MEMY-1805 harvest: vision-fixhub (part 9)

vision-fixhub/court-01/8f4428a21857a50c6d5175552662196399896ae9ca767d71abeadfa08204996f.md

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+Case 9:08-CV-80069-KAM Document 4-1 Entered on FLSD Docket 01/29/2008 Page 1 of 3
+
+
+
+Case 9:08-cv-80069-KAM Document 4-1 Entered on FLSD Docket 01/29/2008 Page 2 of 3
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-80069 CIV-MARRA/
+JANE DOE NO.1, by and through
+JANE DOE's FATHER as parent and natural
+guardian, and JANE DOE's FATHER, and
+JANE DOE's STEPMOTHER, individually,
+Plaintiffs,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+AFFIDAVIT IN SUPPORT OF MOTION TO STAY PROCEEDINGS
+• being duly sworn deposes and says that:
+I am the mother and natural guardian for Jane Doe No.1 as referenced in the
+Complaint filed on January 24, 2008, in the United States District Court Southern District of
+Florida, Case No. 08-80069 CIV-MARRA-||
+This Affidavit is filed in support of the
+Motion to Stay Proceedings.
+2.
+Jane Doe No. 1 will be eighteen (18) years of age on May 13, 2008.
+3.
+Jane Doe No.1 has been estranged from her father since Thanksgiving day,
+November 22, 2007.
+On January 24, 2008, Jane Doe No.I's father filed a lawsuit on behalf of himself and
+as parent and natural guardian of Jane Doe No. 1 against Jeffrey Epstein in the United States District
+Court, Southern District of Florida, Case No. 08-80069 CIV-MARRA-|
+_ Jane Doe's
+
+A
+
+
+*Case 9:08-cv-80069-KAM Document 4-1 Entered on FLSD Docket 01/29/2008 Page 3 of 3
+father filed this lawsuit against Defendant Jeffrey Epstein without the knowledge, consultation or
+consent of me or of my daughter, Jane Doe No.1.
+Jane Doe No.l does not want her lawsuit to be prosecuted on her behalf by her
+father.
+FURTHER, AFFIANT SAYETH NOT.
+steres
+natural guardian of Jane Doe No. 1
+as mother and
+STATE OF GEORGIA
+SS:
+COUNTY OF WALESKA
+The foregoing instrument was acknowledged before me this 28day or January 2008
+by
+who is personally known to me or has produced
+GA Drivers Lianse
+_as identification and who (did/did not) take an oath.
+many urey, Pauze
+Commission No.:
+TAN
+ANY B. PARKER
+NOTARY
+EXPIRES
+GEORGIA
+July 13, 2009
+PUBLIC
+Page 2of 2

vision-fixhub/court-01/8f4428a21857a50c6d5175552662196399896ae9ca767d71abeadfa08204996f.receipt.json

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vision-fixhub/court-01/8f5c330c20052696172a762a9e8c6b5912af5b7ebf9e23db41182bfb1d0a49c8.md

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+Case 99480319KAJE Doeument 546 Entered On FLSD Dookat 0405/2010 Page 1 Off 15
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO. 10-80309-CIV-
+JANE DOE No. 103,
+Plaintiff,
+VS.
+JEFFERY EPSTEIN,
+Defendant.
+DEFENDANT EPSTEIN'S MOTION TO DISMISS,COUNT VI&
+FOR MORE DEFINITE STATEMENT & TO STRIKE
+DIRECTED TO PLAINTIFF JANE DOE NO. 103'S
+COMPLAINT [dated 2/23/20101
+Defendant, JEFFREY EPSTEIN, ("EPSTEIN"), by and through his undersigned
+counsel, moves to dismiss Count Six of Plaintiff JANE DOE 103's Complaint for failure
+to state a cause of action, as specified herein. Rule 12(b)(6), Fed.R.Civ.P. (2009); Local
+Gen. Rule 7.1 (S.D. Fla. 2009). Defendant further moves for More Definite Statement
+and to Strike. Rule 12(e) and (f), In support of his motion, Defendant states:
+The Complaint attempts to allege 6 counts, all of which are purportedly brought
+pursuant to 18 U.S.C. §2255 - Civil Remedies for Personal Injuries. Count Six is subject
+to dismissal because the predicate act relied upon by Plaintiff for her claims did not come
+into effect until July 27, 2006, well after the conduct alleged by Plaintiff occurred. The
+More Definite Statement requested is for Plaintiff to allege her date of birth in that her
+being a minor has significance in the claims she alleges.
+1
+
+
+Case 9980480319KA Document 546 Entered On FLSD DOSKA 0H05201 PaGE 2 Of 15
+Supporting Memorandum of Law
+Principles of Statutory Interpretation
+It is well settled that in interpreting a statute, the court's inquiry begins with the
+plain and unambiguous language of the statutory text. CBS, Inc. v. Prime Time 24
+Venture, 245 F.3d 1217 (11" Cir. 2001); U.S. v. Castroneves, 2009 WL 528251, *3 (S.D.
+Fla. 2009), citing Reeves v. Astrue, 526 F.3d 732, 734 (11" Cir. 2008); and v.
+Husband, 376 F.Supp.2d at 610 ("When interpreting a statute, [a court's] inquiry begins
+with the text."). "The Court must first look to the plain meaning of the words, and
+scrutinize the statute's 'language, structure, and purpose."" Id. In addition, in construing
+a statute, a court is to presume that the legislature said what it means and means what it
+said, and not add language or give some absurd or strained interpretation. As stated in
+CBS, Inc., supra at 1228 - "Those who ask courts to give effect to perceived legislative
+intent by interpreting statutory language contrary to its plain and unambiguous meaning
+are in effect asking courts to alter that language, and "[courts have no authority to alter
+statutory language.... We cannot add to the terms of [the] provision what Congress left
+out.' Merritt, 120 F.3d at 1187." See also Dodd v. U.S., 125 S.Ct. 2478 (2005); 73
+Am.Jur.2d Statutes §124.
+Title 18 of the U.S.C. is entitled "Crimes and Criminal Procedure." §2255 is
+contained in "Part I. Crimes, Chap, 110. Sexual Exploitation and Other Abuse of
+Children." 18 U.S.C. §2255 (2002)', is entitled Civil remedy for personal injuries, and
+provides:
+(a) Any minor who is a victim of a violation of section 2241(c), 2242, 2243, 2251,
+2251A, 2252, 2252A, 2260, 2421, 2422, or 2423 of this title and who suffers
+' The above quoted version of 18 U.S.C. §2255 was the same beginning in 1999 until
+amended in 2006, effective July 27, 2006.
+2
+
+
+Case 998-eV80BU9KAJ Document 546 Entered On FLSD DOSKA OHOS2OMO PAGES Of 15
+personal injury as a result of such violation may sue in any appropriate United
+States District Court and shall recover the actual damages such minor sustains
+and the cost of the suit, including a reasonable attorney's fee. Any minor as
+described in the preceding sentence shall be deemed to have sustained damages
+of no less than $50,000 in value.
+(b) Any action commenced under this section shall be barred unless the complaint
+is filed within six years after the right of action first accrues or in the case of a
+person under a legal disability, not later than three years after the disability.
+See endnote 1 hereto for statutory text as amended in 2006, effective July 27,
+2006. Prior to the 2006 amendments, the version of the statute quoted above was in
+effect beginning in 1999.!
+All of Plaintiff's allegations of abuse occurred between January 2004 and May
+2005 (par. 18), well prior to 18 U.S.C. §2255 being amended.
+Motion to Dismiss
+Plaintiff's reliance on the amended version of 18 U.S.C. §2255, such reliance is
+improper. The version of Defendant's position that 18 U.S.C. §2255 in effect
+prior to the 2006 amendments applies to this action, and therefore Count Six is
+required to be dismissed as it relies on a predicate act that was not in effect at
+the time of the alleged conduct."
+Plaintiff does not specifically allege in her Complaint on which version of 18
+U.S.C. §2255 she is relying. However, in Count Six of her Complaint, 150, she alleges
+that Defendant "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(g)(I)." §2252A is one of the
+specified predicate acts under 18 U.S.C. §2255. However, subsection (g) of §2252 was
+2 Points (2) and (3) are addressed together as the legal arguments overlap.
+" In other §2255 actions filed against Defendant, Defendant has previously asserted the position
+that 18 U.S.C. §2255's creates a single cause of action on behalf of a plaintiff against a
+defendant, as opposed to multiple causes of action on a per violation basis or as opposed to an
+allowance of a multiplication of the statutory presumptive minimum damages or "actual
+damages." EPSTEIN asserts his position regarding the single recovery of damages in order to
+properly preserve all issues pertaining to the proper application of §2255 for appeal. EPSTEIN
+will fully honor his obligations as set forth in the Non-Prosecution Agreement with the United
+States Attorney's Office; principally, as related to the claims made in this case by Jane Doe 103,
+the obligations as set forth in paragraph 8 of that Agreement. In particular, EPSTEIN will not
+contest the allegation that he committed at least one predicate offense as alleged by Jane Doe
+103.
+3
+
+
+Case 998-eV80BU9KAJ Document 546 Entered On FLSD DOSKAL OHOSZOR PAGE A OF 15
+not added to the statute until 2006. Thus, to the extent that Plaintiff is relying on the
+amended version of 18 U.S.C. §2255, such reliance is improper and Count Six is required
+to be dismissed as it relies on a statutory predicate act that did not exist at the time of the
+alleged conduct.
+The statute in effect during the time the alleged conduct occurred is 18 U.S.C.
+§2255 (2005) - the version in effect prior to the 2006 amendment, eff. Jul. 27, 2006,
+(quoted above), and having an effective date of 1999 through July 26, 2006. See
+endnote 1 hereto. Plaintiff's Complaint alleges that Defendant's conduct occurred during
+the time period from the age of 17, January 2004 until approximately May 2005.
+Complaint, 1917, 18. Thus, the version in effect in 2004-2005 of 18 U.S.C. §2255
+applies.
+It is an axiom of law that "retroactivity is not favored in the law." Bowen, 488
+U.S., at 208, 109 S.Ct., at 471 (1988). As eloquently stated in Landgraf v. USI Film
+Products, 114 S.Ct. 1483, 1497, 511 U.S. 244, 265-66 (1994):
+jurisprudence, and embodies a legal doctrine centuries older than our Republic
+Elementary considerations of fairness dictate that individuals should have at
+oportily to any not they dire on from their cod conting at le
+FN18. See General Motors Corp. v. Romein, 503 U.S. 181, 191, 112 S.Ct. 1105,
+[Further citations omitted].
+4
+
+
+Case 9980480319KA Document 546 Entered On FLSD DOSKA HOS2O1 PAGES Of 15
+from passing another type of retroactive legislation, laws "impairing the Obligation of
+Contracts." The Fifth Amendment's Takings Clause prevents the Legislature (and other
+government actors) from depriving private persons of vested property rights except for
+a "public use" and upon payment of "just compensation." The prohibitions on "Bills of
+Attainder" in Art. I, §§ 9-10, prohibit legislatures from singling out disfavored persons
+and meting out summary punishment for past conduct. See, e.g.. United States v.
+, 381 U.S. 437, 456-462, 85 S.Ct. 1707, 1719-1722, 14 L.Ed.2d 484 (1965). The
+Due Process Clause also protects the interests in fair notice and repose that may be
+compromised by retroactive legislation; a justification sufficient to validate a statute's
+prospective application under the Clause "may not suffice" to warrant its retroactive
+application. Usery v. Turner Ellchorn Mining Co., 428 U.S. 1, 17, 96 S.Ct. 2882, 2893,
+49 L.Ed.2d 752 (1976).
+FN19. Article I contains two Ex Post Facto Clauses, one directed to Congress (§ 9,
+cl. 3), the other to the States (§ 10, cl. 1). We have construed the Clauses as
+applicable only to penal legislation. See Calder v. Bull, 3 Dall. 386, 390-391, 1
+L.Ed. 648 (1798) (opinion of Chase, J.).
+These provisions demonstrate that retroactive statutes raise particular concerns. The
+Legislature's unmatched powers allow it to sweep away settled expectations suddenly
+and without individualized consideration. Its responsivity to political pressures poses a
+risk that it may be tempted to use retroactive legislation as a means of retribution
+against unpopular groups or individuals. As Justice Marshall observed in his opinion for
+**1498 the Court in Weaver v. Graham, 450 U.S. 24, 101 S.Ct. 960, 67 L.Ed.2d 17
+(1981), the Ex Post Facto Clause not only ensures that individuals have "fair warning"
+about the effect of criminal statutes, but also "restricts governmental power by
+restraining arbitrary and potentially vindictive legislation." Id., at 28-29, 101 S.Ct., at
+963-964 (citations omitted). PN20
+FN20. See Richmond v. J. A. Croson Co., 488 U.S. 469, 513-514, 109 S.Ct. 706,
+732, 102 L.Ed.2d 854 (1989) (*Legislatures are primarily policymaking bodies that
+promulgate rules to govern future conduct. The constitutional prohibitions against
+the enactment of ex post facto laws and bills of attainder reflect a valid concern
+about the use of the political process to punish or characterize past conduct of
+private citizens. It is the judicial system, rather than the legislative process, that is
+the conditions that presumably would have existed had no wrong been committed")
+(STEVENS, .., concurring in part and concurring in judgment); James v. United
+states, 366 U.S. 213, 247, n. 3, 81 S.Ct. 1052, 1052, n. 3, 6 L.Ed.2d 246 (1961)
+(retroactive punitive measures may reflect "a purpose not to prevent dangerou
+conduct generally but to impose by legislation a penalty against specific persons ol
+classes of persons").
+These well entrenched constitutional protections and presumptions against
+retroactive application of legislation establish that 18 U.S.C. §2255 (2005) in effect at the
+time of the alleged conduct applies to the instant action, and not the amended version.
+5
+
+
+Case 998-eV 80B@KA Document 546 Entered On FLSD DOSKAt 0H0520A PaGEGO 15
+Not only is there no clear express intent stating that the statute is to apply
+retroactively, but applying the current version of the statute, as amended in 2006, would
+be in clear violation of the Ex Post Facto Clause of the United States Constitution as it
+would be applied to events occurring before its enactment and would increase the penalty
+or punishment for the alleged crime. U.S. Const. Art. 1, §9, cl. 3, §10, cl. 1. U.S. V.
+Seigel, 153 F.3d 1256 (11" Cir. 1998); U.S. v.
+, 162 F.3d 87 (3d Cir. 1998); and
+generally, Calder v. Bull, 3 U.S. 386, 390, 1 L.Ed. 648, 1798 WL 587 (Calder) (1798).
+The United States Constitution provides that "En]o Bill of Attainder or ex
+post facto Law shall be passed" by Congress. U.S. Const. art. I, § 9, cl. 3. A law
+violates the Ex Post Facto Clause if it " 'appli[es] to events occurring before its
+nactment … [and] disadvantage[s] the offender affected by it' by altering the
+definition
+of criminal conduct or increasing the punishment for the crime.'
+Lynce v. Mathis, 519 U.S. 433, 117 S.Ct. 891, 137 L.Ed.2d 63 (1997) (quoting
+Weaver v. Graham, 450 U.S. 24, 29, 101 S.Ct. 960, 67 L.Ed.2d 17 (1981)).
+U.S. v. Siegel, 153 F.3d 1256, 1259 (11" Cir. 1998).
+The statute, as amended in 2006, contains no language stating that the application
+is to be retroactive.
+Thus, there is no manifest intent that the statute is to apply
+retroactively, and, accordingly, the statute in effect during the time of the alleged conduct
+is to apply. Landgraf v. USI Film Products, supra, at 1493, ("A statement that a statute
+will become effective on a certain date does not even arguably suggest that it has any
+application to conduct that occurred at an earlier date.").
+This statute was enacted as part of the Federal Criminal Statutes targeting sexual
+predators and sex crimes against children. H.R. 3494, "Child Protection and Sexual
+Predator Punishment Act of 1998;" House Report No. 105-557, 11, 1998 U.S.C.A.N.
+678, 679 (1998). Quoting from the "Background and Need For Legislation" portion of
+the House Report No. 105-557, 11-16, H.R. 3494, of which 18 U.S.C. §2255 is included,
+6
+
+
+Case 998-eV80BU9KAJ Document 546 Entered On FLSD DOSKA OHOS2OMO PAGET O 15
+is described as "the most comprehensive package of new crimes and increased penalties
+ever developed in response to crimes against children, particularly assaults facilitated by
+computers." Further showing that §2255 was enacted as a criminal penalty or
+punishment, "Title II - Punishing Sexual Predators," Sec. 206, from House Report No.
+105-557, 5-6, specifically includes reference to the remedy created under §2255 as an
+additional means of punishing sexual predators, along with other penalties and
+punishments. Senatorial Comments in amending §2255 in 2006 confirm that the creation
+of the presumptive minimum damage amount is meant as an additional penalty against
+those who sexually exploit or abuse children. 2006 WL 2034118, 152 Cong. Rec. S8012-
+02. Senator Kerry refers to the statutorily imposed damage amount as "penalties." Id.
+The cases of U.S. v. Siegel, supra (11" Cir. 1998), and U.S. v.
+supra (3d
+Cir. 1998), also support Defendant's position that application of the current version of 18
+U.S.C. §2255 would be in clear violation of the Ex Post Facto Clause. In Siegel, the
+Eleventh Circuit found that the Ex Post Facto Clause barred application of the Mandatory
+Victim Restitution Act of 1996 (MVRA) to the defendant whose criminal conduct
+occurred before the effective date of the statute, 18 U.S.C. §3664(f)(1)(A), even though
+the guilty plea and sentencing proceeding occurred after the effective date of the statute.
+On July 19, 1996, the defendant Siegel pleaded guilty to various charges under 18 U.S.C.
+§371 and §1956(a)(1)(A), (conspiracy to commit mail and wire fraud, bank fraud, and
+laundering of money instruments; and money laundering). He was sentenced on March
+7, 1997. As part of his sentence, Siegel was ordered to pay $1,207,000.00 in restitution
+under the MVRA which became effective on April 24, 1996. Pub.L. No. 104-132, 110
+Stat. 1214, 1229-1236. The 1996 amendments to MVRA required that the district court
+7
+
+
+Case 998-eV80BU9WAJ Document 546 Entered On FLSD DOSKAt 0HOS2OAO PageS Of 15
+must order restitution in the full amount of the victim's loss without consideration of the
+defendant's ability to pay. Prior to the enactment of the MVRA and under the former 18
+U.S.C. §3664(a) of the Victim and Witness Protection Act of 1982 (VWPA), Pub.I. No.
+97-291, 96 Stat. 1248, the court was required to consider, among other factors, the
+defendant's ability to pay in determining the amount of restitution.
+When the MVRA was enacted in 1996, Congress stated that the amendments to the
+VWPA "shall, to the extent constitutionally permissible, be effective for sentencing
+proceedings in cases in which the defendant is convicted on or after the date of enactment
+of this Act [Apr. 24, 1996]." Siegel, supra at 1258. The alleged crimes occurred between
+February, 1988 to May, 1990. The Court agreed with the defendant's position that 1996
+MVRA "should not be applied in reviewing the validity of the court's restitution order
+because to do so would violate the Ex Post Facto Clause of the United States
+Constitution. See U.S. Const. art I, §9, cl. 3."
+The Ex Post Facto analysis made by the Eleventh Circuit in Siegel is applicable to
+this action. In resolving the issue in favor of the defendant, the Court first considered
+whether a restitution order is a punishment. Id, at 1259. In determining that restitution
+was a punishment, the Court noted that §3663A(a)(1) of Title 18 expressly describes
+restitution as a "penalty." In addition, the Court also noted that "Callthough not in the
+context of an ex post facto determination, ... restitution is a 'criminal penalty meant to
+have strong deterrent and rehabilitative effect.' United States v. Twitty, 107 F.3d 1482,
+1493 n. 12 (11th Cir.1997)." Second, the Court considered "whether the imposition of
+restitution under the MVRA is an increased penalty as prohibited by the Ex Post Facto
+Clause." Id, at 1259. In determining that the application of the 1996 MVRA would
+8
+
+
+Case 998-eV80BU9KAJ Document 546 Entered On FLSD DOSKA OHOSZOR PAGEDO 15
+indeed run afoul of the Constitution's Ex Post Facto Clause, the Court agreed with the
+majority of the Circuits that restitution under the 1996 MVRA was an increased penalty.*
+"The effect of the MVRA can be detrimental to a defendant. Previously, after considering
+the defendant's financial condition, the court had the discretion to order restitution in an
+amount less than the loss sustained by the victim. Under the MVRA, however, the court
+must order restitution to each victim in the full amount." Id, at 1260. See also U.S. v.
+, 162 F.2d 87 (3'd Circuit 1998).
+As discussed above, 18 U.S.C. §2255 was enacted as part of the criminal statutory
+scheme to punish and penalize those who sexually exploit and abuse minors, and thus, the
+Ex Post Fact Clause prohibits a retroactive application of the 2006 amended version.
+Notwithstanding the above legal analysis, in the recent case of Individual Known
+to Defendant As 08MIST096.JPG and 08mist067.jpg v. Falso, 2009 WL 4807537 (N.D.
+N.Y. Dec. 9, 2009), United States District Court for the Northern District of New York
+addressed the issue of whether §2255 is a civil or criminal statute for purposes of the
+constitutional prohibition against double jeopardy. The New York Court stated that
+"looking to the plain language of §2255(a), it is clear that the statutory intent was to
+provide a civil remedy. This is exemplified by the title ... and the fact that the statute
+aims to provide compensation to individuals who suffered personal injury as a result of
+criminal conduct against them." The New York Court in analyzing whether §2255
+violated the Constitutional prohibition against double jeopardy, concluded that although
+* The Eleventh Circuit, in holding that "the MVRA cannot be applied to a person whose
+with the Second, Third, Eighth, Ninth, and D.C. Circuits. See U.S. v. Futrell, 209 F.3d
+1286, 1289-90 (11" Cir. 2000).
+9
+
+
+Case 998-eN 80319-KAN Document 546 Entered On FLSD DOSKAL DAOSZOR PAGE 1O OF 15
+the behavior to which §2255 is criminal, it did not find that the "primary aim" was
+"retribution and deterrence." "The statute serves civil goals." The "primary aim" is "the
+compensation for personal injuries sustained as a result of criminal conduct."
+Therefore, because Jane Doe 103 has invoked the provisions of the criminal Non-
+Prosecution Agreement (NPA) between EPSTEIN and USAO (see paragraphs 25 and 26
+of complaint), plaintiff cannot avoid the full protection of the rule of lenity and due
+process to which EPSTEIN is entitled in the context of these unique factual
+circumstances.
+Although there does not exist any definitive ruling of whether the damages
+awarded under §2255 are meant as criminal punishment or a civil damages award,
+Defendant is still entitled to a determination as a matter of law that the statute in effect at
+the time of the alleged criminal conduct applies.
+As explained by the Landgraf court, supra at 280, and at 1505,5
+impair rights a party possessed when he acted, increase a party's liability for pas
+conduct, or impose new duties with respect to transactions already completed. If the
+statute would operate retroactively, our traditional presumption teaches that it does not
+Here, there is no clear expression of intent regarding the 2006 Act's application to
+conduct occurring well before its enactment. See discussion of House Bill Reports and
+Congressional background above herein.
+> In Landgraf, the United States Supreme Court affirmed the judgment of the Court of Appeals
+and refused to apply new provisions of the Civil Rights Act of 1991 to conduct occurring before
+the effective date of the Act. The Court determined that statutory text in question, §102, was
+subject to the presumption against statutory retroactivity.
+10
+
+
+Case 998-ev80BU9KAN Document 546 Entered On FLSD OAOSIZORO PAGE ALOF15
+As stated in Landgraf, "the extent of a party's liability, in the civil context as well as
+the criminal, is an important legal consequence that cannot be ignored." Courts have
+consistently refused to apply a statute which substantially increases a party's liability to
+conduct occurring before the statute's enactment. Landgraf, supra at 284-85. Even if
+plaintiff were to argue that retroactive application of the new statute "would vindicate its
+purpose more fully," even that consideration is not enough to rebut the presumption
+against retroactivity. Id, at 285-86. "The presumption against statutory retroactivity is
+founded upon sound considerations of general policy and practice, and accords with long
+held and widely shared expectations about the usual operation of legislation." Id.
+Thus, Count Six should be dismissed.
+Motion For More Definite Statement and To Strike, Rule 12(e) and (f), F.R.C.P.
+As noted above, Plaintiff alleges that she was 17 year old high school student as
+of January, 2004, and that the alleged conduct involving EPSTEIN occurred "between
+approximately January 2004 and May 2005. Thus, Plaintiff had to be 18 (no longer a
+minor) by January of 2005. Under the principles of statutory construction, the language
+of §2255(a) is clear - "Any minor who is a victim of a violation of section ...of this title
+and who suffers personal injury as a result of such violation may sue in any appropriate
+United States District Court and shall recover the actual damages such minor sustains
+and the cost of the suit, including a reasonable attorney's fee. Any minor as described in
+the preceding sentence shall be deemed to have sustained damages of no less than
+$50,000 in value."
+As Plaintiff's date of birth is significant to her §2255 claim, she should be
+required to more definitely state her date of birth so that Defendant and this Court are
+11
+
+
+Case 998-eN 80319KAN Document 546 Entered On FLSD DOSKAL DAOSZORO PAGE 12 OF 15
+able to determine precisely when she reached the age of majority. (The age of majority
+under both federal and state law is 18 years old. See 18 U.S.C. §2256(1), defining a
+"minor" as "any person under the age of eighteen years;" and §1.01, Definitions, Fla.
+Stat., defining "minor" to include "any person who has not attained the age of 18 years.")
+To the extent that Plaintiff is relying on any alleged conduct that occurred after
+her 18 birthday as an element of her §2255 claim, such allegations should be stricken as
+immaterial and she should be required to more definitely state the dates of the alleged
+conduct. See Rule 12(f). Defendant also seeks to strike 1910, 11, 12, 13, 14, 15, and 16,
+of Plaintiff's Complaint as immaterial and impertinent. None of the allegations in those
+paragraphs specifically pertain to the Plaintiff. Not until 917 does Plaintiff assert
+allegations pertaining to her and the conduct of Defendant directly involving her. What
+EPSTEIN may or may not have allegedly done with respect to other alleged girls does
+not effect Plaintiff's claim brought pursuant to §2255. The allegations in 11910-16 are not
+related to the elements of Plaintiff's §2255 claim and, thus, are required to be stricken.
+Conclusion
+Pursuant to the above, Count Six is required to be dismissed. In addition, Plaintiff
+should be required to more definitely state her date of birth, and any conduct occurring
+after her 18* birthday should be stricken, and 9910 - 16 of the Complaint should also be
+stricken.
+WHEREFORE, Defendant requests hat this Cout dismiss Count six apains him,
+and further grant his Motion for More Definite Stardent tend to Strike.
+Attorney for Defendant
+Certificate of Service
+12
+
+
+Case 948080BIKAJE Doeument 546 Entered On FLSD DOSKA OHOS2O1 PAge 13 Of 15
+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 I
+being served this day on all counsel of record identified on the following Service List ir
+the manner specified by CM/ECE on this I day of Halle
+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
+kezell@podhurst.com
+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
+Fax: 561-835-8691
+jagesq(@bellsouth.net
+Counsel for Defendant Jeffrey Epstein
+Respectfully flibmited,
+ROBERT D. CRITTON, JR., ESQ.
+Florida Bar No. 224162
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER &
+COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Counsel for Defendant Jeffrey Epstein)
+13
+
+
+Case 998-0480319-KAN Document 546 Entered On FLSD DOSKAI OHOSZORO PAGE 14 OF 15
+18 USCA $2255 (1999-July 26, 2006):
+PART I--CRIMES
+CHAPTER 110--SEXUAL EXPLOITATION AND OTHER ABUSE OF
+CHILDREN
+§ 2255. Civil remedy for personal injuries
+(a) Any minor who is a victim of a violation of section 2241(c), 2242,
+2243, 2251, 2251A, 2252, 2252A, 2260, 2421, 2422, or 2423 of this title
+and who suffers personal injury as a result of such violation may sue in
+any appropriate United States District Court and shall recover the actual
+damages such minor sustains and the cost of the suit, including a
+reasonable attorney's fee. Any minor as described in the preceding
+sentence shall be deemed to have sustained damages of no less than
+$50,000 in value.
+(b) Any action commenced under this section shall be barred unless the
+complaint is filed within six years after the right of action first accrues or
+in the case of a person under a legal disability, not later than three years
+after the disability.
+CREDIT(S)
+(Added Pub.L. 99-500, Title I, § 101(b) [Title VII, § 703(a)], Oct. 18,
+1986, 100 Stat. 1783-75, and amended Pub.L.. 99-591, Title I, § 101(b)
+[Title VII, § 703(a)], Oct. 30, 1986, 100 Stat. 3341-75; Pub.L. 105-314,
+Title VI, § 605, Oct. 30, 1998, 112 Stat. 2984.)
+18 U.S.C. $2255, as amended 2006, Effective July 27, 2006:
+PART I--CRIMES
+CHAPTER 110-SEXUAL EXPLOITATION AND OTHER ABUSE OF
+CHILDREN
+§ 2255. Civil remedy for personal injuries
+incuding sentence shal be deif co have sustained damascibed in less
+14
+
+
+Case 948080319-KANE DoGument 546 Entered On FLSD DOSKAI OHOS2010 PAGe 15 Of 15
+(b) Statute of limitations.--Any action commenced under this section shall
+be barred unless the complaint is filed within six years after the right of
+action first accrues or in the case of a person under a legal disability, not later
+than three years after the disability.
+CREDIT(S)
+(Added Pub.L. 99-500, Title I, § 101(b) [Title VII, § 703(a)), Oct. 18, 1986,
+100 Stat. 1783-75, and amended Pub.L. 99-591, Title I, § 101(b) [Title VII, §
+703(a)], Oct. 30, 1986, 100 Stat. 3341-75; Pub.L. 105-314, Title VI, § 605,
+Oct. 30, 1998, 112 Stat. 2984; Pub.L. 109-248, Title VII, § 707(b), (c), July
+27, 2006, 120 Stat. 650.)
+15

vision-fixhub/court-01/8f5c330c20052696172a762a9e8c6b5912af5b7ebf9e23db41182bfb1d0a49c8.receipt.json

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vision-fixhub/court-01/8f67235e333fe0ed8c1b55530b3f05b6574f973908ef5cd931819145eeb448a6.md

