal justice system in any criminal case which has potential to become a civil or regulatory matter as well. Such defendants will be loath to be fully forthcoming during plea discussions or communications and indeed, if the potential civil or regulatory consequences are sufficiently severe, may decline to enter into plea negotiations at all, if they must fear that their communications will be made available to civil plaintiffs in discovery, thus entirely defeating both the purpose and spirit of Rules 410 and 11(f). + +In addition, the communications made during the plea negotiation process contain fact and opinion attorney work product of both Mr. Epstein's attorneys and government attorneys. Particularly given the strong public policy in favor of confidentiality of plea/settlement + +Page No. 11 + +negotiations, the disclosure of such information should be treated as falling within the selective waiver provisions of Fed. R. Evid. 502 and not be treated as an open-ended waiver of the attorney-client and work product privileges, and, if the discovery order is upheld as to request 10 a request for an order pursuant to FRE 502(d) mandating that the communications that led to the execution of a Non-Prosecution Agreement and communications regarding its implementation should be, to the extent they involve fact or opinion work product, not disclosed to third parties in civil litigation outside the criminal proceedings to which they relate. FRE 502(D) provides: ". . . a Federal court may order that the privilege or protection is not waived by disclosure connected with the litigation pending before the court - -in which event disclosure is also not a waiver in any other Federal or State proceeding." + +The correspondence in question contained what would constitute paradigm opinion work product with the single caveat that the opinions of each counsel, Epstein's and the United States Attorney's were exchanged with each other pursuant to the overall expectation that they were safeguarded from disclosure by the policies of confidentiality that protect communications during settlement and plea negotiations. The requested communications include the views of Epstein's counsel in the criminal case regarding why a federal prosecution was inappropriate, why the federal statutes did not fit the alleged offense conduct, why certain of the alleged victims were not credible. It also includes Epstein's counsel's views on the limits and inapplicability of certain elements of 18 U.S.C. §2255, one of the principal causes of action in the Jane Doe cases. This opinion work-product should not be disclosed when it was incorporated into heartland plea negotiations that are accorded protection under the federal rules of evidence. It is the disclosure of such legal opinions — and not just their admissibility — that should be protected from a civil + +Page No. 12 + +discovery request that lacked any statement as to why this information was even necessary to the fair litigation of the civil cases. + +Concomitantly, to the extent that the request is now limited to communications from the Government to Epstein, see DE 54, pgs 3 and 8, the narrowed request implicates the same concerns for the opinions, the work product, and the expectation of privacy of the United States Attorney or Assistant United States Attorney who authored the many letters received by counsel for Epstein. As such, to the extent that the Court is considering affirming any part of the Magistrate-Judge's opinion allowing request 10 that would result in the required disclosure of communications from the Government counsel to Epstein, that notice be provided to the United States Attorney so they may intervene to protect their opinion work product, assert their rights to confidentiality under FRE 408 and 410, and assert where appropriate their interests in grand jury secrecy and in the privacy rights of their witness who in at least one document are identified. The defendant requests that if the Court were considering allowing the disclosure of any portion of the communications sent by Epstein to the Government which are within the original request for production but apparently not plaintiff's latest filing, DE 354, pg 3, the Court first consider permitting the defendant to provide a privilege log that would identify specific portions of the correspondence that contains the opinion work product of counsel for Epstein and permitting leave to seek an order under FRE 502(d) that would protect such communications from disclosure to third parties such as requested in this matter. + +If the USA() cannot be compelled to release its investigation(s) and related work-product directly due to the protections of Fed. R. Crim. Pro. 6, Epstein cannot be compelled to disclose same in violation of his constitutional rights? He cannot. Rules 408, and 410 all counsel strongly against the discoverability of such documents. The court is requested to reverse the + +Page No. 13 + +Magistrate-Judge's order as to paragraph 10. Alternatively, the Court is requested to permit a privilege log that would be filed by Epstein's counsel — and if they so desire the Government particularizing the prejudice to their work product and to the values otherwise protected by FRE 408 and 410 on a document by document basis. + +Epstein also continues to maintain that the requested correspondence is protected under the Fifth Amendment, as it could furnish a link in the chain of evidence needed to prosecute him for a crime or provide the federal government with information that provides a lead or clue to evidence having a tendency to incriminate Epstein. See infra; Hoffman v. United States 341 U.S. at 486; United States v. Neff, 315 F.2d at 1239; Blau v. United States, 340 U.S. at 159; and SEC v Leach, 156 F.Supp.2d at 494. + +As this court has recognized, the threat of criminal prosecution is real and present as Epstein remains under the scrutiny of the USAO, which is explained and/or acknowledged in the Court's Orders (DE 242, p.4 and 462, p.2). As this Court knows, Epstein entered into a Non-Prosecution Agreement ("NPA") with the USAO for the Federal Southern District of Florida . However, the NPA does not provide Epstein with any protection from criminal investigation or prosecution other than in the Southern District of Florida. As the court has acknowledged in its orders (e.g., DE 462), complaints in these related matters allege that Epstein both resided in and allegedly engaged in illegal sexual conduct in districts outside the Southern District of Florida, and that he allegedly lured economically disadvantaged girls to homes other than in Palm Beach. Thus, the fact that there exists a NPA does not mean that Epstein is free from a reasonable fear of future criminal prosecution. In fact, this court acknowledged that "[t]he danger Epstein faces by being forced to testify in this case is substantial and real, and not merely trifling or imaginary as required." (DE 242, p. 10). + +As such, in the event Epstein is required to produce information provided to him by the federal government — or provided by Epstein to the Government - that information could provide a link in the chain of evidence needed to prosecute Epstein of a crime outside the protections of the NPA. Given the nature of the allegations, to wit, a scheme and plan of sexual misconduct, this court should find it entirely reasonable for Epstein to assert his Fifth Amendment privilege as to request Number 10, especially since it is broad enough to encompass information that could violate Epstein's Fifth Amendment Privileges. Hubbell, supra. In responding to the request, Epstein would be compelled admit that such documents exist, admit that the documents were in his possession or control, and further admit that the documents produced were authentic. In other words, the very act of production of the category of documents requested would implicitly communicate "statements of fact." as well as authenticate the letters as genuine examples of communications that include disclosures made by Epstein's attorney i.e., his agent on his behalf, see Hubbell,supra; Hoffman,supra. + +The defendant requests that the Court order that the documents in question are protected by FRE 408 and 410, that if not they should be subject to a "selective waiver" order under FRE 502(d) given their inclusion of attorney opinion and fact work product that was only disclosed in reasonable expectation they would be solely used to further plea and settlement discussions. o the extent this court orders production of any of the requested materials, the information should first be produced in camera to determine what portions of the materials should be redacted to protect the attorneys' mental impressions and to assist the Court in making further determinations as to what information , should be protected by Federal Rules 408, 410, and 502. See supra. Again, as set forth in the Reply attached hereto as Exhibit "B", the USAO and the + +Palm Beach State Attorneys' Office should be put on notice that their underlying files are being requested by and through backdoor methods. + +### (b) Plaintiffs' Attorneys Already Have Much Of The Information They Seek Pursuant To This Improper Motion Practice And Have No Demonstrable Need For More + +Several depositions have occurred over the last 4 weeks wherein it appears Mr. IM already has the information he seeks responsive to these requests, which is likely the reason Mr. has not filed any affidavits supporting the specious arguments set forth in Plaintiff's Motions. As such, there is no substance or factual representations made by Plaintiff to support her argument. Plaintiff is wasting attorney time and judicial resources in her effort to obtain what she already has in her possession. For example, at a deposition of Mr. Epstein on February 17, 2010, the following exchange occurred: + +> Mr. The 87-page Palm Beach Police Department incident report where there are numerous underage females describing their interaction with Mr. Epstein at his house. I'm specifically reading from page 41 related to A.H., who was one of the victims he pled guilty to. + +> Mr. Pike: Is that the same document that you're seeking production of, in this same exact case? + +> Mr. I don't know what you're talking about. This is something from the state attorneys' file. + +It is clear from Mr. response above (attached as Exhibit "C") that he has the information from the Palm Beach Police Department and the information from the State Attorneys' file. This begs the question — if plaintiff already has the information she seeks, why is Plaintiff wasting valuable attorney time and judicial resources to obtain what is already in hand? See also Exhibits "D-1" and "D-2" and "E," a copy of the 89-page incident report marked as an Exhibit by Plaintiff's counsel at Detective Recarey's deposition as well as certain message pads Plaintiff claims was pulled from the residence at 358 Brillo Way. + +Page No. 16 + +Moreover, at the deposition of AR on March 15, 2010, the following exchange occurred: + +Mr. Well, at some point in time what's been marked as defense Exhibit "1", you received a grand jury investigation target letter, correct? + +\*Si + +Mr. There's another message from 9/11/05 saying "I got a car for," and then the name is blotted out. The State Attorneys' Office blotted the names of minors out sometimes in their file. . . . + +\*\*It + +Once again, Mr. MMIresponse above (attached as Exhibit "F") establishes that he has the information from both the Palm Beach Police Department and the State Attorneys' file. In fact, as argued infra, Mr. IM has certain information from the Palm Beach Police Department, which resulted from various alleged "trash pulls" from a residence on Palm Beach (e.g., certain notepads). + +Finally, at the deposition of Detective Recarey of the Palm Beach Police Department, on March 19, 2010, the following exchange occurred: + +Mr. Kuvin: Okay. And what were the dates of the surveillance? + +Witness: [Referencing his Report] It appears she met with members of the B.S.F. unit, Burglary Strike Force. . . . + +\*\*\* + +Mr. Kuvin: [Referencing the Report] If we go down to page 40 in your report, first let me back up. . . . + +Mr. Kuvin: Okay. So the chain of custody which we have marked as Exhibit 5 shows that all the evidence you had in this case was given to the FBI. . . . Sm Exhibit "G". + +The undersigned was at Detective Recarey's deposition. Mr. Kuvin and Mr. had copies of various reports and also had copies of various message pads claimed to be "pulled" from Epstein's trash by the Palm Beach Police Department. See infra. It is clear from the + +Page No. 17 + +deposition that opposing counsel has the information from the Palm Beach Police Department and the State Attorneys' file. See also, infra for additional argument. + +# (i) Work-Product — Palm Beach State Attorneys' File + +Next, as to any information obtained from the State Attorney at any phase (request numbers 801), the State Attorney has not provided anything to Epstein or his attorneys. While the State Attorneys' file was made available for inspection, Jack Goldberger, Epstein's criminal lawyer, went over to the State Attorneys' Office and hand selected information from the file for copying, including certain witness interviews. See Exhibit "H" Affidavit of Jack Goldberger. Accordingly, the information hand selected by Mr. Goldberger falls under the work-product doctrine as production of same would reveal Mr. Goldberger's mental impressions, thought processes and strategy relative to the defense of Epstein. v. Florida Power & Light Company, 632 So.2d 696, 698 (Fla. 3rd DCA 1994)(even if individual documents are not workproduct, "the selection process itself represents defense counsel's mental impressions and legal opinions as to how the evidence in the documents relates to the issues and the defenses in the litigation"). Id. The information simply falls under the "highly protected category of opinion work-product." Id; see also Fla.R.Civ.Pro. 1.280. + +Also, Counsel for Jane Does 2-8 in the Federal companion cases apparently obtained a copy of the file retained by the Palm Beach State Attorneys' Office. It is reasonably believed that all Plaintiffs' attorneys in this action have extensive materials from the State Attorney and the Palm Beach Police Department pursuant to various public records requests. Certainly, Mr. + +Page No. 18 + +is able make such public records requests or can subpoena the requested information, neither of which would implicate the work product privilege as outlined above. + +Here, the standard is a showing of a need to obtain the information, and the inability to obtain the substantial equivalent without undue hardship. Metric Engineering, Inc. v. Small, 861 So. 2d 1248, 1250 (Fla. 1st DCA 2003)(To show `need,' a party must present testimony or evidence demonstrating the material requested is critical to the theory of the requestor's case, or to some significant aspect of the case); Ashemimry v. Ba Nafa, 847 So.2d 603 (Fla. 5th DCA 2003). In addition, Florida Rule of Civil Procedure 1.280(13)(3), does allow discovery of fact work product where the requesting party can show need and the inability to obtain the substantial equivalent by other means without undue hardship. Vesta Fire Ins. Corp. v. M, 821 So.2d 1233, 1234 (Fla. 5th DCA 2002)(the showing of need and undue hardship necessary to overcome the work product immunity must include specific explanations and reasons). Again, Mr. fails to submit any affidavit or any other document meeting the above criteria. + +Additionally, this court should consider placing the Palm Beach State Attorney and the USAO on Notice that their investigative files are being requested. Since Plaintiff seeks information given by federal government and the state attorney to Epstein, including correspondence, Epstein reincorporates the arguments set out in his initial Rule 4 Appeal as that information is within the penumbra of the protections of Federal Rules of Evidence 408 and 410. Moreover, despite Plaintiff's contention, Federal Rule of Evidence 410 is applicable because negotiations did not end with a federal plea. Furthermore, Federal Rule of Evidence 408 is applicable given that 18 U.S.C. 2255 is quasi-civil remedy. Clearly, the information sought by Plaintiff has no evidentiary value - given that Plaintiffs have the raw materials and police reports and affidavits resulting from state investigation. Accordingly, there is a chance that the Palm + +Beach State Attorney and the USAO may not want to disclose their files for one reason or another. + +# (ii) Third Party Privacy Rights And Judge Jeffrey's Colbath's Order + +The Magistrate's Order does not consider the privacy rights of other alleged victims. As this Court knows, attached to the NPA is a list which delineates alleged victims. Once the NPA was made public, Judge Colbath, with the agreement of the Palm Beach Post, Brad Esq. and Spencer Kuvin, Esq. agreed that the "list" would remain private. As such, Request for Production Numbers 7, 9 and 10 seeks information that may violate others third-party privacy rights in that certain names may be mentioned in correspondence, including those on the "list." As noted in Eisenstadt v. Baird, 405 U.S. 438, 454, 92 S.Ct. 1029, 1038, at fn. 10 (1972): + +In Stanley, 394 U.S., at 564, 89 S.Ct., at 1247, the Court stated:'(A)Iso fundamental is the right to be free, except in very limited circumstances, from unwanted governmental intrusions into one's privacy." The makers of our Constitution undertook to secure conditions favorable to the pursuit of happiness. They recognized the significance of man's spiritual nature, of his feelings and of his intellect. They knew that only a part of the pain, pleasure and satisfactions of life are to be found in material things. They sought to protect Americans in their beliefs, their thoughts, their emotions, and their sensations. They conferred, as against the Government, the right to be let alone-the most comprehensive of rights and the right most valued by civilized man.' [Citations omitted]. + +The fundamental right of privacy is not only guaranteed under by the Fourteenth Amendment of the United States Constitution, but also under the Constitution of the State of Florida, Art. I, Sect. 23. As summarized by the Florida Supreme Court in Shaktman v. State, 553 So.2d 148, 150-51 (Fla. 1989): + +The right of privacy, assured to Florida's citizens, demands that individuals be free from uninvited observation of or interference in those aspects of their lives which fall within the ambit of this zone of privacy unless the intrusion is warranted by the necessity of a compelling state interest. In an opinion which predated the adoption of section 23, the First District aptly characterized the nature of this right. + +> A fundamental aspect of personhood's integrity is the power to control what we shall reveal about our intimate selves, to whom, and for what purpose. + +> Bryon, Harless, Schaffer, Reid & Assocs., Inc. v. State ex rel, Schellenberg, 360 So.2d 83, 92 (Fla. 1st DCA 1978), quashed and remanded on other grounds, 379 So.2d 633 (Fla.1980). Because this power is exercised in varying degrees by differing individuals, the parameters of an individual's privacy can be dictated only by that individual. The central concern is the inviolability of one's own thought, person, and personal action. The inviolability of that right assures its preeminence over "majoritarian sentiment" and thus cannot be universally defined by consensus. + +(Emphasis added). + +Clearly, the nature of the question would require Epstein to produce information that may identify third parties (including alleged victims), which would necessarily thwart such individuals' rights to assert their constitutional right of privacy as guaranteed under the United States and Florida Constitutions. See generally Eisenstadt v. Baird, supra at 454-455 (the right encompasses privacy in one's sexual matters and is not limited to the marital relationship). The Magistrate's Order did not address this issue. + +Federal law provides crime victims with rights similar to those afforded by the Florida constitution which includes, but is not limited to, "the right to reasonable, accurate, and timely notice of any pubic court. . .proceeding involving the crime. . . . ," "the right not to be excluded from any public court proceeding. . . . ," and "the right to be heard." 15 Fla. Jur.2d Crim.Proc. §1839; Fla. Stat. 960.0021. Based upon the foregoing, any alleged victim that may be identified in any of the requested information must first be notified, which means that this court must, at the very least, conduct an in camera inspection of any and all information to determine which alleged victim must be placed on notice that their identity may be revealed or redact their names in camera. Ss& also Fla. Stat. §794.03, §794.024 and §794.026. The right to privacy encompasses at least two different kinds of interests, the individual interests of disclosing + +Page No. 21 + +personal matters and the interest in independence in making certain kinds of important decisions. + +Favalora v. Sidaway, 966 So.2d 895 (Fla. 4th DCA 2008). + +Accordingly, based on the facts and circumstances of this case, and under applicable law, Defendant's assertion of the protections afforded under the 5th, 6th, and 14th Amendments of the United States Constitution are required to be upheld. In addition, this Court must address the privacy rights of others as outlined above. + +### c. Jane Doe - Request Numbers 12 and 13 + +Request No. 12: Personal tax returns for all years from 2002 through the present. + +Request No. 13: A photocopy of your passport, including any supplemental pages reflecting travel to locations outside the 50 United States between 2002 and 2008, including any documents or records regarding plane tickets, hotel receipts, or transportation arrangements. + +Response to Request Numbers : Defendant is asserting specific legal objections to the production request as well as his U.S. constitutional privileges. I intend to produce all relevant documents regarding this lawsuit, however, my attorneys have counseled me that at the present time I cannot select, authenticate, and produce documents relevant to this lawsuit without waiving my Fifth Amendment constitutional rights and I must accept this advice or risk losing my Sixth Amendment right to effective representation. Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an adverse inference under these circumstances would unconstitutionally burden my exercise of my constitutional rights, would be unreasonable, and would therefore violate the Constitution; overly broad. + +As set forth in more detail in DE 282 and 283, which were provided to the court in camera and which the court considered in other Rule 4 Appeals, Epstein cannot provide answers/responses to questions relating to his financial history and condition without waiving his Fifth, Sixth, and Fourteenth Amendments. Asking for Epstein's personal tax returns is financial in nature and it is confidential, proprietary and seeks information much of which is neither relevant to the subject matter of the pending action nor does it appear to be reasonably calculated + +to lead to the discovery of admissible evidence. Importantly, the Magistrate did not make a ruling on relevancy as to the personal tax returns, and the Plaintiff has not met the burden of establishing a "compelling need" for the tax returns. + +Producing the specified information, in full, would result in testimonial disclosures that would communicate statements of fact and would require Epstein to produce the returns and thereby "stipulate" to their genuiness, their existence, his control of the records, and their authenticity as his executed tax returns even though his possession of such records are by no means a foregone conclusion. Again, the information sought relates to potential federal claims violations. See DE 282 and 283, in camera, which the court permitted sua sponte. Production would therefore constitute a testimonial admission of the genuineness, the existence, and Epstein's control of such records, and thus presents a real and substantial danger of selfincrimination in this case, in other related cases and as well in areas that could result in criminal prosecution. See generally Hoffman v United States, 341 U.S. at 486; United States v. Hubbell, 530 U.S. at 36 and United States v. Apfelbaum, 445 U.S. at 128. + +The Court's order seems to hone in on the "required records" exception for the proposition that, as a matter of law, Epstein's personal tax returns must be produced because they are allegedly a mandatory part of a civil regulatory scheme and have assumed some public aspect. (DE 462, p.12) However, "required records" are ordinarily records collected by highly regulated business (e.g., physicians) wherein the records themselves have assumed public aspects which render them analogous to public documents. See In re Dr. John Doe, 97 F.R.D. 640, 641- 643 (S.D.N.Y. 1982). Usually, these documents are known to more than the filer and the agency in which the document(s) were filed (i.e., known to other persons of the general public). Id. Even though the IRS may have certain returns, they remain confidential under 26 U.S.C. §6103 + +from any disclosures and are therefore different than a regulated/public record that can be accessed by the public. In Trudeau v. New York State Consumer Protection Bd., 237 F.R.D. 325 (N.D.N.Y. 2006), the court maintained that "[r]outine discovery of tax returns is not the rule but rather the exception." Id. at 331. The Court went on to note that [for nearly the past thirty-five years, tax returns have been considered `confidential,' pursuant to 26 U.S.C. §6103." Id. Because of the principle of confidentiality, it further noted, "courts in the Second Circuit have found personal financial information to be presumptively confidential or cloaked with a qualified immunity," and must, therefore, "balance the countervailing policies of liberal discovery set forth in the Federal Rules of Civil procedure against maintaining the confidentiality of such documents." Id. + +To achieve that balance, courts in the Second Circuit have developed a "more stringent" standard than that set forth in the rules. To order disclosure of tax returns, a court must find that "the requested tax information is relevant to the subject matter of the action" and that "there is a compelling need for this information because the information contained therein is not otherwise readily available." Id. The Magistrate's Order makes no such finding in the instant matter. In fact, the burden of showing compelling need is on the party seeking discovery, but once a compelling need has been found, the party whose tax return information has been requested has the burden to "provide alternative sources for this sensitive information. Id. If the requested information is available from alternate sources, disclosure should not be compelled. Potential alternate sources to which the court pointed were gathering the information through deposition or disclosure in an affidavit by the requested party of net worth, wealth, and income. Id. at 331-32. See Barton v. Cascade Regional Blood Services, 2007 WL 2288035 (W.D.Wash. 2007)("Tax returns are confidential communications between the taxpayer and the government [citing + +§6103] and although not privileged from discovery there is a recognized policy against unnecessary public disclosure The Court finds no compelling need which overcomes this recognized policy"). Courts have broadly construed these provisions to embody a general federal policy against indiscriminate disclosure of tax returns from any source. Federal Say. & Loan Ins. Corp. v. Krueger, 55 F.R.D. 514-15 (N.D. Ill. 1972)("it is the opinion of this court that [§6103] reflect[s] a valid public policy against disclosure of income tax returns. This policy is grounded in the interest of the government in full disclosure of all the taxpayer's income which thereby maximizes revenue. To indiscriminately compel a taxpayer to disclose this information merely because he has become a party to a lawsuit would undermine this policy"); Kg also Premium Service Corp. v. Sperry & Hutchinson Co., 511 F.2d 225, 229 (9th Cir. 1975)(would have been appropriate for district court to quash subpoena for tax returns based on the "primacy" of the "public policy against unnecessary disclosure [of tax returns] arises from the need, if tax laws are to function properly, to encourage taxpayers to file complete and accurate returns"). + +In Pendlebury v. Starbucks Coffee Co., 2005 WL 2105024 at \*2 (S.D. Fla. 2005), the court agreed that "[i]ncome tax returns are highly sensitive documents" and that courts should be reluctant to order disclosure during discovery. Citing, Natural Gas Pipeline Co. of Am. v. Energy Gathering, Inc., 2 F.3d 1397, 1411 (5th Cir. 1993); DeMasi v. Weiss. Inc., 669 F.2d 114, 119-20 (3d Cir. 1982)(noting existence of public policy against disclosure of tax returns); Premium Serv. Corp. v. Sperry & Hutchinson Co., 511 F.2d 225, 229 (9th Cir. 1975). The court in Pendlebury agreed that parties seeking the production of tax returns must demonstrate (1) relevance of the tax returns to the subject matter of the dispute and (2) a compelling need for the tax returns exists because the information contained therein is not otherwise available. Id. at \*2; see also Dunkin Donuts, Inc. v. Marv's Donuts, Inc., 2001 WL 34079319 (S.D. Fla. 2001); + +Page No. 25 + +v. HaHearten & Co., 34 F.R.D. 482, 483-84 (S.D.N.Y. 1964). Thus, before the Court can order production of the requested returns in this matter, the Plaintiff must satisfy the "relevance" and "compelling need" standards. The Magistrate's Order fails to address the "relevancy" standard and Plaintiff fails to provide same with supporting argument and case law, and the Plaintiff fails to delineate any "compelling need" or availability of net worth from other sources (e.g., a stipulation as to net worth, which is certainly an alternative means). To the extent that the Court determines that the tax returns are relevant and that there is a compelling need for at least their disclosure of Epstein's wealth for punitive damage purposes, Epstein through his attorneys, as per the discussion at the status conference on May 7, 2010, agreed to a confidential stipulation that his net worth is in excess of nine figures. Such a stipulation more than satisfies any necessity for the disclosure of the tax returns or any additional net worth information. See e.g., Myers v. Central Florida Investments, Inc., 592 F.3d 1201 (l i th Cir. 2010)(reasoning that a compensatory award of \$103,622.09 and a punitive damage award of \$506,847.78 for 5 years of sexual harassment and sexual touching was reasonable). Unfortunately, the parties were unable to reach a agreement. + +Myers clearly demonstrates that Epstein's offer to agree to a net worth in excess of \$50,000,00 is reasonable in light of the allegations made by Jane Doe as compared to the allegations in Myers. Moreover, allowing such discovery at this juncture goes against the grain and the law in that Plaintiff has not made a reasonable showing establishing that she will recover on her claims or that if she did such a compensatory damage recovery could possible implicate punitive damages in excess of Epstein's offer to stipulate.. v. Estaleiro Itaiai S/A. 541 F.Supp.2d 1344. 1357 (S.D. Fla. 2008)(The court cannot apply Rule 26 and allow Plaintiff to obtain discovery she seeks without any prior showing of a reasonable basis for recovery). See + +Page No. 26 + +also Fed.R.Civ.P. 26(b)(1) and Fla. Stat. 768.72; Gallina v. Commerce And Industry, Ins., 2008 WL 3895918 (S.D. Fla. 2009)(unless liability for punitive damages is established at trial, the discovery sought is not relevant). + +In Gallina the court held that in light of the proprietary of the financial worth information sought, and the statutory protections against discovery of such information, it was recommended that the court defer financial discovery until it is deemed necessary and that production of such financial information not occur until the ". . . final pretrial conference. . . or when it becomes apparent that punitive damages can be awarded." Id. at \*5. Since bifurcation is required in the instant matter, W.R. & Company v. Waters 638 So.2d 502 (Fla. 1994), it is reasonable and consistent with the applicable law, that any tax returns not be produced until such time as it becomes apparent at the first stage of the trial that punitive damages will be an issue. + +To the extent this court orders production of tax returns and to the extent Epstein's personal tax returns contain such information, same should be redacted and subject to heightened confidentiality order pursuant to the court's previous orders. However, this can only be done subsequent to an in camera hearing wherein this court can make a ruling on relevancy, production, redaction and confidentiality; but only after the Plaintiff shows a compelling need. In addition, for the reasons outlined herein including, but not limited to, the discovery abuses and bad faith litigation tactics that Epstein has been the subject of at the hands of Scott Rothstein and his-co-conspirators, any tax returns must be redacted to preserve confidently and to prevent further abuses. See supra. + +Further, Epstein's complicated business transactions have no relevancy to this lawsuit and, therefore, evidence of same should not be produced. The Fifth Amendment is a safe harbor for all citizens, including those who are innocent of any underlying offense. This request, if + +answered, may result in compelled production and/or testimonial communications from Epstein regarding his financial status and history and would require him to waive his right to decline to respond to other inquiries related to the same subject matter. Responding to this and other related inquiries would have the potential to provide a link in a chain of information and/or leads to other evidence or witnesses that would have the specific risk of furthering an investigation against him and therefore are protected from compulsion by Epstein's constitutional privilege. + +Accordingly, any compelled testimony that provides a "lead or clue to a source of evidence of such [a) crime" is protected by Fifth Amendment. SEC v Leach, 156 F.Supp.2d at 494. Questions seeking "testimony" regarding names of witnesses, leads to phone or travel records, or financial records that would provide leads to tax or money laundering or unlicensed money transmittal investigations are protected. les also Hoffman v United States, 341 U.S. 479, 486 (1951)("the right against self-incrimination may be invoked if the answer would furnish a link in the chain of evidence needed to prosecute for a crime"). + +Based upon the above admissions, it is clear that Plaintiff now seeks information that may provide a link in the chain of evidence used to prosecute Epstein including, but not limited to the significant fact that target letters and subpoenas were issued relating to certain financial offenses. See Lg., DEs 282 and 283 submitted in camera and U.S. v. Zolin, 491 U.S. 554 (1989)(disclosing materials to the district court does not have the legal effect of terminating a privilege thereby allowing parties to disclose documents in camera and make that in camera request — which request is made in the instant Rule 4 Appeal for which Defendant is awaiting the court's response). As a result, DEs 282 and 283 (in camera) and other related Orders must be analyzed to reach the correct legal conclusion. The court must be cognizant of the allegations in + +the related cases regarding sexual misconduct with and abuse, exploitation, and sexual battery of alleged minors. For example: + +In this and the other civil actions, the Plaintiffs reference federal and state criminal statutes in an attempt to allege claims ranging from sexual battery to intentional infliction of emotional distress, to a violation of 18 U.S.C. 2422, Chapter 117 – “Transportation for Illegal Sexual Activity and Related Crimes,” to a cause of action pursuant to 18 U.S.C. §2255 – which creates a civil remedy for personal injuries where a plaintiff can show a violation of specified criminal statutes. Most importantly, the lynchpin for the exercise of federal criminal jurisdiction under 18 U.S.C. 2422(b) is the use of “any facility or means of interstate or foreign commerce”. Thus, facially, an essential condition of any allegation of this statutory offense is the use of a facility of interstate commerce during which use there was persuasion, inducement, enticing, or coercing of an underage person to engage in prostitution or sexual activity. As more fully discussed, infra, contested request numbers 12 asks that Epstein to make a testimonial disclosure of information regarding the availability to him of such interstate facilities (e.g., the tax returns could list assets such as planes) and thus would constitute a link in the chain of evidence that could potentially expose him to the hazards of self-incrimination as to 18 U.S.C. 2423(b) violations. Likewise, other Jane Does have contended that they are entitled to 18 U.S.C. 2255 damages based on Epstein’s violation of 18 U.S.C. 2423(b) a separate federal criminal statute that prohibits “a person who travels in interstate commerce or travels into the United States...for the purpose of engaging in illicit sexual activity”. As more fully discussed, infra, contested request number 13, by seeking testimonial disclosures regarding Epstein’s passport and dates Epstein traveled to and from the State of Florida, would constitute a link in the chain of evidence that could potentially expose him to the hazards of self-incrimination as to 18 U.S.C. 2423(b) violations. + +Both 18 U.S.C. 2422(b) and 18 U.S.C. 2423(b) were amongst the target offenses of a joint FBI-United States Attorney investigation further demonstrating the extent to which Epstein’s refusal to respond to each request is, as required, based on a specific apprehension of a compelled disclosure providing a link in the chain of evidence adverse to him as required by Hoffman v United States, 341 US 479, 486 (1951). Epstein, in fact, can deny the occurrence of the assaults alleged and still maintain the safe harbor of the 5th Amendment.2 See Ohio v. Reiner, 532 U.S. 17 (1991). + +2 See DeLisi v. Bankers Ins. Company, 436 So.2d 1099 (Fla. 4th DCA 1983); Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964) (the Fifth Amendment’s Self-Incrimination Clause applies to the states through the Due Process Clause of the Fourteenth Amendment - “[i]t would be incongruous to have different standards determine the validity of a claim of privilege based on the same feared prosecution, depending on whether the claim was asserted in state or federal court.”); 5 Fed. Prac. & Proc. Civ. 3d §1280 Effect of Failure to Deny – Privilege Against Self-Incrimination (“...court must treat the defendant’s claim of privilege as equivalent to a specific denial.”). See also 24 Fla.Jur.2d Evidence §592. Defendants in civil actions. – “... a civil defendant who raises an affirmative defense is not + +Plaintiffs also allege that Epstein had a plan and scheme (which) reflected a particular pattern and method" in the alleged recruiting of girl's to come to Epstein's Palm Beach mansion and give him "massages" in exchange for money. Plaintiffs also allege that Epstein "sexually assaulted" them, and that Epstein "maintains his principal home in New York and also owns residences in New Mexico, St. [REDACTED]'s and Palm Beach, FL." They further allege "Upon information and belief, Jeffrey Epstein carried out his scheme and assaulted girls in Florida, New York and on his private island, known as Little St. James, in St. [REDACTED]." The nature of the allegations are serious, and state clearly that the alleged assaults occurred in Florida, New York and in St. [REDACTED]. See e.g., Second Amended Complaints of Jane Does 2-8. and DE 485, p.18. + +As this Court knows, Epstein entered into a Non-Prosecution Agreement ("NPA") with United States Attorney's Office for the Federal Southern District of Florida. The terms and conditions of the NPA also entailed Epstein entering into a Plea Agreement with the State Attorney's Office, Palm Beach County, State of Florida. By its terms, the NPA took effect on June 30, 2008. As well, pursuant to the NPA, any criminal prosecution against Epstein is deferred as long as the terms and conditions of the NPA are fulfilled by Epstein. The federal grand jury investigation against Epstein is held in abeyance i.e. it is not concluded with finality until the NPA expires by its terms in late 2010 and as long as the USAO determines that Epstein has complied with those terms and conditions. The threat of criminal prosecution against Epstein by the USAO continues presently and through late 2010. The USAO possesses the right to declare that the agreement has been breached, give Epstein's counsel notice, and attempt to move forward with the prosecution. Moreover, the NPA does not provide Epstein with any protection from criminal investigation or prosecution in any federal district other than the Southern District of Florida. The Second Amended Complaints and Plaintiff Response at DE 485, p.18 include averments that Epstein both resided in and engaged in illegal sexual conduct in districts outside the Southern District of Florida. In other words, the fact that there exists a NPA does not mean that Epstein is free from future criminal prosecution, which the Magistrate Judge's Order also acknowledged. (DE 242, p.4) In fact, the Order acknowledged that "[t]he danger Epstein faces by being forced to testify in this case is substantial and real, and not merely trifling or imaginary as required." (DE 242, p. 10). For the reasons set forth in Epstein's Rule 4 Appeal and herein, that same ruling should be reached relative to Request Numbers 12 and 13 given the close nexus between the information requested and the pivotal jurisdictional requisites of 18 U.S.C. 2423(b)(the requirement of interstate travel i.e. travel from one of Epstein's out of state residences to Florida or from Florida to one of such residences. + +--- + +precluded from asserting the privilege [against self-incrimination], because affirmative defenses do not constitute the kind of voluntary application for affirmative relief" which would prevent a plaintiff bringing a claim seeking affirmative relief from asserting the privilege. + +Page No. 30 + +Accordingly, it is clear that Plaintiff and her counsel seek this information not to further their civil case, but to gain information to aid in the future prosecution of Epstein in direct violation of his Fifth Amendment rights. In fact, the Mermelstein and Horowitz firm was quoted in the Palm Beach Post stating, among other things, that the book sold to undercover agents could open the door to future prosecution of Epstein. As such, Plaintiffs' counsels' intention is clear — to use the civil discovery process to attempt to further prosecute Epstein. See httn:lliessicaarbour.blogspot.com/2010/03/horowitz-discusses-possibility-othtml. Moreover, Mr. himself admitted at his own deposition to repeated disclosures to a variety of media outlets including, but not limited to, the NY Post and Vanity Fair. Accordingly, Epstein's 5'h Amendment rights in this regard should be sustained. + +Furthermore, as set forth in a Civil Complaint attached hereto as Exhibit "I" attorney Scott Rothstein aided by other lawyers and employees at the firm of Rothstein, Rosenfeldt, and Adler, P.A., deliberately engaged in a pattern of racketeering that involved a staggering series of gravely serious obstructions of justice, actionable frauds, and the orchestration and conducting of egregious civil litigation abuses that resulted in profoundly serious injury to Jeffrey Epstein, including substantial attorneys' fees and costs. In short, Rothstein and his co-conspirators forged Federal court orders and opinions and, among other things, staged a series of depositions that were unrelated to any principled litigation purpose but instead designed to discover extraneous private information about Epstein or his personal and business associates (including well-known public figures) in order to defraud investors and support extortionate demands for payment from Epstein. The misconduct featured the filing of legal motions and the pursuit of a civil litigation strategy that was unrelated to the merits or value of their clients' cases and, instead, had as its improper purpose the furthering of Rothstein's misrepresentations and deceit to third-party + +Page No. 31 + +investors. As a result, Epstein was subject to abusive investigatory tactics, unprincipled media attacks, and unsupportable legal filings and discovery abuses. Since Plaintiff's counsel is formerly of RRA and due to the fact that certain information may contain the names of thirdparties, that information (should this court order production of same after an in camera inspection) must be redacted to secure the names of unsuspecting third-parties. Moreover, Michael Fisten (formerly an employee of RRA and now an employee/independent contractor of Mr. firm) acted, upon information and belief, as a broker or middleman who staged regular meetings during which false statements were made about the number of cases/clients that existed or RRA had against Epstein. For this reason alone, such information should be redacted in order to protect those unsuspecting third parties. + +# (1) Request Number 13 + +As to Request Number 13, Defendant provided this court with sufficient argument at DE 282 and DE 283 detailing why the production of information showing Epstein's whereabouts could provide a link in the chain of evidence regarding: (a) Epstein's air travel within the United States and Foreign Territories; (b) Epstein's communications with others relating to or referring to females coming into the United States from other countries; and (c) Epstein's personal calendars and schedules. Given that the essential proof of an allegation of 18 U.S.C. 2423(b) would include travel records, schedules regarding trips and locations, flight records, calendars, and transportation arrangements, the court found that Epstein had made a more particularized showing because producing such information "could reveal the availability to him and/or use by him of interstate facilities and thus would constitute a link in the chain of evidence that could potentially expose (Epstein] to the dangers of self incrimination." (DE 293, p.6) See infra, regarding private aircraft. + +The Magistrate's Order (DE 462) provides that Epstein's Fifth Amendment privilege does not extend to his passport because its existence is known to the government or is a "foregone conclusion." Id. at p. 11. First, the magistrate's order presupposes that Epstein has all his passports from 2002 up through to the current date and that the government has an exact copy of same. Second, the Order presupposes that U.S. Customs and Border Patrol ("CPB") keeps a record and/or has maintained records of Epstein's travel and whereabouts from 2002 up through to the current date. Third, assuming Epstein traveled internationally, the Order presupposes that the CPB has records of all of Epstein's destinations and that other countries have shared that information with the CBP. In short, the order would require Epstein to produce documents that he may or may not have 8 years of passport information thus requiring him to "admit" to the genuiness and possession of the documents produced. + +For instance, CBP now offers "Global Entry" to enter the United States by kiosk. However, it is unclear whether the Global Entry kiosk records and copies the pages of a traveler's destinations outside of the United States, or does it simply record exit from and entry back into the United States?3 Moreover, it is unclear whether CBP maintains the Sample Customs Declaration Form for any period of time, which form sets out (i.e., if filled out) the countries visited by a traveler.4 This Court cannot Compel Epstein to produce information in violation of his Fifth Amendment by simply stating that Epstein's passport is "known to the government" or is a "forgone conclusion." In fact, from the websites listed herein, any CBP documents or forms filled out by a traveler take on a complete different form when compared to an original passport, which is initially issued with blank pages. This Court would be hard- + +3 ate Lg., htto://www.customs.gov/xo/cgokravetrusred\_travelerklobal entry/ + +4 Sec e.g., htto://vnvw.customs.gov/xn/caov/traveVvacation/samnle declaration form.xml + +Page No. 33 + +pressed to find that the CBP has an exact copy of every page of every traveler's passport. Obviously, this would create more document management than CBP anticipates on its website. + +Moreover, pursuant to 19 C.F.R. §122.2, pilots of private aircraft are required to electronically transmit passenger and crew manifest information for all flights arriving into and/or departing out of the United States. As this court knows, Mr. has conducted extensive discovery, has questioned individuals as to whether Epstein owns private aircraft and has obtained certain flight manifests. Arguably, if such a procedure were followed in Epstein's case pursuant to 19 C.F.R. §122.2, then Epstein's passport would arguably take on a substantially different form when compared to the information maintained by the CBP (i.e., information that was electronically transferred). Under that circumstance, CBP would not have an exact copy of Epstein's passports. Accordingly, the assumptions made in the Magistrate's Order have serious Fifth Amendment implications in that the exact information sought is not "known to the government" and is not a "forgone conclusion" in that the government is not likely to have an exact copy of Epstein's passports. + +Again, Plaintiff's request for Epstein's passport "reflecting travel to locations outside the 50 United States between 2002 and 2008, is no different from the requests this Court has already ruled upon and sustained Epstein's Fifth Amendment privilege in response thereto. (DE 292). In summary, this court reasoned that: + +"[On this and the other civil actions, Plaintiff's allege that Epstein violated certain federal and state criminal statutes in an attempt to make claims against Epstein ranging from sexual battery to intentional infliction of emotional distress. The lynchpin for the exercise of federal criminal jurisdiction under 18 U.S.C. §2422(b), which figures in some of the complaints filed, is `the use of any facility or means of interstate or foreign commerce' and the analogous essential element of 18 U.S.C. §2423(b), which also figures in some of the Complaints, is `travel[s] in interstate commerce or travels into the United States or . . . travels in foreign commerce.' Accordingly, requiring Epstein to provide responses. . .would in essence be compelling him to provide assertions of fact, thereby admitting that + +> such documents existed and further admitting that the documents in his possession or control were authentic. + +As such, if you believe Plaintiff's footnote 4 at (DE 210), responding to this request could very well implicate Epstein's Fifth Amendment privilege. The allegations of Epstein's use of interstate commerce and travel and any compelled production is clearly a violation of Epstein's Fifth Amendment rights.5 Based upon the arguments set forth in DE 283 (which is incorporated herein), this Court sustained Epstein's Fifth Amendment Privilege. That same ruling should apply here. (DE 293). If not, this court may be requiring Epstein to produce a log of his travels, which this Court already sustained under the Fifth Amendment. + +Plaintiff must also show that the requested information is relevant to the disputed issues of the underlying action. See Young Circle Garage, LLC. v. Koppel, 916 So. 2d 22 (Fla. 4th DCA 2005); see also Equitable Life Assurance Society of the United States v. Daisy Worldwide. Inc., 702 So. 2d 263 (Fla. 3d DCA 1997). Plaintiff has failed to meet this burden and, in doing so, has also failed to show any substantial need for the documents. + +## IV. Jane Does 2-8 - Request Number 1 + +As to Request number one of Jane Doe 2-8s' request for production, it provides: + +Request No. 1: All Federal and State income tax returns, including all W-2 forms, 1099 forms and schedules, for tax years 2003-2008. + +Accordingly, for the same reasons expressed herein relative to Jane Doe's request for tax records, same should be denied. Epstein adopts and reincorporates the arguments set out above and the relief requested herein relative to Jane Doe's request for tax returns as if same was fully set forth in this section. + +Wherefore, Epstein respectfully requests that this Court issue and order: + +Once again, a ruling on these issues cannot be made in a vacuum. This court must, as it has done in the past, consider the other related cases and the allegations made therein when considering whether a response to a particular discovery requests would implicate Epstein's Fifth Amendment rights. leg DEs 242, 283 and 462. + +1. a. granting the relief requested above as to Jane Doe and Jane Does 2-8; +2. b. finding that the danger Epstein faces by being forced to testify in these cases relative to the above requests is substantial and real, and not merely trifling or imaginary; +3. c. sustaining Epstein's Fifth Amendment Privilege as it relates to the above requests and denying Plaintiffs' Motions in that regard; +4. d. reversing the Magistrate's Order (DE 462, 480 and 513) relative to Request Numbers 7, 9, 10, 12 and 13 (Jane Doe) and Request Number 1 (Jane Does 2-8) and entering an amended order sustaining Epstein's objections to the Magistrate's Order as to those specific requests and not requiring him to produce information relative to same; +5. e. sustaining Epstein's arguments as stated above and ordering that FRE Sections 408, 410 and 502 provide substantive reasoning to sustain Epstein's arguments relative to requests numbers 7, 9 and 10 including, but not limited to, the entering of an order as provided for under FRE 502(d), denying the requests as irrelevant and as barred by Fed. R. Evid. 408 and 410 and issuing a selective waiver order under Fed. R. Evid. 502(d) thereby applying the selective waiver provision of Rule 502(d) to the information exchanged between Epstein's attorneys, the USAO and the State Attorney during the criminal stage of said proceedings. Alternatively, and only to the extent this court orders production of any information, this court should put the USAO and the State Attorney on notice before any disclosure to give each entity an opportunity to raise objections to protect their work-product and attorney-mental impressions and to allow Epstein and the USAO the opportunity to submit objections and a privilege log outlining why the content of the documents sought have no relevance and should be barred from production under Fed. R. Evid. 408, 410 and 502(d). This should occur only after an in camera hearing, after this court determines what portions of the requested documents should be redacted as privileged and only after this court ensures that each and every document produced is the subject of a heightened-confidentiality order where disclosure will result in the disclosing party being held in contempt of court; +6. f. likewise, if this court rules that any of the information requested herein should be produced (e.g., Requests Numbers 12 and 13 (tax returns and passport - Jane Doe) and Request Number 1 (tax returns-Jane Doe 2-8)), it shall only do so after an in camera hearing allowing the documents to be reviewed and placed on a privilege log outlining why the content of those documents have no relevance and establishing why the danger of disclosure is more prejudicial than probative, and after this court determines what portions of the requested documents should be redacted as privileged including, but not limited to, what portions of the tax returns should be redacted due to the confidentiality interests relative to detailed information and financial tax data which was provided to the IRS within the context of the protections of 26 U.S.C. 6103. Again, the foregoing should only occur after this court ensures that each and every document + +produced is the subject of a heightened-confidentiality order where disclosure will result in the disclosing party being held in contempt of court; + +g. accepting the offered stipulation of net worth as identified above in lieu of any net worth discovery being produced; and + +h. for such other and further relief as this Court deems just and proper. + +Respe itted, + +By: MI AE 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 served this day on all counsel of record identified on the following Service List in the manner specified by CM/ECF on this a day of April, 2010. + +Respectfully submitted, + +By: ROBERT D. CRITTON, JR., ESQ. + +Florida Bar No. 224162 + +rcrit@bciclaw.com + +MICHAEL J. PIKE, ESQ. + +Florida Bar #617296 + +inpike@belelaw.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 E stein + +Case No. 08-CV-80119-MARRA/ + +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@sexabuseattomey.com + +ahorowitz@sexabuseattomey.com + +Counsel for Plaintiffs + +In related Cases Nos. 08-80069, 08-80119, 08- + +80232, 08-80380, 08-80381, 08-80993, 08- + +80994 + +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 + +jageso®bellsouth.net + +Counsel for Defendant Jeffrey Estein + +, Jaffe, Weissing, Fistos & + +Lehrman, PL + +425 N. Andrews Avenue + +Suite 2 + +Fort Lauderdale, FL 33301 + +Phone: 954-524-2820 + +Fax: 954-524-2822 + +brad@pathloiustice.com + +Counsel for Plaintiff in Related Case No. 08- + +80893, - + +Paul G. Cassell, Esq. + +Pro Hac Vice + +332 South 1400 E, Room 101 + +Salt Lake City, UT 84112 + +801-585-5202 + +801-585-6833 Fax + +cassellpRlaw.utah.edu + +Co-counsel Jane Doe + +Isidro M. Esq. + +Law Firm, P.A. + +224 Datura Street, Suite 900 + +West Palm Beach, FL 33401 + +561-832-7732 + +561-832-7137 F + +isidrogarcia@bellsouth.net + +Counsellor:Plaintiff in Related Case No. 08- + +80469 + +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 + +rioscfsberg@podhurst.com + +kezell@oodhurst.com + +Counsel for Plaintiffs in Related Case \ No newline at end of file diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821438/EFTA02821438.metadata.json b/marker2/court-redacted-v-epstein-81111/EFTA02821438/EFTA02821438.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..5caad933a0ae5481c0ae09e41d630d2eed0a9657 --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821438/EFTA02821438.metadata.json @@ -0,0 +1,1683 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-redacted-v-epstein-81111/EFTA02821438.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 37, + "chars": 79720, + "elapsed_seconds": 17.85, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 195.228, + 72.9 + ], + [ + 406.36800000000005, + 72.9 + ], + [ + 406.36800000000005, + 99.63 + ], + [ + 195.228, + 99.63 + ] + ] + }, + { + "title": "DEFENDANT'S, CONSOLIDATED RULE 4 REVIEW AND APPEAL OF PORTIONS OF THE MAGISTRATE'S ORDERS DATED FEBRUARY 4, 2010 (DE 462), (DE 480) AND APRIL 1, 2010 (DE 513), WITH INCORPORATED OBJECTIONS AND MEMORANDUM OF LAW", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 74.05199999999999, + 333.71999999999997 + ], + [ + 532.4399999999999, + 333.71999999999997 + ], + [ + 532.4399999999999, + 389.61 + ], + [ + 74.05199999999999, + 389.61 + ] + ] + }, + { + "title": "I. 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FLORIDA + +JANE DOE, + +Plaintiff, + +Vs. + +JEFFREY EPSTEIN, et al. + +Defendant. + +CASE NO. 08-CV-80893-CIV-MARRa + +Related Cases: + +08-80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 + +## PLAINTIFF JANE DOE'S PROTECTIVE RESPONSE TO DEFENDANT'S MOTION FOR RECONSIDERATION AND/OR REQUEST FOR RULE 4 REVIEW AND APPEAL + +Plaintiff, Jane Doe, hereby files this protective response to Defendant's Consolidated Rule 4 Review and Appeal of Portions of the Magistrate's Orders Dated February 4, 2010 (DE 462), (DE 480) and April 1, 2010 (DE 513), with Incorporated Objections and Memorandum of Law (doc. #454). + +Jane Doe had understood that she had fully briefed the issues raised by the defendant's pleading when on March10, 2010, she filed her response in Opposition to Defendant's Motion for Reconsideration (doc. #485). It appears, however, the defendant Epstein may view his "consolidated" appeal as requiring some sort of new response from Jane Doe. If so, Jane Doe wishes to make clear that she continues to + +CASE NO: 08-CV-80119-MARRa + +assert the responses she raised in her earlier response and hereby files this protective response incorporating by reference all of her earlier arguments. + +Jane Doe would also note she filed her request for these documents on July 20, 2009. Through a seemingly endless series of motions, all of which have been rejected on the merits, Epstein has blocked turning over tax returns and other documents that the Government has already seen on Fifth Amendment grounds for more than ten months. Jane Doe's trial date is less than two months away on July 19, 2010, and she needs the requested items soon to prepare for trial. + +Jane Doe attempted to negotiate a resolution to these issues with counsel for Epstein, but the negotiations failed. + +Jane Doe therefore respectfully requests that the Court promptly order production of these documents to her. + +DATED: May 27, 2010 + +Respectfully Submitted, + +JAFFE, WEISSING, , FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 Florida Bar No.: 542075 E-mail: brad@pathtojustice.com + +and + +CASE NO: 08-CV-80119-MARRa + +Paul G. Cassell Pro Hac Vice 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: 801-585-5202 Facsimile: 801-585-6833 E-Mail: cassellp@law.utah.edu + +## CERTIFICATE OF SERVICE + +I HEREBY CERTIFY that on May 27, 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 on 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 filed Notices of Electronic Filing. + +J. + +## SERVICE LIST + +Jane Doe v. Jeffrey Epstein United States District Court, Southern District of Florida + +Jack Alan Goldberger, Esq. Jgoldberoer@aqwpa.com + +Robert D. Critton, Esq. rcritton@bciclaw.com + +Isidro Manual isidrogarciaftbellsouth.net + +Jack iph@searcvlaw.com • + +Katherine Warthen Ezell KEzell@podhurst.com + +Michael James Pike + +CASE NO: 08-CV-80119-MARRA/[REDACTED] + +[MPike@bclclaw.com](mailto:MPike@bclclaw.com) + +Paul G. Cassell +[cassellp@law.utah.edu](mailto:cassellp@law.utah.edu) + +Richard Horace Willits +[lawyerswillits@aol.com](mailto:lawyerswillits@aol.com) + +Robert C. Josefsberg +[rjosefsberg@podhurst.com](mailto:rjosefsberg@podhurst.com) + +Adam D. Horowitz +[ahorowitz@sexabuseattorney.com](mailto:ahorowitz@sexabuseattorney.com) + +Stuart S. Mermelstein +[ssm@sexabuseattorney.com](mailto:ssm@sexabuseattorney.com) \ No newline at end of file diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821475/EFTA02821475.metadata.json b/marker2/court-redacted-v-epstein-81111/EFTA02821475/EFTA02821475.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..4892f3604da71a8c74609ab9249bade1b49b1b79 --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821475/EFTA02821475.metadata.json @@ -0,0 +1,253 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-redacted-v-epstein-81111/EFTA02821475.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 4, + "chars": 3776, + "elapsed_seconds": 3.46, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { 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b/marker2/court-redacted-v-epstein-81111/EFTA02821479/EFTA02821479.md new file mode 100644 index 0000000000000000000000000000000000000000..7d7b21efdbf0a92253411e76cfe6fec293d1b3e7 --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821479/EFTA02821479.md @@ -0,0 +1,47 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA + +CASE NO.: 08-CIV-80119-MARRAi + +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 + +## ORDER AFFIRMING MAGISTRATE JUDGE DISCOVERY ORDERS + +THIS CAUSE is before the Court upon Defendant's Consolidated Rule 4 Review and Appeal of Portions of the Magistrate's Orders Dated February 4, 2010 (DE 462), (DE 480) and April 1, 2010 (DE 513), with Incorporated Objections and Memorandum of Law (DE 545), filed May 12, 2010) Plaintiff filed a response in opposition on May 27, 2010 (DE 551)2 and Defendant filed a reply on June 14, 2010 (DE 567). The Court has conducted a review of the motion, response, reply, the pertinent portions of the record, and is otherwise fully advised in the premises. + +Under Fed. R. Civ. P. 72(a), a district court reviewing a magistrate judge's order shall + +' The portion of the appeal pertaining to Jane Does 2-8 was withdrawn pursuant to the Joint Notice of Withdrawal as to Jane Does 2-8 (DE 561). + +2 Plaintiffs response relies upon the arguments presented in Plaintiffs brief opposing reconsideration before the magistrate judge (DE 485). + +only modify or set aside the order if it is "found to be clearly erroneous or contrary to law." See also 28 U.S.C. § 636(b)(1)(A); Local Magistrate Judge Rule 4(a)(1). An order is clearly erroneous if "the reviewing court, after assessing the evidence in its entirety, is left with a definite and firm conviction that a mistake has been committed." Krys v. Lufthansa German Airlines, 119 F.3d 1515, 1523 (11th Cir. 1997). See also United States v .United States Gypsum a., 333 U.S. 364, 395 (1948) (explaining generally "[a] finding is`clearly erroneous' when although there is evidence to support it, the reviewing court on the entire evidence is left with the definite and firm conviction that a mistake has been committed"). The mere fact that a reviewing court might have decided the issue differently is not sufficient to overturn a decision when there are two permissible views of the issue. Georgia State Conference of Branches of NAACP v. Georgia, 775 F.2d 1403, 1416 (11th Cir. 1985). + +After careful review of the Magistrate's Orders, Defendant's appeal, the response, and the reply, the Court finds that the Magistrate's Orders were not clearly erroneous or contrary to law.' Accordingly, it is hereby ORDERED AND ADJUDGED that Defendant's Consolidated Rule 4 Review and Appeal is DENIED, as follows: + +Defendant shall produce the documents compelled by Judge Orders within three (3) business days from the date of this Order. See DE 468. Before turning the documents over to Plaintiff, defense counsel shall redact from those documents the identification of any + +As the Court previously stated, it did not consider in Defendant's appeal any legal arguments which were not previously provided to Judge in the discovery motions and motion for reconsideration being appealed. See DE 532. + +minor sexual assault victims. 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On February 4, 2010, this Court entered an order (DE 462) requiring that Epstein produce his tax returns, passport and certain information provided to him by the federal government during certain criminal proceedings + +2. After Motions for Reconsideration and Rule 4 Appeal/Responses were fully briefed, this court entered its order at DE 572 requiring that Jeffrey Epstein produce his tax returns, his passport and the information the federal government gave to Epstein's lawyers during said criminal proceedings. See DEs 462 and 572. The Order requires that Epstein, through his counsel, comply within 3 days (i.e., by June 30, 2010). As such, this motion must be respectfully addressed before June 30, 2010. + +3. As part of that order at DE 572, this court ruled that "...Plaintiff shall not disclose Defendant's tax returns to any third parties without Defendant's consent and/or further court order. . .[and) Plaintiff may disclose this information to an expert witness retained to testify at trial, but only on condition that the expert will agree to retain the confidentiality of the information and not disclose it to any third parties without the agreement of defendant or further order of the Court." The order went on to state that it "...is without prejudice to any future motion by defendant to exclude any of the information produced pursuant to this order at trial." + +4. As to the information given to Epstein's lawyers by the federal government as outlined in DE 462, the court did not address in DE 572 any order of confidentiality. + +5. As a result of the foregoing, and consistent with DE 572 related to tax returns and passport, Epstein hereby requests that this court enter an order: + +- a. limiting Mr. and Jane Doe's use of the information given to Epstein's lawyers by the federal government only to this litigation; +- b. ordering that the information not be disclosed to any third parties without the consent of the Defendant or further order of this court, which includes news and television media; +- c. requiring, as it did relative to the tax returns and the passport, that any expert that receives the information given to Epstein's lawyers by the federal government must be one retained to testify at trial and shall only receive said information on condition that the expert will agree to retain the confidentiality of the information + +and not disclose it to any third parties without the agreement of defendant or further order of the Court; + +- d. that the information given to Epstein's lawyers by the federal government be returned to Epstein's lawyers at the conclusion of this trial; +- e. that failure to follow the court's directives set forth in said order shall result in contempt of court; and +- f. for such other and further relief as this court deems just and proper. + +WHEREFORE, Defendant, JEFFREY EPSTEIN, requests the Court enter a protective order and confidentiality order incorporating the terms set forth in paragraph 5a-f and grant any additional relief the Court deems just and proper. + +## Local Rule 7.1 Statement + +Pursuant to the above rule, the undersigned counsel and Plaintiff's counsel have conferred and were unable to reach an agreement. /s/ Robert D. Critton, Jr. ,./ + +Robert D. Critton, 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 manner spec' ied via transmission of Notices of Electronic Filing generated by CM/ECF on this day of lc-ti 2010: + +Brad Esq. Jaffe, Weissing, Fistos & Lehrman, PL 425 N. Andrews Ave. Suite #2 + +Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 + +Fort Lauderdale, FL 33301 Phone: 954-524-2820 Fax: 954-524-2822 Brad(apathtojustice.com + +Paul G. Cassell, Esq. Pro Plac Vice 332 South 1400 E, Room 101 Salt Lake City, UT 84112 801-585-5202 801-585-6833 Fax cassellp@law.utah.edu Co-counsel for Plaintiff + +561-659-8300 561-835-8691 Fax jaueso@bellsouth.net Co-Counsel for Defendant Jeffrey Epstein + +Respectfully submitted, + +By: /s/ Robert D. Critton. Jr. ROBERT D. CR1TTON, JR., ESQ. Florida Bar No. 224162 roriabelclaw.com MICHAEL J. PIKE, ESQ. 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+|------------|----------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| +| 06/25/2010 | 165 | Defendant's MOTION to Bifurcate Plaintiff's Punitive Damages Claims, Rule 42(b), Fed.R.Civ.P., and Supporting Memorandum of Law by Jeffrey Epstein. Responses due by 7/12/2010 (Pike, Michael) (Entered: 06/25/2010) | +| 06/25/2010 | 166 | NOTICE by Jeffrey Epstein re 165 Defendant's MOTION to Bifurcate Plaintiff's Punitive Damages Claims, Rule 42(b), Fed.R.Civ.P., and Supporting Memorandum of Law Notice of Filing Local Rule 7.1 Compliance (Pike, Michael) (Entered: 06/25/2010) | +| 06/25/2010 | 167 | Defendant's MOTION for Leave to File Excess Pages in Motion in Limine to Exclude Similar Fact Evidence by Jeffrey Epstein. (Attachments: # 1 Text of Proposed Order Proposed Order)(Pike, Michael) (Entered: 06/25/2010) | +| 06/28/2010 | 168 | Defendant's MOTION for Settlement Conference, or in the Alternative, Motion to Direct Parties Back to Mediation by Jeffrey Epstein. Responses due by 7/15/2010 (Pike, Michael) (Entered: 06/28/2010) | +| 06/28/2010 | 169 | ORDER granting 168 Motion for Settlement Conference. It is hereby ORDERED AND ADJUDGED that this case is REFERRED to United States Magistrate Judge Peter R. Palermo for the purpose of conducting a settlement conference in this action. The conference will be held on Tuesday, July 6, 2010 at 9:30 A.M. before Judge Palermo. Judge Palermo will enter a separate order providing details regarding the conference. The deadlines for filing the mandatory pretrial stipulation and motions in limine are hereby EXTENDED to two (2) business days following completion of the settlement conference.. Signed by Judge Kenneth A. Marra on 6/28/2010. (mkz) (Entered: 06/28/2010) | +| 06/28/2010 | 170 | Defendant's MOTION for Protective Order and/or Order of Confidentiality Regarding the Production of the Information Outlined in DE 462 and DE 572 by Jeffrey Epstein. (Pike, Michael) (Entered: 06/28/2010) | +| 06/29/2010 | 171 | Notice to Parties: These cases are no longer consolidated. Any future filings shall be made only in the individual case number.. Signed by Judge Kenneth A. Marra on 6/29/2010. (mkz) (Entered: 06/29/2010) | +| 06/29/2010 | 172 | ORDER denying 170 Motion for Protective Order. Signed by Judge Kenneth A. Marra on 06/29/2010. (mkz) (Entered: 06/29/2010) | +| 06/29/2010 | 173 | ORDER SCHEDULING Settlement Conference set for 7/6/2010 09:30 AM in Miami Division before Sr. Magistrate Judge Peter R. Palermo. Signed by Sr. Magistrate Judge Peter R. Palermo on 6/29/2010. 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On February 4, 2010, this Court entered an order (DE 462) requiring that Epstein produce his tax returns, passport and certain information provided to him by the federal government during certain criminal proceedings. + +2. After Motions for Reconsideration and Rule 4 Appeal/Responses were fully briefed, this court entered its order at DE 572 requiring that Jeffrey Epstein produce his tax returns, his passport and the information the federal government gave to Epstein's lawyers during said criminal proceedings. See DEs 462 and 572. The Order requires that Epstein, + +through his counsel, comply within 3 days (i.e., by June 30, 2010). As such, this motion must be timely addressed. + +3. As part of that order at DE 572, this court ruled that "...Plaintiff shall not disclose Defendant's tax returns to any third parties without Defendant's consent and/or further court order. . .