@@ -0,0 +1,279 @@
+Case 9:08-cv-80994-KAM Document 92 Entered on FLSD Docket 05/28/2010 Page 1 of 10
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA/
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related Cases:
+08-80232, 08-80380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092,
+PLAINTIFES JANE DOES 2-8' MEMORANDUM IN
+RESPONSE TO DEFENDANT'S RULE 4 APPEAL
+Plaintiffs, Jane Does 2-8 ("Plaintiffs"), by and through undersigned counsel, file this
+Memorandum in Response to Defendant's Rule 4 Appeal of the Magistrate Judge's Orders (DE
+480 and DE 513) directing Defendant to produce his income tax returns, as follows:
+Introduction
+Defendant appeals the Magistrate Judge's Orders (DE 480 and DE 513) compelling
+Defendant to produce income tax returns and related forms and schedules. He fails, however, to
+demonstrate that the Magistrate Judge's decision as to tax returns is clearly erroneous or contrary
+to law. The applicable case law establishes that the tax returns are not protected from discovery
+by the Fifth Amendment privilege under the act of production doctrine, or alternatively, that they
+fall within the "required records" exception to the Fifth Amendment privilege.
+The tax returns are indisputably relevant in these cases, particularly as to Plaintiff's
+claims for punitive damages, and given the Defendant's invocation of the Fifth Amendment in
+
+
+Case 9:08-cv-80994-KAM Document 92 Entered on FLSD Docket 05/28/2010 Page 2 of 10
+blanket fashion to all requests for net worth discovery, there is a compelling need for this
+discovery. Even if Plaintiffs could not demonstrate a compelling need for the tax returns in
+discovery, under applicable Eleventh Circuit precedent and reported cases in this District,
+Plaintiffs would be entitled to this discovery under the broad relevance standard of Fed. R. Civ.
+P. 26(b). Finally, there is no basis to delay this discovery, as the tax returns are relevant to
+punitive damages, which is an important, current issue in these cases. For the reasons set forth
+herein, Plaintiff's request that the Magistrate Judge's Orders as to Defendant's tax returns be
+affirmed and that Defendant be ordered to produce the tax return discovery requested by
+Plaintiffs.
+Argument
+I.
+DEFENDANT HAS BURDEN TO SHOW THAT MAGISTRATE
+JUDGE'S ORDER IS CLEARLY ERRONEOUS OR CONTRARY TO LAW
+In seeking reversal of the Magistrate Judge's Order as to discovery of tax returns, it is the
+Defendant's burden to show that the order is "clearly erroneous or contrary to law". 28 U.S.C.
+§636(b)(1). Absent such a showing, the Magistrate Judge's decision "shall not be disturbed."
+Emmisive Energy Corp. v. Novatac, Inc., 2009 WL 2834841 *1 (S.D. Fla. 2009). In the instant
+appeal, Defendant has not shown that the Magistrate Judge's Order to produce tax returns is
+clearly erroneous or contrary to law.
+Il.
+THE ACT OF PRODUCTION OF TAX RETURNS IS NOT
+PROTECTED BY THE FIFTH AMENDMENT PRIVILEGE
+The Plaintiffs served the following document request in discovery, to which Defendant
+asserted the Fifth Amendment privilege:
+Request No. 1: All Federal and State income tax returns, including all W-2
+forms, 1099 forms and schedules, for tax years 2003-2008.
+The Magistrate Judge rejected the Defendant's privilege assertion as to tax returns. (De 480, pp.
+8-9). In so holding, the Magistrate Judge applied the act of production doctrine set forth in
+2
+
+
+Case 9:08-cv-80994-KAM Document 92 Entered on FLSD Docket 05/28/2010 Page 3 of 10
+Fisher v. United States, 425 U.S. 391, 410 (1976) and United States v. Hubbell, 530 U.S. 27, 35-
+36 (2000). As noted by the Magistrate Judge, "Defendant cannot reasonably and in good faith
+argue that in producing these documents to Plaintiff he will somehow be incriminating himself."
+(Order, p. 9). Yet, Defendant argues just that. In Hubbell, the Supreme Court made express
+reference to tax returns in discussing documents that cannot be protected by the Fifth
+Amendment privilege under the act of production doctrine:
+[T]he fact that incriminating evidence may be the byproduct of
+obedience to a regulatory requirement, such as filing an income
+tax return, maintaining required records, or reporting an accident,
+does not clothe such required conduct with the testimonial
+privilege.
+120 U.S. at 2043, 530 U.S. at 35 (footnotes omitted) (emphasis supplied). Accord United States
+v. Hammes, 3 F.3d 1081, 1083 (7th Cir. 1993) (*[wle reject [defendant's] compulsory selfincrimination claim because the government may use voluntarily filed tax returns against a
+defendant without violating the Fifth Amendment"). See also Garner v. United States, 96 S.Ct.
+1178, 424 U.S. 648 (1976) (holding that disclosures in tax returns are not compelled
+incriminations and may be used as evidence in criminal prosecution); Ebay, Inc. v. Digital Point
+Solutions, Inc., 2010 WL 147967 *8 (N.D. Cal. 2010) (holding that a person cannot incriminate
+himself by turning over a document already in the government's possession); Federal Savings
+and Loan Ins. Corp. v. Hardee, 686 F. Supp 885 (N.D. Fla. 1988) (holding that personal income
+tax returns and supporting schedules are not protected by the "act of production" doctrine under
+Fisher).
+As an alternative to finding that the Fifth Amendment privilege does not apply because
+the act of producing documents is not testimonial and communicative, courts have invoked the
+"required records" exception to the act of production doctrine. See Federal Saving & Loan Ins.
+Corp. v. Rodrigues, 717 F. Supp. 1424, 1427 (N.D. Cal 1988) ("required records" exception is a
+3
+
+
+Case 9:08-cv-80994-KAM Document 92 Entered on FLSD Docket 05/28/2010 Page 4 of 10
+distinct basis to deny Fifth Amendment privilege alternative to the "foregone conclusion"
+rationale under Fisher). The "required records" exception defeats the Fifth Amendment privilege
+where: "(1) because of the public aspect of the required records the individual admits little of
+significance by their production; and (2) by doing business in an area where the government
+requires record keeping, an individual may be deemed to have waived the Fifth Amendment
+privilege as to the production of those records." In re Grand Jury Subpoena, 21 F.3d 226, 229
+(8th Cir. 1994).
+Defendant contends that the "required records" exception does not apply to tax returns
+because they cannot be accessed by the public. This is wrong, however, as the "required
+records" exception requires only that there be "public aspects" to the documents at issue. Id.
+Numerous courts that have addressed this precise issue have found that tax returns have "public
+aspects". See Rodrigues, 717 F. Supp. at 1426-27 (citing cases); accord Doe v. United States,
+711 F.2d 1187, 1191 (2d Cir. 1983).' Accordingly, the "required records" exception applies to
+the production of tax returns. In Rodrigues, the Court denied the Fifth Amendment privilege for
+the act of producing tax returns under the "required records" exception, noting that "records filed
+with a public body pursuant to a valid regulatory scheme have been held to have public aspects."
+Id. at 1427. Accordingly, the fact that federal tax returns cannot be accessed by the general
+public does not aid the Defendant. Accord Resolution Trust Corp. v.
+1, 794 F. Supp. 1, 3
+(D.D.C. 1992).
+Thus, there are two alternative grounds for holding that Defendant's assertion of the Fifth
+Amendment privilege to production of tax returns is invalid: (1) the tax returns are in the
+' Defendant further appears to argue that the "required records" exception should be limited to
+"highly regulated business (e.g., physicians)", citing In re Dr. John Doe, 97 F.R.D. 640, 641-643
+(S.D.N.Y. 1982). In Dr. John Doe, however, the Court held contrary to Defendant's assertion
+and consistent with the case law cited herein stating, "[w]e agree that some of these records (e.g
+W-2 and other tax forms) may indeed fall within the required records exception." Id. at 644
+(ordering that Dr. Doe comply with subpoena for W-2 forms).
+4
+
+
+Case 9:08-cv-80994-KAM Document 92 Entered on FLSD Docket 05/28/2010 Page 5 of 10
+possession of the government, their existence is a foregone conclusion, and there is no risk of
+"implicit authentication" by Defendant's production of these documents; or (2) tax returns fall
+within the "required records" exception to the act of production doctrine, and are thus not
+protected by the Fifth Amendment. Under either of these grounds, the Defendant's tax returns
+are not privileged and must be produced in discovery.
+II. THERE IS NO HEIGHTENED BURDEN
+FOR DISCOVERY OF TAX RETURNS
+Defendant asserts that there is a heightened burden on a party seeking discovery of tax
+returns, requiring that party to show not only relevance, but also that "a compelling need for the
+tax returns exists because the information contained therein is not otherwise available." (Appeal,
+p. 24). However, in the Eleventh Circuit this heightened burden has been rejected. "IT]he
+Eleventh Circuit does not require a showing of compelling need before tax information may be
+obtained by a party in discovery." Bellosa v. Universal Tile Restoration, Inc.., 2008 WL 2620735
+(S.D. Fla. 2008) (citing Maddow v. Procter & Gamble Co., 107 F.3d 846 (11th Cir. 1997));
+accord U.S. v. Certain Real Property, 444 F.Supp. 2d 1258 (S.D.Fla. 2006); Platypus Wear, Inc.
+y. Clarke Modet & Co., 2008 W.L. 728540 (S.D. Fla. 2008); Preferred Care Partners Holding
+Corp. v. Humana, Inc., 2008 WL 4500258 (S.D. Fla. 2008); Ruskin Co. v. Greenheck Fan Corp.,
+2009 WL 383349 (S.D. Fla. 2009). Significantly, in both Preferred Care and Ruskin the Court
+affirmed the decision of a Magistrate Judge rejecting a higher standard for production of tax
+returns, holding that, despite an arguable split of authority, ' the Magistrate Judge's decision was
+not "contrary to law." Id. Likewise, the Magistrate Judge's decision in this case compelling
+* Defendant relies upon Pendlebury v. Starbucks Coffee Co., 2008 WL 2105024 (S.D. Fla. 2005)
+and Dunkin Donuts, Inc. v. Mary's Donuts, Inc., 2001 WL 34079319 (S.D. Fla. 2001), in which
+the Court applied the higher standard. These cases do not consider the Eleventh Circuit's
+opinion in Maddow, and the federal judges in this District over the past five years since
+Pendlebury have consistently rejected the "compelling need" standard for production of tax
+returns. See cases cited above.
+5
+
+
+Case 9:08-cv-80994-KAM Document 92 Entered on FLSD Docket 05/28/2010 Page 6 of 10
+production of tax returns is consistent with authority in this District and the Eleventh Circuit, and
+thus should be affirmed.
+IIl.KEVIDENCE OF DEFENDANT'S FINANCIAL
+STATUS AND HISTORY IS RELEVANT TO
+PUNITIVE DAMAGES, AMONG OTHER ISSUES
+Defendant does not go so far as to contend that the discovery of his tax returns is not
+relevant under Fed.R.Civ.P. 26. Defendant only argues that the Magistrate Judge did not address
+the relevancy standard in her Order. (Appeal, p. 25). As a result, Defendant does nothing to
+show that the Magistrate Judge's Order as to tax returns is clearly erroneous or contrary to law.
+In any event, it is abundantly clear that Defendant's financial status and history are relevant to
+punitive damages, among other issues in these cases, and in this regard the Defendant's tax
+returns are pertinent and discoverable. Tennant v. Charlton, 377 So.2d 1169 (Fla. 1979) (holding
+that party may obtain tax returns for purposes of net worth discovery on issue of punitive
+damages). See also State v. O'Malley, 53 S.W. 3d 623 (Mo. App. 2001) ("[ilt is well settled that
+when a plaintiff seeks punitive damages against a defendant, evidence of the defendant's
+financial status is both relevant and admissible"); Interstate Narrow Fabrics, Inc. V. Century
+USA, Inc., 2004 WL 444570 (M.D. N.C. 2004) (holding that tax returns are relevant to the jury's
+determination of the amount of punitive damages to award); E.J. Lavino & Co. v. Universal
+Health Services, Inc., 1991 WL 275767 (E.D. Pa. 1991) ("[m]ost courts that have considered this
+issue have held that a plaintiff seeking punitive damages may discovery information pertaining
+to a defendant's net worth").
+Defendant further argues that he should not have to produce his tax returns until it
+becomes apparent" that "punitive damages will be an issue." (Appeal, p. 26). This argument
+ignores Florida law on punitive damages. It is well established that "punitive damages are
+always recoverable in intentional tort cases where malice is one of the essential elements of the
+6
+
+
+Case 9:08-cv-80994-KAM Document 92 Entered on FLSD Docket 05/28/2010 Page 7 of 10
+tort." Ciamar Marcay, Inc. v. Monteiro Da Costa, 508 So.2d 1282 (Fla. 3d DCA 1987)
+(emphasis supplied). "In Florida it is clear that an act of intentional assault and battery
+committed without legal justification supplies proof of malice." Joab, Inc. v. Thrall, 245 So.2d
+291 (Fla. 3d DCA 1971). Therefore, it is clear in this intentional tort case that punitive damages
+are an issue. As this Court knows, Defendant Epstein is alleged to have perpetrated a plan and
+scheme to sexually molest dozens of underage teenage girls."
+Even assuming that the "compelling need" standard were applicable for discovery of tax
+returns, clearly in this case there is a compelling need. Defendant has provided no net worth
+discovery, asserting a blanket Fifth Amendment privilege.* Defendant nonetheless contends that
+there exists an "alternative" - not to discovery of the necessary information, but through his offer
+to "stipulate" to a net worth in the nine figures. Of course, a stipulation requires the consent of
+the parties and there is no agreement in this case on the Defendant's net worth. Defendant
+cannot unilaterally by fiat claim a certain net worth for purposes of trial. The law is well
+established that a jury may determine punitive damages "by exacting from [the defendant's]
+pocketbook a sum of money which, according to his financial ability, will hurt, but not
+" Defendant's reliance on Gallina v. Commerce and Industry Ins., 2008 WL 3895918 (M.D. Fla.
+2008) is misplaced. Gallina is an insurance bad faith case and does not involve a claim of
+punitive damages against an intentional tortfeasor. Moreover, in the present case it would make
+no sense to have a different "stage" for punitive damages discovery or trial.
+4 "[T]he burden to identify an alternative source of the information lies with the resisting party."
+Interstate Narrow Fabrics, 2004 WL 444570 at *2. Here, Epstein's blanket Fifth Amendment
+privilege assertion to all net worth discovery makes it clear that there is a compelling need for
+any net worth discovery not protected by the Fifth Amendment privilege.
+S Defendant relies upon Myers v. Central Florida Investment, Inc., 592 F.3d 1201 (11th Cir.
+2010) for its "stipulation" argument. In Myers, however, the district court heard testimony
+regarding each of the defendant's net worth. There was no unilateral statement of net worth in
+Myers as Defendant wishes to create in the instant case. To the extent that Defendant relies
+upon the Court's holding in Myers regarding the reasonableness of the trial court's award of
+punitive damages, the issue of reasonableness is determined by the particular facts and
+circumstances of the case and the discussion in Myers of this issue has no relevance here. Id.
+7
+
+
+Case 9:08-cv-80994-KAM Document 92 Entered on FLSD Docket 05/28/2010 Page 8 of 10
+bankrupt." Joab, Inc. v. Thrall, 245 So.2d 291 (Fla. 3d DCA 1971) (emphasis supplied).
+Plaintiffs are therefore entitled to discovery on the Defendant's real net worth so that the jury
+will be in a position to make an award that "will hurt". In any event, it seems beyond dispute
+that Defendant's tax returns are relevant and discoverable, either under a straight relevance test
+under Fed.R.Civ.P. 26 or a heightened "compelling need" standard.
+Conclusion
+Based on the foregoing, the Magistrate Judge's Orders as to Defendant's production of
+tax returns in response to Plaintiffs" document request no. 1 are not clearly erroneous and not
+contrary to law. As a result, the Magistrate Judge's Orders as to production of tax returns should
+be affirmed. Plaintiffs respectfully request that the documents responsive to Plaintiffs' document
+request no. 1 be ordered to be produced forthwith.
+Dated: May 28, 2010.
+Respectfully submitted,
+By: s/ Stuart S. Mermelstein
+Stuart S. Mermelstein (FL Bar No. 947245)
+ssm@sexabuseattorney.com
+Adam D. Horowitz (FL Bar No. 376980)
+ahorowitz@sexabuseattorney.com
+MERMELSTEIN & HOROWITZ, P.A.
+Attorneys for Plaintiffs
+18205 Biscayne Blvd., Suite 2218
+Miami, Florida 33160
+Tel: (305) 931-2200
+Fax: (305) 931-0877
+8
+
+
+Case 9:08-cv-80994-KAM Document 92 Entered on FLSD Docket 05/28/2010 Page 9 of 10
+CERTIFICATE OF SERVICE
+I hereby certify that on May 28, 2010, I electronically filed the foregoing document with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served
+this day to all parties on the attached Service List in the manner specified, either via transmission
+of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for
+those parties who are not authorized to receive electronically Notices of Electronic Filing.
+Is/ Stuart S. Mermelstein
+
+
+Case 9:08-cv-80994-KAM Document 92 Entered on FLSD Docket 05/28/2010 Page 10 of 10
+SERVICE LIST
+DOE vs. JEFFREY EPSTEIN
+United States District Court, Southern Distriet of Florida
+Jack Alan Goldberger, Esq.
+jgoldberger@agwpa.com
+Robert D. Critton, Esq.
+rcritton @bclclaw.com
+James
+bedwards@rra-law.com
+Isidro Manuel
+isidrogarcia@bellsouth.net
+Jack
+jph@searcylaw.com
+Katherine Warthen Ezell
+KEzell@podhurst.com
+Michael James Pike
+MPike@bclclaw.com
+Paul G. Cassell
+cassellp@law.utah.edu
+Richard Horace Willits
+lawyerwillits@aol.com
+Robert C. Josefsberg
+rjosefsberg@ podhurst.com
+10

vision-fixhub/court-01/8f67235e333fe0ed8c1b55530b3f05b6574f973908ef5cd931819145eeb448a6.receipt.json

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vision-fixhub/court-01/8f6c5eccb12f861b4e3b203c576683335ed447f8d36e26ea83882029a637b399.md

@@ -0,0 +1,81 @@
+Case 9:08-cv-80736-KAM Document 205-3 Entered on FLSD Docket 07/05/2013 Page 1 of 4
+Appendix C
+
+
+Case 9:08-cv-80736-KAM Document 205-3 Entered on FLSD Docket 07/05/2013 Page 2 of 4
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO. 08-80736-CIV-MARRA
+JANE DOE #1 and JANE DOE #2,
+Petitioners,
+VS.
+UNITED STATES,
+Respondent.
+MOTION TO SEAL
+The United States of America, by and through the undersigned Assistant United States
+Attorney, hereby moves to seal its Motion to Stay Discovery Pending Ruling upon Respondent's
+Motion to Dismiss for the following reasons:
+1.
+The Motion contains information regarding proceedings before West Palm Beach
+Federal Grand Jury 05-02 and West Palm Beach Federal Grand Jury 07-103, which is subject to the
+secrecy protections of Fed. R. Crim. P. 6.
+Pursuant to Rule 6(e)(6), "[r]ecords, orders, and subpoenas relating to grand-jury
+proceedings must be kept under seal to the extent and as long as necessary to prevent the
+unauthorized disclosure of a matter occurring before a grand jury."
+On November 7, 2011, the United States moved for permission to disclose limited
+information from those grand jury proceedings relevant to this litigation. The Court issued an Order
+allowing such limited disclosure, but required that all pleadings containing such information be filed
+under seal.
+
+
+Case 9:08-cv-80736-KAM Document 205-3 Entered on FLSD Docket 07/05/2013 Page 3 of 4
+WHEREFORE, the United States respectfully requests that the Motion to Stay Discovery
+Pending Ruling upon Respondent's Motion to Dismiss be sealed.
+DATED: November 7, 2011
+Respectfully submitted,
+By:
+WIFREDO A. FERRER
+UNITED STATES ATTORNEY
+Acclane for
+DEXTER A. LEE
+Assistant U.S. Attorney
+Fla. Bar No. 0936693
+I VILLAFAÑA
+99 N.E. 4'" Street
+Miami, Florida 33132
+(305) 961-9320
+Fax: (305) 530-7139
+E-mail: dexter.lee@usdoj gov
+Attorney for Respondent
+CERTIFICATE OF SERVICE
+The undersigned hereby certifies and affirms that a copy of the foregoing was served via
+United States Mail this 7th day of November, 2011, upon Counsel for Petitioners Jane Doe #1 and
+Jane Doe #2.
+DEXTER A. LEF
+ASSISTANT U.S. ATTORNEY
+
+
+Case 9:08-cv-80736-KAM Document 205-3 Entered on FLSD Docket 07/05/2013 Page 4 of 4
+Brad
+, Esq.,
+The Law Offices of Brad
+Associates, LLC
+2028
+Street, Suite 202
+Hollywood, Florida 33020
+(954) 414-8033
+Fax: (954) 924-1530
+SERVICE LIST
+Jane Does 1 and 2 v. United States,
+Case No. 08-80736-CIV-MARRA/
+United States District Court, Southern District of Florida
+1 &
+Paul G. Cassell
+S.J. Quinney College of Law at the
+University of Utah
+332 S. 1400 E.
+Salt Lake City, Utah 84112
+(801) 585-5202
+Fax: (801) 585-6833
+E-mail: casselp@law.utah.edu
+Attorneys for Jane Doe # 1 and Jane Doe # 2

vision-fixhub/court-01/8f6c5eccb12f861b4e3b203c576683335ed447f8d36e26ea83882029a637b399.receipt.json

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vision-fixhub/court-01/8f763f2cd094be0c23a0bb4479e0550c437e7ac7820f2d54400ffb8f75e8421d.md

@@ -0,0 +1,423 @@
+Case 1:20-cv-00484-JGK-DCF Document 37 Filed 04/17/20 Page 1 of 14
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+JANE DOE,
+Plaintiff
+V.
+DARREN K. INDYKE and RICHARD D. KAHN in
+their capacities as the executors of the ESTATE OF
+JEFFREY EDWARD EPSTEIN and GHISLAINE
+MAXWELL, an individual,
+Defendants.
+Case No. 1:20-cv-00484-JGK-DCF
+THE CO-EXECUTORS' MEMORANDUM OF LAW IN SUPPORT OF
+THEIR MOTION TO DISMISS IN PART PLAINTIFF'S COMPLAINT
+TROUTMAN SANDERS LLP
+875 Third Avenue
+New York, New York 10022
+Tel: 212-704-6000
+Fax: 212-704-6288
+Attorneys for Defendants
+Darren K. Indyke and Richard D. Kahn,
+as Co-Executors of the Estate of Jeffrey E. Epstein
+
+
+Case 1:20-cv-00484-JGK-DCF Document 37 Filed 04/17/20 Page 2 of 14
+TABLE OF CONTENTS
+Page
+1
+2
+PRELIMINARY STATEMENT
+ARGUMENT
+A.
+B.
+C.
+Legal Standard: Legal conclusions, labels and formulaic recitations of the
+elements of causes of action are insufficient to state a claim.
+Plaintiff's claims based on alleged torts that occurred outside of New York
+and those that occurred when she was an adult, regardless of location, are
+time-barred
+Plaintiff's claim for false imprisonment must be dismissed in its entirety
+as untimely.
+Plaintiff's claim for punitive damages against the Co-Executors must be
+dismissed because each jurisdiction where the torts allegedly occurred
+bars recovery of punitive damages against a deceased tortfeasor's estate.
+CONCLUSION
+2
+2
+4
+6
+8
+i
+
+
+Case 1:20-cv-00484-JGK-DCF Document 37 Filed 04/17/20 Page 3 of 14
+TABLE OF AUTHORITIES
+Page(s)
+Cases
+AHW Inv. P'ship, MFS, Inc. v. Citigroup Inc.,
+661 F. App'x 2 (2d Cir. 2016)
+Ashcroft v. Iqbal,
+556 U.S. 662(2009).
+Bell Atl. Corp. v. Twombly,
+550 U.S. 544 (2007)
+Carson Optical Inc. v. eBay Inc.,
+202 F. Supp. 3d 247 (E.D.N.Y. 2016) ....
+Deutsch v. Novartis Pharms. Corp.,
+723 F. Supp. 2d 521 (E.D.N.Y. 2010) ....
+Guidi v. Inter-Continental Hotels Corp.,
+No. 95-CV-9006, 2003 U.S. Dist. LEXIS 6390 (S.D.N.Y. Apr. 16, 2003).
+In re M.,
+93 Misc. 2d 545 (N.Y. Fam. Ct. Bronx Cnty. 1978) .
+In re Merrill
+Auction Rate Sec. Litig.,
+851 F. Supp. 2d 512 (S.D.N.Y. 2012).....
+In re Venie,
+No. 2017-NMSC-018, 395 P.3d 516 (Sup. Ct. N.M. 2017)
+Jaramillo v. Providence Wash. Ins. Co.,
+117 N.M. 337 (N.M. 1994)
+Kunica v. St. Jean Fin.,
+No. 97 Civ. 3804, 1998 U.S. Dist. LEXIS 11867 (S.D.N.Y. July 29, 1998)
+(Sweet, J.).
+Nash v. Coram Healthcare Corp.,
+No. 96 Civ. 0298 (LMM), 1996 U.S. Dist. LEXIS 9101 (S.D.N.Y. June 27,
+1996)
+Poindexter v. Zacharzewski,
+No. 18-civ-14155, 2018 U.S. Dist. LEXIS 189861 (Nov. 5, 2018 S.D. Fla.).
+.6
+.2
+2
+.2
+6
+.6
+.5
+8
+.4
+.7
+..7
+.8
+..7
+ii
+
+
+Case 1:20-cv-00484-JGK-DCF Document 37 Filed 04/17/20 Page 4 of 14
+Simons v. Marriott Corp.,
+No. 92 Civ. 3762 (SWK), 1993 U.S. Dist. LEXIS 14365 (S.D.N.Y. Oct. 12,
+1993)
+S/B v. N.Y.C. Dep't of Educ.,
+No. 03 Civ. 6653, 2004 U.S. Dist. LEXIS 13227 (S.D.N.Y. July 14, 2004)
+(Buchwald, J.).
+Starr Indem. & Liab. Co. v. Am. Claims Mgmt.,
+No. 14-cv-0463-JMF, 2015 U.S. Dist. LEXIS 60272 (S.D.N.Y. May 7, 2015).
+The Cookware Co. (USA), LLC v. Austin,
+No. 15 Civ. 5796, 2016 U.S. Dist. LEXIS 177691 (S.D.N.Y. Dec. 8, 2016)
+(Batts, J.)
+Whitley v. Bowden,
+No. 17-cv-3564 (KMK), 2018 WL 2170313 (S.D.N.Y. May 9, 2018)….
+Statutes
+CPLR 214-g..
+CPLR $ 202
+CPLR § 214(5).
+CPLR § 215(3).
+EPTL § 11-3.2 (a)(1).
+Fla. Stat. § 95.11 (3)(O).
+Fla. Stat. § 95.11(7).
+Fla. Stat. § 95.11(9).
+N.M. Stat. § 37-1-8
+N.M. Stat. § 37-1-30
+N.M. Stat. § 37-1-30(A)(2).
+New York Child Victims' Act
+New York Penal Law Art. 130
+New York Penal Law Article 135.
+.6
+...7
+.6
+..7
+.2,3
+.3,5
+...4
+4, 6
+4, 6
+....7
+.3
+...3
+3,4
+.4
+..4
+.4
+.2
+4, 5, 6
+.5
+iii
+
+
+Case 1:20-cv-00484-JGK-DCF Document 37 Filed 04/17/20 Page 5 of 14
+Other Authorities
+C.L
+& A.
+, 5C Fed. Prac. & Proc. Civ. § 1380 (3d ed.)
+N.Y.P.L. §§ 135.00
+Federal Rule of Civil Procedure 12(b)(6)…...
+Restatement (Second) of Torts.
+WAYNE R. LAFAVE, ET AL., CRIMINAL PROCEDURE, § 16.4(c) (4th ed. 2019)
+.8
+..5
+..1
+...7
+.3
+iv
+
+
+Case 1:20-cv-00484-JGK-DCF Document 37 Filed 04/17/20 Page 6 of 14
+Defendants Darren K. Indyke and Richard D. Kahn, as Co-Executors of the Estate of
+Jeffrey E. Epstein (the "Co-Executors"), submit this memorandum of law in support of their
+motion, made pursuant to Federal Rule of Civil Procedure 12(b)(6), to dismiss Counts I-IV in
+Plaintiff Jane Doe's (*Plaintiff") Complaint (ECF Doc. 9) to the extent they are time-barred, Count
+V in its entirety, and Plaintiff's demand for punitive damages against them.
+PRELIMINARY STATEMENT
+Several of Plaintiff's claims, which allege torts that ended over twenty years ago, are timebarred. Plaintiff alleges that Jeffrey E. Epstein ("Decedent"), now deceased, sexually abused her
+starting in 1994, when she was 14, until sometime in 1999, when Plaintiff was an adult, in Florida,
+New York and New Mexico. (Compl. 11 17-19, 21, 22, 24.) Plaintiff alleges she was 16 in 1996
+(id. at 1| 20); she therefore turned 18 in 1998. Plaintiff asserts causes of action for sexual assault,
+sexual battery, intentional infliction of emotional distress and false imprisonment, and seeks
+punitive damages. (Id. at 11 33-58, 60.)
+While preserving all rights and legal positions, the Co-Executors do not seek to dismiss
+Plaintiff's first four claims (for battery, assault, and infliction of emotional distress) in their
+entirety. However, to the extent those claims are based on alleged torts that occurred in Florida or
+New Mexico, or after Plaintiff turned 18, regardless of where they occurred, they are time-barred
+and must be dismissed.
+Further, Plaintiff's fifth claim (false imprisonment) must be dismissed in its entirety for
+two reasons. First, the claim is time-barred regardless of how old Plaintiff was at the time or where
+it occurred. Second, even if it were not time-barred, Plaintiff failed to allege the facts necessary to
+assert a claim for false imprisonment.
+1
+
+
+Case 1:20-cv-00484-JGK-DCF Document 37 Filed 04/17/20 Page 7 of 14
+Finally, Plaintiff's claim for punitive damages against the Co-Executors must be dismissed
+as a matter of law. None of the jurisdictions where the alleged torts occurred permits recovery of
+punitive damages in actions against the personal representatives of a decedent tortfeasor's estate.
+ARGUMENT
+A. Legal Standard: Legal conclusions, labels and formulaic recitations of the elements
+of causes of action are insufficient to state a claim.
+"To survive a motion to dismiss, a complaint must contain sufficient factual matter,
+accepted as true, to state a claim to relief that is plausible on its face." Ashcroft v. Iqbal, 556 U.S.
+662, 678 (2009). While the Court must normally accept as true all well-pleaded factual allegations
+in a complaint and draw all inferences in Plaintiff's favor, those principles are "inapplicable to
+legal conclusions." Id. at 678 (2009) (citing Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 & 556
+(2007)). Thus, a pleading that offers only "labels and conclusions" or "a formulaic recitation of
+the elements of a cause of action will not do." Twombly, 550 U.S. at 555 (2007). Moreover,
+"'[w]here [the] plaintiff's own pleadings are internally inconsistent, a court is neither obligated to
+reconcile nor accept the contradictory allegations in the pleadings as true in deciding a motion to
+dismiss."' Whitley v. Bowden, No. 17-cv-3564 (KMK), 2018 WL 2170313, at *11 (S.D.N.Y. May
+9, 2018) (quoting Carson Optical Inc. v. eBay Inc., 202 F. Supp. 3d 247, 255 (E.D.N.Y. 2016)).
+B. Plaintiff's claims based on alleged torts that occurred outside of New York and
+those that occurred when she was an adult, regardless of location, are time-barred.
+In an apparent attempt to suggest her untimely claims have been revived by the New York
+Child Victims' Act (CVA"), Plaintiff alleges that each of her causes of action has been brought
+pursuant to it. (Compl. 11 37, 43, 48, 52 and 58.) However, Plaintiff ignores that the CVA does
+not revive her claims (i) based on conduct that allegedly occurred after she turned 18 in 1998, or
+2
+
+
+Case 1:20-cv-00484-JGK-DCF Document 37 Filed 04/17/20 Page 8 of 14
+(il) outside of New York, regardless of Plaintiff's age at the time.'
+The CVA creates a one-year window in which civil claims alleging damages "suffered as
+a result of conduct which would constitute a sexual offense as defined in article one hundred
+thirty of the penal law committed against a child less than eighteen years of age" may be filed
+despite the statute of limitations having already run. CPLR § 214-g (emphasis added). The CVA's
+New York Penal Law predicate applies only to acts that occurred in New York. See, e.g., WAYNE
+R. LAFAVE, ET AL., CRIMINAL PROCEDURE, § 16.4(c) (4th ed. 2019) ("a state has power to make
+conduct or the result of conduct a crime only if the conduct takes place or the result happens within
+its territorial limits.").
+Therefore, Plaintiff's claims based on torts occurring in New York after she became an
+adult, as well as her claims based on torts occurring in Florida and New Mexico-regardless of
+whether she was a minor at the time expired as follows:
+• Florida: for torts occurring while she was a minor, the later of within seven years
+shetsh treaded age or Deider le sometime in 2005 a vitiates, arither
+four years from the time she discovered both her injury and the causal relationship
+between that injury and the abuse (i.e., by sometime in 2003 at the latest)? (See Fla.
+Stat. § 95.11(7)); and, within four years after Plaintiff reached age of majority (i.e..,
+by sometime in 2002) (See Fla. Stat. § 95.11 (3)(O)).*
+(S.D.N.Y. May 9, 2018).
+2 Plaintiff alleges she "escaped" from Decedent in 1999, when she moved to California. (Compl. 9 24.) Plaintiff could
+not have depended on him after that time.
+3 Plaintiff does not allege belated discovery of her injuries. To the contrary, she alleges she has experienced pain and
+suffering daily. (See, e.g., Compl. 11| 25, 36, 42.) Plaintiff further claims she "was aware of" Decedent's alleged false
+imprisonment of her. (Id. at ( 54.)
+* In 2010, the Florida Legislature enacted Fla. Stat. § 95.11(9), which provides: *An action related to an act constituting
+a violation of's. 794.011 involving a victim who was under the age of 16 at the time of the act may be commenced at
+any time. This subsection applies to any such action other than one which would have been time barred on or before
+3
+
+
+Case 1:20-cv-00484-JGK-DCF Document 37 Filed 04/17/20 Page 9 of 14
+• New Mexico: for torts occurring while she was a minor, the later of the "first
+instant" of Plaintiff's 24th birthday (i.e., sometime in 2004) or three years from the
+date of the time that she knew or had reason to know of the childhood sexual abuse
+and that the childhood sexual abuse resulted in an injury to her, as established by
+competent medical or psychological testimony (Plaintiff makes no allegations in
+this regard) (see N.M. Stat. § 37-1-30);S and three years after Plaintiff reached age
+of majority (i.e., sometime in 2001) (see N.M. Stat. § 37-1-8).
+• New York: excluding alleged torts subject to the CVA, if any, Plaintiff's causes of
+action sounding in battery must be commenced within one year of accrual (see
+CPLR § 215(3)); or, if Plaintiff's claims sound in personal injury, within three years
+(see CPLR § 214(5)). Therefore, under New York law, Plaintiff's claims arising
+from her alleged sexual abuse occurring in New York when she was no longer a
+minor expired in 2002 at the latest.°
+C. Plaintiff's claim for false imprisonment must be dismissed in its entirety as
+untimely.
+Plaintiff's false imprisonment cause of action (Count V) must be dismissed because the
+CVA does not apply to it. As explained above, one of the two predicates for the CVA's application
+is a civil claim arising from conduct which would constitute a sexual offense as defined in New
+York Penal Law Art. 130:
+July I, 2010." (emphasis added). As explained above, Plaintiff's cause of action based on alleged abuse in Florida
+expired by 2005. Accordingly, Fla. Stat. § 95.11(9) is inapplicable to her claim.
+5 As her cause of action expired before the current version of N.M. Stat. § 37-1-30(A)(2) became effective on April 6,
+2017, Plaintiff is not entitled to avail herself of it. See In re Venie, No. 2017-NMSC-018, 395 P.3d 516 (Sup. Ct. N.M.
+2017) (distinguishing cases such as this, in which a cause of action expires before the enactment of a new limitations
+period, from cases in which a new limitations period extends the time to bring a cause of action before the prior
+limitations period had expired such that a defendant has no vested right in the statute of limitations defense based on
+the prior limitations period). Rather, Plaintiff is only entitled to invoke the prior version of N.M. Stat. § 37-1-30(A)(2),
+which provided that an action for damages based on personal injury caused by childhood sexual abuse must be
+commenced "three years from the date of the time that a person knew or had reason to know of the childhood sexual
+abuse and that the childhood sexual abuse resulted in an injury to the person, as established by competent medical or
+psychological testimony." See current version of N.M. Stat. § 37-1-30(A)(2) ("An action for damages based on
+personal injury caused by childhood sexual abuse shall be commenced by a person before the latest of the following
+dates ... (2) three years from the date that a person first disclosed the person's childhood sexual abuse to a licensed
+medical or mental health care provider in the context of receiving health care from the provider."). In any event,
+Plaintiff fails to allege the condition precedent to either version of the statute.
+" That Plaintiff's causes of action accruing outside New York are untimely under New York law alone renders those
+claims time-barred. Plaintiff alleges she resides in California. (Compl. 9 4.) New York's borrowing statute, CPLR §
+202, provides that, when a non-New York resident such as Plaintiff sues on causes of action accruing outside New
+York, the complaint must be timely under the statute of limitations of both New York and the jurisdiction where the
+claim accrued. (As explained above, the torts that Plaintiff alleges occurred outside New York fall outside the scope
+of the CVA.)
+4
+
+
+Case 1:20-cv-00484-JGK-DCF Document 37 Filed 04/17/20 Page 10 of 14
+Notwithstanding any provision of law which imposes a period of limitation to the contrary
+and the provisions of any other law pertaining to the filing of a notice of claim or a notice
+of intention to file a claim as a condition precedent to commencement of an action or
+special proceeding, every civil claim or cause of action brought against any party alleging
+intentional or negligent acts or omissions by a person for physical, psychological, or other
+injury or condition suffered as a result of conduct which would constitute a sexual offense
+as defined in article one hundred thirty of the penal law committed against a child less
+than eighteen years of age, incest as defined in section 255.27, 255.26 or 255.25 of the
+penal law committed against a child less than eighteen years of age, or the use of a child in
+a sexual performance as defined in section 263.05 of the penal law, or a predecessor statute
+that prohibited such conduct at the time of the act, which conduct was committed against
+a child less than eighteen years of age, which is barred as of the effective date of this section
+because the applicable period of limitation has expired, and/or the plaintiff previously
+failed to file a notice of claim or a notice of intention to file a claim, is hereby revived, and
+action thereon may be commenced not earlier than six months after, and not later than one
+year and six months after the effective date of this section.
+CPLR 214-g (emphasis added).
+However, Article 130 of the New York Penal Law, titled "Sex Offenses," does not cover
+conduct that would give rise to a claim of false imprisonment, but rather various types of sexual
+abuse, misconduct, and assault. See N.Y.P.L. §§ 130.00, et seq. Conduct that could give rise to a
+claim of false imprisonment, specifically, "knowingly unlawful restraint without consent," is
+covered by Article 135 of the New York Penal Law, which address "unlawful imprisonment"
+among "Kidnapping, Coercion and Related Offenses." N.Y.P.L. §§ 135.00, et seq.
+Here, albeit in a formulaic, threadbare fashion, Plaintiff alleges as the basis of her false
+imprisonment claims—as opposed to the conduct that forms the basis of her sexual assault and
+sexual battery claims that Decedent and Defendant Ghislaine Maxwell 'imprison[ed]" her
+"without lawful authority"—i.e., "unlawful imprisonment." (Compl. 9| 54.) While that alleged
+underlying conduct may in theory give rise to a N.Y.P.L. § 135 violation, it cannot give rise to a
+N.Y.P.L. § 130 violation. See In re M., 93 Misc. 2d 545, 549 (N.Y. Fam. Ct. Bronx Cnty. 1978)
+("Further argument advanced by respondent's attorney that the charge of unlawful imprisonment,
+second degree, under section 135.05 of the Penal Law does not exist independently of the charge
+5
+
+
+Case 1:20-cv-00484-JGK-DCF Document 37 Filed 04/17/20 Page 11 of 14
+of sexual abuse, second degree [Penal Law 135.05], is equally without merit ... Clearly, the
+elements of each of these crimes are totally different and each can stand independent of the
+other.").
+Therefore: (i) Plaintiff's false imprisonment claim is subject to the 1 - or 3-year statutes of
+limitation set forth in CPR §§ 215(3) and 214(5), respectively; and (ii) accordingly, and
+regardless of whether she was a minor at the time of the alleged false imprisonment, Count V
+expired by 2002 at the latest.
+D. Plaintiff's claim for punitive damages against the Co-Executors must be dismissed
+because each jurisdiction where the torts allegedly occurred bars recovery of
+punitive damages against a deceased tortfeasor's estate.
+As a matter of law, none of the jurisdictions where Plaintiff alleges she was abused permits
+her to recover punitive damages from the Co-Executors. It is black-letter law that the place of a
+tort (here, Florida, New Mexico or New York) generally applies to the issue of punitive damages.
+When determining which state's law applies, courts look to the choice-of-law rules of the forum
+state. Simons v. Marriott Corp., No. 92 Civ. 3762 (SWK), 1993 U.S. Dist. LEXIS 14365, at *15
+(S.D.N.Y. Oct. 12, 1993).
+Under New York law, "[b]ecause punitive damages are conduct-regulating, "the law of the
+jurisdiction where the tort occurred will generally apply."" Starr Indem. & Liab. Co. v. Am. Claims
+Mgmt., No. 14-cv-0463-JMF, 2015 U.S. Dist. LEXIS 60272, *7 (S.D.N.Y. May 7, 2015) (quoting
+Deutsch v. Novartis Pharms: Corp., 723 F. Supp. 2d 521, 524 (E.D.N.Y. 2010); Guidi v. Inter-
+Continental Hotels Corp., No. 95-CV-9006, 2003 U.S. Dist. LEXIS 6390, at *1 (S.D.N.Y. Apr.
+16, 2003)). See also AHW Inv. P'ship, MFS, Inc. v. Citigroup Inc., 661 F. App'x 2, 5 (2d Cir.
+2016) ("[Jt is the place of the allegedly wrongful conduct that generally has superior "interests in
+protecting the reasonable expectations of the parties who relied on the laws of that place to govern
+6
+
+
+Case 1:20-cv-00484-JGK-DCF Document 37 Filed 04/17/20 Page 12 of 14
+their primary conduct and in the admonitory effect that applying its law will have on similar
+conduct in the future.").
+Because none of the jurisdictions where the alleged torts occurred permits punitive
+damages against the personal representatives of a decedent tortfeasor's estate, the Court must
+dismiss Plaintiff's claim for punitive damages against the Co-Executors. See Poindexter v.
+Zacharzewski, No. 18-civ-14155, 2018 U.S. Dist. LEXIS 189861, at *6 (Nov. 5, 2018 S.D. Fla.)
+("Florida law prohibits recovery of punitive damages from the estate of a wrongdoer who is
+deceased."); Jaramillo v. Providence Wash. Ins. Co., 117 N.M. 337, 346 (N.M. 1994)
+("punishment and deterrence are not accomplished by enabling recovery of punitive damages from
+the estate of deceased tortfeasors."); NY EPTL § 11-3.2 (a)(1) ("For any injury, an action may be
+brought or continued against the personal representative of the decedent, but punitive damages
+shall not be awarded nor penalties adjudged in any such action brought to recover damages for
+personal injury." (emphasis added)). That is also the law in most U.S. jurisdictions, as reflected
+in the Restatement (Second) of Torts. See Restat. (Second) Of Torts § 908 cmt. a ("Punitive
+damages are not awarded against the representatives of a deceased tortfeasor.").
+Dismissing
+; Plaintiff's punitive damages claim is procedurally proper. Judges in this
+District regularly dismiss and strike punitive damages claims at the pleadings stage where, as here,
+they are legally baseless, whether because they are barred by statute and black-letter law (as is the
+case here) or where a plaintiff fails to allege facts that would permit them. See, e.g., The Cookware
+Co. (USA), LLC v. Austin, No. 15 Civ. 5796, 2016 U.S. Dist. LEXIS 177691, at *17 (S.D.N.Y.
+Dec. 8, 2016) (Batts, J.) (granting motion to dismiss claim for punitive damages without leave to
+replead because allegations regarding defendant's bad-faith conduct were conclusory and did not
+rise to the required level of malice); SJB v. N.Y.C. Dep't of Educ., No. 03 Civ. 6653, 2004 U.S.
+7
+
+
+Case 1:20-cv-00484-JGK-DCF Document 37 Filed 04/17/20 Page 13 of 14
+Dist. LEXIS 13227, at *25-26 (S.D.N.Y. July 14, 2004) (Buchwald, J.) (granting motion to dismiss
+statutorily unavailable punitive damages claims); Kunica v. St. Jean Fin., No. 97 Civ. 3804, 1998
+U.S. Dist. LEXIS 11867, at *26 (S.D.N.Y. July 29, 1998) (Sweet, J.) (granting motion to dismiss
+claim for punitive damages because, even if conduct alleged in complaint was true, it did not rise
+to the level necessary to award punitive damages). See also In re Merrill
+Auction Rate Sec.
+Litig., 851 F. Supp. 2d 512, 544 (S.D.N.Y. 2012) (granting motion to strike sections of complaint
+asserting punitive damages); Nash v. Coram Healthcare Corp., No. 96 Civ. 0298 (LMM), 1996
+U.S. Dist. LEXIS 9101, at *15 (S.D.N.Y. June 27, 1996) ("The motion to strike the punitive
+damages prayer from the Complaint is Granted."). See also C.
+& A.
+, 5C Fed. Prac.
+& Proc. Civ. § 1380 (3d ed.) (*[T]he technical name given to a motion challenging a pleading is
+of little importance ... as prejudice to the nonmoving party hardly can result from treating a motion
+that has been inaccurately denominated a motion to strike as a motion to dismiss the complaint.").
+CONCLUSION
+For the reasons stated above, the Co-Executors respectfully request that the Court dismiss
+Counts I-IV of Plaintiff's Complaint to the extent they are time-barred, Count V in its entirety, and
+Plaintiff's demand for punitive damages, together with such other and further relief as is just and
+equitable.
+
+
+Case 1:20-cv-00484-JGK-DCF Document 37 Filed 04/17/20 Page 14 of 14
+Dated: New York, New York
+April 17, 2020
+By: /s/ Bennet .J. Moskowitz
+Bennet J. Moskowitz
+TROUTMAN SANDERS LLP
+875 Third Avenue
+New York, New York 10022
+Attorneys for Defendants Darren K. Indyke and
+Richard D. Kahn, as Co-Executors of the Estate
+of Jeffrey E. Epstein

vision-fixhub/court-01/8f763f2cd094be0c23a0bb4479e0550c437e7ac7820f2d54400ffb8f75e8421d.receipt.json

@@ -0,0 +1,14 @@
+{
+  "byte_delta": -170,
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+  "doc_id": "8f763f2cd094be0c23a0bb4479e0550c437e7ac7820f2d54400ffb8f75e8421d",
+  "engine": "marble-apple-vision",
+  "event_count": 15,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]",
+  "idempotent": true,
+  "input_sha256": "a327d7666b5f403b45752f19fa6c154b814b3507feaca475183c50950fbc8f62",
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+}

vision-fixhub/court-01/8f777d59f3dda234fbd5177de382115ab43f9663a95b53d38631d6b0f57c5f22.md

@@ -0,0 +1,95 @@
+Case 9:08-cv-80736-KAM Document 236 Entered on FLSD Docket 09/13/2013 Page 1 of 3
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO. 08-80736-CIV-MARRA
+JANE DOE #1 and JANE DOE #2,
+Petitioners,
+VS.
+UNITED STATES OF AMERICA,
+Respondent.
+OF DELIBERATIVE PROCESS PRIVILEGE
+Respondent, by and through its undersigned counsel, files its Motion for Enlargement of
+Time to File Declaration of United States Attorney in Support of Deliberative Process Privilege,
+and states:
+1. On September 4, 2013, this Court granted the government's motion for enlargement of
+time to file declaration in support of invocation of the deliberative process privilege. The Court
+granted the government until Friday, September 13, 2013, to file the declaration.
+2. The government asserted the deliberative process privilege on two classes of
+documents, those generated by components of the Department of Justice, and those generated by
+the U.S. Attorney's Office, Southern District of Florida.
+3. The United States Attorney, Southern District of Florida, is reviewing the documents
+for which the deliberative process privilege was asserted, to determine if he will formally invoke
+the privilege. His review will be complete by September 19, 2013, and the undersigned expects
+the U.S. Attorney's declaration will be filed on Friday, September 20, 2013.
+
+
+Case 9:08-cv-80736-KAM Document 236 Entered on FLSD Docket 09/13/2013 Page 2 of 3
+4. The government respectfully requests an enlargement of time of seven days, up to and
+including September 20, 2013, to file the declaration of the United States Attorney, in support of
+the invocation of the deliberative process privilege.
+CERTIFICATE OF CONFERENCE
+On September 13, 2013, petitioners' counsel advised that they do not oppose this motion.
+At present, petitioners' reply in support of their renewed motion for an order directing the U.S.
+Attorney's Office not to withhold relevant evidence is due on September 23, 2013, ten days after
+the filing of the government's declaration. D.E. 234. In the event the Court grant's the
+government's motion, the government respectfully requests that petitioners' date for filing their
+reply be enlarged to September 30, 2013.
+DATED: September 13, 2013
+Respectfully submitted,
+WILFREDO A. FERRER
+UNITED STATES ATTORNEY
+By:
+s/ Dexter A. Lee
+DEXTER A. LEE
+Assistant U.S. Attorney
+Fla. Bar No. 0936693
+99 N.E. 4th Street, Suite 300
+Miami, Florida 33132
+(305) 961-9320
+Fax: (305) 530-7139
+E-mail: dexter.lee@usdoj.gov
+ATTORNEY FOR RESPONDENT
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on September 13, 2013, I electronically filed the foregoing
+document with the Clerk of the Court using CM/ECF
+s/ Dexter A. Lee
+2
+
+
+Case 9:08-cv-80736-KAM Document 236 Entered on FLSD Docket 09/13/2013 Page 3 of 3
+DEXTER A. LEE
+Assistant U.S. Attorney
+SERVICE LIST
+Jane Does 1 and 2 v. United States,
+Case No. 08-80736-CIV-MARRA/
+United States District Court, Southern District of Florida
+J.
+Esq.
+Jaffe, Weissing,
+Fistos & Lehrman, P.L.
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale, Florida 33301
+(954) 524-2820
+Fax: (954) 524-2822
+E-mail: brad@pathtojustice.com
+Paul G. Cassell
+S.J. Quinney College of Law at the
+University of Utah
+332 S. 1400 E.
+Salt Lake City, Utah 84112
+(801) 585-5202
+Fax: (801) 585-6833
+E-mail: casselp@law.utah.edu
+Attorneys for Jane Doe # 1 and Jane Doe # 2
+Roy Black
+Jackie Perczek
+Black, Srebnick, Kornspan & Stumpf, P.A.
+201 South Biscayne Boulevard
+Suite 1300
+Miami, Florida 33131
+(305) 371-6421
+Fax: (305) 358-2006
+E-mail: rblack@royblack.com
+jperczek@royblack.com
+Attorneys for Intervenors
+3

vision-fixhub/court-01/8f777d59f3dda234fbd5177de382115ab43f9663a95b53d38631d6b0f57c5f22.receipt.json

@@ -0,0 +1,14 @@
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+  "doc_id": "8f777d59f3dda234fbd5177de382115ab43f9663a95b53d38631d6b0f57c5f22",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "a05d7de5671b24fd848b1f38ad855bad23cb1078bbb1a13fd0cc352238da92ae",
+  "output_sha256": "7041c9962f2b27cb3af83ba47a74894a20d9a2ced9f065142f9e14ae5f6176a7",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}

vision-fixhub/court-01/8f84f0600a1e03a06c6193386d66a8d634ff382c77a1b8d5105f6960722d7d97.md

@@ -0,0 +1,243 @@
+Case 9:08-cv-80119-KAM Document 559 Entered on FLSD Docket 06/04/2010 Page 1 of 7
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CIV-80119-MARRA/JOHNSON
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-08380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+DEFENDANT'S, MOTION FOR MODIFICATION AND RECONSIDERATION OF THE
+MAGISTRATE'S ORDER DATED JUNE 1, 2010 (DE 555), WITH INCORPORATED
+OBJECTIONS AND MEMORANDUM OF LAW
+Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through his undersigned
+attorneys, hereby files his Motion for Modification and Reconsideration of the Magistrate's
+Order (DE 555) pursuant to Rule 60, Rule 4, Rule 4(c) and Fed. R. Civ. P. 53(e), and other
+applicable Federal Rules and Local Rules. In support, Epstein states:
+1.
+This court entered an order (DE 555) stating that Alfredo Rodriguez
+("Rodriguez") (DE 469), must produce, to the extent in his possession, "...any and all journal,
+notes, diaries, and writings relating to Jeffrey Epstein including the journal described by
+Rodriguez to Palm Beach Police that [allegedly] contains the names of girls who visited the
+residence." (DE 555, p.2)
+2.
+As set forth in Rodriguez's deposition, he was an employee of Epstein.
+Rodriguez Deposition, Exhibit "A" at p. 12-13. Moreover, as an individual employee,
+1
+
+
+Case 9:08-cv-80119-KAM Document 559 Entered on FLSD Docket 06/04/2010 Page 2 of 7
+Rodriguez claims he executed a confidentiality agreement with Epstein. Exhibit "A" at p. 135.
+Furthermore, in his plea agreement, Rodriguez "admitted removing [a book or journal] from
+Epstein's home without Epstein's permission. ..." Plea Agreement, Exhibit "B" at p.8. In
+short, if Rodriguez's testimony and Plea Agreement are correct, then he stole the property from
+Epstein's home, which would be a breach of his fiduciary obligations as an employee, a breach
+of the Employment Agreement he testified he executed and an invasion of Epstein's privacy
+rights and potentially his commercially sensitive financial and trade secret information. To the
+extent Rodriguez's testimony is true, Epstein never gave Rodriguez permission for this "journal"
+or "book" to be removed.
+3.
+This "book" or "journal" or "papers" could contain the names of Epstein's
+business associates and other highly confidential commercially sensitive information that would
+be entirely irrelevant to this action and not reasonably calculated to lead to the discovery of
+admissible evidence.
+Accordingly, depending upon what this "book" or "journal" contains,
+there may be commercially sensitive and trade secret information contained therein including,
+but not limited to, lists of business associates which could result in irreparable harm to Epstein if
+disseminated.
+v. Silcox, 2001 WL 1200656 (S.D. Fla. 2001).
+Courts have often enjoined the dissemination of confidential or private
+information wrongfully obtained from the employer by a (now) ex-employee during the course
+of his employment, either through a free-standing action for injunctive relief or in conjunction
+with a tort action for, among other things, breach of fiduciary duty. See, c.g., Saini V.
+International Game Technology, 434 F.Supp.2d 913, 924 (D.Nev. 2006)(court finds that
+company had shown likelihood of success in proving breach of implied covenant of good faith
+and fair dealing where former employee's "decision to distribute internal IGT documents to a
+2
+
+
+Case 9:08-cv-80119-KAM Document 559 Entered on FLSD Docket 06/04/2010 Page 3 of 7
+party adverse to IGT in litigation demonstrates a deliberate attempt to violate the spirit of his
+confidentiality agreements with IGT;" injunction issued); see also In re Zyprexa Injunction, 474
+F.Supp.2d 385, 419 (E.D.N.Y. 2007)(court has power to enjoin dissemination of stolen
+documents obtained in violation of court's protective order). Even where the employee is not
+subject to a formal confidentiality agreement, "an employee may still be enjoined from using
+confidential information where he or she has obtained such information by wrongful means, such
+as theft or intentional memorization." Tactica Intern., Inc. V. Atlantic Horizon Intern., Inc., 154
+F.Supp.2d 586, 608 (S.D.N.Y. 2001); Standard Brands, Inc. v. Zumpe, 264 F.Supp. 254, 262
+(D.La. 1967)(internal quotation marks omitted). See A.H. Emery Co. v. Marcan Products Corp,
+268 F.Supp. 289, 299 (S.D.N.Y. 1967)("A confidential relationship exists between an employee
+and his employer. It survives the termination of his employment. It does not depend on any
+express contract. Disclosure by an employee of a trade secret entrusted to him by his employer in
+the course of his employment is a classic instance of a disclosure which constitutes a breach of
+confidence and which is therefore actionable. It is not necessary that the employee expressly
+agree not to disclose it"), aff'd 389 F.2d 11 (2d Cir. 1968), cert. denied, 393 U.S. 835 (1968).
+The simple fact is that this court must determine, in camera, what is in the "book" or "journal"
+such that relevancy, privileges, privacy interests and commercially sensitive and trade secret
+privileges can be addressed before disclosure.
+5.
+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). The Supreme Court has "consistently held that a person has no legitimate
+expectation of privacy in information he voluntarily turns over to the third parties."
+V.
+3
+
+
+Case 9:08-cv-80119-KAM Document 559 Entered on FLSD Docket 06/04/2010 Page 4 of 7
+Maryland, 442 U.S. 735, 743-44, 99 S.Ct. 2577, 2582 (1979). To the extent this "book" or
+"journal" exists, Rodriguez admitted that he took same without Epstein's permission. Therefore,
+Epstein could not have voluntarily given same to him and, as such, Epstein has not waived any
+objections, privileges and/or privacy interests in the "book" or "journal.". 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 intrusions); New
+Jersey v. T.L.O., 469 U.S. 325, 375 (1985)(search of a woman's purse by a school administrator
+is a serious invasion of her legitimate expectation of privacy). Based upon the foregoing,
+Epstein should be afforded his due process rights to review this alleged "book" and/or "journal"
+in an effort to determine what, if any, legal objections and privileges should be asserted before
+disclosure.
+6.
+As this court is well aware, there are serious 4"', s"*, 6, and 14"h Amendment
+implications involved in this case. The fact that Rodriguez claims to have stolen the "book" or
+"journal" gives this court good reason to, at the very least, hold an in camera proceeding to
+determine if the confidential information set forth therein should be disclosed.
+Epstein has not had the opportunity to review what is in this "book" or "journal"
+to determine whether various legal objections should be made and to determine what, if any, 4*,
+s"', 6*, and 14" Amendment implications would arise due to its disclosure as well as other legal
+objections and privileges. See infra. Therefore, an in camera hearing should occur to determine
+what objections and privileges must be raised before disclosure is made. U.S. v. Zolin, 491 U.S.
+554, 575 (1989)(disclosing materials to the district court does not have the legal effect of
+4
+
+
+Case 9:08-cv-80119-KAM Document 559 Entered on FLSD Docket 06/04/2010 Page 5 of 7
+terminating a privilege thereby allowing parties to disclose documents in camera and make that
+in camera request - especially when there is a question as to whether those documents were
+obtained by unlawful means); St. Andrews Park, Inc. v. U.S. Dept. of Army Corps of Engineers,
+299 F.Supp.2d 1264 (S.D. Fla. 2003)(court determined that an in camera proceeding was
+appropriate when it involved a small volume of documents); see also In re Alberto Duque, 134
+B.R. 679 (S.D. Fla. 1991)(in camera inspection afforded adequate protection against disclosure
+of any privileged documentary material). A trial court departs from the essential requirements of
+law in ordering production of confidential information without conducting an in camera review
+to determine whether the assertion of privilege is valid. See Westco, Inc. v. Scott
+Gardening & Trimming, Inc., 26 So. 3d 620, 622 (Fla. 4th DCA 2009).
+If disclosure is made, this court should then determine what portions of the
+"book" or "journal" should be produced, redacted and then subject to a heightened
+confidentiality agreement.
+Wherefore, Epstein requests that this court enter an order:
+granting the relief requested above inclusive of a modification of the order
+and or reconsideration of same for the reasons set out above:
+b.
+finding that an in camera hearing should occur to determine if any
+privileges, objections, privacy interests, redactions and/or discovery objections can be
+made by Epstein before disclosure is made and granting a reasonable time to do so;
+C.
+reversing the Magistrate's Order relative to the carte blanch production of
+the "journal" and/or "book" (DE 555);
+d.
+likewise, if this court rules that the "book" or "journal" should be
+produced, Epstein respectfully requests that it do so only after an in camera hearing
+allowing the document 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 document should be redacted as privileged including, but not
+limited to, what portions should be redacted due to the confidentiality and privacy
+interests, trade secret and commercially sensitive financial and business information.
+5
+
+
+Case 9:08-cv-80119-KAM Document 559 Entered on FLSD Docket 06/04/2010 Page 6 of 7
+Again, the foregoing should only occur after this court ensures that the document (i.e., the
+"journal" or "book") produced is the subject of a heightened-confidentiality order where
+disclosure will result in the disclosing party being held in contempt of court; and
+for such other and further relief as this Court deems just and proper.
+By: Is/ Robert D. Critton, Jr.
+ROBERT D. CRITTON, JR., ESQ.
+Florida Bar #224162
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was being served this day on all
+counsel of record identified on the following Service List via electronic mail (EMAIL) on this
+day of 4t day of June 2010.
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Boulevard
+Suite 2218
+Respectfully submitted,
+By: Is/ Robert D. Critton, Jr.
+ROBERT D. CRITTON, JR., ESQ.
+Florida Bar No. 224162
+rcrit@bclelaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER & COLEMAN
+303 Banyan Blvd., Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/253-0164 Fax
+(Counsel for Defendant Jeffrey Epstein)
+Certificate of Service
+ane Doe No. 2 v. Jeffrey Epsteir
+Case No. 08-CV-80119-MARRA/,
+1 Esq.
+Banner, Jafle, sing, 1
+& Lehrman, PL
+425 N. Andrews Ave.
+Suite #2
+Fistos
+6
+
+
+Case 9:08-cv-80119-KAM Document 559 Entered on FLSD Docket 06/04/2010 Page 7 of 7
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+ssm@sexabuseattorney.com
+ahorowitz/@sexabuseattorney.com
+Counsel for Plaintiffs
+In related Cases Nos. 08-80069, 08-80119, 08-
+80232, 08-80380, 08-80381, 08-80993, 08-
+Fort Lauderdale, FL 33301
+Phone: 954-524-2820
+Fax: 954-524-2822
+Brad@pathtojustice.com
+Counsel for Plaintiff in Related Case No. 08-
+80893
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Counsel for Defendant Jeffrey Epstein
+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 Jane Doe
+Isidro M.
+Esq.
+Tara A. Finnigan, 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
+S046sel for Plainit in Related Case No. OS.
+7

vision-fixhub/court-01/8f84f0600a1e03a06c6193386d66a8d634ff382c77a1b8d5105f6960722d7d97.receipt.json

@@ -0,0 +1,14 @@
+{
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+  "doc_id": "8f84f0600a1e03a06c6193386d66a8d634ff382c77a1b8d5105f6960722d7d97",
+  "engine": "marble-apple-vision",
+  "event_count": 7,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "7bd7f22a04113ed127a3335d5f4cfeec7cf2f0138830557a8d45aad88e2514be",
+  "output_sha256": "311abb5a1881c35f01c062b0ddddefc958ab77f3664623737d1b0b96539f54eb",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}

vision-fixhub/court-01/8f917117bfe4355423f61feb7232f20163dba72fad3bb122a537eae9321abd05.md