[and] Plaintiff may disclose this information to an expert witness retained to testify at trial, but only on condition that the expert will agree to retain the confidentiality of the information and not disclose it to any third parties without the agreement of defendant or further order of the Court." The order went on to state that it "...is without prejudice to any future motion by defendant to exclude any of the information produced pursuant to this order at trial." + +4. Plaintiff's counsel here, and in other cases, has always been quick to respond to media inquiries. The court has directed that the tax returns themselves remain confidential. Defendant expects that the information contained therein will be afforded that same protection. However, if Plaintiff's counsel provides information (such as the identification and sources of Defendant's income) to others (i.e., non-lawyers, investigators, etc...), they will use that information in an improper manner and in violation of the court's order. As set forth in DE 569, Mr. admittedly has provided the journal and/or book secured from Alfredo Rodriguez to his investigators "who are now following-up [alleged] significant discovery leads found in the book." + +5. Therefore, Epstein, in good faith, moves this court for an order allowing him to redact certain information or designate the documents produced "Attorneys and Experts' Eyes Only." + +6. While the tax returns in this case are to be maintained as confidential, certain information should be redacted in those tax returns including, but not limited to, the names of the companies, trusts, properties and other investment vehicles EPSTEIN has invested in over the years. This information is personal, confidential and trade secret information. The commercially sensitive and trade secret information contained in the tax returns could result in irreparable harm to Epstein if disseminated, and thus should be protected. v. Silcox, 2001 WL 1200656 (S.D. Fla. 2001). Save v. Old ■ **Partners, Inc., 478 F.Supp. 248, 274-276 (D.Ct. Conn. 2007Xquestion of fact existed as to whether investment company's business formula, which included investment trading strategy, investor lists, portfolios, financing methods. . . was tradesecret); see also U.S. v. Baez-Alcaino, 718 F. Supp. 1503, 1505-06 (M.D. Fla. 1989) (affirming lower court's decision to file redacted plea agreements to serve compelling government interests); In re Duque, 134 B.R. 679, 687 (S.D. Fla. 1991) (finding that court's procedure requiring attorneys to provide privileged documents to court for in-camera inspection while providing redacted versions to the bankruptcy trustee was proper).** + +**7. No figures or income information in the tax returns will be redacted.** + +**8. Moreover, the right to privacy encompasses at least two different kinds of interests, the individual interests of disclosing personal matters and the interest in independence in making certain kinds of important decisions. Favalora v. Sidaway, 966 So.2d 895 (Fla. 4th DCA 2008). Likewise, Article 1, s. 23, Right of Privacy, provides that every natural person has the right to be let alone and free from governmental intrusion into the person's private life. Colorado v. Bertine, 479 U.S. 367, 387 (1986); State v. Jardines, 9 So.3d 1 (Fla. 3d DCA 2008)(the Fourth Amendment clearly protects the right of people to be secure in their persons, houses, papers and effects from intrusion).** + +**9. While the scope of discovery is broad, it is not without limits. Washington v. & Williamson Tobacco, 959 F.2d 1566, 1570 (11th Cir. 1992). Courts have long held** + +that while the standard of relevancy in discovery is a liberal one, it is not so liberal as to allow a party to roam in the shadow zones of relevancy and to explore matters which does not presently appear germane on the theory that it might conceivably become so. Food Lion, Inc. v. United Food & Commercial Workers Intern. Union, 103 F.3d 1007, 1012-13 (C.A. D.C. 1997) (string cite omitted). See also Capco Properties, LLC v. Monterry Gardens of Pinecrest Condo., 982 So. 2d 1211, (Fla. 3d DCA 2008) (holding that discovery in civil cases must be relevant to the subject matter of the case and must be admissible or reasonably calculated to lead to admissible evidence) Morton Plant Hospital Ass'n, Inc. v. Shahbas, 960 So. 2d 820, 824 (Fla. 2d DCA 2007) (holding that "discovery should be denied when it has been established that the information requested is neither relevant to any pending claim or defense nor will it lead to the discovery of admissible evidence," citin¢ Tanchel v. Shoemaker, 928 So. 2d 440, 442 (Fla. 5th DCA 2006)). + +10. At this juncture, and in an effort to comply with the above order, Epstein is producing the redacted versions of the tax returns until further order from the court. + +WHEREFORE, Defendant, JEFFREY EPSTEIN, requests the Court enter an order and/or protective order allowing Epstein to redact the above information and grant any additional relief the Court deems just and proper. + +## Local Rule 7.1 Statement + +Pursuant to the above rule, the undersigned counsel and Plaintiff's counsel have conferred and were unable to reach an agreement. + +> /s/ Robert D. Critton, Jr. Robert D. Critton, 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 manner specified via transmission of Notices of Electronic Filing generated by CM/ECF on this ;0 day of 2010: + +Brad p. Esq. Jaffe, Weissing, ME Fistos & Lehrman, PL 425 N. Andrews Ave. Suite #2 Fort Lauderdale, FL 33301 Phone: 954-524-2820 Fax: 954-524-2822 BradApathtoiustice.com + +Paul G. Cassell, Esq. Pro Hac Vice 332 South 1400 E, Room 101 Salt Lake City, UT 84112 801-585-5202 801-585-6833 Fax cassel Ip@law.titah.edu Co-counsel for Plaintiff + +Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 561-659-8300 561-835-8691 Fax jaaesu@bellsouth.net Co-Counsel for Defendant Jeffrey Epstein + +Respectfully submitted, + +By: / Jr. ROBERT D. CRITTON, JR., ES Florida Bar No. 224162 rcriiabelclaw.com MICHAEL J. PIKE, ESQ. 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0000000000000000000000000000000000000000..9e2f7eeec2d476ef576fb2b02b3a79b016266130 --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821493/EFTA02821493.md @@ -0,0 +1,13 @@ +| 06/29/2010 | 174 | ORDER granting 167 Motion for Leave to File Excess Pages in motion in limine to exclude similar fact evidence.. Signed by Judge Kenneth A. Marra on 6/29/2010. (mkz) (Entered: 06/29/2010) | +|------------|---------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| +| 06/29/2010 | 175 | Plaintiff's MOTION for Writ of Habeas Corpus ad testificandum Alfredo Rodriguez by Jane Doe. (Attachments: # 1 Exhibit A)( [REDACTED] , [REDACTED] ) (Entered: 06/29/2010) | +| 06/29/2010 | 176 | NOTICE by Jane Doe re 38 Amended Complaint Count V Seeks Punitive Damages ( [REDACTED] , [REDACTED] ) (Entered: 06/29/2010) | +| 06/29/2010 | 177 | Notification of Ninety Days Expiring DE 483 (#08-80119) Motion for Order to Show Cause by Jane Doe ( [REDACTED] , [REDACTED] ) (Entered: 06/29/2010) | +| 06/29/2010 | 178 | Plaintiff's MOTION in Limine to Prevent Improper Use of 5th Amendment and Memo of Law by Jane Doe. (Attachments: # 1 Exhibit A)( [REDACTED] , [REDACTED] ) (Entered: 06/29/2010) | +| 06/30/2010 | 179 | Notification of Ninety Days Expiring by Jeffrey Epstein (Pike, Michael) (Entered: 06/30/2010) | +| 06/30/2010 | 180 | ORDER granting 161 Motion for open trial and to identify Jane Doe at trial. Signed by Judge Kenneth A. Marra on 6/30/2010. (mkz) (Entered: 06/30/2010) | +| 06/30/2010 | 181 | *Endorsed Order requiring expedited response. Response to (DE 175) Plaintiff's Motion for a Writ of Habeas Corpus Ad Testificandum due on or before July 6, 2010 at 12:00 noon.. Signed by Judge Kenneth A. Marra on 6/30/2010. (mkz) (Entered: 06/30/2010) | +| 06/30/2010 | 182 | Defendant's MOTION for Leave/Protective Order to Redact Portions of Tax Records in Accordance with the Last Portion of DE 572 (08-80119) and Incorporated memorandum of Law by Jeffrey Epstein. (Pike, Michael) (Entered: 06/30/2010) | +| 06/30/2010 | 183 | ORDER denying 182 Motion leave/protective order to redact portionss of tax records. The limitation regarding disclosure ordered by the Court in DE 572 (case 08-80119) applies not only to Defendant's tax records and passport but also to the information contained in those documents.. Signed by Judge Kenneth A. Marra on 6/30/2010. (mkz) (Entered: 06/30/2010) | +| 06/30/2010 | 184 | Defendant's MOTION for Jury Questionnaire, Motion for Individual Voir Dire, Motion to Select Jury Venire from Outside Jurisdiction and Motion for Jury Sequestration Throughout the Trial by Jeffrey Epstein. (Pike, Michael) (Entered: 06/30/2010) | +| 06/30/2010 | 185 | Defendant's MOTION to Continue Trial by Jeffrey Epstein. 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Both of these failures stand in clear violation of this Court's discovery orders. Jane Doe further asks that Epstein be directed to produce these materials forthwith and that the Court impose appropriate sanctions. Jane Doe respectfully asks that this motion be decided rapidly. + +As the Court is well aware, there has now been more than eleven months of litigation on whether defendant was going to produce any discovery to Jane Doe. More than a year ago, Jane Doe propounded three discovery requests: + +Request No. 7: All discovery information obtained by you or your attorneys as a result of the exchange of discovery in the Stare criminal case against you or the Federal investigation against you. + +Request No. 9: Any documents or other evidentiary materials provided to local, state, or federal law enforcement investigators or local, state or federal prosecutors investigating your sexual activities with minors. + +Request No. 10: All correspondence between you and your attorneys and state or federal law enforcement or prosecutors (includes, but not limited to, letters to and from the States Attorney's office or any agents thereof). + +After innumerable motions and continuances and delays, this Court's order to produce these items came due yesterday. Jane Doe finally received her discovery last night. Remarkably, however, Epstein deliberately limited his discovery in two ways. + +First, while Requests No. 7, 9, and 10 clearly cover discovery information that Epstein obtained in both federal and state proceedings, Epstein produced only federal discovery (or, more precisely, because he claims to have received no federal discovery, he provided nothing at all). In addition, while Request No. 10 clearly covers correspondence with both federal and state prosecutors, Epstein has produced only correspondence with federal prosecutors. There is no basis for limiting production to federal materials. + +Second, while Request No. 10 clearly covers correspondence both to and front Epstein's criminal defense attorneys, Epstein has redacted all of this correspondence so that only correspondence to him is revealed. The resulting mishmash of redactions means that much of the correspondence and virtually all of the correspondence most useful to Jane Doe — has been withheld by Epstein. + +These deliberate violations of the Court's orders are part of a persistent pattern by Epstein to thwart legitimate discovery by Jane Doe.' Accordingly, the Court should order production of these items forthwith. Jane Doe seeks production on an emergency basis because she has been compelled to attend a second settlement conference on July 6, 2010, at 9:30 a.m., and these items of discovery might + +' For another blatant example of improper delays during discovery, see Plaintiff's Motion to Prevent Improper Use of 51h Amendment and Memorandum of Law, case no. 9:08-cv-80893, doc. #178 (Epstein's filibustering and insertion of irrelevant and prejudicial information during his deposition). + +put her in a much better position to understand the strength of her case at that time. Jane Doe therefore respectfully requests that the Court rule on this motion rapidly by Friday, July 2, 2010. (Monday, July 5, 2010, is a federal holiday.) Jane Doe also seeks appropriate sanctions. + +## PROCEDURAL BACKGROUND + +For the convenience of the Court, here is the full saga of several straightforward discovery requests that Jane Doe has filed in this case. On July 20, 2009, Jane Doe tiled a motion to compel production of various previously-requested documents, including discovery provided to Epstein by state and federal prosecutors in the criminal cases against him and correspondence between his criminal defense attorneys and state and federal prosecutors during the criminal investigation. Case No. 9:08-cv-80119, doc. #210. Specifically, her motion sought production of the following: + +Request No. 7: All discovery information obtained by you or your attorneys as a result of the exchange of discovery in the State criminal case against you or the Federal investigation against you. + +Request No. 9: Any documents or other evidentiary materials provided to local, state, or federal law enforcement investigators or local, state or federal prosecutors investigating your sexual activities with minors. + +Request No. 10: All correspondence between you and your attorneys and state or federal law enforcement or prosecutors (includes, but not limited to, letters to and from the States Attorney's office or any agents thereof). + +(doc. #210 at pp. 10-12 (emphases added)). Epstein obtained an extension of time in which to respond and, two-and-a-half months later, on October 6, 2009, Epstein filed an objection to producing these items primarily on Fifth Amendment grounds (doe. #339). On October 16, 2009, Jane Doe promptly filed a reply in support of her motion (doe. #354). On January 22, 2010, Jane Doe filed a notice that more than 90 days had elapsed since the filing of her motion (doc. #453). + +On February 4, 2010, the magistrate judge granted in part and denied in part Jane Doe's motion to compel, specifically ruling that Epstein had to produce the discovery provided to him by state and + +federal prosecutors and the requested correspondence, rejecting Fifth Amendment and other objections raised by Epstein. (case no. 9:08-cv-80119, doc. #462). The magistrate judge specifically granted requests 7, 9, and 10. Id. at 10 ("Accordingly, Epstein is ordered to produce the documents subjects to these Requests [i.e., requests 7, 9, and 10] within ten (10) days from the date hereof."). + +Epstein then filed for an extension of time in which to appeal (doc. #464), which Jane Doe opposed on grounds of delay (doc. #465). On February 11, 2010, the Court granted in part and denied in part the extension of time, specifically warning Epstein that "[i]n the event that Magistrate Judge February 4, 2010 Order is affirmed on appeal, Defendant will have three (3) business days from the date of this Court's order to produce the documents at issue." (doc. #468). Epstein then ultimately filed his appeal/motion for reconsideration of the magistrate decision on February 26, 2010. (doc. #477). On March 10, 2010, Jane Doe then filed her response in Opposition to Defendant's Motion for reconsideration. (doc. #. 485). + +On April I, 2010, the magistrate judge rejected Epstein's challenge, reaffirming his earlier order that "compelled production from state and federal prosecutors in the criminal case against him." (doc. #513). + +On May 6, 2010, the court held a status conference on the appeal (which also involved other consolidated cases raising similar appeals and issues). The Court asked the parties to attempt to reach a resolution of issues surrounding Epstein's net worth. + +On May 12, 2010, Epstein filed a "Consolidated" Rule 4 Review and Appeal of Portions of the Magistrate Judge's orders (doc. #545). On May 27, 2010, Jane Doe filed a "protective" response to the consolidated reply, noting that she had previously responded to all of the arguments raised by the appeal and that the "consolidated" appeal did not require any new response from her (doc. #551). The response also noted Jane Doe and Epstein had been unable to resolve disputed net worth issues. + +On Friday, June 25, 2010, this Court entered an order affirming the magistrate judge's discovery orders in all respects (Case No. 9:08-cv-80119-ICAM, doc. #572) and, as it previously warned Epstein, requiring Epstein to produce the discovery materials within three business days. + +At this point, despite having had a year to assemble the requested discovery items and prepare for their production — and more than four months since this Court's warning to be prepared to produce the documents on three days notice — Epstein began filing motions to restrict production. On Monday evening, June 28, 2010, at approximately 5:11 p.m., Epstein filed a motion for a protective order regarding dissemination of the materials (Case No. 9:09-cv-80893, doc. #170). On Tuesday morning, June 29, 2010, at approximately 9:31 a.m., this Court summarily denied the motion (doc. #172). Then, as the deadline for production drew even nearer, on Wednesday, June 30, 2010, at approximately 2:19 p.m., Epstein filed a motion for a right to redact tax returns that were being produced and informed the Court in his Motion that he was going to go ahead and only produce redacted tax returns (doe. #182). Shortly thereafter, Epstein began transmitting redacted returns to Jane Doe's counsel via email. Acting with impressive speed, at approximately 2:33 p.m., the Court summarily denied Epstein's motion (doc. #183). + +Following these actions by the Court, yesterday defendant Epstein made his production of unredacted tax returns electronically to Jane Doe's counsel. However, Epstein remarkably still failed to produce materials he was required to produce in two critical ways. First, Epstein did not produce any information he had obtained from the state during discovery of the criminal investigation against him. Indeed, because he had not (apparently in his view) obtained any federal discovery during the criminal investigation, he turned over nothing at all responsive to Jane Doe's Requests No. 7 and No. 9. And similarly, with regard to correspondence from the prosecutors, Epstein also produced only correspondence with federal prosecutors — not with state prosecutors. Of course, this significantly + +limited the production he made, as Epstein pled guilty to state sex charges rather than federal sex charges — leaving Jane Doe with no correspondence or discovery from the State. + +Second, with regard to his correspondence with federal prosecutors that he did produce, Epstein redacted anything coming from attorneys, leaving only the responses from the federal prosecutors. The result is an often unintelligible mishmash of back-and-forth emails, where only half of what is being said is disclosed. It forces Jane Doe to read everything out of context and severely limits the utility of what was produced. To give but two of what are literally dozens of examples of the unintelligibility, consider these e-mail chains — or, more precisely, half e-mail chains: + +That is fine. I'm sorry I didn't get your e-mail sooner. Since I am out of the office, the best way to reach me is on my cell, or you can send an e-mail (which becomes a text message) to 5616012301@cingularme.com + +Tomorrow I am available early in the morning (7:00 to 7:45), or at 8:30, or at 5:00, or after 6:45. + +Thanks. + +A. pill Villafaft Assistant U.S. Attorney 561 209-1047 Fax 561 820-8777 + +O ' 1 Messa e 111111111111\* + +CASE NO: 08-CV-80893-MARRA/ [REDACTED] + +Exhibit 1, found as Correspondence 5 from defense counsel (June 30, 2010). + +Jay – I hate to have to be firm about this, but we need to wrap this up by Monday. I will not miss my indictment date when this has dragged on for several weeks already and then, if things fall apart, be left in a less advantageous position than before the negotiations. I have had an 82-page pros memo and 53-page indictment sitting on the shelf since May to engage in these negotiations. There has to be an ending date, and that date is Monday. + +A. [REDACTED] *Villafaña* +Assistant U.S. Attorney +561 209-1047 + +[REDACTED] +[REDACTED] +S [REDACTED] + +[REDACTED] + +Exhibit 2, found as Correspondence 3 from defense counsel (June 30, 2010). + +The net result of these redactions, of course, is that what is produced is of essentially no value to Jane Doe for discovery or at trial – what is left is merely statements from prosecutors, rather than statements from agents of Mr. Epstein that could be used to help build Jane Doe’s case. + +**EPSTEIN SHOULD BE HELD IN CONTEMPT AND SANCTIONED FOR DELIBERATE VIOLATIONS OF THE ORDER TO PRODUCE** + +**I. EPSTEIN SHOULD BE HELD IN CONTEMPT FOR FAILING TO PRODUCE STATE DISCOVERY AND STATE CORRESPONDENCE RESPONSIVE TO REQUESTS NOS. 7, 9, AND 10** + +As noted above, Jane Doe’s Requests for Production No. 7 and 9 plainly requested that Epstein produce discovery provided to him in both the federal and state criminal cases. *See, e.g.*, Request No. 7 (requesting production of “[a]ll discovery information obtained by you or your attorneys as a result + +of the exchange of discovery in the State criminal case against you or the Federal investigation against you" (emphasis added)). In addition, Request No. 10 plainly requested "[It'll correspondence between you and your attorneys and state or federal law enforcement or prosecutors (including, but not limited to, letters to and from the States Attorney's office or any agents thereof (emphasis added))." Indeed, given the intertwined nature of these two investigations (with a federal non-prosecution agreement ultimately resulting when Epstein pled guilty to state sex charges), it would be difficult to segregate the two. Of course, Jane Doe would want discovery and correspondence from both cases — it makes no difference to her the source of the documents or correspondence. And the legal principles governing production would not vary between federal and state investigations. + +Astonishingly then, Epstein now after 11 months of litigation has decided that Jane Doe's request — and the magistrate judge's order affirming that request — are somehow to be limited to merely the federal criminal investigation. And, with amazing convenience for Epstein, since he apparently deems all the discovery his criminal defense team received to be purely state discovery, he has to produce nothing on request for production nos. 7 and 9, and only half of what would be expected for request for production no. 10. + +In the context of this case, it should be readily apparent to the Court that Epstein has deliberately decided to produce substantially less information than he is required to produce. He is doing so by taking a ridiculous and absurd position that is not supported by any reasonable reading of the discovery requests or this Court's rulings. And he is doing so in a civil case, where discovery is supposed to be freely and readily exchanged. + +The only even arguable basis for Epstein's deliberate intransigence is that he is apparently taking the position that a single sentence in one of Jane Doe's many pleadings on these issues should be deemed to have "narrowed" the plain language of her clear Requests for Production. In a reply brief + +in October 2009, counsel for Jane Doe in briefly described the nature of requests for production nos. 7, 9, and 10, writing one sentence that referred to the requests as covering materials from the federal government. See Plaintiff's Jane Doe's Reply to Response to Motion to Compel, doc. #354 at 3 (referring to requests as seeking "information that the federal government gave to Epstein in the course of its plea discussions with him"). In reviewing that single sentence, it should have been obvious that Jane Doe was not suddenly — and for no apparent reason — narrowing her request to half of the material that she would otherwise have been entitled to receive. At the very most (and this is debatable), it appears that one could argue that Jane Doe's counsel spoke loosely or made a typographical error, as the sentence could have more clearly said "federal and state government." Whatever can be said of this single sentence, the remaining sentences in this pleading immediately following this sentence plainly refer to both the federal and state governments, as there is no limitation to the federal government in approximately nine other sentences in close proximity to the sentence Epstein apparently seizes upon. See, e.g.,id. at 4 ("The government itself gave Epstein the documents!" (emphasis in original)); id. at 6 "the government was showing him the documents in the first place to convince him to plead guilty to a crime" (emphasis added)); id. at 9 ("Jane Doe's requests for production number 7 and 9, which seek respectively discovery provided by the government and "evidentiary materials' provided by the government" (emphasis added)). And, eliminating any legitimate