@@ -0,0 +1,1573 @@
+Entered on FLSD Docket 09/23/2009 Page 1 of 38
+
+CASE NO.: 08-CV-80119-MARRA-|
+JANE DOE NO. 2,
+Plaintiff,
+V.
+JEFFREY EPSTEIN,
+Defendant.
+!
+Related Cases:
+08-80232, 08-80380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80581, 09-80656, 09-80802, 09-81092.
+DEFENDANT'S. JEFFREY EPSTEIN, MOTION FOR SANCTIONS AND
+TO COMPEL DEPOSITION OF JANE DOE NO. 4 AND MEMORANDUM IN
+SUPPORT THEREOF
+Defendant, JEFFREY EPSTEIN, by and through his undersigned attorneys, moves this
+court for an order granting sanctions pursuant to Rule 30(d)(2) and (3)(A) and (C) (referencing
+Rule 37(a)(5)), Federal Rules of Civil Procedure and compelling the deposition of Jane Doe No.
+4 within fifteen (15) days and as grounds therefore would state:
+On August 16, 2009, the deposition of Jane Doe No. 4 was noticed for September
+16, 2009 to begin at 1:00 p.m. Plaintiff's counsel had advised that Jane Doe No. 4 could not
+appear for a deposition prior to that time of day, i.e. 1:00 p.m.
+2.
+The deposition was originally set at the offices of the undersigned, but Plaintiff's
+counsel requested that it be moved to the court reporter's office. The court reporter is Prose
+Court Reporting located at 250 Australian Avenue South, Suite 115, West Palm Beach, FL
+33401.
+"1"
+
+
+Case 9:08-cv-80119-KAM Document 322-1 Entered on FLSD Docket 09/23/2009 Page 2 of 38
+Entered on FLSD Docket 09/17/2009 Page 2 of 8
+3.
+The undersigned's office began attempting to set the deposition of Jane Doe No. 4
+on July 21, 2009. Because of the number of attorneys who would be attending (based on the
+court's consolidation order) coordinating the video deposition creates logistical problems.
+4.
+On August 27, 2009, the undersigned wrote a letter to counsel for the Plaintiff
+indicating that Mr. Epstein would be present at the deposition. A copy of that letter is attached
+as Exhibit 1.
+Some 13 days later, counsel for Jane Doe No. 4 filed a motion for protective order
+on September 9, 2009 attempting to prohibit Mr.Epstein's presence at the deposition. The
+Defendant immediately filed a response (an Emergency Motion) on September 11, 2009
+requesting that the court enter an order allowing Epstein, the Defendant in this matter, to attend
+the deposition. This is common procedure. See Exhibit 2, without exhibits. As of the date of
+the deposition, the court had not ruled on these motions.
+On Monday, counsel for Jane Doe No. 4 and the undersigned spoke, an agreement
+was reached that the deposition would proceed as scheduled, and that Mr. Epstein would not be
+in attendance other than by telephone or other means. See Exhibit 3.
+The deposition was originally scheduled on the 15" Floor and moved by Prose to
+a larger ground floor to accommodate the number of people who were to attend
+8.
+The undersigned and his partner, Mark T. Luttier, had scheduled a meeting with
+Mr. Epstein for approximately an hour prior to the deposition. It is well known through multiple
+newspaper articles that Mr. Epstein's office at the Florida Science Foundation is located on the
+14"' Floor in the same building as the court reporter and Mir. Epstein's criminal attorney, Mr.
+Goldberger. As well, had the court issued an order prior to the deposition that would have
+allowed Mr. Epstein to attend, he was readily available.
+2
+
+
+Case 9:08-cv-80119-KAM Document 322-1 Entered on FLSD Docket 09/23/2009 Page 3 of 38
+Case 9:08-Cv-80119-KAM Document 305 Entered on FLSD Docket 09/17/2009 Page 3 of 8
+9.
+As of 1:00 p.m., no order had been received from the court, so Epstein's
+attorneys, in good faith, decided that Epstein would not attend the deposition (as per the
+agreement), if we chose to proceed, which we were doing. The undersigned and Mr. Luttier
+specifically waited until just after 1:00 o'clock, the time that the deposition was to start, prior to
+leaving with Mr. Epstein, Counsel instructed Mr. Epstein to leave the building. Clearly,
+Defendant and his counsel simply wish to have meaningful discovery.
+10.
+The undersigned and Mr. Luttier exited the elevator heading toward the
+deposition room and Mr. Epstein and his driver, Igor Zinoviev exited in separate elevator at the
+same time and turned to depart from through the front entrance such that he could go to his home
+to watch the deposition and assist counsel, from a video feed.
+Completely unbeknownst and unexpected by anyone, apparently the Plaintiff and
+her attorney(s) were at the front door where Mr. Epstein was intending to exit. Upon seeing two
+women, one who might be the Plaintiff, Mr. Epstein immediately made a left turn and exited
+through a separate set of doors to the garage area. See affidavit of Jeffrey Epstein and Igor
+Zinoviev, Exhibit 4 and 5, respectively.
+12. The entire incident was completely unknown to the undersigned and Mr. Luttier
+until Adam Horowitz, Esq. came in and announced that the deposition was not going to take
+place in that Mr. Epstein and his client saw one another, she was upset and therefore the
+deposition was cancelled from his perspective.
+13.
+The undersigned and his partner, Mr. Luttier, had a court reporter and a
+videographer present. Additionally, Mr. I on behalf of C.M.A., Adam Langino on behalf of
+B.B., William Berger on behalf of three Plaintiffs were present for the deposition.
+3
+
+
+Case 9:08-cv-80119-KAM Document 322-1 Entered on FLSD Docket 09/23/2009 Page 4 of 38
+Case 9:08-cv-80119-KAM Document 305 Entered on FLSD Docket 09/17/2009
+
+14.
+Any suggestion that the chance "visual" between Mr. Epstein and Jane Doe No. 4
+was "pre-planned" would be absurd, disingenuous and false. The undersigned counsel went out
+of his way to make certain Mr. Epstein would not be in the building after the time the deposition
+was set to begin. Had the Plaintiff and her counsel been in the deposition room at the appointed
+time, no visual contact would have occurred.
+15.
+It is possible that Plaintiff's counsel, by filing their motion for protective order on
+September 9, 2009 and then advising the undersigned on September 14, 2009 that the deposition
+would not go forward unless the undersigned agreed to exclude Mr. Epstein from the deposition,
+were not prepared and/or did not want to proceed with the deposition.
+16.
+The unilateral termination of the deposition was unnecessary, inappropriate and a
+substantial waste of attorney time and the costs related to the deposition (court reporter and
+videographer). (See Affidavit of Robert D. Critton, Jr., Mark T. Luttier and Deposition
+Transcript, Exhibits 6, 7, and 8 respectively).
+17. Had the "visual" been premeditated, the cancellation of the deposition may have
+been justified, however, under these circumstances, it was grandstanding and improper. In that
+the Plaintiff has stated that she voluntary went to JE's home 50 plus times without trauma until
+she filed a lawsuit, this brief visual encounter from a distance should not have resulted in the
+unilateral cancellation of her deposition.
+The costs associated with the court reporter and videographer total $428.80. See
+18.
+
+Memorandum of Law In support of Motion
+A substantial amount of administrative time went into the setting up the deposition of
+Jane Doe No. 4. Almost two months passed from the time that the Defendant's counsel first
+4
+
+
+Case 9:08-cv-80119-KAM Document 322-1 Entered on FLSD Docket 09/23/2009 Page 5 of 38
+Case 9:08-cv-80119-KAM Document 305 Entered on FLSD Docket 09/17/2009 Page 5 of 8
+requested a date for the deposition of Jane Doe No. 4. The deposition of Jane Doe No. 4 was to
+begin at 1:00 p.m, based on her schedule, and was moved from the undersigned's office to the
+office of the court reporter at her counsel's request.
+Pursuant to Rule 30(d)(2) and (3)(A) and (C) and its reference to 37(a)(5)), Federal Rules
+of Civil Procedure, the court may impose an appropriate sanction, including reasonable expenses
+in attorneys fees incurred by any party on a person who impedes or delays the fair examination
+of the deponent. In this instance, the brief visual encounter, which was completely unintended
+and inadvertent, should not have been grounds for Plaintiff's counsel and Plaintiff refusing to
+move forward with the deposition. Furthermore, pursuant to (3)(A) and (C), Plaintiff and
+Plaintiff's counsel had no right to unilaterally terminate/cancel the deposition and fail to move
+forward. Plaintiff should have continued with the deposition and filed any motion deemed
+appropriate post deposition. Therefore, Defendant is asking for the costs associated with the
+attendance of the court reporter, her transcript and the presence of the videographer. Defendant
+would also request reasonable fees for 2.5 hours at $500 per hour for being required to prepare
+this motion and affidavits associated with same.
+The records obtained thus far on Jane Doe No. 4, do not reflect any "emotional trauma"
+by her own account of some 50 plus visits to the Defendant's home prior to the time that she
+hired an attorney. Even in her interview with attorney's handpicked expert, Dr. Kliman, by her
+own comments, her significant emotional trauma relates to physical and verbal abuse by a prior
+boyfriend, Preston Vineyard, and deaths associated with two close friends, Chris and Jen.
+Therefore, the supposed "emotional trauma" caused by a chance encounter resulting in a
+"glance" at best, should not be the basis for Plaintiff unilaterally cancelling her deposition.
+5
+
+
+Case 9:08-cv-80119-KAM Document 322-1 Entered on FLSD Docket 09/23/2009 Page 6 of 38
+Case 9:08-cv-80119-KAM Document 305 Entered on FLSD Docket 09/17/2009 Page 6 of 8
+Rule 7.1 A. 3. Certification of Pre-Filing Conference
+Counsel for Defendant conferred with Counsel for Plaintiff by telephone and by e-mail;
+however, an agreement has not been reached.
+WHEREFORE, Defendant moves this court for an order granting sanctions to include
+attorneys fees and costs as set forth above and costs associated with the attendance of the court
+reporter, the transcript and the presence of the videographer and direction that Jane Doe No. 4
+appear for deposition within fifteen (15) days from the date of the court's order at the court
+reporter's office. If the court has not issued an order regarding Mr. Epstein's attendance at
+Plaintiff's deposition when Jane Doe No. 4 is to appear, the Defendant will agree that Mr.
+Epstein will not be present in the building on the date of her scheduled deposition such that no
+"inadvertent" contact will occur.
+Robert D. Critton, Jr.
+Michael J. Pike
+Attorneys for Defendant Epstein
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was hand-delivered to the Clerk
+of the Court as required by the Local Rules of the Southern District of Florida and electronically
+mailed to all counsel of record identified on the following Service List on this_ 7 # day of
+September, 2009.
+Certificate of Service
+Jane Doe No. 2 v. Jeffrey Epstein
+Case No. 08-CV-80119-MARRA/JOHNSON
+6
+
+
+Case 9:08-cv-80119-KAM Document 322-1 Entered on FLSD Docket 09/23/2009 Page 7 of 38
+Entered on FLSD Docket 09/17/2009 Page 7 of 8
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+ssm@sexabuseattorney.com
+ahorowitz@sexabuseattorney.com
+Brad
+1, 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 in Related Case No. 08-
+80893
+Counsel for Plaintiffs
+In related Cases Nos. 08-80069, 08-80119, 08-
+80232, 08-80380, 08-80381, 08-80993, 08- Paul G. Cassell, Esq.
+80994
+Pro Hac Vice
+332 South 1400 E, Room 101
+Richard Horace Willits, Esq.
+Salt Lake City, UT 84112
+Richard H. Willits, P.A.
+801-585-5202
+2290 10*h Avenue North
+801-585-6833 Fax
+Suite 404
+Lake Worth, FL 33461
+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
+L. Esq.
+| Law Firm, P.A
+24 Datura Street, Suite 90(
+West Palm Beach, FL 33401
+Jack Scarola, Esq.
+isidrogarcia@bellsouth.net
+Searcy Denney Scarola Barnhart & Shipley, Sounsel for Plaintiff in Related Case No. 08-
+P.A.
+2139 Palm Beach Lakes Boulevard
+Robert C. Josefsberg, Esq.
+West Palm Beach, FL 33409
+Katherine W. Ezell, Esq.
+561-686-6300
+Podhurst Orseck, P.A.
+Fax: 561-383-9424
+jsx@searcylaw.com
+25 West Flagler Street, Suite 800
+Miami, FL 33130
+jph@searcylaw.com
+305 358-2800
+Counsel for Plaintiff, C.M.A.
+Fax: 305 358-2382
+rjosefsberg@podhurst.com
+kezell@podhurst.com
+Bruce Reinhart, Esq.
+Counsel for Plaintiffs in Related Cases Nos.
+Bruce E. Reinhart, P.A.
+09-80591 and 09-80656
+250 S. Australian Avenue
+Suite 1400
+Jack Alan Goldberger, Esq.
+7
+
+
+Case 9:08-cv-80119-KAM Document 322-1 Entered on FLSD Docket 09/23/2009 Page 8 of 38
+Entered on FLSD Docket 09/17/2009 Page 8 of 8
+West Palm Beach, FL 33401
+561-202-6360
+Fax: 561-828-0983
+ect@brucereinhartlaw.com
+Counsel for Defendant L
+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-
+skuvin@riccilaw.com
+tleopold@riccilaw.com
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Counsel for Defendant Jeffrey Epstein
+Respectfully submitted,
+By: —
+ROBERT D. CRITTON, JR., ESQ.
+Florida Bar No. 224162
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+pike @bciclaw.co
+URMAN, CRITTON, LUTTIER & COLEMA
+303 Banyan Boulevard, Suite 400
+West Palm Beach, FL 33401
+561/213-0164 Fax
+(Co-Counsel for Defendant Jeffrey Epstein)
+8
+
+
+Entered on FLSD Docket 09/23/2009 Page 9 of 38
+Case 9:08-cv-80119-KAM Document 305-2
+Entered on FLSD Docket 09/17/2009 Page 1 of 1
+BE BUMN EMANE
+A LIMITED LIABILITY PARTNERSHIP
+J. MICHAEL BURMAN, PA.12 -
+GREGORY W. COLEMAN, PA.
+ROBERT D. CRITTON, JR. RA. I'
+BERNARD LEBEDEKER
+MARK T. LUTTIER, PA.
+JEFFREY C. PEPEN
+MICHAEL ). PIKE
+HEATHER MONAMARA RUDA
+DAVID YAREMA
+'FLORIDA DOARD CERTIFIED CIVIL TRIAL LAWYÉR,
+ADMITTED TO PRACTICE IN FLORIDA AND COLORADO
+DELQUL - BENAVEN
+RALEOAL/INVESTIGATI
+ASHLIE STOKEN-BARING
+BETTY STOKES
+D RICO
+August 27, 2009
+Sent by E. Mail and U.S. Mail
+Stuart S. Mermelstein, Esq.
+Herman & Mermelstein, P.A.
+18205 Biscayne Blvd.
+Suite 2218
+Miami, FL 33160
+Re: Jane Doe No. 4 v. Epstein
+Dear Stuart:
+Please be advised that Mr. Epstein plans to be in attendance at the deposition of
+rour client. He does not intend to engage in any conversation with your client. However, i
+s certainly his right as a party-defendant in the lawsuit to be present and to assist counse
+in the defense of any case.
+Cordially ours,
+Robof b. CHiton, Jr.
+RDC/clz
+Cc:
+Jack A. Goldberger, Esq.
+EXHIBIT /
+303 BANYAN BOULEVARD : SUITE 400 • WEST PAIM BEACH, FL 33401 • PHONE: 561-842-2820 - FAX: 561-841-6929 - MAIL@BCLCIAW.COM
+WWW.BCLCLAW.COM
+
+
+Case 9:08-CV-80119-KAM Document 322-1 Entered on FLSD Docket 09/23/2009 Page 10 of
+Case 9:08-cv-80119-KAM-
+Document 305-3
+Document 296
+Entered on FLSD Docket 09/11/2009
+
+
+CASE NO.: 08-CV-80119-MARRA-1
+JANE DOE NO. 2,
+Plaintiff,
+V.
+FILED by
+JEFFREY EPSTEIN,
+SEP 1 1 2009
+Defendant.
+Related Cases:
+08-80232, 08-80380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80581, 09-80656, 09-80802, 09-81092.
+/
+Defendant Epstein's Emergency Motion To Strike Plaintiff's Motion For
+Protective Order (DE 292) And Emergency Motion To Allow The
+Attendance Of Jeffrey Epstein At The Deposition Of Plaintiffs And Response
+In Opposition To Plaintiffs', Jane Doe Nos. 2-8, Motion For Protective Order
+As To Jeffrey Epstein's Attendance At The Deposition Of Plaintiffs, With
+Incorporated Memorandum of Law
+Defendant, Jeffrey Epstein, by and through his undersigned counsel, and pursuant to all
+applicable rules, including Local Rule 7.1(e) and Local Rule 12, hereby files and serves his
+Emergency Motion To Strike Plaintiff's Motion For Protective Order (DE 292) And Emergency
+Motion To Allow The Attendance Of Jeffrey Epstein At The Deposition Of Plaintiffs And
+Response In Opposition To Plaintiffs', Jane Doe Nos. 2-8, Motion For Protective Order As To
+Jeffrey Epstein's Attendance At The Deposition Of Plaintiffs. In support, Epstein states:
+Introduction and Background
+On August 19, 2009, Defendant sent a Notice for Taking the Deposition of Jane
+Doe No. 4 for September 16, 2009. See Exhibit "1"
+
+2
+
+
+Case 9:08-cv-80119-KAM Document 322-1 Entered on FLSD Docket 09/23/2009 Page 11 of
+Entered on FLSD Docket 09/17/2009 Page 2 of 11
+Case 9:08-cv-80119-KAM Document 296
+Entered on FLSD Docket 09/11/2009 Page 2 of 33
+2.
+Additionally, notices were sent out in other cases in connection with deposing
+additional Plaintiffs.
+3.
+No objection(s) was/were received for Jane Doe No. 4, which was the only
+deposition set relative to the Jane Doe 2-8 Plaintiffs.
+4.
+On August 27, 2009, the undersigned counsel sent a letter to counsel for Jane Doe
+No. 4 concerning her deposition and the scheduling of same on the above date. See Exhibit "2".
+5.
+No response was received until counsel for Jane Doe No. 4 called on September
+8, 2009, approximately eight days prior to the scheduled deposition, to indicate that they now
+had an objection and would be filing a motion for protective order seeking to prevent Epstein
+from attending the deposition. Once again, Plaintiffs are attempting to stifle this litigation
+through their own delay tactics during discovery. Plaintiffs wish not only to attempt to force
+Epstein to trial without any meaningful discovery, but now wish to ban Epstein from any
+depositions, thereby preventing him from assisting his attorneys in his very own defense. What's
+next - will Plaintiffs seek to prevent Epstein from attending any of the trials that result from the
+lawsuits Jane Does 2-8 have initiated? Plaintiffs see millions of dollars in damages, both
+compensatory and punitive, against Defendant.
+6.
+Defendant is filing this emergency motion and his immediate response to the
+motion for protective order to guarantee his right to be present and assist counsel in deposing not
+only Jane Doe No. 4, but other plaintiffs and witnesses in these cases. To hold otherwise would
+violate Epstein's due process rights to defend the very allegations Plaintiffs have alleged against
+him. Does a Defendant not have a right to be present at depositions or other court proceedings to
+assist counsel with the defense of his case? Does a Defendant, no matter what the charges or the
+allegations, have full and unbridled access to the court system and the proceedings it governs,
+
+
+Case 9:08-cv-80119-KAM Document 322-1 Entered on FLSD Docket 09/23/2009 Page 12 of
+Entered on FLSD Docket 09/17/2009 Page 3 of 11
+Case 9:08-cv-80119-KAM Document 296
+Entered on FLSD Docket 09/11/2009 Page 3 of 33
+Page 3
+including discovery? The short answer is unequivocally, yes. To hold otherwise would be a
+direct violation of Epstein's constitutional due process rights. Plaintiffs' attempts to play fast
+and loose with the law should not be tolerated.
+7.
+As the court is aware, plaintiffs and defendants routinely attend depositions of
+parties and other witnesses in both State and Federal court proceedings. In fact, parties have a
+right under the law to attend such depositions.
+8. As the court will note from Exhibit 2, counsel for the Defendant specifically
+stated that "Please be advised that Mr. Epstein plans to be in attendance at the deposition of your
+client. He does not intend to engage in any conversation with your client. However, it is
+certainly his right as a party-defendant in the lawsuit to be present and to assist counsel in the
+defense of any case." Despite this right, Plaintiffs continue to attempt to control how discovery
+is conducted in this case and how this court has historically governed discovery.
+9.
+Interestingly, in Jane Doe II, the state court case, attorney Sid
+took the
+deposition of the Defendant and his client, Jane Doe II, was present throughout the deposition.
+This is despite her claims of "emotional trauma" set forth in her complaint. Jane Doe No. II is
+also a Plaintiff in the federal court proceeding Jane Doe II v. Jeffrey Epstein (Case No. 09-CIV-
+80469). Is this court going to start a precedent where it allows Plaintiffs to attend the depositions
+of Jeffrey Epstein, but not allow Epstein to attend their depositions (i.e., the very Plaintiffs that
+have asserted claims against him for millions of dollars)? This court should not condone such a
+practice.
+10.
+The undersigned is well aware of the court's No-Contact Order entered on July
+31, 2009 (DE 238). A copy of the order is attached as Exhibit "3". In fact, the order provides
+that the defendant have no direct or indirect contact with the plaintiffs, nor communications with
+
+
+Case 9:08-Cv-80119-KAM Document 322-1 Entered on FLSD Docket 09/23/2009 Page 13 of
+Case 9:08-cv-80119-KAM Document 305-3 Entered on FLSD Docket 09/17/2009 Page 4 of 11
+Case 9:08-CV-80119-KAM Document 296 Entered on FLSD Docket 09/11/2009 Page 4 of 33
+Page 4
+the plaintiffs either directly or indirectly. However, there is no prohibition against Mr. Epstein's
+attendance at a deposition where, as is reflected in the order, the communication will be made to
+the plaintiff solely through defense counsel with one or more of plaintiffs' counsel of record
+present in the room in a videotaped deposition. Obviously, any inappropriate contact or
+communication will certainly be flagged by the attorneys in attendance. As such, Plaintiffs
+really have the cart before the horse in this instance (i.e., nothing prevents Epstein from attending
+these depositions and, to the extent Plaintiffs believe that something improper occurs at any
+deposition, only then can that circumstance be addressed by a motion such as the instant one.)
+11. Next, Plaintiffs, Jane Does 2-8, attempt to use the Affidavit of Dr. Kliman for
+every motion for protective order/objection filed to date. This also includes the two most recent
+motions, which attempt to prevent Defendant's investigators from doing their job, such that the
+Defendant and his attorneys can defend the claims asserted in these cases. Plaintiffs lose sight of
+the fact that the court, in discussing the Non-Prosecution Agreement, inquired as to whether
+Epstein and his counsel could fully defend the case, which included discovery and investigation.
+All plaintiffs' counsel and the USAO responded in the affirmative. In fact, Plaintiffs universally
+agreed at the June 12, 2009 hearing on Defendant's Motion to Stay that regular discovery could
+proceed. See Composite Exhibit "4" at pages 26-30 & 33-34. For instance, the court asked
+Plaintiffs' attorneys the following questions:
+The Court: ) So again, I just want to make sure that if the cases go forward and
+if Mr. Epstein defends the case as someone ordinarily would defend a case being
+prosecuted against him or her, that that in and of itself is not going to cause him t
+›e subject to criminal prosecution? (Ex. "A," p.26)
+The Court: You agree he should be able to take the ordinary steps that a
+defendant in a civil action can take and not be concerned about having to be
+prosecuted? (Ex. "A," p.27).
+
+
+Case 9:08-cv-80119-KAM Document 322-1 Entered on FLSD Docket 09/23/2009 Page 14 of
+Entered on FLSD Docket 09/17/2009 Page 5 of 11
+Case 9:08-cv-80119-KAM Document 296 Entered on FLSD Docket 09/11/2009 Page 5 of 33
+Page 5
+***
+The Court: Okay. But again, you're in agreement with everyone else so far
+that's spoken on behalf of a plaintiff that defending the case in the normal course
+of conducting discovery and filing motions would not be a breach? (Ex. "A,"
+p.30).
+Mr. Horowitz - counsel for Jane Does 2-7: Subject to your rulings, of course,
+yes. (Ex. "A," p.30).
+***
+The Court: But you're not taking the position that other than possibly doing
+something in litigation which is any other discovery, motion practice,
+investigations that someone would ordinarily do in the course of defending a civil
+case would constitute a violation of the agreement? (Ex. "A," p.34).
+Ms. Villafana: No, your honor. I mean, civil litigation is civil litigation, and
+being able to take discovery is part of what civil litigation is all about.... But...,
+Mr. Epstein is entitled to take the deposition of a Plaintiff and to subpoena
+12. It is clear from the transcript attached as Exhibit "4" that each of the Plaintiffs'
+attorneys, including Mr. Horowitz for Jane Does 2-8, expected and conceded that
+regular/traditional discovery would take place (i.e., discovery, motion practice, depositions,
+requests for records, and investigations).
+13.
+Importantly, Plaintiffs' counsel advised the undersigned that they coordinate their
+efforts in joint conference calls at least two times per month. At recent depositions of two
+witnesses, Alfredo Rodriguez and Juan Alessi, five different plaintiffs' attorneys questioned the
+witnesses for approximately six to eight hours, often repeating the same or similar questions that
+had previously been asked.
+14.
+Clearly, the Plaintiffs' counsel wish to control discovery and how the Defendant
+is allowed to obtain information to defend these cases. However, the court has ruled on a
+number of these issues as follows:
+A.
+Plaintiffs' counsels sought to preclude the Defendant from serving third
+party subpoenas and allowing only Plaintiffs" counsel to obtain
+
+
+Case 9:08-Cv-80119-KAM Document 322-1 Entered on FLSD Docket 09/23/2009 Page 15 of
+Document 305-3 Entered on FLSD Docket 09/17/2009 Page 6 of 11
+Case 9:08-Cv-80119-KAM Document 296 Entered on FLSD Docket 09/11/2009 Page 6 of 33
+Page 6
+B.
+C.
+depositions and those materials and "filter them" to defense counsel.
+That motion was denied, and the court tailored a method such that the
+Defendant could obtain the records directly.
+Plaintiffs'
+Praminion in Col V. Setter pen and a doladic asylo, 08-
+(Case No. 08-
+MIY-80811), as to time, subject matter and scope. However, Magistrate
+entered an order denying the requested restrictions.
+Other Plaintiffs" attorneys have said that they object to requested
+psychological exam of their clients), thus motions for such exams will
+now need to be filed; yet all seek millions of dollars in damages for
+alleged psychological and emotional trauma.
+Many Plaintiffs' object to discovery regarding current and past
+employment (although they are seeking loss of income, both in past and
+All Plaintiffs object to prior sexual history, consensual and forced as
+being irrelevant, although in many of the medical records that are now
+being obtained, as well as the psychiatric exams done by Dr. Kliman,
+there is reference to rape, molestation, abusive relationships (both
+physical and verbal), prior abortions, illegal drugs and alcohol abuse.
+15.
+Clearly, Plaintiffs wish to make allegations; however, they forget that they must
+meet their burden by proving same. Meeting that burden and disproving those allegations is not
+possible if this court allows Plaintiffs to stifle and/or control the discovery process.
+16.
+Specifically, with regard to Jane Doe No. 4, which is the deposition set for next
+week, September 16, 2009, the plaintiff has in her past (see affidavit of Richard C.W.
+M.D., an expert psychiatrist retained by Defendant to conduct exams on various claimants.) See
+
+A.
+C.
+Sought counseling due to a dysfunctional home situation, specifically with
+She described herself as being angry, bitter,
+depressed and having body image problems;
+Had an ex-boyfriend, Preston Vinyard, who was, on information and
+belief, a drug dealer who she lived with;
+Had drug and alcohol problems herself; and
+
+
+Case 9:08-Cv-80119-KAM Document 322-1 Entered on FLSD Docket 09/23/2009 Page 16 of
+Entered on FLSD Docket 09/17/2009 Page 7 of 11
+Case 9:08-cv-80119-KAM Document 296
+Entered on FLSD Docket 09/11/2009 Page 7 of 33
+Page 7
+Spoke with two psychiatrists when she was sixteen or seventeen (before
+this lawsuit!) and did not reference Epstein, but did reference her
+boyfriend and family issues.
+17. There are police reports that reflect that:
+A.
+In September 2004, a battery report was filed regarding Jane Doe No. 4
+and Vinyard based on an argument where he grabbed her by the neck and
+began spitting on her and calling her a cheater.
+B.
+Also in September 2004, there was a domestic violence file opened where
+Vinyard was physically and verbally abusive to Jane Doe No. 4, his
+girlfriend at the time.
+There is reference that the two started a serious
+relationship in January 2002, when she was only fourteen (14) years old.
+C.
+Vinyard was arrested in December 2003, and charged with reckless
+driving and leaving the scene of the accident with Jane Doe No. 4, when
+their vehicle hit a tree and they fled.
+18.
+Moreover, an ex-boyfriend of Jane Doe No. 4 died in a DUI accident and it took
+her two years to get over his death, and another good friend of hers, "Jen," died in an automobile
+accident involving drinking. Within her Amended Complaint and Answers to Interrogatories,
+she indicates that she went to Epstein's house on several occasions. However, at no time did she
+call the police, at no time did she report any traumatic or severe emotional trauma, not alleged
+coercion, force or improper behavior by Epstein until she got a "lawyer" and is now pursuing
+claims for millions of dollars. Epstein's assistance to his attorneys at these depositions regarding
+the above issues is not only a constitutional due process right afforded to him but essential given
+the fact that this court has ruled that Plaintiffs' depositions can only occur one time, no "second
+bite" absent a court order.
+19.
+Given the breadth of the allegations made against Epstein and the substantial
+damages sought, Epstein has an unequivocal and constitutional right to be present at any
+deposition such that he can assist his counsel with the defense of these cases. See infra. Dr.
+
+
+Case 9:08-cv-80119-KAM Document 322-1 Entered on FLSD Docket 09/23/2009 Page 17 of
+Entered on FLSD Docket 09/17/2009 Page 8 of 11
+Case 9:08-CV-80119-KAM Document 296 Entered on FLSD Docket 09/11/2009 Page 8 of 33
+Page B
+also prepared affidavits regarding Jane Does 2, 3, 5, 6, and 7, which are attached to DE
+247.
+Memorandum Of Law
+20.
+Plaintiffs' motion is required to be denied as they have failed to meet their burden
+showing the "extraordinary circumstances" necessary to establish good cause to support a
+protective order which would grant the extraordinarily rare relief of preventing a named party
+from attending in person the deposition of another named party. Also requiring denial of
+Plaintiffs' motion is the fact that it seeks to exclude Epstein from all the depositions of all the
+Plaintiffs in actions before this Court. Such relief is unprecedented and attempts to have this
+Court look at the Plaintiffs' collectively as opposed to analyzing each case based on facts versus
+broad speculation whether "extraordinary circumstances" exist on a case by case basis. In other
+words, the standard is such that the Court would be required to determine whether each Plaintiff
+has met her burden, should the Court consider adopting such extraordinary relief. On its face,
+the motion does not meet the necessary burden as to Jane Doe 4, or Jane Does 2, 3, 5, 6, or 7.
+Discussion of Law Requiring the Denial of the Requested Protective Order
+Rule 26(c)(1)(E), Fed.R.Civ.P. (2009), governing protective orders, provides in relevant
+part that:
+(1) In General. A party or any person from whom discovery is sought may move for
+a protective order in the court where the action is pending--or as an alternative on
+matters relating to a deposition, in the court for the district where the deposition will
+be taken. The motion must include a certification that the movant has in good faith
+conferred or attempted to confer with other affected parties in an effort to resolve the
+dispute without court action. The court may, for good cause, issue an order to
+protect a party or person from annoyance, embarrassment, oppression, or
+undue burden or expense, including one or more of the following:
+(E) designating the persons who may be present while the discovery is conducted;
+
+
+Case 9:08-cv-80119-KAM Document 322-1 Entered on FLSD Docket 09/23/2009 Page 18 of
+Entered on FLSD Docket 09/17/2009 Page 9 of 11
+Case 9:08-cv-80119-KAM Document 296
+Entered on FLSD Docket 09/11/2009 Page 9 of 33
+Page 9
+*
+In seeking to prevent the Defendant from being present in the room where the Plaintiffs
+are being deposed, Plaintiffs generally rely on treatise material from
+&
+, 8 Federal
+Practice & Procedure Civ.2d, §2041, and cases cited therein. The case of Gaella v. Onassis, 487
+F.2d 986, at 997 (2d Cir. 1973), cited by Plaintiffs, makes clear that the exclusion of a party from
+a deposition "should be ordered rarely indeed." Unlike the Gaella case, there is no showing by
+each of the Plaintiffs that there has been any conduct by Epstein, in rightfully defending the
+actions filed against him, reflecting "an irrepressible intent to continue ... harassment" of any
+Plaintiff or a complete disregard of the judicial process, i.e. prior alleged conduct versus any
+action/conduct displayed in this or other cases that would justify extraordinary relief. There is
+absolutely no basis in the record to indicate that Epstein will act other than properly and with the
+proper decorum at the depositions of the Plaintiffs and abide in all respects with the No-Contact
+Order.
+Wherefore, Epstein respectfully requests that this Court enter an order denying Plaintiffs'
+Motion for Protective Order, provide that Epstein is permitted to attend the depositions of the
+Plaintiffs that have asserted claims against him in the related matters, and for such other and
+further relief as this court deems just and proper.
+Robert D. Critton, Jr.
+Michael J. Vike
+Attorney for Defendant Epsten
+
+
+Case 9:08-CV-80119-KAM Document 322-1 Entered on FLSD Docket 09/23/2009 Page 19 of
+Document 305-3
+Entered on FLSD Docket 09/17/2009 Page 10 of 11
+Case 9:08-cv-80119-KAM Document 296
+Entered on FLSD Docket 09/11/2009 Page 10 of 33
+Page 10
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was hand-delivered to the Clerk
+of the Court as required by the Local Rules of the Southern District of Florida and electronically
+mailed to all counsel of record identified on the following Service List on this Ilth day of
+September, 2009.
+Certificate of Service
+Jane Doe No. 2 v. Jeffrey Epstein.
+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
+ahorowitz@sexabuseattorney.com
+Brad
+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 in Related Case No. 08-
+80893
+Counsel for Plaintiffs
+In related Cases Nos. 08-80069, 08-80119, 08-
+80232, 08-80380, 08-80381,
+80994
+08-80993, 08- Paul G. Cassell, Esq.
+Pro Hac Vice
+332 South 1400 E, Room 101
+Richard Horace Willits, Esq.
+Salt Lake City, UT 84112
+ichard H. Willits, P.A
+801-585-5202
+290 10* Avenue Nort
+801-585-6833 Fax
+Suite 404
+cassellp@law.utah.edu
+Lake Worth, FL 33461
+Co-counsel for Plaintiff Jane Doe
+561-582-7600
+Fax: 561-588-8819
+Costsel for Plaimtif in Related Case No. 08.
+reelrhw@hotmail.com
+Jack Scarola, Esq.
+Jack P.
+Searcy Denney Scarola Barnhart & Shipley, 80469
+Isidro M.
+1, 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
+Counsel for Plaintiff in Related Case No. 08-
+
+
+Case 9:08-CV-80119-KAM Document 322-1 Entered on FLSD Docket 09/23/2009 Page 20 of
+
+Case 9:08-cv-80119-KAM Document 296
+Entered on FLSD Docket 09/11/2009
+
+Page 11
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33409
+561-686-6300
+Fax: 561-383-9424
+isx@searcylaw.com
+jph@searcylaw.com
+Counsel for Plaintiff,
+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
+Cossel for Plaintif in Related Case No. 08-
+skuvin@riccilaw.com
+tleopold@riccilaw.com
+Robert C. Josefsberg, Esq.
+Katherine W. Ezell, Esq.
+Podhurst Orseck, P.A.
+25 West Flagler Street, Suite 800
+Miami, FL 33130
+305 358-2800
+Fax: 305 358-2382
+riosefsberg@podhurst.com
+kezell@podhurst.com
+Counsel for Plaintiffs in Related Cases Nos.
+09-80591 and 09-80656
+Jack Alan Goldberger, Esq
+Atterbury Goldberger & Weiss, P.A
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+agesq@bellsouth.ne
+ounsel for Defendant Jeffrey Epstel
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER & COLEMAN
+(Co-Counsel for Defendant Jeffrey Epstein)
+
+
+Case 9:08-cv-80119-KAM Document 322-1 Entered on FLSD Docket 09/23/2009 Page 21 of
+• Case 9:08-cv-80119-KAM Document 305-4
+Entered on FLSD Docket 09/17/2009 Pegbof ef 2
+Robert D. Critton Jr.
+From: Adam Horowitz [ahorowitz@sexabuseattorney.com]
+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. Horowitz, Esq.
+www.sexabuseattorney.com
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+ghorowitz@sexabuseattorney.com
+Tel: (305) 931-2200
+Fax: (305) 931-0877
+From: Michael J. Pike [mailto:MPike@bclclaw.com.
+Sent: Tuesday, September 15, 2009 10:54 AM
+To: Stuart Mermelstein; Adam Horowitz
+Cc: Robert D. Critton Jr.; Jessica Cadwell
+Subject: FW: Jane Does v. Epstein
+Gentlemen:
+I sent the e-mail below weeks ago. I have not heard back from you. I'm entitled to the
+questionnaires Kliman had your clients fill out and which he utilized to formulate his opinions. I
+need them by tomorrow since they are well over due. If not, I will have no other choice to file a
+motion, which I do not want to do given how we have worked together on these issues in the
+past. Let me know, pike.
+From: Michael J. Pike
+Sent: Tuesday, August 18, 2009 11:37 AM
+To: Robert D. Critton Jr.; Stuart Mermelstein; Ashlie Stoken-Baring; Connie Zaguirre
+Subject: Jane Does v. Epstein
+From reviewing the transcripts, it seems Dr. Kliman utilized Questionnaire's with all of your
+clients. I need them. Please advise of your position. I'm sure you will produce since they are
+
+9/15/2009
+
+
+Case 9:08-cv-80119-KAM Document 322-1 Entered on FLSD Docket 09/23/2009
+Page 22 of
+Case 9:08-cv-80119-KAM Document 305-4 k
+Faage 2 of 2
+discoverable. Thanks.
+Michael J. Pike, Esq.
+Burman, Critton, Luttier & Coleman
+515 N. Flagler Dr., Ste. 400
+West Palm Beach, Florida 33401
+Telephone: (561) 842-2820
+Facsimile (561) 844-6929
+
+The information contained in this tansmission is attorney/client privileged and/ or attorney work product.
+If you are not the addressee or authotized by the addressee to receive this message, you shall not review,
+disclose, copy, distribute ot otherwise use this message (including any attachments). If you have received
+this e-mail in error, please immediately notify the sender by reply e-mail and destroy the message (including
+attachments) and all copies. Thank you.
+9/15/2009
+
+
+Case 9:08-CV-80119-KAM Document 322-1 Entered on FLSD Docket 09/23/2009 Page 23 of
+
+JANE DOE NO. 2,
+Plaintiff,
+JEFFREY B. EPSTEIN,
+Defendant.
+Related Cases:
+08-80232, 08-80380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80581, 09-80656, 09-80802, 09-81092.
+AFFIDAVIT OF JEFFREY E. EPSTEIN
+STATE OF FLORIDA
+) SS
+COUNTY OF PALM BEACH
+)
+BEFORE ME, the undersigned authority, personally appeared Jeffrey B. Epstein
+having personal knowledge and being duly sworn, deposes and says:
+My office is located at 250 Australian Avenue South, 14 Floor, West Palm
+Beach, Florida. Its location has been well publicized in the news.
+I met with my attorneys, Robert D. Critton, Jr. and Mark T. Luttier, at 12:30 p.m.
+in preparation for the deposition of Jane Doe No. 4 which was to take place beginning at 1:00
+p.m. on September 16, 2009.
+3.
+I was aware of the motion for protective order which had been served in this case
+by counsel for Jane Doe No. 4 and the Emergency Motion To Strike Plaintiff's Motion For
+
+
+
+Case 9:08-Cv-80119-KAM Document 322-1 Entered on FLSD Docket 09/23/2009 Page 24 of
+Entered on FLSD Docket 09/17/2009 Page 2 of 3
+Protective Order And Bmergency Motion To Allow The Attendance Of Jeffrey Epstein At The
+Deposition Of Plaintiffs And Response In Opposition To Plaintiffs', Jane Doe Nos. 2-8, Motion
+For Protective Order As To Jeffrey Epstein's Attendance At The Deposition Of Plaintiffs, With
+Incorporated Memorandum of Law, which had been filed on my behalf such that I could attend
+the deposition and assist my attorneys in my defense.
+4.
+I also understood that as of 1:00 p.m. on September 16, after I had finished.
+speaking with my attorneys that the court had not ruled regarding the above-referenced motions.
+I was instructed by my attorneys that I could not attend the deposition and
+therefore a video feed was set up such that I could view the deposition from my home.
+6. I also understood that my attorneys did not want me in the building after the
+deposition began.
+At 1:04 p.m. after we assumed that everyone would be in the deposition room, my
+lawyers went down on one elevator and I went down on another elevator with my driver, Igor
+Zinovier, both exiting at approximately the same time.
+8. I asked Igor where he had parked, and he said "out front". We exited the
+elevator, I walked toward the front door. Near the front door, I saw a taller woman and a
+shorter woman who I thought might be Jane Doe No. 4 and immediately turned to my left and
+went out a separate exit to the garage.
+9.
+At no time did I speak with or attempt to interact with either women.
+FURTHER THE AFFLANT SAYETH NAUGHT.
+
+
+Case 9:08-CV-80119-KAM Document 322-1 Entered on FLSD Docket 09/23/2009 Page 25 of
+
+Page 3
+STATE OF FLORIDA
+COUNTY OF PALM BEACH
+I hereby Certify that on this day, before me, an officer duly authorized to administer
+oaths and take acknowledgments, personally appeared Jeffrey B. Epstein known to me to be the
+person described in and who executed the foregoing Affidavit, who acknowledged before me
+that he/she executed the same, that I relied upon the following form of identification of the above
+named person: Jeftay Epstein.
+, and that an oath was/was not taken.
+ITNESS my hand and official seal in the County and State last aforesaid th
+ay of Sept. 17
+- 2009.
+:
+4. Val
+TAME: Shen I Make (SBAL)
+NOTARY PUBLIC/STATE OF FLORIDA
+COMMISSION NO.:
+MY COMMISSION PAIN
+NOTARY
+L MAHONAL
+: My Comm. Expires
+May 28, 2010
+No. DD519867
+PUBLIC
+
+
+Case 9:08-CV-80119-KAM Document 322-1 Entered on FLSD Docket 09/23/2009 Page 26 of
+
+4: At no time did Mr. Epstein speak or gesture to anyone, including the individuals
+whom I saw near the front door.
+5.
+At no time did I speak with the individuals at the main entrance.
+FURTHER THE AFFIANT SAYETH NAUGHT.™
+STATE OF FLORIDA
+COUNTY OF PALM BEACH
+I hereby Certify that on this day, before me, an officer duly authorized to administer
+day of
+WITNESS my hand and official seal in the County and State last aforesaid this
+Sept. 17
+- 2009.
+......
+SOTARY
+Expire
+MY Make
+My May 28, 2010
+No. DD519B67
+STATE
+FOR TARY POLICIAN OF FORMan. (SEAL)
+COMMISSION NO.:
+
+
+Case 9:08-Cv-80119-KAM Document 322-1 Entered on FLSD Docket 09/23/2009 Page 27 of
+
+CASE NO.: 08-CV-80119-1
+JANE DOE NO. 2,
+Plaintiff,
+V.
+JEPFREY EPSTEIN,
+Defendant.
+Related Cases:
+08-80232, 08-80380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80581, 09-80656, 09-80802, 09-81092.
+AFFIDAVIT OF IGOR ZINOVIEY
+STATE OF FLORIDA
+COUNTY OF PALM BBACH
+) SS
+)
+BEFORE ME, the undersigned authority, personally appeared Igor Zinovier
+having personal knowledge and being duly sworn, deposes and says:
+I work for Jeffrey Epstein. I as well drive him from place to place.
+2.
+At approximately 1:04 p.m., Mr. Epstein and I went down in the elevator from the
+14"* floor to the ground level. I was to drive Mr. Epstein to his home. His lawyers went down at
+approximately the same time in a separate elevator.
+3.
+I parked the car at the front entrance. As I walked toward the front door and
+noticed that Mr. Epstein quickly turned to the left so as to exit through the door to the garage of
+the building rather than the front entrance.
+
+
+
+Case 9:08-CV-80119-KAM Document 322-1 Entered on FLSD Docket 09/23/2009 Page 28 of
+Case 9:08-cv-80119-KAM Document 305-7
+
+JANE DOE NO. 2,
+Plaintiff,
+V.
+JEFFREY EPSTEIN,
+Defendant.
+Related Cases:
+08-80232, 08-80380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80581, 09-80656, 09-80802, 09-81092.
+AFFIDAVIT OF ROBERT D. CRITTON, JR.
+STATE OF FLORIDA
+COUNTY OF PALM BEACH
+) SS
+)
+BEFORE ME, the undersigned authority, personally appeared Robert D. Critton, Jr.,
+having personal knowledge and being duly sworn, deposes and says:
+I am counsel for Jeffrey Epstein in the above-styled matter and other civil
+lawsuits.
+The information contained in motion, paragraphs 1 through 9, 11, 13, 14 and 16
+is true and accurate based on my personal knowledge.
+3.
+The costs and fees set forth in the motion are true, correct and reasonable.
+FURTHER THE AFFIANT SAYETH NAUGHT.
+Robert TP. Critton, Jr.
+XHIBIT 6
+
+
+Case 9:08-CV-80119-KAM Document 322-1 Entered on FLSD Docket 09/23/2009 Page 29 of
+Case 9:08-cv-80119-KAM Document 305-7
+Entered on FLSD Docket 09/17/2009 Page 2 of 2
+STATE OF FLORIDA
+COUNTY OF PALM BEACH
+I hereby Certify that on this day, before me, an officer duly authorized to administer
+oaths and take acknowledgments, personally appeared Robert D. Critton, Jr.. known to me to be
+the person described in and who executed the foregoing Affidavit, who acknowledged before me
+that he/she executed the same, that I relied upon the following form of identification of the above
+named person: Deborally known
+→ and that an oath was/was not taken.
+WITNESS my hand and official seal in the County and State last aforesaid this
+day of [1, Septenber
+_ 2009.
+JESSICA CADWELL
+MY COMMISSION # DD 853529
+EXPIRES: April 19, 2013
+Bonded Thra Notary Public Undentlers
+sin (adwell
+ELSICA CADWASAL)
+NOTAR& PUBLIC/STATE OF FLORIDA
+COMMISSION NO: DD 853529
+04/19/13
+
+
+Case 9:08-Cv-80119-KAM Document 322-1 Entered on FLSD Docket 09/23/2009 Page 30 of
+Case 9:08-cv-80119-KAM Document 305-8
+Entered on FLSD Docket 09/17/2009 Page 1 of 2
+CASE NO.: 08-CV-80119-MARRA-u
+JANE DOE NO. 2,
+Plaintiff,
+V.
+JEFFREY EPSTEIN,
+Defendant.
+Related Cases:
+08-80232, 08-80380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80581, 09-80656, 09-80802, 09-81092.
+AFFIDAVIT OF MARK T. LUTTIER
+STATE OF FLORIDA
+COUNTY OF PALM BEACH
+) SS
+)
+BEFORE ME, the undersigned authority, personally appeared Mark T. Luttier, having
+personal knowledge and being duly sworn, deposes and says:
+I am counsel for Jeffrey Epstein in the above-styled matter and other civil
+lawsuits.
+The information contained in motion, paragraphs 1 through 10, 11, 13, 14 and 16
+is true and accurate based on my personal knowledge.
+FURTHER THE AFFIANT SAYETH NAUGHT.
+Mach I Cutte
+Mark T. Luttier
+
+
+
+Case 9:08-cv-80119-KAM Document 322-1 Entered on FLSD Docket 09/23/2009 Page 31 of
+Document 305-8 Entered on FLSD Docket 09/17/2009 Page 2 of 2
+STATE OF FLORIDA
+COUNTY OF PALM BEACH
+I hereby Certify that on this day, before me, an officer duly authorized to administer
+oaths and take acknowledgments, personally appeared Mark T. Luttier, known to me to be the
+person described in and who executed the foregoing Affidavit, who acknowledged before me
+that he/she executed the same, that I relied upon the following form of identification of the above
+named person: De Sonall Known, and that an oath was/was not taken.
+ayOr LENESS my hand and official seal in the County and State last aforesaid this /774
+sept: 2009
+JESSICA CADWELL.
+MY COMMIESION & CD 853529
+(PIRES: April 19, 20
+ded Thera Notary Public Undi
+Jessien adwell
+PRINT NAMB TESSICA C42181B/C
+NOTARY PUBLIC/STATE OF FLÓRIDA
+COMMISSION NO: 3D853529
+04/19/13
+
+
+Case 9:08-Cv-80119-KAM Document 322-1 Entered on FLSD Docket 09/23/2009 Page 32 of
+Case 9:08-CV-80119-KAM Document 305-9
+Entered on FLSD Docket 09/17/2009 Page 1 of 3
+CASE NO. 08-CV-80119-MARRA/4
+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 uble, state of Florida
+Prose Court Reporting
+
+(561) 832-7500
+Electronically signed by cynthia
+PROSE COURT REPORTING AGENCY, INC.
+(561) 832-7506
+(601-051-976-2934)
+d2a436e3-9513-4206-9641-6687d2dff905
+
+
+Entered on FLSD Docket 09/23/2009 Page 33 of
+
+Page
+4
+4
+5
+10
+11
+12
+13
+14
+15
+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 Jeflrey Epstein:
+JACK ALAN GOLDBERGER, ESQUIRE
+ATTERBURY, GOLDBERGER & WEISS, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palen Beach, Florida 33401-5012
+Phons: 561.659.8300
+On behalf of LM and EW:
+WILLIAM I. BERGER, ESQUIRE
+ROTHSTEIN, ROSENFELDT, ADLER
+401 East Las Olas Boulevand
+Suite 1650
+Fort Lauderdale, Florida 33301
+Phome: 954.522.3456
+In behalf MA, ESQUIRE
+SEARCY, DENNEY, SCAROLA
+BARNHART & SHIPLEY, P.A
+1
+2
+3
+4
+5
+6
+7
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 3
+PROCEEDINGS
+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
+1: Jack
+I 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 a stipulation 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
+Page 5
+her and intimidated her, and for that reason
+1
+2
+5
+6
+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
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+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
+were not going forward.
+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.
+He was going to appear by way of Skype so
+that he could be on a video camera so that he
+could see this.
+(Mr. Goldberger entered the room.)
+MR. CRITTON; Had you been here on time,
+and not faulting, I am just saying had you been
+here on time at 1:00, as everyone else seemed
+to be here at least get here before you dia,
+Adam, you and your client, your paths never
+would have crossed.
+I directed 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 (Pages 2 to 5)
+(561) 832-7500
+PROSE COURT REPORTING AGENCY, INC.
+(561) 832-7506
+d2a436e3-95f3-42e6-9641-6687d2dff9e5
+Electronically signed by cynthia hopkins (601-051-976-2934)
+
+
+Document 322-1
+Entered on FLSD Docket 09/23/2009 Page 34 of
+
+Page 8
+1
+2
+3
+4
+5
+6
+7
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+4
+5
+6
+7
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+(561) 832-7500
+Electronically signed by cynthia
+Page 6
+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
+Page 7
+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.)
+1
+2
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+25
+CERTIFICATE
+STATE OF FLORIDA
+COUNTY OF PALM BEACH
+1, 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 a true and
+complete record of my stenographic notes.
+Dated this 16th day of September, 2009.
+3
+(Pages 6 to 8)
+PROSE COURT REPORTING AGENCY, INC.
+(561)
+832-7506
+(601-051-976-2934)
+d2a436e3-95f3-42e6-9641-6687d2dff9e5
+
+
+Case 9:08-cv-80119-KAM Document 322-1 Entered on FLSD Docket 09/23/2009 Page 35 of
+Ca8e9:0B-20810905AM
+Document 305-10
+Entered on FLSD Docket 09M7/2009 PPage 1 of 2
+Prose Court Reporting Agency, Inc
+One Clearlake Centre
+250 South Australian Avenue, Suite 1500
+West Paim Beach, Florida 33401
+(561) 832-7500 Phone (561) 832-7506 Fax
+Tax ID: 26-3892897
+www.proseora.com
+September 17, 2008
+Robert Critton, Esquire
+Burman, Critton, Luttier & Coleman - WPB
+303 Banyan Boulevard
+Sulte 400
+West Palm Beach, FL 33401
+Involce Number
+CH 411
+Re: Jane Doe No. 2 vs. Jeffrey Epstein
+9-18-09 Scheduled Deposition of Jane Doe No. 4
+Statement for Record
+Description of Services
+Depo App NT - 1st Hr
+Depo Trans 081-Reg
+E-Transcript Emalled
+Appearance 1st Hr
+Transcript Pages - B
+Complimentary
+Involce total:
+110.00
+28.80
+$138.80
+Thank you for choosing Prose Court Reporting Agency, inc. Payment is due upon receipt.
+
+
+
+Case 9:08-Cv-80119-KAM Document 322-1 Entered on FLSD Docket 09/23/2009 Page 36 of
+East 9108-208801992RAR765530Cument 305-10
+elfered on FLSD Docket 09/7i23dg "Page2/872
+VISUAI
+Invoice
+EVIDENCE
+P.O. ox 0987 West Palm Beach, FL 33405
+Date
+Number
+9/17/2009
+28616
+Terms
+Due on receipt
+BURMAN, CRITTON & LUTTIER
+ROBERT CRITTON
+303 BANYAN BLVD
+SUITE 400
+WEST PALM BEACH, FL 33401
+Date
+9/18/2009
+9/17/2009
+Case / Reference:
+JANE DOE #2 V EPSTEIN
+Services Rendered
+Qty
+VIDEOTAPED DEPOSITION OF: JANE DOE # 4
+Tech Time - 1ST 2 Hours
+Daltal Tape
+TAPE CONSISTS OF DISCUSSIONS BETWEEN ATTORNEYS PRIOR TO SWEARING IN
+REGARDING CANCELLATION OF DEPO.
+Delivery
+TAPES FORWARDED PER YOUR REQUEST. NO COPIES HAVE BEEN MADE OR KEPT ON
+BIAN VISUAL EVIDENCE. SHOULD COPIES BE REQUIRED IN THE FUTURE PLEASE FORWARD
+TAPES TO OUR OFFICE FOR DUPLICATION. THANK YOU.
+Amount
+275.00
+15.00
+0.00
+MORE THAN JUST VIDEO / See ALL avallable presentation
+technology services at: www.visualevldence.org.
+TOTAL:
+$290.00
+Remit to
+P.O. Box 696.
+Wast Palm Beach, FL. 33405
+Tax ID # 59-2476529
+Phone: (561) 655-2855 Fux: (561) 655-2896 office@visualevidence.org
+
+
+Case 9:08-cv-80119-KAM Document 322-1 Entered on FLSD Docket 09/23/2009 Page 37 of
+Case 9:08-CV-80119-KAM Document 305-11
+
+JANE DOE NO. 2,
+Plaintiff,
+v.
+JEFFREY EPSTEIN,
+Defendant.
+Related Cases:
+08-80232, 08-80380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80581, 09-80656, 09-80802, 09-81092.
+ORDER ON DEFENDANT'S, JEFFREY EPSTEIN, MOTION FOR SANCTIONS
+AND TO COMPEL DEPOSITION OF JANE DOE NO. 4
+AND MEMORANDUM IN SUPPORT THEREOE
+This matter came before the Court on Defendant's, JEFFREY EPSTEIN, Motion For
+Sanctions and to Compel Deposition of Jane Doe No. 4. Having considered Defendant's motion,
+it is HEREBY ORDERED and ADJUDGED that:
+Defendant's motion is hereby GRANTED: Plaintiff shall pay sanctions in the amount of
+in costs and $
+in fees directly to Burman, Critton, Luttier and
+Coleman within 10 days, and further directs that the Plaintiff make herself available for
+deposition no later than October .
+_ 2009 beginning at 9:30 a.m. at the same location. Mr.
+• Epstein shall not be present in the building on the day of the deposition absent a court order on
+pending motions.
+
+
+Case 9:08-Cv-80119-KAM Document 322-1 Entered on FLSD Docket 09/23/2009 Page 38 of
+Case 9:08-cv-80119-KAM Document 305-11
+
+DONE and ORDERED this _
+_day of
+, 2009.
+Kenneth A. Marra
+United States District Judge
+Courtesy Copies: Counsel of Record

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vision-fixhub/court-01/8f95619050f6401c3d0db3432dbde718a98699b1c45e3c3cf29445dc3d9b216d.md

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+Case 9:08-cv-80119-KAM Document 499 Entered on FLSD Docket 03/24/2010 Page 1 of 1
+Case 9:08-cv-80119 KAM Document 491-1
+Entered on PLSD Docket 03/18/2010
+
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA •
+CASE NO.: 08-CIV-80119-MARRA/JOHNSON
+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
+MAR 2 4 2010
+STEVEN M. LARIMORE
+CLERK U.S. DIST. CT.
+S.D. OF FLA. - W.P.B.
+ORDER
+This matter came before the Court on Defendant, JEFFREY EPSTEIN'S, Motion
+for Extension of Time to File Reply to Plaintiff, JANE DOE'S, Response in Opposition
+to Defendant's Motion for Reconsideration and/or Request for Rule 4 Appeal (DE 485),
+having considered Defendant's Motion, it is HEREBY ORDERED and ADJUDGED
+that:
+Defendant's Motion is GRANTED. Defendant shall file his Reply to Plaintiff,
+JANE DOE'S, Response in Opposition to Defendant's Motion for Reconsideration
+and/or Request for Rule 4 Appeal on or before March 26, 2010.
+DONE and ORDERED this 2Y day of MArch 2010.
+Luneformon
+UNNEA R. Ichnsm
+United States Distriot-Judge
+Courtesy Copies all counsel
+MAGISTRATE

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vision-fixhub/court-01/8fd6a53809ebf65104b156f3d102116d9cd61e913c586b36e32864185f38973b.md