confusion, at the end of this section in this brief, Jane Doe explained quite clearly that she was seeking not only correspondence with the U.S. Attorney's Office but more general with "government agencies," — i.e., both federal and state agencies. Id. at 10. + +Regardless of how Epstein might have intentionally misconstrued this single sentence in the Jane Doe's reply, the magistrate judge ultimately ruled on the actual request for production. The magistrate judge in using a shorthand to describing the nature of the Requests for Production, also + +referred at one point to "the federal government" and at another point to "the government." Compare case no. 9:08-CV-80893, doc. 462 at 8 (describing Requests 7, 9 and 10 as involving "documents the federal government gave to Epstein") with id. (describing requests as "documents the government itself gave to Epstein"). But the Court's ultimate order was that the Request for Productions 7, 9, and 10 was granted. Id. Nothing in the context of the magistrate judge's decision indicated any principle of law that would make federal information and correspondence discoverable and state information and correspondence non-discoverable. Indeed, the magistrate judge made clear on the next page of the order that he understood he was reviewing a discovery matter relating to documents involving "Epstein's Florida guilty" plea and "federal or state criminal investigations." Id. at 9 (emphases added). Nor would there have been any logical reason for the magistrate judge to have awarded to Jane Doe production of only half of the materials she sought (i.e., awarded her only production of federal materials, but not state materials on the same subject). + +Following the magistrate judge's ruling, Epstein filed a motion to reconsider. If Epstein believed that the order only obligated him to produce federal discovery materials/correspondence and that he had no such materials — it would have been a simple matter for him to have simply said that and not appeal the ruling on Requests Nos. 7 and 9 (and to a large extent 10). To the contrary, however, Epstein spent nine pages asking the magistrate judge to reverse its rulings on these three requests for production. (Case No. 9:08-cv- 80119-KAM, doc. #477, at 3-11). Epstein also stated that he did not have discovery information or evidentiary information provided to him by the federal government. Id. at 4. + +In response, Jane Doe noted Epstein's Ms -half-empty representations that he had no federal discovery materials and objected to his "semantic games." Plaintiff Jane Doe's Response to Defendant's Motion for Reconsideration and/or Request for Rule 4 Review, Case No. 9:08-cv-80119- + +KAM, doe. #485, at 3. She made clear that she expected Epstein to honor the Request for Productions as they were written and produce both federal and state materials: + +Jane Doe does not take these representations to mean that Epstein possesses no information responsive to these requests. If this were the case, Epstein could have avoided seven months of litigation by simply making this representation to the Court at the outset. Rather, Epstein seems to be playing semantic games. With regard to discovery request no. 7, Epstein represents only that he has no discovery information from the federal government — not contesting the obvious fact (as Jane Doe has been reliably informed) that he received significant discovery in connection with the state criminal charges to which he pled guilty. With regard to discovery request no. 9, Epstein represents only that he has not been given evidentiary documents by the federal government — again not contest the obvious fact (as Jane Doe has been reliably informed) that he received documents from both the state and federal authorities working on his case. If Epstein is going to continue to mince words in this fashion, Jane Doe asks that he clearly explain to the Court in any reply pleading that he may file what materials responsive to the requests for production he has so that the Court may make an informed ruling. + +Id. (emphases in original). Jane Doe also noted specifically that request no. 10 "covers correspondence with 'state or federal law enforcement or prosecutors.' For convenience, the request will be described as being for correspondence with 'the Government.'" Id. at 5 n.2. + +In his reply to Jane Doe's response, Epstein cited the single sentence in Jane Doe's October pleading discussed above and made an argument that the magistrate judge had somehow impliedly adopted it as narrowing the scope of the her requests. Defendant's Reply to Plaintiff's Response to Defendant's Motion for Reconsideration, Case No. 9:08-cv-80119-KAM, doe. #502, at 2-3. Epstein then went on to spend seven pages arguing on the merits that he should not be required to produce state discovery materials. He made two detailed arguments against producing state discovery materials. He first argued that the request for state materials was somehow "improper" because Jane Doe's counsel had received some materials from state prosecutors. Id. at 34.2 Epstein then argued that the state materials were "work product" because his attorney had picked out certain materials from the state + +2 To be clear, Jane Doe's counsel believes that Epstein possesses significant state discovery materials that have never been seen by Jane Doe. + +prosecutor. In support of this argument, Epstein for the first time attached an affidavit from Jack Goldberger, his criminal defense attorney, about the process of obtaining the state discovery materials. Id. at 5-7. + +As has been the case with many other claims presented by the Epstein in the course of this litigation, the magistrate judge was not impressed with these arguments against producing both federal and state discovery materials. In the final order on the subject on April 1, 2010, the magistrate judge explained: "Epstein takes issue with that portion of the Order which compelled production of discovery from state and federal prosecutors in the criminal case against him, his recent tax returns, and his passport. The Court stands behind each of these decisions for the reasons stated in its Order and is not persuaded by any of Epstein's arguments to the contrary." Omnibus Order, Case No. 9:08-cv-80119- KAM, doe. #513 at 2 (emphases added). Notably, the magistrate judge was not persuaded by "any" of Epstein's arguments — including, of course, his argument that the single sentence in Jane Doe's earlier pleading has magically "narrowed" the plain meaning of her requests. And notably, the magistrate judge himself — in the face of a challenge from Epstein that the court order only required Epstein to produce federal materials — specifically described the order as including "production of discovery from state and federal prosecutors." + +After various further delays engineered by Epstein as recounted above, pleadings were filed before this Court (Marra, J.), on the appeal of the magistrate judge's ruling. Epstein's pleadings were essentially "cut and paste" pleadings from his pleading with the magistrate judge. Most important for present purposes, the pleadings revealed no doubt that Epstein understood that Jane Doe was requesting — and that the the magistrate judge had ordered -- production of both federal and state materials. See, e.g., doe. #545 at 5 (discussing breadth of Jane Doe's request), at 15 (challenging obligation to produce materials from state and local police agencies); at 17 (arguing that materials in "Palm Beach state Attorney's File" were somehow work product material). And on June 25, 2010, this Court affirmed all of the magistrate judge's discovery rulings. (Case No. 9:08-cv-80119-ICAM, doc. #572). + +Jane Doe has reviewed these pleadings in detail because they point to only one conclusion: defendant Epstein is deliberately violating the clear order of Magistrate Judge that he produce "discovery from state and federal prosecutors in the criminal case against him" Indeed, Epstein has specifically presented his extraordinary and crabbed interpretation of the order (i.e., that it only extends to the federal government materials) to the magistrate judge, and the magistrate judge told him the interpretation was rejected. And this Court affirmed. Epstein is therefore plainly in contempt of this Court's order. He should be directed to immediately produce the discovery and other information he received from state prosecutions and correspondence with state prosecution and be subject to other sanctions as explained below. + +## II. EPSTEIN SHOULD BE HELD IN CONTEMPT FOR FAILING TO PRODUCE UNREDACTED CORRESPONDENCE WITH FEDERAL PROSECUTORS + +Defendant Epstein, making use of yet another dilatory tactic, has also deliberately violated this Court's discovery order by failing to produce unredacted correspondence with federal prosecutors. Instead, he has produced redacted discovery that is essentially gibberish and, in any event, unusable by Jane Doe because it contains no statements from Epstein or his representatives and forces Jane Doe to read all communications about Epstein's crimes against minors out of context. + +Epstein apparently takes the position that he is somehow entitled to redact the correspondence, even though none of the underlying magistrate judge orders regarding the correspondence even mention redaction and even though Epstein has never even raised redaction. Perhaps Epstein was thinking about filing a motion for authorizing redaction — only to be scared off by this Court's 14 minute turnaround time yesterday in rejecting his frivolous motion to redact the tax returns he was + +producing. (Case No. 9:08-cv-80893-KAM, doc. #183). In light of these circumstances, it appears that Epstein's legal counsel have calculated that it is better to force Jane Doe's attorney to file a motion objecting to redaction rather than to present this preposterous idea to the Court for summary rejection. + +The redaction is in clear defiance of the orders in this case. Jane Doe's Request for Production No. 10 plainly and broadly requested "[aill correspondence between you and your attorneys and state or federal law enforcement or prosecutors (includes, but not limited to, letters to and from the States Attorney's office or any agents thereof)." (Case No. 9:08-cv-80119, doc. #210 at 10). The magistrate judge rejected Epstein's arguments against production. (doc. #462 at 10). The magistrate judge "rejected out of hand" any claim that the correspondence was somehow protected by the attorneyclient privilege or work-product doctrine, noting that the correspondence with state and federal prosecutors could hardly be regarded as somehow "confidential." Id. at 9. The magistrate judge therefore ordered Epstein to comply with Request for Production No. 10 "involving settlement discussions and plea negotiations." Id. at 10. + +Once again, defendant Epstein filed for reconsideration, making it quite clear that the Request for Production covered not only what prosecutors were saying to his representatives, but also what his representatives were saying back. Thus, Epstein asked the magistrate judge to reconsider not only because it was purportedly protected by the attorney-client privilege, but also for a new reason: settlement discussion confidentially. Epstein argued that because "[t]he requested communications include the views of Epstein's counsel in the criminal case regarding why a federal prosecution was inappropriate .. .. It also includes Epstein's counsel's views on the limits and inapplicability of certain elements of 18 U.S.C. § 2255 . . . .This opinion work product should not be disclosed . . . ." Defendant's Motion for Reconsideration and/or Request for Rule 4 Review, Case No. 9:08-cv-80119- KAM, doc. #477 at 7-8. Epstein also put in a cryptic sentence stating: "Concomitantly, to the extent + +that the request is now limited to communications form the Government to Epstein, see DE 54, pgs 3 and 8, the narrowed request implicate[s] the same concerns for the opinions, the work product, and the expectations of the privacy of the United States Attorney ...." Id. at 8. + +Jane Doe responded by explaining "[t]here is nothing confidential about materials being exchanged between Epstein and government prosecutors — regardless of whether the materials or correspondence were being sent from the prosecutors to Epstein or from Epstein to the prosecutors." Plaintiff Jane Doe's Response to Defendant's Motion for Reconsideration, doc. #485 at 13 (emphasis added). Jane Doe also objected that Epstein was improperly raising arguments concerning settlement confidentiality for the first time on reconsideration. Id. at 5-6. Jane Doe went on to note the "cryptic sentence" in Epstein's pleading, and explained: "It's hard to understand what Epstein means by this sentence. The cited docket entry — DE 543 — has nothing to do with the discovery request at hand. Perhaps this sentence is simply a mistaken remnant of a botched 'cut and paste' from another pleading in another case where docket entry 564 would relevant. In any event, to be clear, Jane Doe has not 'narrowed' her request to only one-half of the relevant correspondence and thus the magistrate judge's order is not limited to one-half of the correspondence." Id. at 13 n.4. Epstein did not press the point in his reply brief. (doc. #502 at 1-3 (not raising this issue)). + +The magistrate judge — once again — rejected all of Epstein's arguments, reaffirming that Epstein was obligated to comply with Request for Production No. 10. The Court singled out Epstein's argument about settlement confidentiality as specifically flawed: "Epstein's final argument, raised now for the first time, concerns settlement discussion confidentiality. Because Epstein never presented this argument to the undersigned it is inappropriate to raise it now for the first time. . . . Even were the + +3 Docket entry 54 is this Court's Opinion and order granting and denying in part Motion to Dismiss and Motion for a More Definite Statement, entered on February 12, 2009 — before any of the discovery requests at issue here at even been propounded. + +Court to consider the argument on its merits, for the reasons explained in Jane Doe's Response Memorandum (D.E. #485), pp. 4-9, the Court finds said argument without merit." Omnibus Order, Case No. 9:08-cv-80119-KAM, doc. #513, at 2-3. + +As noted above, after various further delays engineered by Epstein, pleadings were filed before this Court (Marra, J.), on the appeal of the magistrate judge's ruling. Here again, Epstein's pleadings make it crystal clear that he knew he was obligated to produce not only what prosecutors said to him, but what he and his representatives said to them. He objected to producing correspondence involving "the opinion of each counsel, Epstein's and the United States Attorney's[,] [which] were exchanged with each other pursuant to the overall expectation that they were safeguarded from disclosure by the policies of confidentiality that protect communications during settlement and plea negotiations. The requested communications include the views of Epstein's counsel in the criminal cases regarding why federal prosecution was inappropriate [and other subjects]." (Case No. 9:08-cv-80119, doc. #545 at I I (emphasis added)). And on June 25, 2010, this Court rejected all of Epstein's arguments and affirmed all of the magistrate judge's discovery rulings. (Case No. 9:08-cv-80119-KAM, doc. #572). + +Once again, it is quite clear that Epstein stands in clear and deliberate defiance of this Court's discovery order obligating him to produce correspondence as directed in Request for Production No. 10. Epstein should be directed to produce the discovery and other information he received from state prosecutions and correspondence with state prosecution forthwith and be subject to other sanctions as explained below. + +## III. THE COURT SHOULD SANCTION EPSTEIN BY DIRECTING PRODUCTION FORTHWITH, IMPOSING A FINE AND BY DEEMING ALL OF THE MATERIALS WITHHELD TO BE ADMISSIBLE AT TRIAL. + +Jane Doe's counsel apologizes for forcing this Court to read this entire discovery saga. But the bottom line remains that after eleven months of litigation, when Jane Doe was receiving her first + +CASE NO: 08-CV-80893-IVIARRA + +discovery production from Epstein yesterday, he clearly and deliberately defied this Court's orders about the scope of that production. Moreover, as the events recounted above make clear, the refusal to produce is willful. They also seemed to be calculated to force Jane Doe's legal counsel to spend a significant amount of time writing a pleading to obtain production, just when she has been ordered (at Epstein's demand) to another settlement conference and while preparing for trial in this matter.° Indeed, it seems probable that Epstein is seeking to prevent Jane Doe from having these materials to review before the settlement conference — and perhaps to block her from having these materials when her trial starts in less than three weeks. + +It is hard to view Epstein's maneuvers — and Epstein's recent attempts to restrict discovery that this Court has summarily rejected — as anything other than a signal that Epstein and his legal counsel believe that they need not follow the rules that apply to other litigants. Perhaps the vast wealth of the defendant and the legal fees that he is paying his attorneys has engendered this attitude. Regardless of the reason, this Court should not tolerate such clear intransigence and impose appropriate sanctions. + +Epstein should be found to be in contempt of court. To find contempt, "the Court must determine whether there is clear and convincing evidence that (1) the allegedly violated order was valid and lawful; (2) the order was clear, definite and unambiguous; and (3) the alleged violator had the ability to comply with the order." Brauchle v. Southern Sports Grill, Inc., 2008 WL 4753707, at \*I (S.D.Fla.,2008) (citing McGregor v. Chierico, 206 F.3d 1378, 1383 (11i6 Cir. 2000)). For the reasons described in detail above, the discovery orders at issue here were clearly valid. unambiguous about their breadth, and Epstein plainly had the ability to comply. Indeed, given all the circumstances recounted here, it is clear that Epstein made a deliberate choice not to comply. The Court accordingly + +Judge Palermo has ordered Jane Doe to prepare a confidential settlement statement and file it by 5 p.m. today as part of that conference. Jane Doe's completion of that statement has been interrupted by the need to file this motion. + +should use the full panoply of powers that it possesses to punish this blatant contempt. The Court also has additional powers under Rule 37 of the Federal Rules of Criminal Procedure to deter discovery abuses. + +Jane Doe respectfully requests the Court impose the following sanctions: + +First, Epstein should be required to produce forthwith all discovery information, documents, and other evidentiary materials covered by Requests No. 7, 9, and 10 — e.g.., all discovery and evidentiary information from both the federal and state prosecuting and investigating authorities and all correspondence — in unredacted form — both from and to federal and state prosecuting and investigating authorities.5 Jane Doe respectfully requests that the Court rule on this motion before her mandated settlement conference, so that she can have the benefit of those materials at that time. + +Second, Epstein's counsel should be required to pay \$5,000 to the Court and instructed not to play any further games as this case moves to trial. + +Third, Epstein should be deemed to have waived any objection to the use by Jane Doe at trial of any of the materials subject to the discovery demands at issue here (Requests for Production Nol. 7, 9, and 10). See Fed. R. Crim. P. 37(b)(2)(A)(i) (allowing the Court to award as a sanction for discovery violation "prohibiting the disobedient party from supporting or opposing designated claims or defenses"). + +# CONFERENCE WITH COUNSEL + +Jane Doe's counsel understands Epstein to object to this motion. + +5 The full terms of the discovery requests speak for themselves. + +## CONCLUSION + +The Court should find that Epstein has deliberately violated its discovery orders, hold him in contempt of court, direct that the requested discovery be produced forthwith, and impose appropriate sanctions as described above. + +DATED: July 1.2010 + +Respectfully Submitted, + +J. JAFFE, WEISSING, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 Florida Bar No.: 542075 E-mail: brad@pathtojustice.com + +and + +Paul G. Cassell Pro Hac Vice 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: 801-585-5202 Facsimile: 801-585-6833 E-Mail: cassellp@law.utah.edu + +# CERTIFICATE OF SERVICE + +I HEREBY CERTIFY that on July 1, 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 on 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 filed Notices of Electronic Filing. + +> /s/ J. + +CASE NO: 08-CV-80893-MARRA/ [REDACTED] + +**SERVICE LIST** + +**Jane Doe v. Jeffrey Epstein** +**United States District Court, Southern District of Florida** + +Jack Alan Goldberger, Esq. +[Jgoldberger@agwpa.com](mailto:Jgoldberger@agwpa.com) + +Robert D. Critton, Esq. +[rcritton@bclclaw.com](mailto:rcritton@bclclaw.com) + +Isidro Manual [REDACTED] +[isidrogarcia@bellsouth.net](mailto:isidrogarcia@bellsouth.net) + +Michael James Pike +[MPike@bclclaw.com](mailto:MPike@bclclaw.com) + +Paul G. Cassell +[cassellp@law.utah.com](mailto:cassellp@law.utah.com) \ No newline at end of file diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821494/EFTA02821494.metadata.json b/marker2/court-redacted-v-epstein-81111/EFTA02821494/EFTA02821494.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..efd0b769e7e8acb0fd3872de3c522b6afe437deb --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821494/EFTA02821494.metadata.json @@ -0,0 +1,1002 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-redacted-v-epstein-81111/EFTA02821494.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 20, + "chars": 38857, + "elapsed_seconds": 8.27, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF FLORIDA", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 198.89999999999998, + 57.50999999999999 + ], + [ + 412.1572570800781, + 57.50999999999999 + ], + [ + 412.1572570800781, + 85.4830322265625 + ], + [ + 198.89999999999998, + 85.4830322265625 + ] + ] + }, + { + "title": "PLAINTIFF JANE DOE'S EMERGENCY MOTION TO HAVE EPSTEIN HELD IN \nCONTEMPT FOR FAILING TO PRODUCE STATE DISCOVERY AND \nCORRESPONDENCE AND FOR PRODUCING ONLY REDACTED CORRESPONDENCE \nWITH THE U.S. ATTORNEY'S OFFICE AND MOTION FOR SANCTIONS", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 63.036, + 360.45000000000005 + ], + [ + 548.9951171875, + 360.45000000000005 + ], + [ + 548.9951171875, + 416.9830322265625 + ], + [ + 63.036, + 416.9830322265625 + ] + ] + }, + { + "title": "PROCEDURAL BACKGROUND", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 215.42399999999998, + 176.57999999999998 + ], + [ + 397.90252685546875, + 176.57999999999998 + ], + [ + 397.90252685546875, + 191.68353271484375 + ], + [ + 215.42399999999998, + 191.68353271484375 + ] + ] + }, + { + "title": "EPSTEIN SHOULD BE HELD IN CONTEMPT AND SANCTIONED FOR DELIBERATE VIOLATIONS OF THE ORDER TO PRODUCE", + "heading_level": null, + "page_id": 6, + "polygon": [ + [ + 67.932, + 554.85 + ], + [ + 547.128, + 554.85 + ], + [ + 547.128, + 581.5799999999999 + ], + [ + 67.932, + 581.5799999999999 + ] + ] + }, + { + "title": "I. 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b/marker2/court-redacted-v-epstein-81111/EFTA02821514/EFTA02821514.md @@ -0,0 +1,39 @@ +## AFFIDAVIT OF JAMES + +- 1. I am an attorney in good standing with the Florida Bar and admitted to practice in the Southern District of Florida. +- 2. The law firm of Jaffe Weissing Fistos and Lehrman, of which I am apartner, filed a recent lawsuit on September 17, 2010 against Jeffrey Epstein, case number 10- 81111, in federal Court in the Southern District of Florida. +- 3. Defendant Epstein is aregistered sex offender as a result of his pleading guilty to felonies related to his illegal sexual conduct with minor children. +- 4. Through discovery in other cases, I learned that Ghislaine Maxwell and Jean Luc Brunel were close friends and business associates of Mr. Epstein who had important and relevant information concerning Mr. Epstein. +- 5. Both Ms. Maxwell and Mr. Brunel avoided having their depositions taken by relaying false information that they were out of the country with no intentions of returning. +- 6. Ms. Maxwell relayed through counsel that, just before her scheduled deposition, her mother became deathly ill, and Ms. Maxwell was therefore going to be with her mother outside the United States with no intention of returning. +- 7. She was photographed a month later in the United States attending Chelsea Clinton's wedding and that photograph was captured in US Weekly magazine. +- 8. According to widely circulated press reports, including a 60 minutes documentary and Ian Halperin's book "Bad and Beautiful: Inside the Dazzling and Deadly World of Supermodels", Mr. Brunel has been known as adrug abuser that has molested children through his modeling agencies. +- 9. Mr. Brunel frequently stayed at Epstein's house as a house guest and also has reported his primary address at an apartment building in New York at 301 East 66th Street, an apartment that is believed to be owned by Mr. Epstein. +- 10. Mr. Brunel visited Mr. Epstein approximately 67 times while Mr. Epstein was in jail serving his jail sentence for his sexual crimes in Palm Beach County. +- 11. Mr. Brunel was set for deposition and avoided his deposition by providing information through his counsel that he was out of the country with no intention of ever returning to the United States. +- 12. When Mr. Brunel relayed the information that he was out of the country with no plans to return, he was actually staying with Mr. Epstein at Mr. Epstein's according to Mr. Epstein's probation logs. +- 13. During discovery it was nearly impossible to take the deposition of someone that could provide relevant information against Mr. Epstein that was not represented by an attorney being paid by Mr. Epstein. +- 14. It was learned that in addition to paying for his own counsel, Mr. Epstein also paid for counsel for the following other material witnesses: (Epstein's executive assistant and procurer of girls for him to abuse), Larry Visoski (Epstein's personal pilot), Dave Rogers (Epstein's personal pilot), Larry (Epstein's personal pilot), (Epstein's housekeeper), (Epstein's live-in sex slave), Ghislaine Maxwell (manager of Epstein's affairs and businesses) , Mark Epstein (Epstein's brother), and Janusz Banasiak (Epstein's house manager). + +1. 15. In this case of MJ v. Jeffrey Epstein, case 10-81111, I contacted Mr. Epstein's counsel, Mr. Knight to request that he accept service for his client and he declined. +2. 16. My law firm was then forced to retain the services of [REDACTED] Marsigliano, a private investigator in New York, to serve Mr. Epstein. +3. 17. My law firm has been forced to spend more than \$1,400.00, on the service of process in this case to date. +4. 18. In a previous civil case against Jeffrey Epstein that I litigated on behalf of my client, Jane Doe, case number 08-80893, Mr. Epstein invoked his 5th amendment right against self-incrimination on nearly all discovery requests as well as all relevant questions posed to him and his co-conspirators in deposition. +5. 19. One piece of "evidence" that Mr. Epstein was ordered to produce included correspondence between him and his lawyers and the United States government. +6. 20. Mr. Epstein alleged to have produced all correspondence from the U.S. government to him or his attorneys but did not produce that correspondence from him or his attorneys to the government. +7. 21. I recently learned that there exists additional correspondence between Mr. Epstein or his attorneys and the United States government that was not produced for some unknown reason. +8. 22. Specifically, I learned that there exists correspondence between Epstein attorney Lilly Ann [REDACTED] and former United States prosecutor Matthew Menchel as well as between Epstein attorney Ken Starr and various government attorneys and/or supervisors. + +I declare under penalty of perjury that the foregoing is true and correct. + +FURTHER AFFIANT SAYETH NAUGHT. + +Dated this 11th day of November, 2010. + +![]()The foregoing instrument was acknowledged before me this 11th day of November, 2010 by BRAD [REDACTED], who is personally known to me. + +![]()Print Name: \_\_\_\_\_ + +My Commission Expires: + +![](_page_1_Picture_396.jpeg) \ No newline at end of file diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821514/EFTA02821514.metadata.json b/marker2/court-redacted-v-epstein-81111/EFTA02821514/EFTA02821514.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..c5e915c477a6e91c304f0e27107de0f7e1a3ea89 --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821514/EFTA02821514.metadata.json @@ -0,0 +1,134 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-redacted-v-epstein-81111/EFTA02821514.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 5077, + "elapsed_seconds": 6.85, + "image_assets": [ + "_page_1_Picture_396.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "AFFIDAVIT OF JAMES", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 222.894, + 75.33 + ], + [ + 433.608, + 75.33 + ], + [ + 433.608, + 89.4461669921875 + ], + [ + 222.894, + 89.4461669921875 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 563 + ], + [ + "Line", + 45 + ], + [ + "ListItem", + 14 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 344 + ], + [ + "Line", + 31 + ], + [ + "Text", + 15 + ], + [ + "PageHeader", + 2 + ], + [ + "ListGroup", + 2 + ], + [ + "Picture", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02821514" + } +} \ No newline at end of file diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821514/_page_1_Picture_396.jpeg b/marker2/court-redacted-v-epstein-81111/EFTA02821514/_page_1_Picture_396.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..7446d07bc79598fb83accdf6b3639fff0d3363fa --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821514/_page_1_Picture_396.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:b9520010323b1e09f1d5adf590bc14c9e6ae317b2990645d4de3aa657c6a8676 +size 11161 diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821516/EFTA02821516.md b/marker2/court-redacted-v-epstein-81111/EFTA02821516/EFTA02821516.md new file mode 100644 index 0000000000000000000000000000000000000000..dcb154777cdf55eba58a0847e6fde7e9185ca3c0 --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821516/EFTA02821516.md @@ -0,0 +1,37 @@ +![](_page_0_Picture_1.jpeg) + +E. Knight Burnett PA Espirito Santo Plaza Fourteen Floor 1395 Brickell Avenue Miami, FL 33131-3302 + +Jaffe, Weissing, Fistos Et Lehrman, P.L. + +October 28, 2010 + +Re: Withholding of Discoverable Materials in Jane Doe v. Epstein + +Dear Mr. Knight: + +I am writing on an urgent matter. I was recently informed that there are substantial materials that were not produced during discovery in the Jane Doe v. Epstein case, No. 9:08-CV-80893 (S.D. Fla). I am writing to alert you to my concerns and to see if you have any explanation. + +As you know, in 2009 Jane Doe propounded (among others) three discovery requests to Epstein: + +Request No. 7: All discovery information obtained by you or your attorneys as a result of the exchange of discovery in the State criminal case against you or the Federal investigation against you. + +Request No. 9: Any documents or other evidentiary materials provided to local, state, or federal law enforcement investigators or local, state or federal prosecutors investigating your sexual activities with minors. + +Request No. 10: All correspondence between you and your attorneys and state or federal law enforcement or prosecutors (includes, but not limited to, letters to and from the States Attorney's office or any agents thereof). + +425 North Andrews Avenue, Suite 2, Fort Lauderdale, Florida 33301 954.524.2820 office 954.524.2822 fax + +On June 30, 2010, after innumerable motions and continuances and delays, I finally received information responsive to that request by e-mail, totaling approximately 359 pages. Three of my clients settled their cases against Epstein shortly after receiving that information, believing that this was all the information that was subject to the discovery request (and also having filed a motion regarding redactions made in the materials and the absence of materials concerning correspondence with *state* prosecutors). + +Yesterday, I received a report from a reliable source that there was substantial additional correspondence between Epstein's attorneys and federal prosecutors – information clearly covered by the discovery requests that was not produced. In particular, I was informed that there exists email correspondence between Matthew Menchel who was working at the United States Attorney's Office and Lilly Ann [REDACTED], an Epstein attorney. Additionally, I was told that there exists a significant amount of correspondence between the United States Attorney's Office and/or other components of the Justice Department and Ken Starr, another Epstein attorney. + +I am writing to ask you whether the report I received is correct and, if so, why this information was not produced. My clients made significant financial decisions based, in part, on the fact that Epstein was not concealing other information responsive to discovery requests. Accordingly, they may have been seriously harmed if the report is correct. Before we proceed on this information that appears to be a clear obstruction of justice committed by Epstein and most likely several of his attorneys we wanted to hear your side of this story. If that correspondence was not turned over *inadvertently* then you have an ethical obligation to inform the Court of your client's *mistake* and to provide my office with the additional discovery to allow for my office to review those materials and determine whether my client was prejudiced by your client's failure to respond completely to our discovery requests and the Court's Order that compelled that production. + +Thank you in advance for your prompt response to this letter. + +Very truly yours, + +[REDACTED], JAFFE, WEISSING, [REDACTED], FISTOS & LEHRMAN, P.L. + +![]() \ No newline at end of file diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821516/EFTA02821516.metadata.json b/marker2/court-redacted-v-epstein-81111/EFTA02821516/EFTA02821516.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..c742a85b142ed43f1230aad2465e315e7ecee328 --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821516/EFTA02821516.metadata.json @@ -0,0 +1,90 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-redacted-v-epstein-81111/EFTA02821516.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 3675, + "elapsed_seconds": 7.73, + "image_assets": [ + "_page_0_Picture_1.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 81 + ], + [ + "Line", + 36 + ], + [ + "Text", + 11 + ], + [ + "PageHeader", + 1 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 15 + ], + [ + "PageHeader", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02821516" + } +} \ No newline at end of file diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821516/_page_0_Picture_1.jpeg b/marker2/court-redacted-v-epstein-81111/EFTA02821516/_page_0_Picture_1.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..de4d78e564a826b0e9422838494a476854c1befb --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821516/_page_0_Picture_1.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:3dc7484288fcc5643f9207cfb9e19212d6cb9946e57bc43683a480af8900af3c +size 11624 diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821518/EFTA02821518.md b/marker2/court-redacted-v-epstein-81111/EFTA02821518/EFTA02821518.md new file mode 100644 index 0000000000000000000000000000000000000000..e0ad85b323898c37abf9573da7451a495829e799 --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821518/EFTA02821518.md @@ -0,0 +1,99 @@ +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA + +CASE NO. 9:10-CV-81111-WPD + +M.J., + +Plaintiff, + +Vs. + +JEFFREY EPSTEIN, and + +Defendants. + +#### M.J.'S MOTION FOR PRESERVATION OF EVIDENCE RELATING TO CORRESPONCE WITH THE U.S. ATTORNEYS OFFICE. + +Plaintiff, M.J., hereby files this motion to have defendant Epstein ordered to preserve evidence — specifically (1) e-mail correspondence between Matthew Menchel at the United States Attorney's Office and Lilly Ann an Epstein attorney, regarding Epstein's plea negotiation over federal and state sex offenses, and (2) correspondence between the United States Attorney's Office and Ken Starr, another Epstein attorney, regarding Epstein's federal and state sex offenses and the prosecution or non-prosecution of such offenses. In previous litigation in this Court, Epstein did not produce this correspondence, despite being under court order to do so. This gives rise to a reasonable inference that Epstein may be deliberately withholding this correspondence, possibly with the intent to deny its existence. Accordingly, the Court should specifically order Epstein to preserve any such correspondence as possible evidence in M.J.'s case. + +### FACTUAL BACKGROUND + +On July 20, 2009, plaintiff Jane Doe (a victim of Epstein's sexual abuse similar to M.J.) filed a motion to compel production of various previously-requested documents, including discovery provided to Epstein by state and federal prosecutors in the criminal cases against him and correspondence between his criminal defense attorneys and state and federal prosecutors during the criminal investigation. Case no. 9:08-cv-80119, DE210. (Exhibit 1) Specifically, her motion sought production of the following: + +Request No. 7: All discovery information obtained by you or your attorneys as a result of the exchange of discovery in the State criminal case against you or the Federal investigation against you. + +Request No. 9: Any documents or other evidentiary materials provided to local, state, or federal law enforcement investigators or local, state or federal prosecutors investigating your sexual activities with minors. + +Request No. 10: All correspondence between you and your attorneys and state or federal law enforcement or prosecutors (includes, but not limited to, letters to and from the States Attorney's office or any agents thereof). + +(DE210 at pp. 10-12 (emphases added)). Epstein obtained an extension of time in which to respond and, two-and-a-half months later, on October 6, 2009, Epstein filed an objection to producing these items primarily on Fifth Amendment grounds (DE339). (Exhibit 2). On October 16, 2009, Jane Doe promptly filed a reply in support of her motion (DE354). (Exhibit 3) On January 22, 2010, Jane Doe filed a notice that more than 90 days had elapsed since the filing of her motion (DE453). (Exhibit 4) + +On February 4, 2010, the magistrate judge granted in part and denied in part Jane Doe's motion to compel, specifically ruling that Epstein had to produce the + +discovery provided to him by state and federal prosecutors and the requested correspondence, rejecting Fifth Amendment and other objections raised by Epstein. (case no. 9:08-cv-80119, DE462). (Exhibit 5) The magistrate judge specifically granted requests 7, 9, and 10. Id. at 10 (-Accordingly, Epstein is ordered to produce the documents subjects to these Requests [i.e., requests 7, 9, and 10] within ten (10) days from the date hereof."). + +Epstein then filed for an extension of time in which to appeal (DE464), (Exhibit 6) which Jane Doe opposed on grounds of delay (DE465) (Exhibit 7). On February 11, 2010, the Court granted in part and denied in part the extension of time, specifically warning Epstein that "[i]n the event that Magistrate Judge February 4, 2010 Order is affirmed on appeal, Defendant will have three (3) business days from the date of this Court's order to produce the documents at issue." (DE468) (Exhibit 8). Epstein then ultimately filed his appeal/motion for reconsideration of the magistrate decision on February 26, 2010. (DE477) (Exhibit 9). On March 10, 2010, Jane Doe then filed her response in Opposition to Defendant's Motion for reconsideration. (DE. 485). (Exhibit 10) + +On April 1, 2010, the magistrate judge rejected Epstein's challenge, reaffirming his earlier order that "compelled production from state and federal prosecutors in the criminal case against him." (DE513). (Exhibit 11) + +On May 6, 2010, the court held a status conference on the appeal (which also involved other consolidated cases raising similar appeals and issues). The Court asked the parties to attempt to reach a resolution of issues surrounding Epstein's net worth. + +On May 12, 2010, Epstein filed a "Consolidated" Rule 4 Review and Appeal of Portions of the Magistrate Judge's orders (DE545). (Exhibit 12) On May 27, 2010, Jane Doe filed a "protective" response to the consolidated reply, noting that she had previously responded to all of the arguments raised by the appeal and that the "consolidated" appeal did not require any new response from her (DE551). (Exhibit 13) + +On Friday, June 25, 2010, this Court entered an order affirming the magistrate judge's discovery orders in all respects (case no. 9:08-cv-80119-KAM, DE572) (Exhibit 14) and, as it previously warned Epstein, requiring Epstein to produce the discovery materials within three business days. + +At this point, despite having had a year to assemble the requested discovery items and prepare for their production — and more than four months since the Court's warning to be prepared to produce the documents on three days notice — Epstein began filing motions to restrict production. On Monday evening, June 28, 2010, at approximately 5:11 p.m., Epstein filed a motion for a protective order regarding dissemination of the materials (case no. 9:09-cv-80893, DE170) (Exhibit 15). On Tuesday morning, June 29, 2010, at approximately 9:31 a.m., the Court summarily denied the motion (DE172) (Exhibit 16 - no actual written order). Then, as the deadline for production drew even nearer, on Wednesday, June 30, 2010, at approximately 2:19 p.m., Epstein filed a motion for a right to redact tax returns that were being produced and informed the Court in his Motion that he was going to go ahead and only produce redacted tax returns (DE182). (Exhibit 17) Shortly thereafter, Epstein began transmitting redacted returns to Jane Doe's counsel via email. Acting with + +impressive speed, at approximately 2:33 p.m., the Court summarily denied Epstein's motion (DE183). (Exhibit 18 — No actual written Order) + +Following these actions by the Court, late on June 30, 2010, defendant Epstein made his production of unredacted tax returns electronically to Jane Doe's counsel. However, Epstein remarkably still failed to produce the correspondence he was required to produce in two critical ways. First, Epstein did not produce any information he had obtained from the state during discovery of the criminal investigation against him. Indeed, because he had not (apparently in his view) obtained any federal discovery during the criminal investigation, he turned over nothing at all responsive to Jane Doe's Requests No. 7 and No. 9. And similarly, with regard to correspondence from the prosecutors, Epstein also produced only correspondence with federal prosecutors — not with state prosecutors. Of course, this significantly limited the production he made, as Epstein pled guilty to state sex charges rather than federal sex charges — leaving Jane Doe with no correspondence or discovery from the State. + +Second, with regard to his correspondence with federal prosecutors that he did produce, Epstein redacted anything coming from attorneys, leaving only the responses from the federal prosecutors. The result is an often unintelligible mishmash of backand-forth emails, where only half of what is being said is disclosed. It forced Jane Doe to read everything out of context and severely limits the utility of what was produced. + +On July 1, 2010, Jane Doe filed a motion seeking to have Epstein held in contempt and sanctioned for not properly producing discovery materials. (DE-190 ). (Exhibit 19). On July 6, 2010, Epstein settled his case against Jane Doe. At that time, + +Jane Doe had correspondence primarily between Epstein attorney Jay Lefkowitz and federal prosecutors. She had no correspondence between Epstein attorney Lilly Ann and federal or state prosecutors; she likewise had no correspondence between Epstein attorney Ken Starr and federal or state prosecutors. + +Only recently was , Esq., informed that there exists e-mail correspondence between Matthew Menchel at the United States Attorney's Office and Lilly Ann an Epstein attorney. Additionally, he was told that there exists a significant amount of correspondence between the United States Attorney's Office and Ken Starr, another Epstein attorney. Declaration of J. Esq., at 21- 22. (Exhibit 20) immediately sent a letter to Chris Knight, counsel for Epstein, inquiring about the existence of such correspondence that was not produced. (Exhibit 21). Ackerman, another attorney for Jeffrey Epstein, did speak with Mr. about this correspondence and expressed that he did not feel an obligation or responsibility to attempt to confirm or deny the existence of the correspondence in question nor to produce any additional correspondence. + +# LEGAL MEMORANDUM + +It is obvious from the procedural history recounted above that Epstein has gone to great lengths to avoid producing correspondence with prosecutors about his liability for committing sex offenses. There also now exists a strong reason for believing that Epstein violated Judge Marra's discovery orders in a case similar to this one by deliberately withholding evidence. It is a matter of public discussion, for example, that Epstein hired attorney Ken Starr to help defend him against criminal sex offense + +charges. See Wikipedia Entry for Jeffrey Epstein, "Solicitation of Prostitution" (visited Oct. 30, 2010). And yet Epstein did not produce any correspondence between Mr. Starr and federal prosecutors. M.J.'s undersigned counsel has been informed that such correspondence exists. Accordingly, Epstein should have produced it on June 30, 2010 — but did not do so. + +When there is a good faith belief that evidence may be lost or destroyed, the Court has authority to order the preservation of such evidence. See AT&T Mobility L.L.C. v. Dynamic Cellular Corp., 2008 WL 2139518 (S.D. Fla. May 7, 2008); Tracfone Wireless, Inc v. Trading, Inc., 2008 WL 918243, at #1 (N.D. Tex. Mar. 13, 2008) (finding "a legitimate concern for the continuing existence and maintenance of the integrity of the evidence in question absent an order preserving the evidence."). The correspondence may be highly relevant M.J.'s claims, as it may indeed prove Epstein's awareness of his guilt of sex offenses, as well as liability to many other girls beside M.J. — evidence that will be admissible in this case under Fed. R. of Evid. 415 as well as to prove punitive damages. There should be no significant burden on Epstein, as the material in question is legal correspondence, presumably maintained in a standard file by a large and well-resourced law firm. Epstein is also a billionaire, who can hardly be heard to complain about the financial burden that such an order might impose on him. Accordingly, the evidence should be ordered preserved. + +## CONFERENCE WITH COUNSEL + +M.J.'s counsel has conferred with counsel for Epstein and was unable to reach an agreement as to this motion and understands Epstein to object to this motion. + +### CONCLUSION + +The Court should order Epstein to preserve all evidence regarding (1) e-mail correspondence between Matthew Menchel at the United States Attorney's Office and Lilly Ann an Epstein attorney, regarding Epstein's plea negotiation over federal and state sex offenses, and (2) correspondence between the United States Attorney's Office and Ken Starr, another Epstein attorney, regarding federal and state sex offenses committed by Epstein and the prosecution or non-prosecution of such offenses. + +DATED: November 11, 2010 + +Respectfully Submitted, + +JAFFE, WEISSING, , FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 Florida Bar No.: 542075 E-mail: brad@pathtojustice.com + +## CERTIFICATE OF SERVICE + +I HEREBY CERTIFY that on November 11, 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 on 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 filed Notices of Electronic Filing. + +J. + +### SERVICE LIST + +111.J. v. Jeffrey Epstein United States District Court, Southern District of Florida + +Lill Ann + +E. Kni ht + +Helaine S. Goodner + +BURNETT PA Espirito Santo Plaza, le Floor 1395 Brickell Avenue Miami, FL 33131-3302 + +Counsel for Defendant, Jeffrey Epstein \ No newline at end of file diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821518/EFTA02821518.metadata.json b/marker2/court-redacted-v-epstein-81111/EFTA02821518/EFTA02821518.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..2d4fe82d63ec66ee97050e06692344d3a0814597 --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821518/EFTA02821518.metadata.json @@ -0,0 +1,539 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-redacted-v-epstein-81111/EFTA02821518.