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+Case 1:19-cv-09610-PAE-DCF Document 36-1 Filed 12/23/19 Page 1 of 37
+
+
+
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+CASE NO.
+JANE DOE 17,
+Plaintiff,
+V.
+DARREN K. INDYKE AND
+RICHARD D. KAHN, AS JOINT
+PERSONAL REPRESENTATIVES OF
+THE ESTATE OF JEFFREY E. EPSTEIN,
+NINE EAST 71st STREET CORPORATION,
+LAUREL, INC., FINANCIAL TRUST COMPANY,
+INC., NES, LLC, MAPLE, INC., LSJE, LLC,
+HBRK ASSOCIATES, INC., NAUTILUS, INC.,
+CYPRESS, INC. and JEGE, INC.
+Defendants.
+COMPLAINT
+Plaintiff, JANE DOE 17, by and through the undersigned counsel, in support of her
+claims against Defendants, alleges and states as follows:
+This action is brought, inter alia, pursuant to common law, statutory law and 18
+U.S.C. §1591- §1595. Therefore, jurisdiction is proper under 28 U.S.C. §1331 and the damages
+sought exceed the jurisdictional requirements of this Court.
+2.
+Plaintiff files this complaint under a pseudonym in order to protect her identity
+because the Complaint makes allegations of a sensitive sexual nature the disclosure of which, in
+association with her name, would cause further harm to her.
+Plaintiff is currently a resident and domiciled in the State of Florida and over the
+age of 18.
+
+
+
+4. At all times material, Jeffrey Epstein ("Epstein") was a citizen of the United
+States and resident of the U.S. Virgin Islands. Epstein was a man of extreme wealth who
+frequently travelled between and regularly stayed in his numerous residences, including in New
+York (within the Southern District of New York) at 9 East 71" Street, New York, NY 10021; in
+Palm Beach, Florida at 358 El Brillo Way, Palm Beach, Florida 33480; in New Mexico at 49
+Zorro Ranch Road, Stanley, New Mexico 87056, in Paris, France at 22 Avenue Foch, Paris,
+France 75116, and in the United States Virgin Islands at Little St. James Island No. 6B USVI
+00802.
+5.
+At all times material to this cause of action Epstein was an adult male born on
+January 20, 1953, who died on August 10, 2019.
+6.
+Defendant, Darren K. Indyke and Richard D. Kahn as Joint Personal
+Representatives of the Estate of Jeffrey E. Epstein ("Estate of Jeffrey E. Epstein") was opened
+and domiciled in the United States Virgin Islands, St.
+Division, and is the legal entity
+responsible for intentional, criminal, or tortious conduct committed by Epstein as described in
+this Complaint.
+7. At all times material hereto, Defendant Nine East 71 Street, Corporation ("Nine
+East"), was a domestic business corporation conducting business in New York with its principal
+place of business located at 575 Lexington Avenue, Fourth Floor, New York 10022.
+8.
+At all times material hereto, Defendant Laurel, Inc. ("Laurel") was and is a U.S.
+Virgin Islands corporation conducting business in multiple locations including New York and
+Florida.
+
+
+
+9.
+At all times material hereto, Defendant Financial Trust Company, Inc. (Financial
+Trust"), was and is a U.S. Virgin Islands corporation conducting business in multiple locations
+including New York.
+10.
+At all times material hereto, Defendant NES, LLC, ("NES"), was and is a
+domestic limited liability company registered in and conducting business in multiple locations
+including New York.
+11.
+At all times material hereto, Defendant Maple, Inc., ("Maple"), was and is a U.S.
+Virgin Islands corporation conducting business in New York.
+12.
+At all times material hereto, LSJE., LLC, ("LSJ"), was and is a U. S. Virgin
+Islands corporation conducting business in the United States Virgin Islands conducting business
+in New York.
+13. At all times material hereto, Defendant HBRK Associates, Inc., ("HBRK"), was
+and is a domestic business corporation registered in and conducting business in multiple
+locations including New York with a Registered Agent located at 1365 York Avenue, Apartment
+28, New York 10021.
+14. At all times material hereto, Defendant Nautilus, Inc., ("Nautilus"), was and is a
+U.S. Virgin Islands corporation conducting business in New York.
+15.
+At all times material hereto, Defendant Cypress, Inc., ("Cypress"), was and is a
+U.S. Virgin Islands corporation conducting business in New York and New Mexico.
+16.
+At all times material hereto, Defendant JEGE, Inc., ("JEGE"), is a U.S. Virgin
+Islands corporation conducting business throughout the United States of America, including but
+not limited to, Florida, New York and the United States Virgin Islands.
+
+
+
+17. Corporate Defendants Nine East, Laurel, Financial Trust, NES, Maple, LSJE,
+HBRK, JEGE, Nautilus, and Cypress, referred to as "Corporate Defendants," each performed
+business, in whole or in part, in New York.
+18.
+Plaintiff intends to amend this complaint to add or substitute additional parties as
+discovery reveals the identities of other tortious corporate or individual actors.
+19. Epstein, the leader of a complex commercial sex trafficking and abuse ring, was
+an officer, director, or employee of many corporate entities registered in various states
+throughout the United States, one or more of which may also be legally responsible for the
+crimes and torts he committed against young females, including Plaintiff.
+20.
+Additionally, individuals who worked at the residences where sexual criminal acts
+were committed, or friends or acquaintances who assisted Epstein in committing such violations
+or those of his wealthy, famous, or socially powerful friends with whom Epstein caused Plaintiff
+to be sexually abused by, or those who were employed through, or worked for, numerous other
+corporate entities whose participation caused or contributed to causing the sexual violations that
+caused harm to Plaintiff, may additionally be added as defendants.
+21. A substantial part of the acts, events, and omissions giving rise to this cause of
+action occurred in the Southern District of New York; venue is proper in this District. 28 U.S.C.
+§1391(b)(2).
+22.
+At all times material to this cause of action, Epstein (legally represented now
+through Darren K. Indyke and Richard D. Kahn as Joint Personal Representatives of the Estate
+of Jeffrey E. Epstein (referred to herein as "Estate of Jeffrey E. Epstein") and Corporate
+Defendants owed a duty to Plaintiff to treat her in a non-negligent manner and not to commit, or
+conspire to commit, or cause to be committed intentional, criminal, fraudulent, or tortious acts
+
+
+
+Cas@abd9-99￾@9696PAФĄЄБСFDФUШAn*7011 FilEürb1R171§19ag8a5 0f6зaf 37
+against Plaintiff, including any acts that would cause Plaintiff to be harmed through conduct
+committed against her in violation of Common law battery, New York Penal Law §130.20; or
+New York Penal Law §130.35; or New York Penal Law §130.50; or New York Penal Law
+$130.52; or New York Penal Law §130.66; or any violation of 18 U.S.C. §1591-$1595.
+FACTUAL ALLEGATIONS
+23. At all times material to this cause of action, Epstein was an adult male over 45
+years old. Epstein was a tremendously wealthy individual, widely recognized as a billionaire,
+who used his wealth, power, resources, and connections to commit illegal sexual crimes in
+violation of federal and state laws and who employed or conspired with other individuals and
+corporate entities to assist him in committing those crimes or torts or who facilitated or enabled
+those acts to occur.
+24. Epstein displayed his enormous wealth, power, and influence to his employees; to
+the employees of the corporate or company entities who worked at his direction, to the victims
+procured for sexual purposes; and to the public, in order to advance, carry out, and conceal his
+crimes and torts.
+25. At all relevant times, Epstein had access to numerous mansions, as well as a fleet
+of airplanes, motor vehicles, boats and one or more helicopters. For example, he regularly
+traveled by private jet aboard a Boeing aircraft (of make and model B-727-31H with tail number
+N908JE) or a Gulfstream aircraft (of' make and model G-1159B with tail number N909JE).
+26.
+Epstein also inhabited and frequently travelled between numerous properties and
+homes, each of which he admitted to being owned or controlled by him, including a Manhattan
+townhome located at 9 East 71" Street, New York, New York 10021 valued conservatively by
+Epstein's own admission at $55,931,000.00 (but valued by the US Attorney's office for this
+
+
+
+District at $77,000,000); a ranch located at 49 Zorro Ranch Road, Stanley, New Mexico 87056
+valued conservatively by Epstein's own admission at $17,246,208.00; a home located at 358 El
+Brillo Way, Palm Beach, Florida 33480 valued conservatively by Epstein's own admission at
+$12,380,209.00; an apartment located at 22 Avenue Foch, Paris, France 75116 valued
+conservatively by Epstein's own admission at $8,672,820.00; an Island located at Great St.
+James Island No. 6A USVI 00802 (parcels A, B, and C); and an Island Little St. James Island
+No. 6B USVI 00802 (parcels A, B, and C). See Jeffrey Epstein "Asset Summary - June 30,
+2019" filed in Case No. 1:19-cr-00490-RMB on July 15, 2019 attached hereto as Exhibit A.
+27.
+Epstein controlled or was affiliated with the corporation or business entities that
+owned, managed, or maintained each of the real properties listed in the preceding paragraph and
+enumerated in Exhibit A.
+28.
+The allegations herein concern Epstein's tortious conduct committed against
+Plaintiff while at the residences owned by Defendant Nine East in New York, Defendant Laurel
+in Florida, Defendant Cypress in New Mexico and Defendants LSJE and Nautilus in the U.S.
+Virgin Islands. Many such acts were facilitated by Defendant NES or Defendant HBRK or
+Defendant JEGE.
+29.
+Epstein had a compulsive sexual preference for young females, as young as 14
+years old, and acted on that sexual preference for decades.
+30.
+Epstein enjoyed sexual contact with young females, including minor children, and
+also took pleasure corrupting vulnerable and innocent young females, including minor children,
+into engaging in sexual acts with him.
+
+
+
+31.
+Epstein directed a complex system of individuals, including employees and
+associates of Defendant entities, to work in concert and at his direction, for the purpose of
+harming young females through sexual exploitation, abuse and trafficking.
+32.
+It was widely known among individuals regularly in Epstein's presence that he
+obtained pleasure from corrupting and inducing vulnerable young females into engaging in
+uncomfortable and unwanted sexual acts for his own gratification.
+33.
+Epstein's illegal sexual activities were investigated by law enforcement on at least
+two occasions, once in 2005-2008 by the United States Attorney for the Southern District of
+Florida, and more recently by the United States Attorney for the Southern District of New York.
+34.
+On July 2, 2019 the United States Attorney's Office for the Southern District of
+New York filed a sealed Two Count Indictment including One Count of Sex Trafficking
+Conspiracy and One Count of Sex Trafficking for violations of 18 U.S.C. §1591, in part due to
+Epstein's criminal activities against children in the New York Mansion located at 9 East 71$
+Street.
+35.
+In addition to the allegations in the criminal indictment referenced above, Epstein
+also utilized a similar, if not the same; scheme many years before the time period that was
+charged and many years after as well as in additional locations nationally and internationally.
+36.
+Corporate Defendants enabled Epstein to receive daily massages from young
+females, often minors, who were not experienced in massage. Rather than receive regular body
+massages, Epstein was predictably sexually abusing young females, including Plaintiff, in
+violation of New York Penal Law $130.
+
+
+
+37.
+Additionally, employees of the various Corporate Defendants performed actions
+or failed to perform actions that further placed victims, including Plaintiff, in danger of being
+sexually abused by Epstein, and assisted in the concealment of his sexually abusive acts.
+38.
+Defendants employed many recruiters of young females, or directed employees of
+his related companies, to recruit young females In order to grow the enterprise and satisfy his
+insatiable sexual desire, Epstein and those working at his direction enabled victims themselves to
+elevate their status within the enterprise to that of a paid recruiter of other victims, an elevation
+only made possible through the assistance of Defendants.
+39.
+Recruiters were taught by Epstein or by employees of Corporate Defendants to
+inform targeted young female victims that Epstein possessed extraordinary wealth, power,
+resources, and influence; that he was a philanthropist who would help female victims advance
+their education, careers, and lives; and that she only needed to provide Epstein with body
+massages in order to avail herself of his nearly unlimited assistance and influence.
+40.
+Epstein and Corporate Defendants and their many employees fulfilled Epstein's
+compulsive need for sex with young females by preying on their personal, psychological,
+financial, and related vulnerabilities. Epstein and Defendants' tactics included promising the
+victims money, shelter, transportation, gifts, employment, admission into educational
+institutions, education tuition, professional licensure, protection, healthcare and other things of
+value.
+41.
+Epstein's sexual attraction to young, often underage, females dated back to at
+least the mid-nineties and the number of victims increased substantially with the necessary
+assistance from Defendants and Defendants' employees.
+
+
+
+42.
+Defendants, at the direction of Epstein or in furtherance of his demands, and with
+help from assistants, associates and underlings, and even other victims, recruited or procured
+dozens if not hundreds of young females, including minors, for the purpose of Epstein's sexual
+gratification.
+43.
+Epstein, and employees of certain Corporate Defendants, including at least
+Defendant HBRK,
+specifically targeted underprivileged, emotionally vulnerable and/or
+economically disadvantaged young females to sexually molest and abuse.
+44.
+Additionally, Epstein and Corporate Defendants, through employees, informed
+young females, including Plaintiff that Epstein was wealthy, well-connected, and had the power
+and ability to impact the life of any young female recruited or obtained to provide a massage.
+45.
+Each of the Corporate Defendants committed acts of negligence that allowed for
+Epstein to commit acts in violation of New York Penal Law §130.
+46.
+Each of the Defendants committed acts against Plaintiff in violation of 18 U.S.C.
+§1591 - $1595.
+JANE DOE 17
+47.
+Consistent with Epstein's foregoing plan, scheme/enterprise, the Plaintiff was
+recruited to provide Epstein with massages for monetary compensation. These massages
+provided to Epstein by Plaintiff progressed to instances of inappropriate sexual contact with the
+Plaintiff by Epstein in touching, inappropriate vaginal penetration, and outright rape. Plaintiff
+was sexually assaulted, violated, and otherwise degraded, injured, victimized, and subjected to
+outrageous, reckless abuse and insult.
+48.
+In this regard, the Defendants willingly participated, contributed, cooperated, and
+assisted the inappropriate and illegal scheme by facilitating such scheme by and through the
+
+
+
+employees of the Corporate Defendants such that the Corporate Defendants were acting jointly
+and in concert with the illegal scheme with the goal designed to produce corrupt sexual
+gratification for Epstein and degradation for the targets and victims of the corrupt scheme set in
+motion with the active involvement of the Corporate Defendants and their employees.
+49.
+Epstein's abuse of the Plaintiff was not incidental or fleeting but rather was born
+out of a pathological desire to achieve, corrupt and deviate sexual gratification through the
+subjugation and abuse of Epstein's targeted victims. The actions on behalf of the Corporate
+Defendants by and through its employees enhanced, facilitated, and promoted the deviate sexual
+acts of Epstein and contributed a corrupting influence which ensnared unsuspecting women and
+girls in its reach.
+50.
+Epstein, by acting singularly and in concert with the Corporate Defendants,
+devised a sophisticated plan and a modus operandi which subtly and pervasively over time
+connived to influence the victims and subjects of the corrupt and deviant sexual scheme to
+influence the will to resist the temptations both actual and promised on behalf of the scheme and
+thereby manipulate the victims into acceptance of the scheme as being one that was acceptable
+and appropriate by virtue of communications and representations made on behalf of Epstein by
+the Corporate Defendants and in fact Epstein himself. The scheme utilized a gradual wearing
+down of the victim's will to resist and did so by virtue of offering positive and negative rewards
+for compliance with the scheme's overall deviant methodology and goals.
+51.
+Once Epstein and the Corporate Defendants" victims were entrapped and the
+scheme's methodologies enabled, Epstein and the corporate defendants through its employees
+utilized techniques to further inhibit, indoctrinate, and threaten Epstein's victims such that
+compliance with the deviant scheme's goals could be further obtained.
+
+
+
+52.
+The deviant scheme was perpetuated over years by the actions of Epstein and the
+Corporate Defendants such that victims were caught up in the scheme, pressure, threats, and
+indoctrination techniques utilized to bring the victims to heel.
+53.
+For victims young, vulnerable, and struggling financially, the scheme's
+methodology was particularly effective.
+54.
+As part and parcel of the scheme's goals, Epstein's colleagues and acquaintances
+were involved in the scheme and benefited from the scheme by virtue of receiving sexual favors
+and inappropriate, illegal, and otherwise commercial sexual services provided by Epstein's
+victims such that the corrupt intent of this scheme involved males other than Epstein himself.
+As a direct and proximate result of the methodology of the deviant scheme and the goals of
+sexual exploitation of the women recruited and victimized, Plaintiff was subject to unwanted
+touching of her breasts and genitals, other sensitive areas of her body, required to perform acts
+of a sexual nature against her will and subjected to genital penetration and otherwise sexually
+degraded, abused, insulted, coerced, and injured, experience resulting in confusion, emotional
+distress, mental pain and suffering, shame, humiliation, loss of the enjoyment of life,
+inconvenience, and other injuries to body, mind and soul.
+55.
+Epstein and the Corporate Defendants by and through their employees and agents
+substantially contributed to proximately cause injury to the Plaintiff as aforementioned.
+56.
+Over a course of years, Epstein and the Corporate Defendants, by and through its
+employees and agents, facilitated the multiple rapes conducted on the Plaintiff in addition to
+other deviant sexual acts against her will. Furthermore, the plaintiff's virginity was forcefully
+taken from her against her will.
+
+
+
+57.
+This fraudulent scheme of Epstein's constituted acts of coercion from beginning
+to end, from 2001 through mid-2006, inasmuch as the scheme was designed to and in fact,
+caused Plaintiff to believe that her failure to perform any sex act required by Epstein would
+result in serious financial, reputational, physical and emotional harm to her.
+COUNTI
+(BATTERY AGAINST DARREN K. INDYKE AND RICHARD D. KAHN AS JOINT
+PERSONAL REPRESENTATIVES OF THE ESTATE OF JEFFREY E. EPSTEIN)
+58.
+The Plaintiff adopts and realleges paragraphs 1 through 57 above.
+59.
+Epstein committed a harmful or offensive touching against Plaintiff.
+60.
+As a direct and proximate result of Epstein's battery, the Plaintiff has in the past
+suffered and in the future will continue to suffer physical injury, pain, emotional distress,
+psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem, loss of
+dignity, invasion of her privacy and a loss of her capacity to enjoy life, as well as other damages.
+Plaintiff incurred medical and psychological expenses and Plaintiff will in the future suffer
+additional medical and psychological expenses. These injuries are permanent in nature and
+Plaintiff will continue to suffer these losses in the future.
+WHEREFORE, Plaintiff demands judgment against the Estate of Jeffrey E. Epstein for
+compensatory and general damages, attorney's fees, punitive damages and such other and further
+relief as this Court deems just and proper. Plaintiff hereby demands trial by jury on all issues
+triable as of right by a jury.
+COUNT !!
+(BATTERY/VIOLATION OF SECTION 130 AGAINST DARREN K. INDYKE AND
+RICHARD D. KAHN AS JOINT PERSONAL REPRESENTATIVES OF THE ESTATE
+OF JEFFREY E. EPSTEIN)
+
+
+
+61.
+The Plaintiff adopts and realleges paragraphs 1 through 57 above.
+62.
+The intentional acts of Epstein against Plaintiff constitute a sexual offense as
+defined in New York Penal Law §130, including but not limited to the following:
+a. Sexual misconduct as defined in $130.20 inasmuch as Epstein engaged in
+sexual intercourse with Plaintiff without Plaintiff's consent;
+b. Rape in the first degree as defined in §130.35 inasmuch as Epstein engaged in
+sexual intercourse with Plaintiff by forcible compulsion;
+c. Criminal sexual act in the first degree as defined in §130.50 inasmuch as
+Epstein engaged in oral sexual conduct with Plaintiff by forcible compulsion;
+d. Forcible touching as defined in §130.52 inasmuch as Epstein, intentionally
+nd for no legitimate purpose, engaged the forcible sexual touching o
+'laintiff for the purpose of degrading or abusing her or for the purpose o
+gratifying his own sexual desire; and,
+e. Aggravated sexual abuse in the third degree as defined in §130.66 inasmuch
+as Epstein inserted a foreign object in the vagina of Plaintiff by forcible
+compulsion.
+63.
+As a direct and proximate result of Epstein's violations of New York Penal Law
+§130, Plaintiff has in the past suffered and in the future will continue to suffer physical injury,
+pain, emotional distress, psychological trauma, mental anguish, humiliation, embarrassment, loss
+of self-esteem, loss of dignity, invasion of her privacy and a loss of her capacity to enjoy life, as
+well as other damages. Plaintiff incurred medical and psychological expenses and Plaintiff will
+in the future suffer additional medical and psychological expenses. These injuries are permanent
+in nature and Plaintiff will continue to suffer these losses in the future.
+WHEREFORE, Plaintiff demands judgment against the Estate of Jeffrey E. Epstein for
+compensatory and general damages, attorney's fees, punitive damages and such other and further
+relief as this Court deems just and proper. Plaintiff hereby demands trial by jury on all issues
+triable as of right by a jury.
+
+
+
+COUNT I
+(CAUSE OF ACTION AGAINST DARREN K. INDYKE AND RICHARD D. KAHN AS
+JOINT PERSONAL REPRESENTATIVES OF THE ESTATE OF JEFFREY E.
+EPSTEIN PURSUANT TO 18 U.S.C. § 1595)
+64.
+Plaintiff adopts and realleges paragraphs 1 through 57 above.
+65.
+Epstein, within the special maritime and territorial jurisdiction of the United
+States, in interstate and foreign commerce, and/or affecting interstate and foreign commerce,
+knowingly recruited, enticed, harbored, transported, provided, obtained, maintained, patronized,
+solicited, threatened, forced, or coerced Plaintiff to engage in commercial sex acts.
+66.
+Such actions were undertaken knowing that his use of force, threats of force,
+fraud, coercion, and/or combinations of such means would be used, and were in fact, used, in
+order to cause Plaintiff to engage in commercial sex acts. In doing so, Epstein violated 18
+U.S.C. $1591.
+67.
+Furthermore, Epstein attempted to violate 18 U.S.C. § 1591. In so doing, violated
+18 U.S.C. § 1594(a).
+68.
+Epstein conspired with each member of the enterprise, and with other persons
+known and unknown, to violate 18 U.S.C. § 1591. In so doing, violated 18 U.S.C. § 1594(c).
+69.
+By virtue of Epstein's violations of 18 U.S.C. §§ 1591, 1593A, and 1594,
+Defendants Darren K. Indyke and Richard D. Kahn as Joint Personal Representatives of the
+Estate of Jeffrey E. Epstein ("Estate of Jeffrey E. Epstein") is subject to civil causes of action
+under 18 U.S.C. § 1595 by Plaintiff, who is a victim of the violations.
+70.
+Certain property of Epstein's was essential to the commission of the federal
+crimes and torts described herein, including the Palm Beach, Florida estate located at 358 El
+Brillo Way, Palm Beach, Florida 33480, the use of multiple private aircraft including a Boeing
+
+
+
+aircraft (of make and model B-727-31H with tail number N908JE) and a Gulfstream aircraft (of
+make and model G-1159B with tail number N909JE). Such real property and aircraft, along with
+other of Epstein's property, were used as means and instruments of Epstein's tortious and
+criminal offenses and, as such, are subject to forfeiture.
+71.
+Additionally, Epstein's New York townhouse, located at 9 East 71st Street, New
+York, New York, in the Southern District of New York, Epstein's private island located in the
+United States Virgin Islands and Epstein's New Mexico estate, were used as means and
+instruments of Epstein's tortious and criminal offenses as they relate to Plaintiff and, as such, are
+subject to forfeiture.
+72.
+As a direct and proximate result of Epstein's commission of the aforementioned
+criminal offenses enumerated in 18 U.S.C. § 1591, 1593A, and 1594, and the associated civil
+remedies provided in § 1595, Plaintiff has in the past suffered and will continue to suffer injury
+and pain, 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 privacy, and other damages associated with Epstein's actions. Plaintiff will incur further
+medical and psychological expenses. These injuries are permanent in nature and Plaintiff will
+continue to suffer from them in the future. In addition to these losses, Plaintiff has incurred
+attorneys' fees and will be required do so in the future for which Epstein is liable pursuant to 18
+U.S.C. §1595.
+WHEREFORE, Plaintiff demands judgment against the Estate of Jeffrey E. Epstein for
+compensatory and general damages, attorney's fees pursuant to 18 U.S.C. §1595, punitive
+damages, forfeiture of Epstein's assets and such other and further relief as this Court deems just
+and proper. Plaintiff hereby demands trial by jury on all issues triable as of right by a jury.
+
+
+
+COUNT IV
+(CAUSE OF ACTION AGAINST NINE EAST 7IST STREET, CORPORATION
+PURSUANT TO 18 U.S.C. §1595)
+73.
+Plaintiff adopts and realleges paragraphs 1 through 57 above.
+74.
+Defendant, by and through its management and personnel, within the special
+maritime and territorial jurisdiction of the United States, in interstate and foreign commerce,
+and/or affecting interstate and foreign commerce, knowingly recruited, enticed, harbored,
+transported, provided, obtained, maintained, patronized, solicited by any means Plaintiff from
+2001 through 2006.
+75.
+Defendant, by and through its management and personnel, knew that means of
+fraud or coercion, and/or combinations of such means, would be used, and were in fact used, in
+order to cause Plaintiff to engage in commercial sex acts. In doing so, Defendant corporation
+violated 18 U.S.C. $1591.
+76.
+Furthermore, Defendant corporation attempted to violate 18 U.S.C. § 1591. In so
+doing, violated 18 U.S.C. § 1594(a).
+77.
+Defendant, by and through its management and personnel, conspired with other
+members of the enterprise, and with other persons and companies, known and unknown, to
+violate 18 U.S.C. § 1591. In so doing, Defendant violated 18 U.S.C. § 1594(c).
+78.
+By virtue of its violations of 18 U.S.C. §$ 1591, 1593A, and 1594, Defendant is
+subject to civil causes of action under 18 U.S.C. § 1595 by Plaintiff, who is a victim of their
+violations.
+79.
+Defendant, by and through its management and personnel, participated in a
+venture with Epstein's enterprise by knowingly recruiting, transporting, soliciting, obtaining, and
+
+
+
+maintaining Plaintiff knowing that fraud or coercion would be used to cause Plaintiff to commit
+a commercial sex act.
+80.
+As a direct and proximate result of Defendant corporation's commission of the
+aforementioned criminal offenses enumerated in 18 U.S.C. §§ 1591, 1593A, and 1594, and the
+associated civil remedies provided in §1595, Plaintiff has in the past suffered and will continue
+to suffer injury and pain, 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 privacy, and other damages associated with Defendant's actions.
+81.
+Plaintiff will incur further medical and psychological expenses. These injuries are
+permanent in nature and Plaintiff will continue to suffer from them in the future. In addition to
+these losses, Plaintiff has incurred attorneys' fees and will continue to do so in the future for
+which Defendant is liable pursuant to 18 U.S.C. $1595.
+WHEREFORE, Plaintiff demands judgment against Nine East 71st Street, Corporation for
+compensatory and general damages, attorney's fees pursuant to 18 U.S.C. §1595, forfeiture of
+Defendant's assets, punitive damages and such other and further relief as this Court deems just
+and proper. Plaintiff hereby demands trial by jury on all issues triable as of right by a jury.
+COUNT V
+(CAUSE OF ACTION AGAINST LAUREL, INC. PURSUANT TO 18 U.S.C. $1595)
+82.
+83.
+Plaintiff adopts and realleges paragraphs 1 through 57 above.
+Defendant, by and through its management and personnel, within the special
+maritime and territorial jurisdiction of the United States, in interstate and foreign commerce,
+and/or affecting interstate and foreign commerce, knowingly recruited, enticed, harbored,
+
+
+
+transported, provided, obtained, maintained, patronized, solicited by any means Plaintiff from
+2001 through 2006.
+84.
+Defendant, by and through its management and personnel, knew that means of
+fraud or coercion, and/or combinations of such means, would be used, and were in fact used, in
+order to cause Plaintiff to engage in commercial sex acts. In doing so, Defendant corporation
+violated 18 U.S.C. §1591.
+85.
+Furthermore, Defendant corporation attempted to violate 18 U.S.C. § 1591. In so
+doing, violated 18 U.S.C. § 1594(a).
+86.
+Defendant, by and through its management and personnel, conspired with other
+members of the enterprise, and with other persons and companies, known and unknown, to
+violate 18 U.S.C. § 1591. In so doing, Defendant violated 18 U.S.C. § 1594(c).
+87.
+By virtue of its violations of 18 U.S.C. §$ 1591, 1593A, and 1594, Defendant is
+subject to civil causes of action under 18 U.S.C. § 1595 by Plaintiff, who is a victim of their
+violations.
+88.
+Defendant, by and through its management and personnel, participated in a
+venture with Epstein's enterprise by knowingly recruiting, transporting, soliciting, obtaining, and
+maintaining Plaintiff knowing that fraud or coercion would be used to cause Plaintiff to commit
+a commercial sex act.
+89.
+As a direct and proximate result of Defendant corporation's commission of the
+aforementioned criminal offenses enumerated in 18 U.S.C. §§ 1591, 1593A, and 1594, and the
+associated civil remedies provided in §1595, Plaintiff has in the past suffered and will continue
+to suffer injury and pain, 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 privacy, and other damages associated with Defendant's actions.
+90.
+Plaintiff will incur further medical and psychological expenses. These injuries are
+permanent in nature and Plaintiff will continue to suffer from them in the future. In addition to
+these losses, Plaintiff has incurred attorneys' fees and will continue to do so in the future for
+which Defendant is liable pursuant to 18 U.S.C. $1595.
+WHEREFORE, Plaintiff demands judgment against Laurel, Inc. for compensatory and
+general damages, attorney's fees pursuant to 18 U.S.C. §1595, forfeiture of Defendant's assets,
+punitive damages and such other and further relief as this Court deems just and proper. Plaintiff
+hereby demands trial by jury on all issues triable as of right by a jury.
+COUNT VI
+(CAUSE OF ACTION AGAINST FINANCIAL TRUST COMPANY, INC.
+PURSUANT TO 18 U.S.C. §1595)
+91.
+Plaintiff adopts and realleges paragraphs 1 through 57 above.
+92.
+Defendant, by and through its management and personnel, within the special
+maritime and territorial jurisdiction of the United States, in interstate and foreign commerce,
+and/or affecting interstate and foreign commerce, knowingly recruited, enticed, harbored,
+transported, provided, obtained, maintained, patronized, solicited by any means Plaintiff.
+93.
+Defendant, by and through its management and personnel, knew that means of
+fraud or coercion, and/or combinations of such means, would be used, and were in fact used, in
+order to cause Plaintiff to engage in commercial sex acts. In doing so, Defendant corporation
+violated 18 U.S.C. $1591.
+94.
+Defendant, by and through its management and personnel knowingly benefitted,
+financially and by receiving things of value, from participating in a venture (the Epstein sex
+
+
+
+trafficking venture enterprise) which had engaged in acts in violation of 18 U.S.C. §1592 and
+1595(a), knowing that the venture had engaged in such violations. In so doing, Defendant
+corporation violated 18 U.S.C. § 1593A.
+95.
+Furthermore, Defendant corporation attempted to violate 18 U.S.C. §1591. In so
+doing, violated 18 U.S.C. § 1594(a).
+96.
+Defendant, by and through its management and personnel, conspired with other
+members of the enterprise, and with other persons and companies, known and unknown, to
+violate 18 U.S.C. §1591. In so doing, Defendant violated 18 U.S.C. $1594(c).
+97.
+By virtue of their violations of 18 U.S.C. $§ 1591, 1593A, and 1594, Defendant is
+subject to civil causes of action under 18 U.S.C. §1595 by Plaintiff, who is a victim of their
+violations.
+98.
+Defendant, by and through its management and personnel, participated in a
+venture with Epstein's enterprise by knowingly recruiting, transporting, soliciting, obtaining, and
+maintaining Plaintiff knowing that fraud or coercion would be used to cause Plaintiff to commit
+a commercial sex act.
+99.
+As a direct and proximate result of Defendant corporation's commission of the
+aforementioned criminal offenses enumerated in 18 U.S.C. §§ 1591, 1593A, and 1594, and the
+associated civil remedies provided in §1595, Plaintiff has in the past suffered and will continue
+to suffer injury and pain, 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 privacy, and other damages associated with Defendant's actions.
+100.
+Plaintiff will incur further medical and psychological expenses. These injuries are
+permanent in nature and Plaintiff will continue to suffer from them in the future. In addition to
+
+
+
+these losses, Plaintiff has incurred attorneys' fees and will continue to do so in the future for
+WHEREFORE, Plaintiff demands judgment against Defendant, Financial Trust Company,
+Inc., For compensatory and general damages, attorney's fees pursuant to 18 U.S.C. §1595,
+forfeiture of Defendant's assets, punitive damages and such other and further relief as this Court
+deems just and proper. Plaintiff hereby demands trial by jury on all issues triable as of right by a
+jury.
+COUNT VII
+(CAUSE OF ACTION AGAINST NES, LLC PURSUANT TO 18 U.S.C. $1595)
+101.
+Plaintiff adopts and realleges paragraphs 1 through 57 above.
+102.
+Defendant, by and through its management and personnel, within the special
+maritime and territorial jurisdiction of the United States, in interstate and foreign commerce,
+and/or affecting interstate and foreign commerce, knowingly recruited, enticed, harbored,
+transported, provided, obtained, maintained, patronized, solicited by any means Plaintiff.
+103.
+Defendant, by and through its management and personnel, knew that means of
+fraud or coercion, and/or combinations of such means, would be used, and were in fact used, in
+order to cause Plaintiff to engage in commercial sex acts. In doing so, Defendant corporation
+violated 18 U.S.C. $1591.
+104.
+Furthermore, Defendant corporation attempted to violate 18 U.S.C. §1591. In so
+doing, violated 18 U.S.C. $1594(a).
+105.
+Defendant, by and through its management and personnel, conspired with other
+members of the enterprise, and with other persons and companies, known and unknown, to
+violate 18 U.S.C. §1591. In so doing, Defendant violated 18 U.S.C. §1594(c).
+
+
+
+106.
+By virtue of their violations of 18 U.S.C. §§ 1591, 1593A, and 1594, Defendant is
+subject to civil causes of action under 18 U.S.C. §1595 by Plaintiff, who is a victim of their
+violations.
+107.
+Defendant, by and through its management and personnel, participated in a
+venture with Epstein's enterprise by knowingly recruiting, transporting, soliciting, obtaining, and
+maintaining Plaintiff knowing that fraud or coercion would be used to cause Plaintiff to commit
+a commercial sex act.
+108.
+As a direct and proximate result of Defendant corporation's commission of the
+aforementioned criminal offenses enumerated in 18 U.S.C. $§ 1591, 1593A, and 1594, and the
+associated civil remedies provided in §1595, Plaintiff has in the past suffered and will continue
+to suffer injury and pain, 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 privacy, and other damages associated with Defendant's actions.
+109.
+Plaintiff will incur further medical and psychological expenses. These injuries are
+permanent in nature and Plaintiff will continue to suffer from them in the future. In addition to
+these losses, Plaintiff has incurred attorneys' fees and will continue to do so in the future for
+WHEREFORE, Plaintiff demands judgment against Defendant, NES, Inc., for
+compensatory and general damages, attorney's fees pursuant to 18 U.S.C. §1595, forfeiture of
+Defendant's assets, punitive damages and such other and further relief as this Court deems just
+and proper. Plaintiff hereby demands trial by jury on all issues triable as of right by a jury.
+
+
+
+COUNT VIII
+(CAUSE OF ACTION AGAINST MAPLE, INC. PURSUANT TO 18 U.S.C. $1595)
+110.
+Plaintiff adopts and realleges paragraphs 1 through 57 above.
+111.
+Defendant, by and through its management and personnel, within the special
+maritime and territorial jurisdiction of the United States, in interstate and foreign commerce,
+and/or affecting interstate and foreign commerce, knowingly recruited, enticed, harbored,
+transported, provided, obtained, maintained, patronized, solicited by any means Plaintiff from
+2001 through 2006.
+112.
+Defendant, by and through its management and personnel, knew that means of
+fraud or coercion, and/or combinations of such means, would be used, and were in fact used, in
+order to cause Plaintiff to engage in commercial sex acts. In doing so, Defendant corporation
+violated 18 U.S.C. §1591.
+113.
+Furthermore, Defendant corporation attempted to violate 18 U.S.C. § 1591. In so
+doing, violated 18 U.S.C. § 1594(a).
+114.
+Defendant, by and through its management and personnel, conspired with other
+members of the enterprise, and with other persons and companies, known and unknown, to
+violate 18 U.S.C. § 1591. In so doing, Defendant violated 18 U.S.C. § 1594(c).
+115.
+By virtue of its violations of 18 U.S.C. §$ 1591, 1593A, and 1594, Defendant is
+subject to civil causes of action under 18 U.S.C. § 1595 by Plaintiff, who is a victim of their
+violations.
+116.
+Defendant, by and through its management and personnel, participated in a
+venture with Epstein's enterprise by knowingly recruiting, transporting, soliciting, obtaining, and
+
+
+
+maintaining Plaintiff knowing that fraud or coercion would be used to cause Plaintiff to commit
+a commercial sex act.
+117.
+As a direct and proximate result of Defendant corporation's commission of the
+aforementioned criminal offenses enumerated in 18 U.S.C. §§ 1591, 1593A, and 1594, and the
+associated civil remedies provided in §1595, Plaintiff has in the past suffered and will continue
+to suffer injury and pain, 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 privacy, and other damages associated with Defendant's actions.
+118.
+Plaintiff will incur further medical and psychological expenses. These injuries are
+permanent in nature and Plaintiff will continue to suffer from them in the future. In addition to
+these losses, Plaintiff has incurred attorneys' fees and will continue to do so in the future for
+WHEREFORE, Plaintiff demands judgment against Maple, Inc. for compensatory and
+general damages, attorney's fees pursuant to 18 U.S.C. $1595, forfeiture of Defendant's assets,
+punitive damages and such other and further relief as this Court deems just and proper. Plaintiff
+hereby demands trial by jury on all issues triable as of right by a jury.
+COUNT IX
+(CAUSE OF ACTION AGAINST LSJE, LLC PURSUANT TO 18 U.S.C. $1595)
+119.
+Plaintiff adopts and realleges paragraphs 1 through 57 above.
+120.
+Defendant, by and through its management and personnel, within the special
+maritime and territorial jurisdiction of the United States, in interstate and foreign commerce,
+and/or affecting interstate and foreign commerce, knowingly recruited, enticed, harbored,
+
+
+
+transported, provided, obtained, maintained, patronized, solicited by any means Plaintiff from
+2001 through 2006.
+121.
+Defendant, by and through its management and personnel, knew that means of
+fraud or coercion, and/or combinations of such means, would be used, and were in fact used, in
+order to cause Plaintiff to engage in commercial sex acts. In doing so, Defendant corporation
+violated 18 U.S.C. §1591.
+122.
+Furthermore, Defendant corporation attempted to violate 18 U.S.C. § 1591. In so
+doing, violated 18 U.S.C. § 1594(a).
+123.
+Defendant, by and through its management and personnel, conspired with other
+members of the enterprise, and with other persons and companies, known and unknown, to
+violate 18 U.S.C. § 1591. In so doing, Defendant violated 18 U.S.C. § 1594(c).
+124. By virtue of its violations of 18 U.S.C. §$ 1591, 1593A, and 1594, Defendant is
+subject to civil causes of action under 18 U.S.C. § 1595 by Plaintiff, who is a victim of their
+violations.
+125.
+Defendant, by and through its management and personnel, participated in a
+venture with Epstein's enterprise by knowingly recruiting, transporting, soliciting, obtaining, and
+maintaining Plaintiff knowing that fraud or coercion would be used to cause Plaintiff to commit
+a commercial sex act.
+126.
+As a direct and proximate result of Defendant corporation's commission of the
+aforementioned criminal offenses enumerated in 18 U.S.C. §§ 1591, 1593A, and 1594, and the
+associated civil remedies provided in §1595, Plaintiff has in the past suffered and will continue
+to suffer injury and pain, 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 privacy, and other damages associated with Defendant's actions.
+127.
+Plaintiff will incur further medical and psychological expenses. These injuries are
+permanent in nature and Plaintiff will continue to suffer from them in the future. In addition to
+these losses, Plaintiff has incurred attorneys' fees and will continue to do so in the future for
+which Defendant is liable pursuant to 18 U.S.C. $1595.
+WHEREFORE, Plaintiff demands judgment against LSJE, LLC for compensatory and
+general damages, attorney's fees pursuant to 18 U.S.C. §1595, forfeiture of Defendant's assets,
+punitive damages and such other and further relief as this Court deems just and proper. Plaintiff
+hereby demands trial by jury on all issues triable as of right by a jury.
+COUNT X
+(CAUSE OF ACTION AGAINST HBRK ASSOCIATES, INC.
+PURSUANT TO 18 U.S.C. $1595)
+128.
+Plaintiff adopts and realleges paragraphs 1 through 57 above.
+129.
+Defendant, by and through its management and personnel, within the special
+maritime and territorial jurisdiction of the United States, in interstate and foreign commerce,
+and/or affecting interstate and foreign commerce, knowingly recruited, enticed, harbored,
+transported, provided, obtained, maintained, patronized, solicited by any means Plaintiff.
+130.
+Defendant, by and through its management and personnel, knew that means of
+fraud or coercion, and/or combinations of such means, would be used, and were in fact used, in
+order to cause Plaintiff to engage in commercial sex acts. In doing so, Defendant corporation
+violated 18 U.S.C. §1591.
+131.
+Defendant, by and through its management and personnel knowingly benefitted,
+financially and by receiving things of value, from participating in a venture (the Epstein sex
+
+
+
+trafficking venture enterprise) which had engaged in acts in violation of 18 U.S.C. §§ 1592 and
+1595(a), knowing that the venture had engaged in such violations. In so doing, Defendant
+corporation violated 18 U.S.C. §1593A.
+132.
+Furthermore, Defendant corporation attempted to violate 18 U.S.C. §1591. In so
+doing, Defendant violated 18 U.S.C. §1594(a).
+133.
+Defendant, by and through its management and personnel, conspired with other
+members of the enterprise, and with other persons and companies, known and unknown, to
+violate 18 U.S.C. §1591. In so doing, Defendant violated 18 U.S.C. §1594(c).
+134.
+By virtue of their violations of 18 U.S.C. $§ 1591, 1593A, and 1594, Defendant is
+subject to civil causes of action under 18 U.S.C. §1595 by Plaintiff, who is a victim of their
+violations.
+135.
+Defendant, by and through its management and personnel, participated in a
+venture with Epstein's enterprise by knowingly recruiting, transporting, soliciting, obtaining, and
+maintaining Plaintiff knowing that fraud or coercion would be used to cause Plaintiff to commit
+a commercial sex act.
+136.
+As a direct and proximate result of Defendant corporation's commission of the
+aforementioned criminal offenses enumerated in 18 U.S.C. §§ 1591, 1593A, and 1594, and the
+associated civil remedies provided in §1595, Plaintiff has in the past suffered and will continue
+to suffer injury and pain, 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 privacy, and other damages associated with Defendant's actions.
+137.
+Plaintiff will incur further medical and psychological expenses. These injuries are
+permanent in nature and Plaintiff will continue to suffer from them in the future. In addition to
+
+
+
+these losses, Plaintiff has incurred attorneys' fees and will continue to do so in the future for
+138.
+WHEREFORE, Plaintiff demands judgment against Defendant, HBRK
+Associates, Inc., for compensatory and general damages, attorney's fees pursuant to 18 U.S.C.
+§1595, forfeiture of Defendant's assets, punitive damages and such other and further relief as this
+Court deems just and proper. Plaintiff hereby demands trial by jury on all issues triable as of
+right by a jury.
+COUNT XI
+(CAUSE OF ACTION AGAINST NAUTILUS, INC. PURSUANT TO 18 U.S.C. $1595)
+139.
+Plaintiff adopts and realleges paragraphs 1 through 57 above.
+140.
+Defendant, by and through its management and personnel, within the special
+maritime and territorial jurisdiction of the United States, in interstate and foreign commerce,
+and/or affecting interstate and foreign commerce, knowingly recruited, enticed, harbored,
+transported, provided, obtained, maintained, patronized, solicited by any means Plaintiff.
+141.
+Defendant, by and through its management and personnel, knew that means of
+fraud or coercion, and/or combinations of such means, would be used, and were in fact used, in
+order to cause Plaintiff to engage in commercial sex acts. In doing so, Defendant corporation
+violated 18 U.S.C. §1591.
+142.
+Defendant, by and through its management and personnel knowingly benefitted,
+financially and by receiving things of value, from participating in a venture (the Epstein sex
+trafficking venture enterprise) which had engaged in acts in violation of 18 U.S.C. §§ 1592 and
+1595(a), knowing that the venture had engaged in such violations. In so doing, Defendant
+corporation violated 18 U.S.C. §1593A.
+
+
+
+143.
+Furthermore, Defendant corporation attempted to violate 18 U.S.C. §1591. In so
+doing, Defendant violated 18 U.S.C. §1594(a).
+144.
+Defendant, by and through its management and personnel, conspired with other
+members of the enterprise, and with other persons and companies, known and unknown, to
+violate 18 U.S.C. §1591. In so doing, Defendant violated 18 U.S.C. §1594(c).
+145.
+By virtue of their violations of 18 U.S.C. §$ 1591, 1593A, and 1594, Defendant is
+subject to civil causes of action under 18 U.S.C. §1595 by Plaintiff, who is a victim of their
+violations.
+146.
+Defendant, by and through its management and personnel, participated in a
+venture with Epstein's enterprise by knowingly recruiting, transporting, soliciting, obtaining, and
+maintaining Plaintiff knowing that fraud or coercion would be used to cause Plaintiff to commit
+a commercial sex act.
+147.
+As a direct and proximate result of Defendant corporation's commission of the
+aforementioned criminal offenses enumerated in 18 U.S.C. §§ 1591, 1593A, and 1594, and the
+associated civil remedies provided in §1595, Plaintiff has in the past suffered and will continue
+to suffer injury and pain, 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 privacy, and other damages associated with Defendant's actions.
+148.
+Plaintiff will incur further medical and psychological expenses. These injuries are
+permanent in nature and Plaintiff will continue to suffer from them in the future. In addition to
+these losses, Plaintiff has incurred attorneys' fees and will continue to do so in the future for
+
+
+
+149.
+WHEREFORE, Plaintiff demands judgment against Defendant, Nautilus, Inc., for
+compensatory and general damages, attorney's fees pursuant to 18 U.S.C. §1595, forfeiture of
+Defendant's assets, punitive damages and such other and further relief as this Court deems just
+and proper. Plaintiff hereby demands trial by jury on all issues triable as of right by a jury.
+COUNT XII
+(CAUSE OF ACTION AGAINST CYPRESS, INC. PURSUANT TO 18 U.S.C. $1595)
+150.
+Plaintiff adopts and realleges paragraphs 1 through 57 above.
+151.
+Defendant, by and through its management and personnel, within the special
+maritime and territorial jurisdiction of the United States, in interstate and foreign commerce,
+and/or affecting interstate and foreign commerce, knowingly recruited, enticed, harbored,
+transported, provided, obtained, maintained, patronized, solicited by any means Plaintiff.
+152.
+Defendant, by and through its management and personnel, knew that means of
+fraud or coercion, and/or combinations of such means, would be used, and were in fact used, in
+order to cause Plaintiff to engage in commercial sex acts. In doing so, Defendant corporation
+violated 18 U.S.C. §1591.
+153.
+Defendant, by and through its management and personnel knowingly benefitted,
+financially and by receiving things of value, from participating in a venture (the Epstein sex
+trafficking venture enterprise) which had engaged in acts in violation of 18 U.S.C. §§ 1592 and
+1595(a), knowing that the venture had engaged in such violations. In so doing, Defendant
+corporation violated 18 U.S.C. §1593A.
+154.
+Furthermore, Defendant corporation attempted to violate 18 U.S.C. §1591. In so
+doing, Defendant violated 18 U.S.C. §1594(a).
+
+
+
+155.
+Defendant, by and through its management and personnel, conspired with other
+members of the enterprise, and with other persons and companies, known and unknown, to
+violate 18 U.S.C. §1591. In so doing, Defendant violated 18 U.S.C. §1594(c).
+156.
+By virtue of their violations of 18 U.S.C. §$ 1591, 1593A, and 1594, Defendant is
+subject to civil causes of action under 18 U.S.C. §1595 by Plaintiff, who is a victim of their
+violations.
+157.
+Defendant, by and through its management and personnel, participated in a
+venture with Epstein's enterprise by knowingly recruiting, transporting, soliciting, obtaining, and
+maintaining Plaintiff knowing that fraud or coercion would be used to cause Plaintiff to commit
+a commercial sex act.
+158.
+As a direct and proximate result of Defendant corporation's commission of the
+aforementioned criminal offenses enumerated in 18 U.S.C. §§ 1591, 1593A, and 1594, and the
+associated civil remedies provided in §1595, Plaintiff has in the past suffered and will continue
+to suffer injury and pain, 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 privacy, and other damages associated with Defendant's actions.
+159.
+Plaintiff will incur further medical and psychological expenses. These injuries are
+permanent in nature and Plaintiff will continue to suffer from them in the future. In addition to
+these losses, Plaintiff has incurred attorneys' fees and will continue to do so in the future for
+160.
+WHEREFORE, Plaintiff demands judgment against Defendant, Cypress, Inc., for
+compensatory and general damages, attorney's fees pursuant to 18 U.S.C. §1595, forfeiture of
+
+
+
+Defendant's assets, punitive damages and such other and further relief as this Court deems just
+and proper. Plaintiff hereby demands trial by jury on all issues triable as of right by a jury.
+COUNT XIII
+(CAUSE OF ACTION AGAINST JEGE, INC. PURSUANT TO 18 U.S.C. $1595)
+161.
+Plaintiff adopts and realleges paragraphs 1 through 57 above.
+162.
+Defendant, by and through its management and personnel, within the special
+maritime and territorial jurisdiction of the United States, in interstate and foreign commerce,
+and/or affecting interstate and foreign commerce, knowingly recruited, enticed, harbored,
+transported, provided, obtained, maintained, patronized, solicited by any means Plaintiff from
+2001 through 2006.
+163.
+Defendant, by and through its management and personnel, knew that means of
+fraud or coercion, and/or combinations of such means, would be used, and were in fact used, in
+order to cause Plaintiff to engage in commercial sex acts. In doing so, Defendant corporation
+violated 18 U.S.C. §1591.
+164.
+Furthermore, Defendant corporation attempted to violate 18 U.S.C. § 1591. In so
+doing, violated 18 U.S.C. § 1594(a).
+165.
+Defendant, by and through its management and personnel, conspired with other
+members of the enterprise, and with other persons and companies, known and unknown, to
+violate 18 U.S.C. § 1591. In so doing, Defendant violated 18 U.S.C. § 1594(c).
+166.
+By virtue of its violations of 18 U.S.C. §§ 1591, 1593A, and 1594, Defendant is
+subject to civil causes of action under 18 U.S.C. § 1595 by Plaintiff, who is a victim of their
+violations.
+
+
+
+167.
+Defendant, by and through its management and personnel, participated in a
+venture with Epstein's enterprise by knowingly recruiting, transporting, soliciting, obtaining, and
+maintaining Plaintiff knowing that fraud or coercion would be used to cause Plaintiff to commit
+a commercial sex act.
+168.
+As a direct and proximate result of Defendant corporation's commission of the
+aforementioned criminal offenses enumerated in 18 U.S.C. §§ 1591, 1593A, and 1594, and the
+associated civil remedies provided in §1595, Plaintiff has in the past suffered and will continue
+to suffer injury and pain, 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 privacy, and other damages associated with Defendant's actions.
+169.
+Plaintiff will incur further medical and psychological expenses. These injuries are
+permanent in nature and Plaintiff will continue to suffer from them in the future. In addition to
+these losses, Plaintiff has incurred attorneys' fees and will continue to do so in the future for
+WHEREFORE, Plaintiff demands judgment against JEGE, INC. for compensatory and
+general damages, attorney's fees pursuant to 18 U.S.C. §1595, forfeiture of Defendant's assets,
+punitive damages and such other and further relief as this Court deems just and proper. Plaintiff
+hereby demands trial by jury on all issues triable as of right by a jury.
+Dated:
+October 17, 2019
+By:
+Respectfully Submitted,
+_Is/ Andrew S. Buzin
+Andrew S. Buzin
+BUZIN LAW, P.C.
+111 Broadway, Suite 1204
+New York, NY 10006
+Tel: (646) 470-4878
+
+
+
+Casеabd9-99@9696Р0₺Ą£БСFDФЫBAn*7611 FilEter1P17₽§19ageag4 afaf 37
+By:
+Fax: (347) 736-9490
+Email: abuzin@buzinlaw.com
+Attorney for Plaintiff
+/s/ David H. Brodie
+David H. Brodie, Esq., FBN 0813168
+Laura J. Starr, Esq., FBN 0491888
+WEISMAN, BRODIE, STARR
+& MARGOLIES, P.A.
+1301 N. Federal Highway
+Lake Worth, FL 33460
+Telephone: (561) 588-9500
+Facsimile: (561) 588-9500
+Email: dbrodie@yourfloridacounsel.com
+Email: Istarr@yourfloridacounsel.com
+Attorneys for Plaintiff
+(SEEKING ADMISSION PRO HAC VICE)
+
+
+
+Сasєaś₴9q9QЯ6ф9•АĘR£FCDq9mAn3f111 Filed 18/29/19 P8g09139 gf 37
+
+
+
+Caseds299909609010#REDC@92136111 Filed 10/29/19 p89822307 gf 37
+U.S. v. Jeffrey Epstein, 19-Cr-490 (RMB)
+ASSET SUMMARY - JUNE 30, 2019
+Asset
+Cash
+*
+Fixed Income
+*
+*
+Equities
+Hedge Funds & Private Equity
+** Properties
+***
+9 East 71st Street, New York, NY 10021
+49 Zorro Ranch Road, Stanley New Mexico 87056
+358 El Brillo Way, Palm Beach, FL 33480
+22 Avenue Foch, Paris France 75116
+Great St James Island No. 6A USVI 00802 (parcels A,B,C)
+****
+Little St James Island No. 6B USVI 00802 (parcels A,B,C)
+$
+$
+$
+$
+$
+$
+$
+$
+$
+6/30/19
+Value
+56,547,773
+14,304,679
+112,679,138
+194,986,301
+55,931,000
+17,246,208
+12,380,209
+8,672,823
+22,498,600
+63,874,223
+Total Assets
+$
+559,120,954
+*
+Values reflect gross numbers that are not net of tax
+** All properties are valued at assessed values as per the most recent
+property tax bills
+*** Note the United States Attomey's office for the Souther District of New York
+has stated that the value of this home is $77,000,000 as compared to the
+market value shown above per the June 1, 2019 property tax bill
+**** Note this property is valued at cost basis, however the assessment on
+the most recent tax bill is $4,857,500

vision-fixhub/court-01/8fd6a53809ebf65104b156f3d102116d9cd61e913c586b36e32864185f38973b.receipt.json

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vision-fixhub/court-01/8fe78f32eec10f8e56ace86eae366fb1d1035cd2a2f14ad9d275c112db60a42a.md