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 9, + "chars": 13179, + "elapsed_seconds": 1.26, + 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+ } + ], + "debug_data_path": "debug_data/EFTA02821518" + } +} \ No newline at end of file diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821527/EFTA02821527.md b/marker2/court-redacted-v-epstein-81111/EFTA02821527/EFTA02821527.md new file mode 100644 index 0000000000000000000000000000000000000000..f74cad6f3e9fb7dc484f89f66a86c0f509a66dc8 --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821527/EFTA02821527.md @@ -0,0 +1,23 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA + +CASE NO. 10-81111-CIV-DIMITROULEAS + +M.J.. + +Plaintiff, + +vs. + +JEFFREY EPSTEIN and + +Defendants. + +## ORDER REFERRING MOTION TO MAGISTRATE JUDGE + +PURSUANT to 28 U.S.C. § 636 and the Magistrate Rules of the Local Rules of the Southern District of Florida, the Renewed Motion of Defendant Jeffrey Epstein to Quash Service of Process and Supporting Memorandum of Law [DE-14], in the above-captioned cause is hereby REFERRED to United States Magistrate Judge Lurana S. Snow for appropriate disposition or report and recommendation. + +DONE AND ORDERED in at Fort Lauderdale, Broward County, Florida, this 12th day of November, 2010. + +> LLIAM P. DIMITROULEA United States District Judge + +Copies furnished to: Counsel of record Magistrate Judge Snow \ No newline at end of file diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821527/EFTA02821527.metadata.json b/marker2/court-redacted-v-epstein-81111/EFTA02821527/EFTA02821527.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..4dd4490ad04b31b0a1d9bbfa48b55381e5e02d2d --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821527/EFTA02821527.metadata.json @@ -0,0 +1,109 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-redacted-v-epstein-81111/EFTA02821527.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 798, + "elapsed_seconds": 0.64, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF FLORIDA", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 206.856, + 71.28 + ], + [ + 405.5581359863281, + 71.28 + ], + [ + 405.5581359863281, + 100.4830322265625 + ], + [ + 206.856, + 100.4830322265625 + ] + ] + }, + { + "title": "ORDER REFERRING MOTION TO MAGISTRATE JUDGE", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 142.596, + 283.5 + ], + [ + 469.92901611328125, + 283.5 + ], + [ + 469.92901611328125, + 299.2330627441406 + ], + [ + 142.596, + 299.2330627441406 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 46 + ], + [ + "Line", + 23 + ], + [ + "Text", + 10 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02821527" + } +} \ No newline at end of file diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821528/EFTA02821528.md b/marker2/court-redacted-v-epstein-81111/EFTA02821528/EFTA02821528.md new file mode 100644 index 0000000000000000000000000000000000000000..d7e603377a52054bcede0eefd28bbbd8b6e2954c --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821528/EFTA02821528.md @@ -0,0 +1,21 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA + +CASE NO. 10-8111I-CIV-DIMITROULEAS + +Plaintiff, + +vs. + +JEFFREY EPSTEIN and + +Defendants. + +## OMNIBUS ORDER REFERRING MOTIONS TO MAGISTRATE JUDGE + +PURSUANT to 28 U.S.C. § 636 and the Magistrate Rules of the Local Rules of the Southern District of Florida, M.J.'s Motion for a Protective Order Barring Direct or Indirect Contact by Epstein [DE-16] and M.J.'s Motion for Preservation of Evidence Relating to Correspondence with the U.S. Attorneys Office [DE-17], in the above-captioned cause are hereby REFERRED to United States Magistrate Judge Lurana S. Snow for appropriate disposition or report and recommendation. + +DONE AND ORDERED in at Fort Lauderdale, Broward County, Florida, this 12th day of November, 2010. + +> 6LLIAM P. DIMITR United States District Judge + +Copies furnished to: Counsel of record Magistrate Judge Snow \ No newline at end of file diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821528/EFTA02821528.metadata.json b/marker2/court-redacted-v-epstein-81111/EFTA02821528/EFTA02821528.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..bb408785b599c95330e697eb985a52e2f93be826 --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821528/EFTA02821528.metadata.json @@ -0,0 +1,109 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-redacted-v-epstein-81111/EFTA02821528.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 884, + "elapsed_seconds": 0.65, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF FLORIDA", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 206.856, + 71.28 + ], + [ + 405.5581359863281, + 71.28 + ], + [ + 405.5581359863281, + 100.4830322265625 + ], + [ + 206.856, + 100.4830322265625 + ] + ] + }, + { + "title": "OMNIBUS ORDER REFERRING MOTIONS TO MAGISTRATE JUDGE", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 108.93599999999999, + 284.31 + ], + [ + 502.8746643066406, + 284.31 + ], + [ + 502.8746643066406, + 299.2330627441406 + ], + [ + 108.93599999999999, + 299.2330627441406 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 46 + ], + [ + "Line", + 23 + ], + [ + "Text", + 10 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02821528" + } +} \ No newline at end of file diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821529/EFTA02821529.md b/marker2/court-redacted-v-epstein-81111/EFTA02821529/EFTA02821529.md new file mode 100644 index 0000000000000000000000000000000000000000..52640f4fbbf475696930ffc80cc653dcab1a6725 --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821529/EFTA02821529.md @@ -0,0 +1,37 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA + +Case No. 9:10-cv-81111-WPD + +M.J., + +Plaintiff, + +vs. + +JEFFREY EPSTEIN and + +Defendant. + +## SUPPLEMENTAL AFFIDAVIT OF RICHARD BARNETT + +I, Richard Barnett, being duly sworn, do depose and state as follows: + +- I. I am over the age of 18, am otherwise competent to testify, and base the following on my personal knowledge. + - 2. I am the property manager at 9 East 71' Street, New York, New York. +- 3. I do not presently reside, nor have I ever resided, at 9 East 71" Street, New York, New York. +- 5. On October 8, 2010, no individual resided at 9 East 7I" Street, New York, New York. +- 6. Jeffrey Epstein was not present at 9 East 71" Street, New York, New York on October 8, 2010. + +FU R AFFIAJ4T A ETH NOT. + +CHARD BAR + +Sworn and subscribed before me this 2-t. day of PthAN4har , 2010 by Richard Barnett who is personally known to me or has produced as identification. + +71%1' + +NOTARY PUBLIC STATE OF NEW YORK + +MY COMMISSION EXPIRES: + +HARRY Notary SELLER Public, No. State of New York 018E41353924 OUaliffed Commission in Rockland County ny Expires Feb. 17, 20 7 \ No newline at end of file diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821529/EFTA02821529.metadata.json b/marker2/court-redacted-v-epstein-81111/EFTA02821529/EFTA02821529.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e6db55a95a0bf279821192045ba5cd8ea6216756 --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821529/EFTA02821529.metadata.json @@ -0,0 +1,151 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-redacted-v-epstein-81111/EFTA02821529.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1118, + "elapsed_seconds": 0.77, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF FLORIDA", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 198.89999999999998, + 68.85000000000001 + ], + [ + 411.78729248046875, + 68.85000000000001 + ], + [ + 411.78729248046875, + 96.7330322265625 + ], + [ + 198.89999999999998, + 96.7330322265625 + ] + ] + }, + { + "title": "SUPPLEMENTAL AFFIDAVIT OF RICHARD BARNETT", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 146.88, + 316.71000000000004 + ], + [ + 461.5976257324219, + 316.71000000000004 + ], + [ + 461.5976257324219, + 331.10302734375 + ], + [ + 146.88, + 331.10302734375 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 45 + ], + [ + "Line", + 22 + ], + [ + "Text", + 8 + ], + [ + "ListItem", + 5 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "ListGroup", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 31 + ], + [ + "Line", + 16 + ], + [ + "Text", + 7 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02821529" + } +} \ No newline at end of file diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821531/EFTA02821531.md b/marker2/court-redacted-v-epstein-81111/EFTA02821531/EFTA02821531.md new file mode 100644 index 0000000000000000000000000000000000000000..56a441255cb41a30abefe92d478622c9371079eb --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821531/EFTA02821531.md @@ -0,0 +1,163 @@ +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA + +Case No. 9:10-cv-81111-WPD + +M.J., + +Plaintiff, + +VS. + +JEFFREY EPSTEIN and + +Defendant. + +REPLY IN SUPPORT OF RENEWED MOTION OF DEFENDANT JEFFREY EPSTEIN TO QUASH SERVICE OF PROCESS, RESPONSE IN OPPOSITION TO PLAINTIFF'S MOTION FOR A HEARING TO PROVE FRAUD, TO PROVE PROPER SERVICE, TO OBTAIN SANCTIONS FOR EPSTEIN'S SUBMISSION OF A FRAUDULENT AFFIDAVIT, TO OBTAIN A WARNING FORBIDDING FURTHER OBSTRUCTIONS IN THE CASES, AND TO SET AN ACCELERATED SCHEDULE FOR DISCOVERY AND MOTION TO QUASH + +Defendant Jeffrey Epstein, by and through undersigned counsel, respectfully submits the following: 1) reply in support of Motion to Quash Service of Process (D.E.7) and Renewed Motion to Quash (D.E.I4); 2) response to Plaintiff's Motion for a Hearing to Prove Fraud, to Prove Proper Service, to Obtain Sanctions for Epstein's Submission of a Fraudulent Affidavit, to Obtain a Warning Forbidding Further Obstructions in the Cases, and to Set an Accelerated Schedule for Discovery (D.E. 15); and 3) motion to strike impertinent portions of Plaintiff's response, and states as follows: + +# I. INTRODUCTION + +Plaintiff's response to Mr. Epstein's motion and renewed motion to quash service of process attempts to distort the key issue before the Court with misstatements, misleading + +assertions, and scurrilous, unfounded and irrelevant allegations designed solely to smear Mr. Epstein and poison the well. The narrow threshold issue is whether substitute service was made pursuant to Fed. R. Civ. P. 4(eX2)(B); and not whether discovery misconduct occurred in prior litigation, as claimed by Plaintiff. Plaintiff's injection of unfounded and unproven charges of "obstruction of justice" because two witnesses refused to appear for depositions pushes the envelope of Rule 11, and should not be permitted. + +Plaintiff's bluster cannot obscure the fact that Plaintiff has not carried her burden of demonstrating that service of process was proper under Fed. R. Civ. P. 4(e)(2)(B). Contrary to Plaintiff's contention, the issue is not whether "M. J. has left a copy of her complaint and other documents with someone at the home", which is all that Plaintiff alleges, or whether Mr. Epstein had actual notice (D.E. 15 at 12), but, rather, whether the suit papers were left with "someone of suitable age and discretion who resides" at 9 East 71m Street, New York. See Fed. R. Civ. P. 4(e)(2)(B). In view of the fact that Plaintiff has failed to show that "Mark", the alleged recipient of the suit papers, was of suitable age and discretion and resided at 9 East 7111 Street, New York, Mr. Epstein's motion to quash should be granted. + +There is no need for the Court to hold an evidentiary hearing because Plaintiff has not made a prima facie showing that so-called "Mark" was "someone of suitable age and discretion who resides" at 9 East 71m Street. The affidavit of Marsigliano provides no description of "Mark", including Mark's age, other than to state that Mark was a Male. It provides no indication whatsoever that Mr. Marsigliano even made any attempt to, or did in fact, determine, the relationship of "Mark" to Mr. Epstein or 9 East 71nStreet, or whether "Mark" resided at 9 East 7In Street before allegedly delivering suit papers to "Mark". Accordingly, there is no factual dispute + +and no need for an evidentiary hearing, particularly when the evidence indicates that no one resided on the premises on October 8, 2010. Assuming arguendo that the Court were to conduct an evidentiary hearing, there is certainly no need and indeed no valid reason for Mr. Epstein, who did not submit an affidavit, to testify. + +The Court should also deny Plaintiffs motion for Rule 11 sanctions based upon the submission of an allegedly fraudulent affidavit by Mr. Barnett. Plaintiff has not offered any probative evidence of fraud, relying solely on caustic rhetoric. Moreover, Plaintiff has violated the mandatory safe harbor requirements of Fed. R. Civ. P. 11, which violations require denial of her motion. + +In addition, Plaintiff has not demonstrated that the Court should establish an "expedited schedule" and cannot point to any exigent circumstances. Mr. Epstein's financial standing does not eradicate due process or the requirements of Fed. R. Civ. P 26(O, as set forth in this Court's Order Requiring Counsel to Meet, File Joint Scheduling Report and Joint Discovery Report. (D.E. 4) + +Finally, the Court should enter an Order striking all portions of Plaintiff's response, including the affidavit of Plaintiff's counsel, Brad which allege, argue and purport to show an "obstruction of justice" in prior litigation. Such matters are patently irrelevant to the threshold issue of service of process in the instant case, are intended solely to smear Mr. Epstein and are unduly prejudicial. + +## H. BACKGROUND + +- 1. Plaintiff claims that Mr. Epstein was served on October 8, 2010. Defendant filed a Motion to Quash Service of Process on October 29, 2010 (D.E.7), and a renewed motion to quash + +on November 10, 2010. (D.E. 14) Plaintiff filed a response on November 11, 2010. (D.E. 15). + +2. The Proof of Service filed by Plaintiff (D.E. 11) states that the process server left the summons at Mr. Epstein's + +> residence or usual place of abode with Mark, a person of suitable age and discretion who resides there, on Oct. 8, 2010, and mailed a copy to the individual's last known address; + +The Proof of Service does not identify "Mark" or state that he is a caretaker (as alleged by Plaintiff). (Id.). + +3. Marsigliano, the process server, stated in an affidavit dated November 5, 2010, that on October 8, 2010, he knocked on the front door of 9 East 71° Street, New York; a person named "Mark" opened the door and took the suit papers from him; and "Mark" appeared to have authority to accept service. (D.E. 15-2, ¶¶5 and 6). Mr. Marsigliano provided no description of "Mark" in his affidavit, other than to describe "Mark" as a male. Nor did Mr. Marsigliano provide any indication whatsoever in his affidavit that "Mark" specifically advised Mr. Marsigliano or that Mr. Marsigliano specifically inquired of "Mark" as to any relationship between "Mark" and Mr. Epstein or between "Mark" and 9 East 71° Street. According to Mr. Marsigliano's affidavit, based on a brief encounter with "Mark," without ever making any specific inquiries, and on Mr. Marsigliano's "observations," alone, it was somehow "obvious" to Mr. Marsigliano that ""Mark" was familiar with Jeffrey Epstein, had authority to answer the door of Mr. Epstein's residence and accept service for Mr. Epstein." Most importantly, Mr. Marsigliano provided no indication whatsoever in his affidavit that he asked, was told or even made any attempt to determine that "Mark" resided at 9 East 71° Street, New York, New York. (Id.). Nor did Mr. Marsigliano state the time of day that he allegedly delivered the papers to "Mark". (Id.) + +4. Plaintiff has not submitted any evidence that "Mark" resided at 9 East Ti n Street, New York, New York or, indeed, that anyone else resided at that address on October 8, 2010. + +5. Richard Barnett, the property manager at 9 East 71° Street, did not reside, and has never resided, at 9 East 71° Street. (Ex. A). On October 8, 2010, no individual resided at that address. (Id). Mr. Epstein was not present at 9 East 71° Street on October 8, 2010. (Id.). + +6. Plaintiff asserts that "Epstein's counsel admit they have received proof of service from Mr. Marsigliano attesting that he left M.J.'s complaint with the caretaker at Epstein's residence or usual place of abode." (D.E. 15 at p. 11). This assertion is false. Defendant has never admitted that the proof of service states that Mr. Marsigliano left the Summons and Complaint with "the caretaker" and, more importantly, Mr. Marsigliano, himself, has never attested to leaving the papers with a "caretaker." + +7. Plaintiff asserts that "Epstein concedes the materials were left at his "vacation home." (Id) This assertion is misleading. Mr. Barnett's affidavit states only that the suit papers were discovered in the mailbox at 9 East 7l ° Street, New York, New York. (D.E. 7) + +8. Paragraphs 14-22 of Plaintiff's "Factual Background" contain allegations regarding a "Pattern of Obstruction in Other Similar Cases Against Him," based largely on the affidavit of Brad Plaintiff's counsel, submitted in the instant case. (See D.E. 15, ¶¶ 14-22 and D.E. 15-1). As set forth below, these allegations, as well as Mr. affidavit in support of same, a purported "message" to Mr. Epstein, and a Motion for an Order to Show Cause in another case (D.E. 15-1, D.E. 15-3 and D.E.- 4 respectively) should all be stricken. They pertain to witnesses and depositions in prior litigation, are entirely irrelevant to the motion to quash, and were filed for an improper purpose. + +## III. ARGUMENT + +#### A. PLAINTIFF DID NOT EFFECT SUBSTITUTE SERVICE ON MR. EPSTEIN PURSUANT TO FED. R. CIV. P. 4(e)(2)(B) AND HAS NOT CARRIED HER BURDEN OF PROVING THAT THERE WAS VALID SERVICE + +Plaintiff has tacitly conceded that no service was made on Mr. Epstein in New York pursuant to Florida or New York law.' Plaintiff has not carried her burden of establishing that service was effected on Mr. Epstein pursuant to Fed. R. Civ. P. 4(e)(2XB), which permits substitute service only if the Summons and Complaint are left at the defendant's "dwelling or usual place of abode with someone of suitable age and discretion who resides there." (Emphasis added) See, e.g., Trovarello v. McMonagle, 1998 U.S. Dist. LEXIS 18529, at \*4 (E.D. Pa. Nov. 16, 1998) ("Once the sufficiency of service of process is challenged, the party on whose service was made bears the burden of establishing the validity of service."). + +Although Plaintiff claims that service was proper merely because the papers were left with an individual named "Mark" at Mr. Epstein's house (D.E. 15 at 12), Plaintiff has not carried her burden of making a prima facie showing that the suit papers were left with someone of suitable age and discretion who resided at 9 East 71" Street on October 8, 2010, as clearly required by Rule 4(aX2)(B). Significantly, Plaintiff's response, and the November 5, 2010 affidavit of Mr. Marsigliano, are totally silent on this essential requirement. Plaintiff's failure to submit any probative evidence that "Mark" or anyone else resided at 9 East 71' Street on October 8, 2010, alone requires that service of process be quashed. This conclusion is further supported by the supplemental affidavit of Mr. Barnett in which he stated that on October 8, 2010, no one resided at + +'Plaintiff has not refuted Mr. Epstein's argument that service was not effected pursuant to Florida or New York law. Accordingly, the only issue on the table, as Plaintiff has conceded, is whether substitute service was effected pursuant to Fed. R. Civ. P. 4(eX2)(B). (See D.E. 15, ¶ 8). + +Mr. Epstein's vacation home in New York. Given the fact that no one resided at 9 East 71u Street on the date on question, service of process must be quashed. See, e.g., Trovarello, 1998 U.S. Dist. LEXIS 18529, at \*2-3 ("Numerous cases make clear that when service is made by leaving copies of the summons and complaint "with some person of suitable age and discretion then residing therein," the person with whom the papers are left must actually be a resident of defendant's home, and not merely present at the time of service."); Hardy v. Kaszycki & Sons Contractors, Inc., 842 F. Supp. 713, 717 (S.D.N.Y. 1993) (service on recipient under former Rule 4(d)(1)(now Rule 4(e)) was insufficient where nothing indicated that recipient resided in defendant's apartment); Franklin America, Inc. v. Franklin Cast Prods., Inc., 94 F.R.D. 645, 647 (E.D. Mich. 1982) (Rule 4(dX1) requires the recipient to live in the same place as the party to be served). + +As in Trovallero, in which service was quashed where the plaintiff presented "no evidence that Maureen was a resident of Defendant McAleer's home or an adult person in charge who could accept service of process on his behalf," 1998 U.S. Dist. LEXIS 18529, at \*5, service of process in the instant case is likewise invalid because Plaintiff has not presented evidence of "Mark's" age, or his relationship to Mr. Epstein or 9 East 71m Street, New York, New York, or that "Mark" was a resident of 9 East 71st Street, New York, New York. + +### B. THERE IS NO NEED TO HOLD AN EVIDENTIARY HEARING + +Plaintiff argues (D.E. 15 at 9-10) that an evidentiary hearing is necessary to resolve a factual dispute as to whether a representative of Mr. Epstein was served, and seeks permission to question Mr. Marsigliano, Mr. Barnett and Mr. Epstein at the hearing. Defendant submits that no evidentiary hearing is necessary because, as previously demonstrated, Plaintiff has not made a prima facie showing that Mr. Marsigliano served a person of suitable age and discretion who + +resided at 9 East 71° Street, New York. Absent a factual dispute, there is no need for an evidentiary hearing. + +Should the Court conclude that an evidentiary hearing is required, then there is certainly no reason to require Mr. Epstein to testify at such a hearing. Mr. Epstein has not submitted an affidavit in this case and Plaintiff has not shown any legitimate reason for him to testify at a hearing on service of process. Plaintiffs baseless contention (D.E. 15 at 10) that Mr. Epstein should be permitted to testify to his involvement in "orchestrating" a false statement by Mr. Barnett demonstrates the outrageous lengths to which Plaintiff will go to poison the well and attempt to deflect the Court's attention from the substantive service issues. Unsubstantiated allegations regarding witnesses or discovery conduct in prior proceedings not involving this Plaint?, fare patently irrelevant to the issues presented here. Moreover, evidence of other "crimes, wrongs, or acts is not admissible to prove the character of a person in order to show action in conformity therewith." Fed. R. Evid. 404(b). Plaintiff should not be permitted to examine Mr. Epstein at an evidentiary hearing in order to inject collateral and highly impertinent matters. + +## C. ACTUAL NOTICE DOES NOT OBVIATE COMPLIANCE WITH FED. R. CIV. P. 4 + +Although Plaintiff contends that Rule 4 should be liberally construed when there has been actual notice (D.E. 15 at 12), Plaintiff cites no case which holds that service is deemed proper under Rule 4(a)(2)(B) absent proof that the suit papers were delivered to an individual of suitable age and discretion residing at the defendant's house, as explicitly required by the rule. This is not a matter of mere technical non-compliance. Actual notice cannot be used to override the basic requirements of Rule 4(e)(2)(B). As the Eleventh Circuit has noted, "actual notice of a suit does not dispose of the requirements of service of process." v. Warden, FCC Coleman-USP, + +259 Fed. Appx 181, 182 n.2 (11th Cir. 2007). See also Precision Etchings & Findings v. LGP Gem, 953 F.2d 21, 24 (1st Cir. 1992rThe federal courts have made it abundantly clear that actual notice itself, without more, is insufficient to satisfy the requirements of Fed. R. Civ. P. 4(d)(1))(now 4(eX2XB)"). + +## D. NO BASIS FOR IMPOSING SANCTIONS ON MR. EPSTEIN + +Citing Fed. R. Civ. P 11, Plaintiff seeks to impose sanctions on Mr Epstein on the ground that he is responsible for the filing of a knowingly false affidavit by Mr. Barnett. Plaintiff's baseless motion for sanctions is improper, if not itself sanctionable. Plaintiff has not offered even a scintilla of evidence that Mr. Barnett submitted a knowingly false affidavit, and has levied such scurrilous charges merely to harass Mr. Epstein and obfuscate the issues. + +In addition, Plaintiff has violated Fed. R. Civ. P. 11(cX2) by not filing a separate motion for sanctions after giving the Defendant twenty-one (21) days in which to respond to the allegations. Non-compliance with the mandatory safe harbor provisions of Rule 11 mandates denial of the motion. See, e.g., Olmsted v. Defosset, 205 F. Supp. 2d 1316, 1334 (M.D. Fla. 2002). + +Accordingly, Plaintiff's motion for sanctions should be stricken or denied. + +# E. NO EXPEDITED SCHEDULE IS NEEDED + +Plaintiff has offered no valid reason for expediting the proceedings in this case. 'there are no exigent circumstances which justify an accelerated schedule. The Court should address scheduling matters after review of the parties Joint Scheduling Report. + +#### IV. THE COURT SHOULD STRIKE PARAGRAPHS 14-22 OF PLAINTIFF'S RESPONSE AND EXHIBITS 1,3 AND 4 THERETO + +Mr. Epstein hereby moves to strike paragraphs 14-22 of the "Factual Background" of Plaintiff's response, as well as Exhibits 1, 3 and 4 thereto (see D.E. 15 at pp. 6-9, D.E.15- 1, 3 and 4) on the grounds that Plaintiff's allegations, the affidavit from Plaintiff's counsel pertaining to witnesses and depositions in prior litigation involving Mr. Epstein, and Motion for Order to Show Cause submitted in prior litigation were submitted in the instant case solely to harass the Defendant and create a tempest in a tcapot.2 Conduct involving two witnesses in prior litigation, neither of whom is Richard Barnett, is patently irrelevant to the narrow, threshold issue of whether substitute service was properly made in the instant case, and should not be considered by the Court.3 Accordingly, Defendant's motion to strike should be granted. + +## V. CONCLUSION + +WHEREFORE, Defendant Jeffrey Epstein respectfully requests that service of process be quashed, that Plaintiff's motion be denied in all respects, that portions of Plaintiff's response be stricken as set forth hereinabove, and that the Court grant such other and further relief as deemed necessary and proper. + +2Plaintiffs counsel, Brad submitted his own two-page single-spaced affidavit in which he stated inter alia that: 1) in prior litigation two business associates and friends of Mr. Epstein allegedly avoided having their depositions taken; 2) in prior litigation, Mr. Epstein allegedly invoked his right against self-incrimination; and 3) in prior litigation, Mr. Epstein allegedly failed to produce certain correspondence with the United States government. (See D.E. 15-1). It is impossible to fathom how any of this is even remotely relevant to the issue of whether substitute service was properly made on Mr. Epstein in the instant case. + +3Should the Court not strike these portions of Plaintiff's submission with respect to alleged misconduct in prior litigation, Mr. Epstein would request an opportunity to respond to the allegations on the merits. + +Respectfully submitted, + +s/Lilly Anna + +Lilly Ann + +Fla. Bar No. 195677 + +E. Knight + +Fla. Bar No. 607363 + +Helaine S. Goodner + +Fla Bar No. 462111 + +BURNE IT P.A. + +Espirito Santo Plaza, 14th Floor + +1395 Brickell Avenue + +Miami, Florida 33131-3302 + +Telephone: (305) 789-9200 + +Facsimile: (305) 789-9201 + +Counsel for Defendant Jeffrey Epstein + +# CERTIFICATE OF SERVICE + +I hereby certify that on November 22, 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 on all counsel of record or pro se parties identified 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 counsel or parties who are not authorized to receive electronically Notices of Electronic Filing. + +s/Lilly Ann + +Lilly Ann + +Fla. Bar No195 77 + +# SERVICE LIST + +M.J. v. Epstein + +Case No. 9:10-cv-81111-WPD + +United States District Court, Southern District of Florida + +brad@pathtoiusticc.com Farmer, Jaffe, Weissing,EM + +Fistos & Lehrman, PL 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone: (954) 524-2820 Facsimile: (954) 524-2822 Attorneys for Plaintiff M.J. 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a/marker2/court-redacted-v-epstein-81111/EFTA02821543/EFTA02821543.md b/marker2/court-redacted-v-epstein-81111/EFTA02821543/EFTA02821543.md new file mode 100644 index 0000000000000000000000000000000000000000..d7e21e291ec4defe82b2c701212ea2d8e68cb706 --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821543/EFTA02821543.md @@ -0,0 +1,74 @@ +| FILING FEE | | +|---------------------------|----------| +| PAID | 75.00 | +| pro hac | FLS #722 | +| vice | | +| Steven M. Larimore, Clerk | | + +M.J., + +Plaintiff, + +vs. + +JEFFREY EPSTEIN and + +Defendants. + +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA + +CASE NO.: 9: I 0-CV-81111-WPD + +C r c-, \_\_IIto r • r 0 • + +# MOTION FOR LIMITED APPEARANCE, CONSENT TO DESIGNATION AND REQUEST TO ELECTRONICALLY RECEIVE NOTICES OF ELECTRONIC FILING + +In accordance with Local Rules 4.B of the Special Rules Governing the Admission and Practice of Attorneys of the United States District Court for the Southern District of Florida, the undersigned respectfully moves for the admission of Paul G. Cassell, Esquire, for purposes of limited appearance as co-counsel on behalf of M.J., herein, in the above-styled case only, and pursuant to Rule 2B, Southern District of Florida, CM/ECF Administrative Procedures, to permit Paul G. Cassell to receive electronic filings in this case, and in support thereof states as follows: + +- 1. While Paul G. Cassell Esquire, is not admitted to practice in the Southern District of Florida, he is a member in good standing of the Utah State Bar and the bar of the U.S. District Court for the District of Utah. +- 2. Movant, Brad Esquire, of the law firm of=1, Jaffe, Weissing, Fistos & Lehrman, LLP, is a member in good standing of the The Florida Bar and the United States District Court for the Southern District of Florida, maintains an office in this State for the practice of law, and hasfiled the appropriate application to be authorized to file through the Courts electronic filing system. Movant consents to be designated as a member of the Bar of this Court with whom the + +Court and opposing counsel may readily communicate regarding the conduct of the case, upon whom filings shall be served, who shall be required to electronically file all documents and things that may be filed electronically, and who shall be responsible for filing documents in compliance with the CM/ECF Administrative Procedures. See Section 2B of the CM/ECF Administrative Procedures. + +3. In accordance with the local rules of this Court, Paul G. Cassell, Esquire, has made payment (enclosed) of this Court's \$75 admission fee. A certification in accordance with Rule 4B is attached hereto. + +4. Paul G. Cassell, Esquire, by and through designated counsel and pursuant to Section 2B, Southern District of Florida, CM/ECF Administrative Procedures, hereby requests the Court to provide Notice of Electronic Filings to Paul G. Cassell, Esquire, at email address: [cassellp@law.utah.edu](mailto:cassellp@law.utah.edu). + +WHEREFORE, Brad [REDACTED], Esquire, moves this Court to enter an Order permitting Paul G. Cassell to appear before this Court on behalf of MJ, for all purposes relating to the proceedings in the above-styled matter and directing the Clerk to provide notice of electronic filings to Paul G. Cassell. + +DATED: November 23, 2010 + +Respectfully Submitted, + +![]()![]() + +### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA + +CASE NO.: 9:10-CV-81111-WPD + +M.J., + +Plaintiff, + +VS. + +JEFFREY EPSTEIN and + +Defendants. + +# CERTIFICATION OF PAUL G. CASSELL, ESQ. + +Paul G. Cassell, Esquire, pursuant to Rule 4B of the Special Rules Governing the Admission and Practice of Attorneys, hereby certifies that (1) I have studied the Local Rules of the United States District Court for the Southern District of Florida; and (2) I am a member in good standing of the Utah Bar and the bar for the U.S. District Court for the District of Utah. + +Paul G. Cassell,- •tare + +**CERTIFICATE OF SERVICE** + +I HEREBY CERTIFY that on November 23, 2010 I filed foregoing Motion for Limited Appearance, Consent to Designation and Request to Electronically Receive Notices of Electronic Filings the foregoing document with the Clerk of the Court. I also certify that the foregoing document is being served this day on all parties on the attached Service List in the manner specified, via US Mail or in some other authorized manner. + +![]()**SERVICE LIST** + +**M.J. v. 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+ +The undersigned counsel certifies that, counsel for the Defendant, Jeffrey Epstein, has conferred with Esq., counsel for the Plaintiff, in a good faith effort to resolve the issues contained within the Defendant's Motion to Strike which is embedded within the Relief in Support of the Renewed Motion of Defendant, Jeffrey Epstein, to Quash Service of Process, Response in Opposition to Plaintiffs Motion for a Hearing to Prove Fraud, to Prove Proper Service, to Obtain Sanctions for Epstein's Submission of a Fraudulent Affidavit, To Obtain Warning Forbidding Further Obstructions in the Cases, and to Set an Accelerated Schedule for Discovery and Motion to Strike ( D.E. 20). + +Lilly Ann \ No newline at end of file diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821547/EFTA02821547.metadata.json b/marker2/court-redacted-v-epstein-81111/EFTA02821547/EFTA02821547.metadata.json new file mode 100644 index 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EPSTEIN and + +Defendant. + +## NOTICE OF FILING CERTIFICATION OF COMPLIANCE WITH S.D. FI,A. LOCAL RULE 7.1 + +Defendant Jeffrey Epstein, hereby files the attached Local Rule 7.1 Certification in connection with Reply in Support of Renewed Motion of Defendant Jeffrey Epstein to Quash Service of Process, Response in Opposition to Plaintiffs Motion for a Hearing to Prove Fraud, to Prove Proper Service, to Obtain Sanctions for Epstein's Submission of a Fraudulent Affidavit, to Obtain a Warning Forbidding Further Obstructions in the Cases, and to Set an Accelerated Schedule for Discovery and Motion to Strike D.E. 20. + +Respectfully submitted, + +s/Lill Ann + +Lilly Ann + +E. Knight + +Fla. Bar No. 607363 + +Helaine S. Goodner + +Fla. Bar No 46 + +.s h oodner@MMa \_.com + +1MINIMBURNETT P.A. Espirito Santo Plaza, 14'h Floor 1395 Brickell Avenue Miami, Florida 33131-3302 Telephone: (305) 789-9200 Facsimile: (305) 789-9201 Counsel for Defendant Jeffrey Epstein + +## CERTIFICATE OF SERVICE + +I hereby certify that on November 23, 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 on all counsel of record or pro se parties identified 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 counsel or parties who are not authorized to receive electronically Notices of Electronic Filing. + +s/Lilly Ann + +Lilly Ann Fla. Bar No19 77 + +Case No. 9:10-cv-81111-WP + +## SERVICE LIST + +M.J• v. Epstein + +Case No. 9:10-cv-81111-WPD + +United States District Court, Southern District of Florida + +J. brad@ athto ustice.com + +Jaffe, Weissing, + +Fistos & Lehrman, PL 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone: (954) 524-2820 Facsimile: (954) 524-2822 Attorneys for Plaintiff M.J. 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I0-81111-CIV-DIMITROULEAS + +M.J.. + +Plaintiff, + +vs. + +JEFFREY EPSTEIN and + +Defendants. + +## ORDER GRANTING MOTION FOR LIMITED APPEARANCE1 CONSENT TO DESIGNATION AND REQUEST TO ELECTRONICALLY RECEIVE NOTICES OF ELECTRONIC FILING + +THIS CAUSE is before the Court upon the Motion for Limited Appearance of Paul G. Cassell, and Consent to Designation, requesting, pursuant to Rule 4B of the Special Rules Governing the Admission and Practice of Attorneys in the United States District Court for the Southern District of Florida, permission for a limited appearance of Paul G. Cassell in this matter and request to electronically receive notices of electronic filings. [DE-22]. This Court having considered the motion and all other relevant factors, it is hereby + +## ORDERED and ADJUDGED that: + +The Motion for Limited Appearance, Consent to Designation and Request to Electronically Receive Notices of Electronic Filing [DE-22] is hereby GRANTED. Paul G. Cassell is granted to appear and participate in this action on behalf of Plaintiff. The Clerk shall provide electronic notification of all electronic filings to Paul G. Cassell at + +cassellpa,law.utah.edu. + +DONE AND ORDERED in at Fort Lauderdale, Broward County, Florida this + +23rd day of November, 2010. + +LLIAM P. 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On October 11, 2010, Plaintiff filed a Motion for a Protective Order Barring Direct or Indirect Contact by Epstein (D.E. 16) and a Motion for Preservation of Evidence Relating to Correspondence with U.S. Attorney's Office (D.E. 17). Defendant's response to the foregoing motions is presently due on November 29, 2010. +- 2. The parties have recently been engaging in discussions to resolve the foregoing pending motions. + +Case No. 9:10-cv-81111-WPD + +3. The parties require an additional ten (10) days in which to resolve all matters pertaining to the pending motions. + +4. In order to facilitate the resolution of the foregoing motions, and to avoid unnecessary attorney's fees and utilization of judicial resources, Defendant respectfully requests that this Court grant a 10-day enlargement of time for Defendant to respond to the above-listed motions. + +5. Pursuant to Local Rule 7.1, counsel for Defendant has conferred with opposing counsel, Gary I= who has graciously advised that Plaintiff has no objection to the extension requested herein. + +6. This enlargement is sought for the reasons stated and will not prejudice any party. + +WHEREFORE, Defendant Jeffrey Epstein respectfully requests that a 10-day enlargement of time be granted and that the Court grant such other and further relief as deemed necessary and proper. + +Respectfully submitted, + +ll Ann Lilly Ann Fla. Bar No. 1 7 + +E. Fla. Bar No. 607363 11 + +Helaine S. Goodner Fla. Bar No. 462111 + +P.A. Espirito Santo Plaza, 14 Floor 1395 Brickell Avenue Miami, Florida 33131-3302 Telephone: (305) 789-9200 + +Case No. 9:10-cv-81111-WPD + +Facsimile: (305) 789-9201 + +Counsel for Defendant Jeffi-ey Epstein + +## CERTIFICATE OF SERVICE + +I hereby certify that on November 29, 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 on all counsel of record or pro se parties identified 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 counsel or parties who are not authorized to receive electronically Notices of Electronic Filing. + +s/L'll + +Lilly Ann + +Fla. Bar No. 195677 + +Case No. 9:10-ev-81111-WPD + +## SERVICE LIST + +M.J. v. Epstein + +Case No. 9: 10-cv-8IIII-WPD + +United States District Court, Southern District of Florida + +bradcn athto\* ustice.c + +Jaffe, Wcissing, + +Fistos & Lehrman, PL + +425 North Andrews Avenue, Suite 2 + +Fort Lauderdale, Florida 33301 + +Telephone: (954) 524-2820 + +Facsimile: (954) 524-2822 + +Attorneys for Plaintiff M.J. + +Served via CM/ECF \ No newline at end of file diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821553/EFTA02821553.metadata.json b/marker2/court-redacted-v-epstein-81111/EFTA02821553/EFTA02821553.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b7dfcd5dff51db818e1a8c867a9174d36880949a --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821553/EFTA02821553.metadata.json @@ -0,0 +1,273 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-redacted-v-epstein-81111/EFTA02821553.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": 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+## ORDER + +THIS CAUSE is before the Court on Defendant Jeffrey Epstein's Unopposed Motion for Extension of Time to Respond to Plaintiff's Motion for Protective Order Barring Direct Contact by Epstein and Motion for Preservation of Evidence Relating to Correspondence with U.S. Attorney's Office (Docket Entry 25), which was referred to United States Magistrate Judge Lurana S. Snow. With the Court being advised, it is hereby + +ORDERED AND ADJUDGED that the motion is GRANTED. The defendant's responses shall be filed on or before December 13, 2010. + +DONE AND ORDERED at Fort Lauderdale, Florida, this 6th day of December, 2010. + +> L &" -4-44---/A-4--)2 • ,1 -a-e—t-Li L A S. SNOW UNITED STATES MAGISTRATE JUDGE + +Copies to: All Counsel of Record \ No newline at end of file diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821557/EFTA02821557.metadata.json b/marker2/court-redacted-v-epstein-81111/EFTA02821557/EFTA02821557.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..2bda7d1b894543a53085cddc4c9870a78b21bf30 --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821557/EFTA02821557.metadata.json @@ -0,0 +1,109 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-redacted-v-epstein-81111/EFTA02821557.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 906, + "elapsed_seconds": 0.78, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF FLORIDA", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 202.572, + 71.28 + ], + [ + 413.93896484375, + 71.28 + ], + [ + 413.93896484375, + 97.08416748046875 + ], + [ + 202.572, + 97.08416748046875 + ] + ] + }, + { + "title": "ORDER", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 285.804, + 288.35999999999996 + ], + [ + 332.1343994140625, + 288.35999999999996 + ], + [ + 332.1343994140625, + 301.83416748046875 + ], + [ + 285.804, + 301.83416748046875 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 64 + ], + [ + "Line", + 30 + ], + [ + "Text", + 13 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02821557" + } +} \ No newline at end of file diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821558/EFTA02821558.md b/marker2/court-redacted-v-epstein-81111/EFTA02821558/EFTA02821558.md new file mode 100644 index 0000000000000000000000000000000000000000..c38be8ea7097f3338ad047862cca328a6fc73e22 --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821558/EFTA02821558.md @@ -0,0 +1,28 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA + +CASE NO.: 9:10-cv-81111 + +M.J., + +Plaintiff, + +VS. + +JEFFREY EPSTEIN and + +Defendants. + +## FINAL ORDER OF DISMISSAI, WITH PREJUDICE + +THIS CAUSE is before the Court upon the parties' Stipulation of Dismissal with Prejudice [DE I, filed December 13, 2010. The Court has reviewed the Stipulation, the pertinent portions of the record, and is otherwise advised in the premises. In accordance with the parties' Stipulation, it is ORDERED AND ADJUDGED as follows: + +- 1. The above-styled action is hereby DISMISSED WITH PREJUDICE. +- 2. All pending motions are DENIED AS MOOT. +- 3. The Court shall retain jurisdiction to enforce the terms of the parties' settlement. +- 4. The Clerk shall CLOSE THIS CASE. + +DONE AND ORDERED in at Fort Lauderdale, Broward County, Florida this \_ day of 2010. + +> WILLIAM P. DIMITROULEAS United States District Judge + +Copies Furnished to: All counsel of record \ No newline at end of file diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821558/EFTA02821558.metadata.json b/marker2/court-redacted-v-epstein-81111/EFTA02821558/EFTA02821558.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..a68878792799a44e10b7f1db2be9b1998ded502b --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821558/EFTA02821558.metadata.json @@ -0,0 +1,117 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-redacted-v-epstein-81111/EFTA02821558.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 939, + "elapsed_seconds": 0.77, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF FLORIDA", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 206.24400000000003, + 71.28 + ], + [ + 405.95098876953125, + 71.28 + ], + [ + 405.95098876953125, + 99.7330322265625 + ], + [ + 206.24400000000003, + 99.7330322265625 + ] + ] + }, + { + "title": "FINAL ORDER OF DISMISSAI, WITH PREJUDICE", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 163.404, + 305.37 + ], + [ + 449.6607666015625, + 305.37 + ], + [ + 449.6607666015625, + 320.6030578613281 + ], + [ + 163.404, + 320.6030578613281 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 53 + ], + [ + "Line", + 25 + ], + [ + "Text", + 11 + ], + [ + "ListItem", + 4 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02821558" + } +} \ No newline at end of file diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821559/EFTA02821559.md b/marker2/court-redacted-v-epstein-81111/EFTA02821559/EFTA02821559.md new file mode 100644 index 0000000000000000000000000000000000000000..c172a4890fedb13bb7115553f411668075999ab9 --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821559/EFTA02821559.md @@ -0,0 +1,67 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA + +CASE NO.: 9:10-cv-81111 + +M.J., + +Plaintiff, + +vs. + +JEFFREY EPSTEIN and + +Defendants. + +## STIPULATION OF DISMISSAL WITH PREJUDICE + +Plaintiff, MJ, and Defendants, JEFFREY EPSTEIN and SARA a, (collectively, "Parties"), by and through their undersigned counsel and pursuant to Rule 41 (A)(ii) of the Federal Rules of Civil Procedure, hereby stipulate to the dismissal of this action with prejudice. Each party shall bear their own attorney's fecs and costs. The Parties further stipulate that the Court shall retain jurisdiction to enforce the terms of the Parties' settlement and order thereon. + +Dated this /..rdayof December, 2010. + +Respectfully Submitted, + +BURNETT P.A. Attorneys for Defendant Jeffrey Epstein Espirito Santo Plaza, 14Th Floor 1395 Brickell Avenue Miami, FL 33131-3302 Telephone: (305)789-9200 Facsimile: (305)789-9201 E-mail: c + +—CHRI PHER KNIGHT — Florida Bar No.: 607363 + +Florida Bar No.: 542075 + +a, JAFFE, WEISS1NG, FISTOS & LEHRMAN, P.L. Attorneys for MJ 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 E-mail: bradna uathtoiusti + +**CERTIFICATE OF SERVICE** + +I HEREBY CERTIFY that on 12/13, 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 on 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 filed Notices of Electronic Filing. + +Respectfully Submitted, + +By: /s/ [REDACTED] J. [REDACTED] +[REDACTED] J. [REDACTED] + +**SERVICE LIST** + +M.J. v. Jeffrey Epstein +United States District Court, Southern District of Florida + +Lilly Ann [REDACTED] +[REDACTED] [REDACTED] +[REDACTED] E. Knight [REDACTED] + +Helaine S. Goodner +[REDACTED] + +[REDACTED] [REDACTED] BURNETT PA +Espirito Santo Plaza, 14th Floor +1395 Brickell Avenue +Miami, FL 33131-3302 + +Counsel for Defendant, Jeffrey Epstein + +Paul G. Cassell, Esq. +Pro Hac Vice +332 South 1400 E, Room 101 +Salt Lake City, UT 84112 +801-585-5202 +801-585-6833 Fax +cassellp@law.utah.edu + +Co-counsel for Plaintiff \ No newline at end of file diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821559/EFTA02821559.metadata.json b/marker2/court-redacted-v-epstein-81111/EFTA02821559/EFTA02821559.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..0d275bd81e3755afa7571334a0eccdad00e1aa39 --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821559/EFTA02821559.metadata.json @@ -0,0 +1,193 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/court-redacted-v-epstein-81111/EFTA02821559.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2338, + "elapsed_seconds": 5.15, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF FLORIDA", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 217.87199999999999, + 64.80000000000001 + ], + [ + 415.25946044921875, + 64.80000000000001 + ], + [ + 415.25946044921875, + 92.34 + ], + [ + 217.87199999999999, + 92.34 + ] + ] + }, + { + "title": "STIPULATION \nOF DISMISSAL WITH PREJUDICE", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 171.36, + 311.04 + ], + [ + 455.4958801269531, + 311.04 + ], + [ + 455.4958801269531, + 326.43 + ], + [ + 171.36, + 326.43 + ] + ] + }, + { + "title": "CERTIFICATE OF SERVICE", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 230.202, + 67.23 + ], + [ + 394.02299999999997, + 67.23 + ], + [ + 394.02299999999997, + 81.0 + ], + [ + 230.202, + 81.0 + ] + ] + }, + { + "title": "SERVICE LIST", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 266.133, + 326.43 + ], + [ + 353.829, + 326.43 + ], + [ + 353.829, + 340.2 + ], + [ + 266.133, + 340.2 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 220 + ], + [ + "Line", + 38 + ], + [ + "Text", + 14 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 58 + ], + [ + "Line", + 29 + ], + [ + "Text", + 19 + ], + [ + "SectionHeader", + 4 + ], + [ + "PageHeader", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA02821559" + } +} \ No newline at end of file diff --git a/marker2/court-redacted-v-epstein-81111/EFTA02821561/EFTA02821561.md b/marker2/court-redacted-v-epstein-81111/EFTA02821561/EFTA02821561.md new file mode 100644 index 0000000000000000000000000000000000000000..73d436893a8bf4ef73e866a484801a1f5f36a735 --- /dev/null +++ b/marker2/court-redacted-v-epstein-81111/EFTA02821561/EFTA02821561.md @@ -0,0 +1,29 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA + +CASE NO. 10-81111-CIV-DIMITROULEAS + +Plaintiff, + +vs. + +JEFFREY EPSTEIN and + +Defendants. + +## FINAL ORDER OF DISMISSAL + +THIS CAUSE is before the Court upon the Stipulation of Dismissal with Prejudice [DE-27], filed herein on December 13, 2010. The Court has carefully considered the Stipulation and is otherwise fully advised in the premises. + +Accordingly, it is ORDERED AND ADJUDGED as follows: + +- I. The Stipulation of Dismissal with Prejudice [DE-27] is hereby APPROVED; +- 2. This action is hereby DISMISSED with prejudice, with each party to bear its own attorneys' fees and costs. The Court shall retain jurisdiction to enforce the terms of the parties' settlement; +- 3. The Clerk shall CLOSE this case and DENY all pending motions as moot. + +DONE AND ORDERED in at Fort Lauderdale, Broward County, Florida, this + +14th day of December, 2010. + +WILLIAM zetra4;.\_\_P P. 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