@@ -0,0 +1,817 @@
+Case 1:19-cv-08673-KPF-DCF Document 79-3 Filed 06/22/20 Page 1 of 29
+
+
+
+Case 1:19-cv-08673-KPF-DCF Document 79-3 Filed 06/22/20 Page 2 of 29
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+JANE DOE,
+Plaintiff,
+V.
+DARREN K. INDYKE and RICHARD D. KAHN, in
+their capacities as the executors of the Estate of
+Jeffrey E. Epstein,
+Defendants.
+Case No. 19 Civ. 8673 (KPF) (DCF)
+PLAINTIFF JANE DOE'S RESPONSES AND OBJECTIONS TO DEFENDANTS'
+FIRST REQUEST FOR PRODUCTION OF DOCUMENTS
+Pursuant to Rules 26 and 34 of the Federal Rules of Civil Procedure and the Local Rules
+for the Southern District of New York (together, the "Rules"), Plaintiff Jane Doe, by and through
+her attorneys, submits these responses and objections ("Responses") to Defendants Darren K.
+Indyke and Richard D. Kahn, in their capacities as the executors of the Estate of Jeffrey E. Epstein
+("Defendants") First Request for the Production of Documents dated March 10, 2020.
+The Definitions and Instructions below form an integral part of the Requests that follow
+and must be read in conjunction with the Requests and followed when responding to the
+Requests.
+GENERAL OBJECTIONS AND RESPONSES
+The following general objections and responses (the "General Objections") are
+incorporated into each specific objection and response (the "Specific Objections") as if fully set
+forth therein:
+Plaintiff objects to the Requests to the extent they are duplicative, cumulative, or
+seek information that has been or will be provided through other means of discovery.
+
+
+Case 1:19-cv-08673-KPF-DCF Document 79-3 Filed 06/22/20 Page 3 of 29
+2.
+Plaintiff objects to the Requests to the extent they are vague, ambiguous, overly
+broad, unduly burdensome, seck information not relevant to the claims or defenses of any party,
+or are not proportional to the needs of the case.
+Plaintiff objects to the Requests to the extent they impose any obligations or
+requirements beyond the scope of the Rules or any case law interpreting them.
+Plaintiff's Responses are not intended to be and shall not be construed as an
+agreement or concurrence that all information provided is admissible.
+5.
+Plaintiff objects to each Request to the extent that it calls for documents that: (a)
+are already in Defendants' possession, custody, or control; (b) are publicly available; or (c) are
+otherwise independently available to Defendants or their counsel.
+Plaintiff objects to the Requests to the extent they purport to call for documents or
+information that: (a) are subject to the attorney-client privilege; (b) constitute attorney work
+product; (c) are protected from disclosure based on common interest or a similar privilege; or (d)
+are otherwise protected from disclosure under applicable privilege, law, or rule. Plaintiff will not
+produce such information in response to the Requests, and any inadvertent production thereof shall
+not be deemed a waiver of any privilege with respect to such information.
+Plaintiff objects to the Requests to the extent they seek information protected by
+federal or state law. Except to the extent permitted by an applicable exception or court order,
+Plaintiff will not disclose any information in violation of federal or state law.
+8.
+Plaintiff objects to the Requests to the extent they require unreasonable measures
+to locate and produce responsive documents. Plaintiff will construe the Requests to require a
+reasonable and diligent search of her reasonably-accessible files where she would reasonably
+expect to find information, documents, or things related to the Requests, and specifically states
+
+
+Case 1:19-CV-08673-KPF-DCF Document 79-3 Filed 06/22/20 Page 4 of 29
+that she will limit her search for electronically stored information by use of identified search terms
+to be agreed upon by the Parties.
+9.
+Plaintiff objects to the Requests, and in particular, Definitions No. 4 and
+Instructions Nos. 2 and 4, to the extent that they seek information or documents that are not within
+Plaintiff's possession, custody, or control. Subject to this General Objection, in responding to the
+Requests, Plaintiff will provide only responsive, non-privileged documents within Plaintiff's own
+possession, custody, or control.
+10.
+Plaintiff objects to Instruction No. 3 insofar as it seeks to impose obligations greater
+than those imposed by the Rules or any other applicable law or rule.
+11.
+Plaintiff objects to Instruction No. 4 insofar as it imposes obligations greater than
+those imposed by the Rules and it seeks information or documents that are not within Plaintiff's
+possession, custody, or control.
+12.
+Plaintiff objects to Instruction No. 11 to the extent that it seeks information or
+documents beyond the time period relevant to the allegations listed in the Complaint (ECF 1).
+13.
+Plaintiff objects to each Request to the extent that it asks Plaintiff to identify "all"
+documents, communications, information etc., on the ground that each such Request is overly
+broad and that compliance with each such Request would be unduly burdensome and not
+proportional to the needs of this case.
+14.
+Plaintiff objects to each Request to the extent that it seeks information or documents
+beyond the time period relevant to Plaintiff's claims.
+15.
+Plaintiff objects to the Requests to the extent they contain express or implied
+assumptions of fact or law with respect to matters at issue in this case. Plaintiff's Responses to
+the Requests are not intended to be and shall not be construed as an agreement or concurrence with
+
+
+Case 1:19-CV-08673-KPF-DCF Document 79-3 Filed 06/22/20 Page 5 of 29
+Defendants' characterization of any facts, circumstances, or legal obligations. Plaintiff reserves
+the right to contest any such characterization as inaccurate.
+16.
+Plaintiff expressly reserves all rights and privileges under the Rules and any other
+applicable law or rule. The failure to assert such rights and privileges or the inadvertent disclosure
+by Plaintiff of information or documents protected by such rights or privileges shall not constitute
+a waiver thereof, either with respect to these Responses or with respect to any future discovery
+objections or responses.
+17.
+The fact that Plaintiff has responded to a particular Request shall not be interpreted
+as implying that Plaintiff acknowledges the propriety of that Request.
+18.
+Plaintiff's Responses to the Requests are made to the best of Plaintiff's present
+knowledge, information, and belief. These Responses are at all times subject to such additional or
+different information that discovery or further investigation may disclose and, while based on the
+present state of Plaintiff's knowledge and investigation, are subject to such additional knowledge
+of facts as may result from Plaintiff's further discovery or investigation.
+19.
+Plaintiff reserves the right to make any use of, or to introduce at any hearing and at
+trial, information responsive to the Requests but discovered subsequent to the date of these
+Responses, including, but not limited to, any such information obtained in discovery herein.
+20.
+Plaintiff reserves all objections or other questions as to the competency, relevance,
+materiality, privilege, or admissibility of Plaintiff's Responses herein and any documents produced
+subject thereto, as evidence in any subsequent proceeding in, or trial of, this or any other action,
+or for any other purpose whatsoever.
+21.
+Plaintiff's Responses to the Requests will be subject to the protections of any
+Protective Order entered by the Court governing the handling of confidential material in this case.
+
+
+Case 1:19-CV-08673-KPF-DCF Document 79-3 Filed 06/22/20 Page 6 of 29
+22.
+Plaintiff will produce responsive documents pursuant to its General and Specific
+Objections on a rolling basis.
+23.
+Plaintiff is available to meet and confer with Defendants in an effort to resolve any
+disputes that may arise concerning these Responses.
+SPECIFIC OBJECTIONS AND RESPONSES
+REQUEST NO. 1
+All documents and communications with or otherwise concerning Decedent. This
+includes, without limitation, all communications concerning Decedent which are to, from,
+or which copy: (i) members of the press, media or publishing industry; (il) law enforcement
+personnel; (iii) government agents, including, without limitation, prosecutors and
+government attorneys; and communications which are to, from, or which copy you or your
+attorneys, on the one hand, and other persons who have filed lawsuits or made claims
+against Decedent or his estate, or such other persons' attorneys, on the other hand.
+RESPONSE TO REQUEST NO. 1
+Plaintiff objects to Request No. 1 on the ground that it is overly broad, unduly burdensome,
+and seeks information not relevant to either party's claims or defenses in this litigation, and will
+withhold responsive documents and communications, if any, based on this objection. Plaintiff
+further objects to Request No. 1 to the extent it calls for the production of documents and
+communications that are subject to the attorney-client privilege, constitute attorney work product,
+or are otherwise protected from disclosure under applicable privilege, law, or rule, and will
+withhold responsive documents and communications, if any, based on this objection.
+Subject to the General and Specific Objections, Plaintiff will produce non-privileged
+documents and communications concerning the claims and defenses in this litigation and
+responsive to this request, if any.
+
+
+Case 1:19-CV-08673-KPF-DCF Document 79-3 Filed 06/22/20 Page 7 of 29
+REQUEST NO. 2
+To the extent not otherwise produced in response to the foregoing, all documents
+and communications concerning any other legal proceeding or investigation that concerns
+Decedent.
+RESPONSE TO REQUEST NO. 2
+Subject to the General and Specific Objections, Plaintiff will produce non-privileged
+documents and communications that are responsive to this request, if any.
+REQUEST NO. 3
+To the extent not otherwise produced in response to the foregoing, all non-privileged
+documents and communications concerning this litigation.
+RESPONSE TO REQUEST NO. 3
+Plaintiff objects to Request No. 3 on the ground that it is overly broad, unduly burdensome,
+and seeks information not relevant to either party's claims or defenses to the extent that
+"concerning this litigation" has a meaning other than "concerning the claims and defenses in this
+litigation" and will withhold responsive documents and communications, if any, based on this
+objection.
+Subject to the General and Specific Objections, Plaintiff will produce non-privileged
+documents and communications concerning the claims and defenses at issue in this litigation, if
+any.
+REQUEST NO. 4
+A copy of your birth certificate.
+RESPONSE TO REQUEST NO. 4
+Plaintiff objects to Request No. 4 on the ground that it seeks information not relevant to
+either party's claims or defenses, and will withhold responsive documents and communications, if
+any, based on this objection.
+
+
+Case 1:19-cv-08673-KPF-DCF Document 79-3 Filed 06/22/20 Page 8 of 29
+REQUEST NO. 5
+Copies of all of your passports.
+RESPONSE TO REQUEST NO. 5
+Plaintiff objects to Request No. 5 on the ground that it is overly broad, unduly burdensome,
+and seeks information not relevant to either party's claims or defenses to the extent it requests all
+Plaintiff's passports, and will withhold responsive documents and communications, if any, based
+on this objection.
+Subject to the General and Specific Objections, Plaintiff will produce a copy of her current
+passport, if any.
+REQUEST NO. 6
+relevant time period.
+RESPONSE TO REQUEST NO. 6
+Documents sufficient to establish your place of residency at all times during the
+Plaintiff objects to Request No. 6 on the ground that it is vague and ambiguous to the extent
+it uses the undefined phrase "sufficient to establish."
+Subject to the General and Specific Objections, Plaintiff will produce non-privileged
+documents, if any, that demonstrate Plaintiff's residency (1) during the period relevant to the
+allegations in the Complaint and (2) at present.
+REQUEST NO. 7
+Documents sufficient to establish your domicile at all times during the relevant time
+period.
+RESPONSE TO REQUEST NO. 7
+Plaintiff objects to Request No. 7 on the ground that it is vague and ambiguous to the extent
+it uses the undefined phrase "sufficient to establish."
+
+
+Case 1:19-CV-08673-KPF-DCF Document 79-3 Filed 06/22/20 Page 9 of 29
+Subject to the General and Specific Objections, Plaintiff will produce non-privileged
+documents, if any, that demonstrate Plaintiff's domicile (1) during the period relevant to the
+allegations in the Complaint and (2) at present.
+REQUEST NO. 8
+Documents sufficient to identify the location, nature, and scope of your employment
+during the relevant time period.
+RESPONSE TO REQUEST NO. 8
+Plaintiff objects to Request No. 8 on the ground that it is vague and ambiguous to the extent
+it uses the undefined phrase "sufficient to identify" and the terms "nature" and "scope."
+Subject to the General and Specific Objections, Plaintiff will produce non-privileged
+documents and communications demonstrating her employment that are responsive to this request,
+if any.
+REQUEST NO. 9
+Documents sufficient to identify the source, nature, and scope of all financial
+support or income you received during the relevant time period.
+RESPONSE TO REQUEST NO. 9
+Plaintiff objects to Request No. 9 on the ground that it is vague and ambiguous to the extent
+it uses the undefined phrase "sufficient to identify," and the terms "nature" and "scope."
+Subject to the General and Specific Objections, Plaintiff will produce non-privileged
+documents and communications demonstrating her financial support and income that are
+responsive to this request, if any.
+REQUEST NO. 10
+Documents sufficient to establish your complete academic history.
+
+
+Case 1:19-CV-08673-KPF-DCF Document 79-3 Filed 06/22/20 Page 10 of 29
+RESPONSE TO REQUEST NO. 10
+Plaintiff objects to Request No. 10 on the ground that it seeks information not relevant to
+either party's claims or defenses to the extent that it seeks documents concerning Plaintiff's
+"complete academic history" (emphasis added). Plaintiff further objects to the Request on the
+ground that it is vague and ambiguous to the extent it uses the undefined phrases "sufficient to
+establish" and "academic history."
+Subject to the General and Specific Objections, Plaintiff will produce non-privileged
+documents that demonstrate Plaintiff's academic history during the relevant time period, if any.
+REQUEST NO. 11
+Documents sufficient to identify all telephone numbers you used during the relevant
+time period.
+RESPONSE TO REQUEST NO. 11
+Plaintiff objects to Request No. 11 on the ground that it is vague and ambiguous to the
+extent it uses the undefined phrase "sufficient to identify."
+Subject to the General and Specific Objections, Plaintiff will produce non-privileged
+documents to identify each of Plaintiff's telephone numbers during the relevant time period, if any.
+REQUEST NO. 12
+Documents sufficient to identify all email addresses you used during the relevant
+time period.
+RESPONSE TO REQUEST NO. 12
+Plaintiff objects to Request No. 12 on the ground that it is vague and ambiguous to the
+extent it uses the undefined phrase "sufficient to identify."
+Subject to the General and Specific Objections, Plaintiff will produce non-privileged
+documents to identify each of Plaintiff's email addresses during the relevant time period, if any.
+
+
+Case 1:19-cV-08673-KPF-DCF Document 79-3 Filed 06/22/20 Page 11 of 29
+REQUEST NO. 13
+All documents and communications concerning all medical procedures and
+consultations you received during the relevant time period.
+RESPONSE TO REQUEST NO. 13
+Plaintiff objects to Request No. 13 on the ground that it is overly broad, unduly
+burdensome, and seeks information not relevant to either party's claims or defenses to the extent
+that it
+seeks
+documents and communications concerning "all medical procedures and
+consultations" (emphasis added) regardless of the relation to the allegations in the Complaint, and
+will withhold responsive documents and communications, if any, based on this objection.
+Subject to the General and Specific Objections, Plaintiff will produce non-privileged
+documents and communications concerning medical procedures and consultations received by
+Plaintiff during the relevant time period that relate to allegations of the Complaint, if any.
+REQUEST NO. 14
+Regardless of date and the relation (or lack thereof) to Decedent's acts and
+omissions alleged in the Complaint or otherwise, all documents and communications
+concerning all medical procedures and consultations you received evidencing or otherwise
+concerning the following conditions:
+a. an eating disorder,
+b. emotional distress,
+c. psychological or psychiatric trauma,
+d. mental anguish,
+e. humiliation,
+f. confusion,
+g. embarrassment,
+h. loss of self-esteem,
+i. loss of dignity,
+j. loss of enjoyment of life,
+k. pain,
+I. suffering, or
+m. any condition that would require surgery to correct.
+
+
+Case 1:19-cv-08673-KPF-DCF Document 79-3 Filed 06/22/20 Page 12 of 29
+RESPONSE TO REQUEST NO. 14
+Plaintiff objects to Request No. 14 on the ground that it is overly broad, unduly
+burdensome, and seeks information not relevant to either party's claims or defenses to the extent
+that it seeks documents and communications concerning "all medical procedures and
+consultations" regardless of the relation to the allegations in the Complaint and to the extent it
+requests information for "any condition that would require surgery to correct," and will withhold
+responsive documents and communications, if any, based on this objection. Plaintiff further
+objects to Request No. 14 on the ground that it is vague and ambiguous to the extent it uses the
+undefined phrase "evidencing or otherwise concerning."
+Subject to the General and Specific Objections, Plaintiff will produce non-privileged
+documents and communications concerning medical procedures and consultations received by
+Plaintiff concerning the aforementioned conditions that relate to the allegations in the Complaint,
+if any.
+REQUEST NO. 15
+To the extent not otherwise produced in response to the foregoing request and
+regardless of date and the relation (or lack thereof) to Decedent's acts and omissions
+alleged in the Complaint or otherwise, all documents and communications evidencing or
+otherwise concerning your experience of the same or similar conditions and damages for
+which you seek recovery from Defendants in this litigation.
+RESPONSE TO REQUEST NO. 15
+Plaintiff objects to Request No. 15 on the ground that it is vague and ambiguous to the
+extent it uses the undefined phrase "similar conditions and damages" and the term "evidencing."
+Subject to the General and Specific Objections, Plaintiff will produce non-privileged
+documents and communications concerning her experience of the same conditions and damages
+from which she seeks recovery in this litigation, if any.
+
+
+Case 1:19-CV-08673-KPF-DCF Document 79-3 Filed 06/22/20 Page 13 of 29
+REQUEST NO. 16
+To the extent not otherwise responsive to these requests, all documents and
+communications concerning anything of value you received from Decedent.
+RESPONSE TO REQUEST NO. 16
+Plaintiff objects to Request No. 16 on the ground that it is vague and ambiguous to the
+extent it uses the undefined phrase "anything of value."
+Subject to the General and Specific Objections, Plaintiff will produce non-privileged
+documents and communications concerning anything of monetary value she received from
+Decedent, if any.
+REQUEST NO. 17
+To the extent not otherwise responsive to these requests, all documents and
+communications concerning your allegations in the Complaint.
+RESPONSE TO REQUEST NO. 17
+Subject to the General Objections, Plaintiff will produce non-privileged documents and
+communications not otherwise responsive to other Requests concerning the allegations in the
+Complaint, if any.
+REQUEST NO. 18
+To the extent not otherwise responsive to these requests, all documents and
+communications upon which you intend to rely in this litigation, including but not limited
+to in the course of depositions, in support of any motion, and at any hearing and trial.
+RESPONSE TO REQUEST NO. 18
+Plaintiff objects to Request No. 18 on the ground that it is vague and ambiguous to the
+extent it uses the undefined phrase "intend to rely." Plaintiff objects to Request No. 18 to the
+extent that it requires Plaintiff to speculate as to which documents and communications Plaintiff
+may or may not reference later in this litigation.
+
+
+Case 1:19-cv-08673-KPF-DCF Document 79-3 Filed 06/22/20 Page 14 of 29
+Subject to the General and Specific Objections, Plaintiff will produce non-privileged
+documents and communications not otherwise responsive to other Requests that Plaintiff presently
+plans to rely on in this litigation, if any.
+REQUEST NO. 19
+To the extent not otherwise produced in response to these requests, all documents
+and communications evidencing or otherwise concerning any damages you allege you
+suffered concerning the allegations in your Complaint, including but not limited to all
+medical fees, attorneys' fees and lost wages.
+RESPONSE TO REQUEST NO. 19
+Plaintiff objects to Request No. 19 on the ground that it is vague and ambiguous to the
+extent it uses the undefined phrase "evidencing or otherwise concerning."
+Subject to the General Objections, Plaintiff will produce non-privileged documents and
+communications not otherwise responsive to other Requests concerning Plaintiff's damages
+suffered as a result of the allegations in the Complaint, if any.
+REQUEST NO. 19
+All documents identified in your response to Defendants' First Set of Interrogatories
+to Plaintiff.
+RESPONSE TO REQUEST NO. 19
+Subject to the General Objections, Plaintiff will produce non-privileged documents not
+otherwise responsive to other Requests that Plaintiff' identified in response to Defendants' First Set
+of Interrogatories to Plaintiff, if any.
+Dated: April 16, 2020
+New York, NY
+Respectfully submitted,
+By:
+Roun
+Roberta A. Kaplan
+Kate L. Doniger
+Alexandra Conlon
+
+
+Case 1:19-cv-08673-KPF-DCF Document 79-3 Filed 06/22/20 Page 15 of 29
+Kyla Magun
+Louis W. Fisher
+KAPLAN HECKER & FINK LLP
+350 Fifth Avenue, Suite 7110
+New York, NY 10118
+(212) 763-0883
+rkaplan@kaplanhecker.com
+kdoniger@kaplanhecker.com
+aconlon@kaplanhecker.com
+kmagun@kaplanhecker.com
+Ifisher@kaplanhecker.com
+Attorneys for Plaintiff
+
+
+Case 1:19-cv-08673-KPF-DCF Document 79-3 Filed 06/22/20 Page 16 of 29
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+JANE DOE,
+Plaintiff,
+V.
+DARREN K. INDYKE and RICHARD D. KAHN, in
+their capacities as the executors of the Estate of
+Jeffrey E. Epstein,
+Defendants.
+Case No. 19 Civ. 8673 (KPF) (DCF)
+PLAINTIFF JANE DOE'S RESPONSES AND OBJECTIONS TO
+PLAINTIFF'S FIRST SET OF INTERROGATORIES
+Pursuant to Rules 26 and 34 of the Federal Rules of Civil Procedure and the Local Rules
+for the Southern District of New York (together, the "Rules"), Plaintiff Jane Doe, by and through
+her attorneys, submits these responses and objections ("Responses") to Defendants Darren K.
+Indyke and Richard D. Kahn, in their capacities as the executors of the Estate of Jeffrey E. Epstein
+("Defendants") First Set of Interrogatories dated March 10, 2020 (the "Interrogatories").
+GENERAL OBJECTIONS AND RESPONSES
+The following general objections and responses (the "General Objections") are
+incorporated into each specific objection and response (the "Specific Objections") as if fully set
+forth therein:
+Plaintiff objects to the Interrogatories to the extent they are duplicative, cumulative,
+or seek information that has been or will be provided through other means of discovery.
+Plaintiff objects to the Interrogatories to the extent they are vague, ambiguous,
+overly broad, unduly burdensome, seek information not relevant to the claims or defenses of any
+party, or are not proportional to the needs of the case.
+
+
+Case 1:19-CV-08673-KPF-DCF Document 79-3 Filed 06/22/20 Page 17 of 29
+3.
+Plaintiff objects to the Interrogatories to the extent they impose any obligations or
+requirements beyond the scope of the Rules or any case law interpreting them.
+4.
+Plaintiff's Responses are not intended to be and shall not be construed as an
+agreement or concurrence that all information provided is admissible.
+Plaintiff objects to the Interrogatories to the extent that they call for documents that:
+(a) are already in Defendants' possession, custody, or control; (b) are publicly available; or (c) are
+otherwise independently available to Defendants or their counsel.
+6.
+Plaintiff objects to the Interrogatories to the extent they purport to call for
+documents or information that: (a) are subject to the attorney-client privilege; (b) constitute
+attorney work product; (c) are protected from disclosure based on common interest or a similar
+privilege; or (d) are otherwise protected from disclosure under applicable privilege, law, or rule.
+Plaintiff will not produce such information in response to the Interrogatories, and any inadvertent
+production thereof shall not be deemed a waiver of any privilege with respect to such information.
+7.
+Plaintiff objects to the Interrogatories to the extent they seek information protected
+by federal or state law. Except to the extent permitted by an applicable exception or court order,
+Plaintiff will not disclose any information in violation of federal or state law.
+8.
+Plaintiff objects to the Interrogatories to the extent they require unreasonable
+measures to locate and produce responsive documents. Plaintiff will construe the Interrogatories
+to require a reasonable and diligent search of her reasonably-accessible files where she would
+reasonably expect to find information, documents, or things related to the Interrogatories, and
+specifically states that she will limit her search for electronically stored information by use of
+identified search terms to be agreed upon by the Parties.
+Plaintiff objects to the Interrogatories to the extent that they include "discrete subparts" but
+are listed as one individual Interrogatory, pursuant to Rule 33(a)(1).
+
+
+Case 1:19-cV-08673-KPF-DCF Document 79-3 Filed 06/22/20 Page 18 of 29
+10.
+Plaintiff objects to Definition No. 1 to the extent that it imposes obligations greater
+than those imposed by the Rules.
+11. Plaintiff objects to the Interrogatories, and in particular, Definitions No. 4 and
+Instructions No. 5, to the extent that they seek information or documents that are not within
+Plaintiff's possession, custody, or control. Subject to this General Objection, in responding to the
+Requests, Plaintiff will provide only responsive, non-privileged documents within Plaintiff's
+possession, custody, or control.
+12. Plaintiff objects to Instruction No. 7 to the extent it calls for speculation.
+13. Plaintiff objects to each Interrogatory to the extent that it asks Plaintiff to identify
+"each" or "all" persons, documents, communications, etc., on the ground that each such
+Interrogatory is overly broad and that compliance with each such Interrogatory would be unduly
+burdensome and not proportional to the needs of this case.
+14.
+Plaintiff objects to each Interrogatory to the extent that it secks information or
+documents beyond the time period relevant to the allegations in the Complaint.
+15.
+Plaintiff objects to the Interrogatories to the extent they contain express or implied
+assumptions of fact or law with respect to matters at issue in this case. Plaintiff's Responses are
+not intended to be and shall not be construed as an agreement or concurrence with Defendants'
+characterization of any facts, circumstances, or legal obligations. Plaintiff reserves the right to
+contest any such characterization as inaccurate.
+16.
+Plaintiff expressly reserves all rights and privileges under the Rules and any other
+applicable law or rule. The failure to assert such rights and privileges or the inadvertent disclosure
+by Plaintiff of information or documents protected by such rights or privileges shall not constitute
+
+
+Case 1:19-cv-08673-KPF-DCF Document 79-3 Filed 06/22/20 Page 19 of 29
+a waiver thereof, either with respect to these Responses or with respect to any future discovery
+objections or responses.
+17.
+The fact that Plaintiff has responded to a particular Interrogatory shall not be
+interpreted as implying that Plaintiff acknowledges the propriety of that Interrogatory.
+18.
+Plaintiff's Responses to the Interrogatories are made to the best of Plaintiff's
+present knowledge, information, and belief. These Responses are at all times subject to such
+additional or different information that discovery or further investigation may disclose and, while
+based on the present state of Plaintiff's knowledge and investigation, are subject to such additional
+knowledge of facts as may result from Plaintiff's further discovery or investigation.
+19.
+Plaintiff reserves the right to make any use of, or to introduce at any hearing and at
+trial, information responsive to the Interrogatories but discovered subsequent to the date of these
+Responses, including, but not limited to, any such information obtained in discovery herein.
+20.
+Plaintiff reserves all objections or other questions as to the competency, relevance,
+materiality, privilege, or admissibility of Plaintiff's Responses herein and any documents produced
+subject thereto, as evidence in any subsequent proceeding in, or trial of, this or any other action,
+or for any other purpose whatsoever.
+21.
+Plaintiff's Responses to the Interrogatories will be subject to the protections of any
+Protective Order entered by the Court governing the handling of confidential material in this case.
+
+
+Case 1:19-cv-08673-KPF-DCF Document 79-3 Filed 06/22/20 Page 20 of 29
+SPECIFIC OBJECTIONS AND RESPONSES
+INTERROGATORY NO. 1
+Identify all persons with knowledge of information concerning the subject matter of
+this litigation, and the subject matter of their knowledge.
+RESPONSE TO INTERROGATORY NO. 1
+Plaintiff objects to Interrogatory No. 1 as overly broad, unduly burdensome, and seeking
+information that is not relevant to any party's claims or defenses and disproportionate to the needs
+of this case to the extent it requests the identification of all persons with knowledge of information
+concerning "the subject matter of the litigation." Plaintiff further objects to Interrogatory No. 1
+on the ground that it is vague and ambiguous to the extent it uses the phrase "the subject matter of
+this litigation." Plaintiff further objects to Interrogatory No. I on the ground that it calls for
+Plaintiff to speculate as to the scope of someone else's knowledge.
+Subject to the General and Specific Objections, Plaintiff identifies the following persons
+whom Plaintiff believes have direct, relevant knowledge or information about the allegations in
+the Complaint:
+Name
+Lesley Groff
+Dr. Dawn Hughes
+Assistant U.S. Attorney Alexander
+Rossmiller, Esq.
+Diarmuid
+, Esq.
+Subjects of Information
+The allegations in the Complaint, including that Jeffrey
+Epstein repeatedly sexually abused Doe in his home
+between 2002 and 2005.
+The allegations in the Complaint, including that Jeffrey
+Epstein repeatedly sexually abused Doe in his home
+effrey Epstein's sexual abuse of Plaintiff, includin
+sychological impact of that abuse
+Jeffrey Epstein's sexual abuse of Plaintiff.
+Jeffrey Epstein's retention of Mr.
+to represent
+Plaintiff in connection with a criminal investigation into
+Epstein's sexual abuse of minors
+The allegations in the Complaint
+The allegations in the Complaint.
+
+
+Case 1:19-cV-08673-KPF-DCF Document 79-3 Filed 06/22/20 Page 21 of 29
+_ The allegations in the Complaint.
+INTERROGATORY NO. 2
+Identify and describe the computation of each category of damages for which you
+seek recovery in this litigation.
+RESPONSE TO INTERROGATORY NO. 2
+Plaintiff objects to Interrogatory No. 2 on the basis that it requires expert opinion to
+determine the computation of each category of damages.
+Subject to the General and Specific Objections, Plaintiff discloses that she is entitled to
+recover damages in the form of, inter alia, actual damages, compensatory damages, statutory
+damages, consequential damages, punitive damages, attorneys' fees, costs, and interest.
+INTERROGATORY NO. 3
+Identify the existence, custodian and location of, and generally describe, all
+documents and communications concerning the subject matter of this litigation.
+RESPONSE TO INTERROGATORY NO.3
+Plaintiff objects to Interrogatory No. 3 as overly broad, unduly burdensome, and seeking
+information that is not relevant to any party's claims or defenses and disproportionate to the needs
+of this case to the extent it requests the identification of all documents and communications
+concerning "the subject matter of the litigation." Plaintiff further objects to Interrogatory No. 3
+on the ground that it is vague and ambiguous to the extent it uses the phrases "generally describe"
+and "the subject matter of this litigation."
+Subject to the General and Specific Objections, Plaintiff will identify non-privileged,
+responsive documents and communications concerning the allegations in the Complaint, if any,
+when such communications are produced in response to Defendants' First Requests for Production
+("Defendants' RFPs"), subject to Plaintiff's general and specific responses and objections thereto.
+
+
+Case 1:19-CV-08673-KPF-DCF Document 79-3 Filed 06/22/20 Page 22 of 29
+Plaintiff refers Defendants to Plaintiff's Responses and Objections to Plaintiff's First Requests for
+Production of Documents ("Plaintiff's RFP Responses").
+INTERROGATORY NO. 4
+Identify each employee of, agent of, or other individual associated with Decedent
+with whom you communicated or interacted; and identify the date of, and describe the
+nature of, each such communication or interaction.
+RESPONSE TO INTERROGATORY NO. 4
+Plaintiff' objects to Interrogatory No. 4 on the ground that it is vague and ambiguous to the
+extent it uses the phrase "associated with."
+Subject to the General and Specific Objections, Plaintiff first refers Defendants to the
+Complaint and the allegations therein. Plaintiff also identifies
+and Lesley Groff.
+Plaintiff states that she interacted with
+and Groff between approximately 2002 and 2005 to
+schedule her visits to Decedent's Upper East Side mansion, and that
+and Groff periodically
+made payments to Plaintiff on Decedent's behalf during that time. Plaintiff further states that she
+interacted with other individuals employed by and/or associated with Decedent in his Upper East
+Side mansion,
+including
+, maids, butlers/doormen, and drivers, among others, between
+approximately 2002 and 2005.
+INTERROGATORY NO. 5
+Describe with particularity all duties owed to you by Decedent.
+RESPONSE TO INTERROGATORY NO.5
+Plaintiff objects to Interrogatory No. 5 on the ground that it is vague and ambiguous to the
+extent it uses the phrase "duties owed to you." Plaintiff further objects to Interrogatory No. 5 on
+the ground that it calls for a legal conclusion.
+
+
+Case 1:19-cv-08673-KPF-DCF Document 79-3 Filed 06/22/20 Page 23 of 29
+Subject to the General and Specific Objections, for information concerning the nature of
+the relationship between Decedent and Plaintiff, Plaintiff refers Defendants to the Complaint and
+the allegations therein, as well as Plaintiff's RFP Responses.
+INTERROGATORY NO. 6
+Identify and describe with particularity each act or omission on the part of
+Decedent that you allege constitutes a breach of a duty owed to you. For each act or
+omission identified, identify the date of the alleged act or omission, all persons with
+knowledge of the facts set forth in your response to this interrogatory, and all documents
+evidencing or otherwise concerning the information set forth in your response to this
+interrogatory.
+RESPONSE TO INTERROGATORY NO. 6
+Plaintiff objects to Interrogatory No. 6 on the ground that it is vague and ambiguous to the
+extent it uses the undefined term "evidencing." Plaintiff further objects to Interrogatory No. 6 on
+the ground that it calls for a legal conclusion. Plaintiff further objects to Interrogatory No. 6 on
+the ground that it calls for Plaintiff to speculate as to the scope of someone else's knowledge.
+Subject to the General and Specific Objections, for information concerning the interactions
+between Decedent and Plaintiff, Plaintiff refers Defendants to the Complaint and the allegations
+therein, as well as Plaintiff's RFP Responses.
+INTERROGATORY NO. 7
+Identify and describe with particularity each act or omission on the part of
+evidencing or otherwise concerning the information set forth in your response to this
+interrogatory.
+RESPONSE TO INTERROGATORY NO. 7
+Plaintiff objects to Interrogatory No. 7 on the ground that it is vague and ambiguous to the
+extent it uses the undefined term "evidencing." Plaintiff further objects to Interrogatory No. 7 on
+
+
+Case 1:19-cv-08673-KPF-DCF Document 79-3 Filed 06/22/20 Page 24 of 29
+the ground that it calls for a legal conclusion. Plaintiff further objects to Interrogatory No. 7 on
+the ground that it calls for Plaintiff to speculate as to the scope of someone else's knowledge.
+Subject to the General and Specific Objections, Plaintiff refers Defendants to Plaintiff's
+Response to Interrogatory No. 1, the Complaint and the allegations therein, as well as Plaintiff's
+RFP Responses.
+INTERROGATORY NO. 8
+Identify with particularity each act or omission on the part of Decedent that you
+allege constitutes a tort. For each act or omission identified, identify the date of the alleged
+ict or omission, the tort you allege the act or omission constitutes, all persons witl
+nowledge of the information set forth in your response to this interrogatory, and al
+documents evidencing or otherwise concerning such information.
+RESPONSE TO INTERROGATORY NO. 8
+Plaintiff objects to Interrogatory No. 8 on the ground that it is vague and ambiguous to the
+extent it uses the undefined term "evidencing." Plaintiff further objects to Interrogatory No. 8 on
+the ground that it calls for a legal conclusion. Plaintiff further objects to Interrogatory No. 8 on
+the ground that it calls for Plaintiff to speculate as to the scope of someone else's knowledge.
+Subject to the General and Specific Objections, Plaintiff refers Defendants to Plaintiff's
+Response to Interrogatory No. 1, the Complaint and the allegations therein, as well as Plaintiff's
+RFP Responses.
+INTERROGATORY NO. 9
+Identify all persons other than Decedent who have ever committed or attempted to
+commit sexual iis conduct or offense agains or otheral at core sening abuse studing,
+issault, threats or intimidation of a sexual nature, or sexual exploitation, regardless o
+vhether the misconduct or offenses involved physical touching. For each person identified
+identify the misconduct or offense committed, and the date and location of the misconduct
+or offense.
+
+
+Case 1:19-cv-08673-KPF-DCF Document 79-3 Filed 06/22/20 Page 25 of 29
+RESPONSE TO INTERROGATORY NO. 9
+Plaintiff objects to Interrogatory No. 9 as overly broad, unduly burdensome, and seeking
+information that is not relevant to any party's claims or defenses and disproportionate to the needs
+of this case to the extent it requests the identification of "all persons" who have "committed or
+attempted to commit sexual misconduct or offenses against or otherwise concerning you,"
+including, for example, "any unwelcome behavior of a sexual nature," regardless of the relation to
+the allegations in the Complaint and regardless of the severity of the behavior, and to the extent it
+requests the "location of the misconduct or offense." Plaintiff further objects to Interrogatory No.
+9 on the ground that it is vague and ambiguous to the extent it uses the phrases "unwelcome
+behavior of a sexual nature" and "threats or intimidation of a sexual nature."
+Subject to the General and Specific Objections, Plaintiff states that her s
+INTERROGATORY NO. 10
+Identify all medical procedures and consultations you received, including the dates
+of each procedure and consultation, the locations of each procedure and consultation, and
+the identities of all medical providers who conducted or otherwise participated in each
+procedure and consultation. The relevant time period for this interrogatory is the date on
+which you first learned of Decedent through the date of your responses to these
+RESPONSE TO INTERROGATORY NO. 10
+Plaintiff objects to Interrogatory No. 10 as overly broad, unduly burdensome, and seeking
+information that is not relevant to any party's claims or defenses and disproportionate to the needs
+of this case to the extent it requests the identification of "all medical procedures and consultations,"
+regardless of the relation to the allegations in the Complaint and "the identities of all medical
+
+
+Case 1:19-CV-08673-KPF-DCF Document 79-3 Filed 06/22/20 Page 26 of 29
+providers who . .. otherwise participated in each procedure and consultation," regardless of his or
+her role in the procedure or consultation.
+Subject to the General and Specific Objections, Plaintiff identifies the following mental
+and/or physical health care providers who provided treatment or services relevant to the claims
+and defenses in this action:
+Provider
+Treatment Type
+Plaintiff further refers Defendants to the documents produced in response to Request No. 13 of
+Defendants' RFPs.
+INTERROGATORY NO. 11
+Regardless of date and the relation (or lack thereof) to Decedent's acts and
+omissions alleged in the Complaint or otherwise, identify all medical procedures and
+consultations you received evidencing or otherwise concerning the following conditions:
+a. an eating disorder,
+b. emotional distress,
+c. psychological or psychiatric trauma,
+d. mental anguish,
+e. humiliation,
+f. confusion,
+g. embarrassment,
+
+
+Case 1:19-cv-08673-KPF-DCF Document 79-3 Filed 06/22/20 Page 27 of 29
+h. loss of self-esteem,
+i. loss of dignity,
+j. loss of enjoyment of life,
+k. pain,
+1. suffering, or
+m. any condition that would require surgery to correct
+RESPONSE TO INTERROGATORY NO. 11
+Plaintiff objects to Interrogatory No. I on the ground that it is overly broad, unduly
+burdensome, and seeks information not relevant to either party's claims or defenses to the extent
+that it seeks
+documents
+and communications concerning "all medical procedures and
+consultations" regardless of the relation to the allegations in the Complaint and to the extent it
+requests information for "any condition that would require surgery to correct." Plaintiff further
+objects to Interrogatory No. 11 on the ground that it is vague and ambiguous to the extent it uses
+the undefined term "evidencing."
+Subject to the General and Specific Objections, Plaintiff refers Defendants to her Response
+to Interrogatory No. 10 and to the documents produced in response to Request No. 14 of
+Defendants' RFPs.
+INTERROGATORY NO. 12
+State whether you have ever experienced the same or similar conditions and
+damages, for which you seek recovery from Defendants in this litigation, as a result of acts
+or omissions by persons other than Decedent. If you answer this interrogatory in the
+affirmative: identify each such person; describe the acts or omissions that resulted in the
+damages; identify the dates and locations of such acts and omissions; and describe the
+damages that resulted.
+RESPONSE TO INTERROGATORY NO. 12
+Plaintiff objects to Interrogatory No. 12 on the ground that it is vague and ambiguous to
+the extent it uses the undefined phrase "similar conditions and damages." Plaintiff further objects
+to Interrogatory No. 12 on the ground that it calls for speculation. Plaintiff also objects to
+
+
+Case 1:19-cV-08673-KPF-DCF Document 79-3 Filed 06/22/20 Page 28 of 29
+Interrogatory No. 12 on the basis that the determination as to whether Plaintiff has experienced
+"the same or similar conditions or damages ...as a result of acts or omissions by persons other
+than Decedent" calls for an expert opinion.
+Subject to the General and Specific Objections, Plaintiff refers Defendants to the
+forthcoming expert reports in this Litigation.
+INTERROGATORY NO. 13
+Identify all things of value you received from Decedent, including a description of
+the thing, the date on which you received the thing, and the person who tendered the thing
+to you.
+RESPONSE TO INTERROGATORY NO. 13
+Plaintiff objects to Interrogatory No. 13 on the ground that it is vague and ambiguous to
+the extent it uses the undefined phrase "things of value."
+Subject to the General and Specific Objections, Plaintiff refers Defendants to the
+Complaint and the allegations therein, as well as Plaintiff's Response to RFP No. 16. Plaintiff
+states that she received numerous cash payments between 2002 and 2005 from Decedent and
+Decedent's associates,
+and Lesley Groff, on Decedent's behalf. Plaintiff further
+states that she received a shipment of furniture from Decedent to her home in Astoria between
+2002 and 2005, delivered by men employed by Decedent.
+INTERROGATORY NO. 14
+Identify all documents and communications upon which you intend to rely in this
+itigation, including but not limited to in the course of depositions, in support of any
+motion, and at any hearing or trial.
+RESPONSE TO INTERROGATORY NO. 14
+Plaintiff objects to Interrogatory No. 14 on the ground that it is vague and ambiguous to
+the extent it uses the undefined phrase "intend to rely." Plaintiff further objects to Interrogatory
+
+
+Case 1:19-cv-08673-KPF-DCF Document 79-3 Filed 06/22/20 Page 29 of 29
+No. 14 to the extent that it requires Plaintiff to speculate as to which documents and
+communications Plaintiff may or may not reference later in this litigation.
+Subject to the General and Specific Objections, Plaintiff refers Defendants to documents
+and communications produced in response to Defendants' RFPs, if any.
+INTERROGATORY NO. 15
+dentify all documents and communications evidencing or otherwise concernin
+lamages and everything else for which you seek recovery in this litigation, including bu
+not limited to damages you allege in your Complaint, medical fees, attorneys' fees and lost
+wages.
+RESPONSE TO INTERROGATORY NO. 15
+Plaintiff objects to Interrogatory No. 15 on the ground that it is vague and ambiguous to
+the extent it uses the undefined term "evidencing."
+Subject to the General and Specific Objections, Plaintiff refers Defendants to documents
+and communications produced in response to Defendants' RFPs.
+Dated: April 16, 2020
+New York, NY
+Respectfully submitted,
+By:
+Roberta A. Kaplan
+Kate L. Doniger
+Alexandra Conlon
+Kyla Magun
+Louis W. Fisher
+KAPLAN HECKER & FINK LLP
+350 Fifth Avenue, Suite 7110
+New York, NY 10118
+(212) 763-0883
+rkaplan@kaplanhecker.com
+kdoniger(@kaplanhecker.com
+aconlon@kaplanhecker.com
+kmagun@kaplanhecker.com
+Ifisher@kaplanhecker.com
+Attorneys for Plaintiff

vision-fixhub/court-01/8fe78f32eec10f8e56ace86eae366fb1d1035cd2a2f14ad9d275c112db60a42a.receipt.json

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vision-fixhub/court-01/9030846c63e90e50b232ebc52221d146857d76b5203a48cb4129521b7730bb23.md

@@ -0,0 +1,204 @@
+Case 9:08-cv-80119-KAM Document 316 Entered on FLSD Docket 09/18/2009 Page 1 of 5
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CIV-80119-MARRA/
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-08380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+JOINT NOTICE OF AGREEMENT RELATIVE TO PLAINTIFF JANE DOE'S
+MOTIONS TO COMPEL RESPONSES TO ANSWERS TO INTERROGATORIES,
+REQUEST TO PRODUCE AND RESPONSES TO REQUEST FOR ADMISSIONS, AND
+UNOPPOSED MOTION FOR EXTENSION OF TIME IN WHICH TO RESPOND TO
+REMAINING PORTIONS STILL AT ISSUE
+Defendant, JEFFREY EPSTEIN, and Plaintiff, JANE DOE, by and through their
+undersigned counsel hereby file this JOINT NOTICE OF AGREEMENT RELATIVE TO
+PLAINTIFF JANE DOE'S MOTIONS TO COMPEL RESPONSES TO ANSWERS TO
+INTERROGATORIES, REQUEST TO PRODUCE AND RESPONSES TO REQUEST
+FOR ADMISSIONS, AND UNOPPOSED MOTION FOR EXTENSION OF TIME IN
+WHICH TO RESPOND TO REMAINING PORTIONS STILL AT ISSUE, and thus move
+this Court for an Extension of Time until October 6, 2009, to file Responses to Plaintiff
+Jane Doe's Motions to Compel Responses to Request to Produce, Responses to Request
+for Admissions, and Answers to Interrogatories, pursuant to Local Rule 7.1 A.1()(S.D.
+Fla. 2008). As good cause for the requested extension, Defendant states:
+
+
+Case 9:08-cv-80119-KAM Document 316 Entered on FLSD Docket 09/18/2009 Page 2 of 5
+1. Brad
+Counsel for the Plaintiff, is scheduled to return to his office after
+having a surgical procedure on September 20, 2009.
+2. Nonetheless, in a diligent effort to conserve on Judicial resources, attorney
+resources and in light of the court's order addressing the 5" Amendment issues at (DE
+242 and 293) Mr.
+and the undersigned have been able to resolve via telephone
+several discovery requests, thereby relieving the court from having to address certain
+requests in the above Motions to Compel and any responses/replies thereto. Mr.
+does not waive his right to address those requests for which an agreement has been made.
+The Court has already ruled on certain discovery matters. Therefore, that is the binding
+law of the case, and Plaintiff maintains her objections to said discovery requests for
+purposes of any appeal.
+3. In sum, the requests delineated below are simply moot for purposes of the court
+having to rule on same at this time.
+The Interrogatories
+4. Initially, Plaintiff's Motion to Compel Answers to Interrogatories (DE 196)
+addressed interrogatories 1-23.
+5. The undersigned attorneys have agreed that this court is relieved from having to
+currently rule on interrogatory numbers 1, 8, 9, 10, 11, 16, 18, 19, 20, 21 and 22.
+6. Therefore, the remaining interrogatories in dispute are interrogatory numbers 2, 3,
+4, 5, 6, 7, 12, 13, 14, 15, 17, and 23.
+The Requests for Production
+7. Initially, Plaintiff's Motion to Compel Responses to Requests for Production (DE
+210) addressed requests numbers 1-16.
+
+
+Case 9:08-cv-80119-KAM Document 316 Entered on FLSD Docket 09/18/2009 Page 3 of 5
+8. The undersigned attorneys have agreed that this court is relieved from having to
+currently rule on request numbers 1, 2, 3, 4 and 6.
+9. Therefore, the remaining requests in dispute are request numbers 5, 7, 8, 9, 10, 11,
+12, 13, 14, 15 and 16.
+The Requests for Admissions
+10. Initially, Plaintiff's Motion to Compel Responses to Requests for Admissions (DE
+195) addressed requests numbers 1-23.
+11. The undersigned attorneys have agreed that this court is relieved from having to
+currently rule on request for admission numbers 10, 11, 12, 13, 14, 15, 16, 17, 18, 19 and
+20.
+12. Therefore, the remaining requests for admissions in dispute are request numbers
+1, 2, 3, 4, 5, 6, 7, 8, 9, 21, 22, and 23.
+13. While the undersigned lawyers have resolved certain issues in the above motions
+to conserve on judicial resources, no admissions or waivers of objections have been made
+and no arguments are being abandoned.
+14. Therefore, the undersigned attorneys have agreed that Defendant shall file his
+Response Motions to the above Motions to Compel relative to the requests at issue on or
+before October 2, 2009.
+Rule 7.1 A.3 Certification of Pre-Filing Conference
+Counsel for Defendant conferred with Counsel for Plaintiff by telephone and/or
+electronic mail, and Counsel for Plaintiff is in agreement with the toquested extension.
+By:
+MICHAEL J. PIKE, ESQ.
+Floride Bar #617296
+
+
+Case 9:08-cv-80119-KAM Document 316 Entered on FLSD Docket 09/18/2009 Page 4 of 5
+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 thislig day of September, 2009
+ROBERTD. CRITTON, JR., ESQ.
+Florida Bar No. 224162
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.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)
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+ssm@sexabuseattorney.com
+ahorowitz@sexabuseattorney.com
+Certificate of Service
+Jane Doe No. 2 v. Jeffrey Epstein
+Case No. 08-CV-80119-MARRA/JOHNSON
+Brad
+• 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 in Related Case No.
+08-80893
+
+
+Case 9:08-cv-80119-KAM Document 316 Entered on FLSD Docket 09/18/2009 Page 5 of 5
+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 10" Avenue North
+Suite 404
+Lake Worth, FL 33461
+561-582-7600
+Fax: 561-588-8819
+Counsel for Plaintiff in Related Case No.
+08-80811
+reelrhw@hotmail.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
+cassellp@law.utah.edu
+Co-counsel for Plaintiff 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
+Jack Scarola, Esq.
+isidrogarcia@bellsouth.net
+Jack P.
+| Esq.
+Counsel for Plaintiff in Related Case No.
+Searcy Denney Scarola Barnhart & Shipley,
+08-80469
+P.A.
+2139 Palm Beach Lakes Boulevard
+Robert C. Josefsberg, Esq.
+West Palm Beach, FL 33409
+Katherine W. Ezell, Esq.
+561-686-6300
+Podhurst Orseck, P.A.
+Fax: 561-383-9424
+25 West Flagler Street, Suite 800
+jsx@searcylaw.com
+Miami, FL 33130
+iph@searcylaw.com
+305 358-2800
+Counsel for Plaintiff. C.M.A.
+Fax: 305 358-2382
+rjosefsberg@podhurst.com
+kezell@podhurst.com
+Bruce Reinhart, Esq.
+Counsel for Plaintiffs in Related Cases
+Bruce E. Reinhart, P.A.
+Nos. 09-80591 and 09-80656
+250 S. Australian Avenue
+Suite 1400
+West Palm Beach, FL 33401
+561-202-6360
+Fax: 561-828-0983
+ecf@brucereinhartlaw.com
+Counsel for Defendant TI
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Counsel for Defendant Jeffrey Epstein

vision-fixhub/court-01/9030846c63e90e50b232ebc52221d146857d76b5203a48cb4129521b7730bb23.receipt.json

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+}

vision-fixhub/court-01/90488be35ca5be3c81e2bdc2818a40120f666170e26674ebab85648bd16493bc.md

@@ -0,0 +1,109 @@
+Casase 1918Y-0-08675KFP-6EF Bocument 38 Filed 12123189 Page or 2
+
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+JANE DOE,
+USDC SNY
+DOCUMENT
+ELECTRONICALLY FILED
+DOC#:.
+DATE FILED:
+12/18/19.
+Case No. 19 Civ. 8673
+Plaintiff,
+V.
+DARREN K. INDYKE and RICHARD D. KAHN, in
+their capacities as executors of the ESTATE OF
+JEFFREY E. EPSTEIN,
+Defendants.
+JOINT STIPULATION AND [PROPOSED ORDER ON PLAINTIFF'S ANONYMITY
+This stipulation is entered into by plaintiff Jane Doe ("Plaintiff") and defendants Darren
+K. Indyke and Richard D. Kahn, in their capacities as executors of the Estate of Jeffrey E. Epstein
+("Defendants").
+WHEREAS, Plaintiff has moved this Court for an Order permitting Plaintiff to proceed
+under a pseudonym in this action;
+IT IS HEREBY STIPULATED AND AGREED, by and between Plaintiffs and
+Defendants, through their undersigned counsel, subject to the approval of the Court, that:
+1. Within three (3) days of entry of this Order, Counsel of Record for Plaintiff shall disclose
+Plaintiff's identity to Counsel of Record for Defendants, in writing.
+2. Counsel of Record for Defendants may disclose Plaintiff's identity only to Defendants and
+any attorneys, paralegals, and clerical or other assistants working with or for Counsel of
+Record for Defendants on this action; and the recipients of such information shall not
+disclose it to any other persons.
+3. If Defendants wish to disclose Plaintiff's identity to any person not otherwise permitted to
+receive such information under this Order, Defendants are limited to doing so in connection
+with defending this action, and must require such person to first execute a non-disclosure
+agreement, in a form agreed to by the parties and attached to this Order as Exhibit A, that
+prevents such person from disclosing Plaintiff's identity to any other persons. Defendants
+must maintain a list of all such persons to whom Plaintiff's identity is disclosed and copies
+of the executed non-disclosure agreements, all of which are subject to in camera inspection.
+
+
+Case 1:19-cv-08673-KPF-DCF
+Document 41
+Filed 12/18/19
+
+ase 1:19-cv-08673-KPF-DCF Document 38 Filed 12/13/19 Page 2 of
+4. All portions of pleadings, motions or other papers filed with the Court that disclose
+Plaintiff's identity shall be filed under seal with the Clerk of the Court and kept under seal
+until further order of the Court. The parties shall use their best efforts to minimize such
+sealing. Any party filing a motion or any other papers with the Court under seal shall also
+publicly file a redacted copy of the same, via the Court's Electronic Case Filing system,
+that redacts the Plaintiff's identity and text that would reveal Plaintiff's identity.
+5. The parties may seck to modify or amend this Order at any time upon motion to the Court
+or by stipulation.
+Dated: December 13, 2019
+Respectfully submitted,
+Roll
+Roberta A. Kaplan
+Kate L. Doniger
+Alexandra K. Conlon
+KAPLAN HECKER & FINK LLP
+350 Fifth Avenue, Suite 7110
+New York, New York 10118
+Telephone: (212) 763-0883
+Facsimile: (212) 564-0883
+rkaplan@kaplanhecker.com
+kdoniger@kaplanhecker.com
+kmagun@kaplanhecket.com
+aconlon@kaplanhecker.com
+BIM 1к0
+Bennet J. Moskowitz
+TROUTMAN SANDERS LLP
+875 Third Avenue
+New York, New York 10022
+Telephone: (212) 704-6000
+Bennet.Moskowitz@trouthman.com
+Altorneys for Defendants Darren K.
+Escars heard Die olege E.
+Epstein.
+Attorneys for Plaintiff Jane Doe
+SO ORDERED.
+Date:
+12/18/12
+New York, New York
+HON. DEBRA FREEMAN
+United States Magistrate Judge
+2
+
+
+Casse 11100088673KF:BEF Document 8.1 Fild 22/37/9° Page 103 of 3
+EX.A
+JANE DOE,
+Plaintiff,
+V.
+Case No. 19 Civ. 8673
+DARREN K. INDYKE and RICHARD D. KAHN, in their
+capacities as executors of the ESTATE OF JEFFREY E.
+EPSTEIN,
+Defendants.
+NON-DISCLOSURE AGREEMENT
+_ acknowledge that I understand that the name of the Plaintift
+in this action is confidential. I agree that: (1) I will hold in confidence Plaintiff's identity; (2) 1
+vill use Plaintiff's identity only for purposes of this litigation and for no other purpos
+vhatsoever; and (3) I will take all due precautions to prevent the unauthorized or inadverten
+disclosure of Plaintiff's identity.
+By acknowledging these obligations under this Non-Disclosure Agreement, I understand
+contempt of court.
+Dated:
+[Signature]

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vision-fixhub/court-01/905b1e00543106863912a36e74a4fd7e14d3eb97d9e165e5fc0e8010b2d0559b.md

@@ -0,0 +1,161 @@
+Case 9:08-cv-80232-KAM Document 86 Entered on FLSD Docket 05/11/2009 Page 1 of 5
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80232-MARRA-
+JANE DOE NO. 3,
+V.
+JEFFREY EPSTEIN,
+Plaintiff,
+Defendant.
+Defendant, JEFFREY EPSTEIN, by and through his undersigned counsel, moves
+this Court for the entry of an order requiring that the Plaintiff in the above-styled action
+use the proper case-style in all filings in this action, as opposed to improperly including
+all other Jane Does, (Jane Doe No. 2, Jane Doe No. 3, Jane Doe No. 4, Jane Doe No.
+5, Jane Doe No. 6, and Jane Doe No. 7), who are represented by the same counsel.
+Rule 10(a), Fed.R.Civ.P. (2009), Loc. Gen. Rule 7.1 (S.D. Fla. 2009). In support of his
+motion, Defendant states:
+1. Rule 10(a) of the Federal Rules of Civil Procedure, pertaining to "Caption; Names
+of Parties," provides that -
+Every pleading must have a caption with the court's name, a title, a file
+number, and a Rule 7(a) designation. The title of the complaint must name
+all the parties; the title of other pleadings, after naming the first party on
+each side, may refer generally to other parties.
+2. Attached hereto as Exhibit A is the case style which Plaintiff recently used in
+filing papers with this Court. This action has not been consolidated with any of the other
+
+
+Case 9:08-cv-80232-KAM Document 86 Entered on FLSD Docket 05/11/2009 Page 2 of 5
+Jane Doe No. 3 v. Epstein
+Page 2
+Jane Doe actions filed by Plaintiff's counsel. Rule 10(a) makes clear that only the
+parties to this action are to be included in the caption.
+3. By including case styles from five additional cases makes it appear as though the
+cases have been consolidated. Further, the case style used by Plaintiff is not only
+misleading, but confusing in that there is no clear delineation as to in which action the
+matter is properly filed. Each case has different facts and should proceed on those
+facts. Each Plaintiff is claiming personal injury type damages which must be decided
+separately.
+4. Accordingly, Defendant is entitled to an order requiring that Plaintiff uses the
+proper caption and case style in this action and not list every case in which her counsel
+represents other Jane Does.
+WHEREFORE, Defendant respectfully requests that this Court grant Defendant's
+motion, and enter the requested order.
+Rule 7.1 Certification
+Pursuant to letter communication, Plaintiff's counsel did not agree with the relief
+request in Defendant's motion.
+Attorney for Epstein
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically
+filed with the Clerk of the Court using CM/ECF. I also certify that the foregoing
+document is being served this day on all counsel of record identified on the following
+Service List in the manner specified by CM/ECF on this 1 day of May, 2009:
+
+
+Case 9:08-cv-80232-KAM
+Document 86 Entered on FLSD Docket 05/11/2009 Page 3 of 5
+Jane Doe No. 3 v. Epstein
+Page 3
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+ssm@sexabuseattorney.com
+ahorowitz@sexabuseattorney.com
+Counsel for Plaintiff Jane Doe #3
+Jack Alan Goldberger
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Co-Counsel for Defendant Jeffrey Epstein
+Respectfully submitte
+By: _
+ROBERT D. CRITTON, JR., ESQ.
+Florida Bar No. 224162
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER & COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Co-Counsel for Defendant Jeffrey Epstein)
+
+
+Case 9:08-cv-80232-KAM Document 86
+Entered on FLSD Docket 05/11/2009 Page 4 of 5
+Case 9:08-cv-80119-KAM
+Document 82
+Entered on FLSD Doonet 04/23/2009
+
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRAL
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 3,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 4,
+VS.
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80232-MARRA/JOHNSON
+/
+CASE NO.: 08-CV-80380-MARRA/JOHNSON
+JANE DOE NO. 5,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80381-MARRALIL
+-1-
+
+
+
+Case 9:08-cV-80232-KAM Document 86 Entered on FLSD Docket 05/11/2009 Page 5 of 5
+Case 9:08-cv-80119-KAM Document 82
+Entered on FLSD Docket 04/23/2009
+
+JANE DOE NO. 6,
+VS.
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80994-MARRA/
+JANE DOE NO. 7,
+CASE NO.: 08-80993-CIV-MARRA/JOHNSON
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+PLAINTIFFS' MEMORANDUM IN OPPOSITION
+TO MOTION TO STAY AND OR CONTINUE ACTION
+Plaintiffs, JANE DOES 2-7, by and through undersigned counsel, file this Memorandum in
+Opposition to Stay and or Continue Action, as follows:
+I.
+Introduction
+In moving for stay, Defendant has the burden of demonstrating that, due to a parallel criminal
+proceeding, if he exercises his right against self incrimination he will certainly lose on summary
+judgment unless a stay is granted. Defendant has failed to satisfy this burden. There is no pending
+motion for summary judgment.
+• There is also no criminal proceeding at this time arising from
+Epstein's acts against the Plaintiffs or other victims. Indeed, whether such a criminal proceeding is
+ever commenced is entirely within the Defendant's control, by complying with the terms of his
+Non-Prosecution Agreement with the U.S. Attorney's Office. Defendant relies upon an amorphous
+- 2-

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vision-fixhub/court-01/908d534f49c4098d3d7e4f1a5ec21faf3889d3a6fd993a4f3dc6c5d650edb8d2.md

@@ -0,0 +1,102 @@
+Filing # 146708085 E-Filed 03/30/2022 12:23:05 PM
+IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
+IN AND FOR PALM BEACH COUNTY, FLORIDA
+CA FLORIDA HOLDINGS, LLC,
+Publisher of THE PALM BEACH POST,
+Plaintiff,
+Case No.: 50-2019-CA-014681-XXXX-MB
+Division: AG
+v.
+DAVE ARONBERG, as State Attorney of
+Palm Beach County, Florida; SHARON R.
+BOCK, as Clerk and Comptroller of Palm
+Beach County. Florida,
+Defendants.
+COPY
+/
+MOTION TO WITHDRAW AS COUNSEL
+Pursuant to Rule 2.505(f)(1), Florida Rules of Judicial Administration, the law firm of
+Turkel Cuva Barrios, P.A., Kenneth G. Turkel, Esq., Shane B. Vogt, Esq., and James C. Mooney,
+Esq., counsel for Defendant,
+Abruzzo, as Clerk and Comptroller of Palm Beach County,
+Florida (the "Clerk"), through undersigned counsel, request leave of Court to withdraw as counsel
+and state as follows:
+The Clerk hired the law firm of Bajo Cuva
+Turkel, P.A., Kenneth G. Turkel,
+Esq., Shane B. Vogt, Esq., and James C. Mooney, Esq. to represent him in the above matter.
+2.
+On January 1, 2022, Kenneth G. Turkel, Esq., Shane B. Vogt, Esq., and James C.
+Mooney, Esq. left the law firm of Bajo Cuva
+Turkel, P.A. and formed the law firm of Turkel
+Cuva Barrios, P.A., and continued representing the Clerk.
+On January 3, 2022, Collin D.
+, Esq., appeared in this action on behalf of
+the Clerk, and therefore outside counsel's assistance is no longer needed.
+4.
+The Clerk consents to the relief requested herein. See Exhibit A.
+FILED: PALM BEACH COUNTY, FL,
+ABRUZZO, CLERK, 03/30/2022 12:23:05 PM
+
+
+WHEREFORE, the law firm of Turkel Cuva Barrios, P.A., Kenneth G. Turkel, Esq., Shane
+B. Vogt, Esq., and James C. Mooney, Esq. respectfully request the Court grant their motion to
+withdraw as counsel for Defendant,
+Abruzzo, as Clerk and Comptroller of Palm Beach
+County, Florida, in the above-captioned matter, to relieve them of any further responsibility of
+representation in this cause, and for such other and further relief as may be just and necessary
+under the circumstances.
+/s/ Kenneth G. Turkel
+Kenneth G. Turkel - FBN 867233
+E-mail: kturkel@tcb-law.com
+Shane B. Vogt - FBN 257620
+TURKEL CUVA BARRIOS, P.A.
+100 North Tampa Street, Suite 190(
+Tampa, Florida 33602
+Telephone: (813) 834-9191
+NOT A CER
+Facsimile: (813) 443-2193
+Attorneys for Defendant,
+Abruzzo, as Clerk
+and Comptroller of Palm Beach County, Florida
+2
+4879-2778-
+4457, v. 1
+
+
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on March 30, 2022, I caused a true and correct copy of the
+foregoing to be served via the Florida Court's E-Filing Portal upon the following counsel of record:
+Stephen A. Mendelsohn
+Collin D. L
+Esq.
+Clerk of the Circuit Court & Comptroller,
+Palm Beach County
+P.O. Box 229
+West Palm Beach, FL
+Tel.: (561) 355-2983
+E-mail: eservice@mypalmbeachclerk.com
+smithl@gtlaw.com
+FLService@gtlaw.com
+Michael J. Grygiel
+Greenberg Traurig, P.A.
+54 State St., 6th Floor
+Albany, NY 12207
+E-mail:
+grygielm@gtlaw.com
+Nina D. Boyajian
+Greenberg Traurig, P.A.
+1840 Century Park East, Ste. 1900
+Los Angeles, CA 90067
+E-mails:
+boyajiann@gtlaw.com
+riveraal@gtlaw.com
+Attorneys for Plaintiff
+CERTIFIED CO
+/sl
+'Kenneth
+G. Turkel
+Attorney
+NOT A
+3
+4879-2778-
+4457, v. 1

vision-fixhub/court-01/908d534f49c4098d3d7e4f1a5ec21faf3889d3a6fd993a4f3dc6c5d650edb8d2.receipt.json

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vision-fixhub/court-01/90b02cd96cd74e96de1124a0e316c49a1f4de0e183f83427f93eb1bda2900a55.md

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+Case 9:09-cv-80802-KAM Document 1 Entered on FLSD Docket 05/28/2009 Page 1 of 7
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 09-CV-80802-Marra-
+JANE DOE NO. 8,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+FILED D
+ELECTRONIO
+VT
+May 28, 2009
+TEVEN M. LARIMOR
+LERK U.S. DIST. C
+S.D. OF FLA, - MIAMI
+D.C.
+Defendant.
+/
+COMPLAINT
+Plaintiff, Jane Doe No. 8 ("Jane" or "Jane Doe"), brings this Complaint against Jeffrey
+Epstein, as follows:
+Parties, Jurisdiction and Venue
+Jane Doe No. 8 ("Jane Doe") is a citizen and resident of the State of Florida, and is
+sui juris.
+2.
+This Complaint is brought under a fictitious name to protect the identity of the
+Plaintiff because this Complaint makes sensitive allegations of sexual assault and abuse upon a
+minor.
+Defendant Jeffrey Epstein is a citizen and resident of the State of New York, and
+presently serving a prison sentence in Palm Beach County, Florida for, inter alia, solicitation of
+prostitution and solicitation of minors to engage in prostitution..
+4.
+This is an action for damages in excess of $50 million.
+5.
+This Court has jurisdiction of this action and the claims set forth herein pursuant to 28
+U.S.C. §1332(a), as the matter in controversy (i) exceeds $75,000, exclusive of interest and costs;
+MERMELSTEIN & HOrOWITZ, P. A.
+- 1-
+1 of7
+
+
+Case 9:09-cv-80802-KAM Document 1 Entered on FLSD Docket 05/28/2009 Page 2 of 7
+and (ii) is between citizens of different states.
+6.
+Additionally, this Court has jurisdiction pursuant to 28 U.S.C. §1331 because
+Plaintiff alleges a claim under the laws of the United States. This Court has supplemental
+jurisdiction pursuant to 28 U.S.C. §1367(a) over all other claims set forth herein which form part of
+the same case or controversy.
+This Court has venue of this action pursuant to 28 U.S.C. §§1391(a) and 1391(b) as a
+substantial part of the events or omissions giving rise to the claim occurred in this District.
+Factual Allegations
+8.
+At all relevant times, Defendant Jeffrey Epstein ("Epstein") was an adult male in his
+early 50's. Epstein is a financier and money manager with a secret clientele limited exclusively to
+billionaires. He is himself a man of tremendous wealth, power and influence. He maintains his
+principal home in New York and also owns residences in New Mexico, St.
+and Palm Beach,
+FL. The allegations herein concern Epstein's conduct while at his lavish estate in Palm Beach.
+9.
+Upon information and belief, Epstein has a sexual preference and obsession for
+underage minor girls. He engaged in a plan and scheme in which he gained access to primarily
+economically disadvantaged minor girls in his home, sexually assaulted these girls, and then gave
+them money. In or about 2001, Jane Doe, then approximately 16 years old, fell into Epstein's trap
+and became one of his victims.
+10.
+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.
+11. Epstein's scheme involved the use of young girls to recruit underage girls. These
+underage girls were recruited ostensibly to give a wealthy man a massage for monetary compensation
+MERMELSTEIN & HOROWITZ, P. A.
+- 2-
+2o17
+
+
+•
+Case 9:09-cv-80802-KAM Document 1 Entered on FLSD Docket 05/28/2009 Page 3 of 7
+in his Palm Beach mansion. Epstein, upon information and belief, generally sought out economically
+disadvantaged underage girls from Palm Beach County who would be enticed by the money being
+offered - generally $200 to $300 per "massage" session - and who were perceived as less likely to
+complain to authorities or have credibility if allegations of improper conduct were made.
+12.
+Epstein's plan and scheme reflected a particular pattern and method. The underage
+victim would be brought or directed to Epstein's mansion, where she would be led up a flight of
+stairs to a room that contained a massage table in addition to other furnishings. The girl would then
+find herself alone in the room with Epstein, who would be wearing only a towel. He would then
+remove his towel and lie naked on the massage table, and direct the girl to remove her clothes.
+Epstein would then perform one or more lewd, lascivious and sexual acts.
+13. Consistent with the foregoing plan and scheme, Jane Doe was recruited by another
+girl, who told her that she could make some money, but did not tell her what was involved. At all
+relevant times, the girl who recruited Jane Doe was acting on behalf of and as agent for Epstein.
+Jane was contacted by this girl by telephone. Jane was then picked up and brought to Epstein's
+mansion in Palm Beach. Once there, she was led up the flight of stairs to the room with the massage
+table. Epstein came into the room and directed Jane to remove her clothes and give him a massage.
+Jane was frightened and felt trapped. As directed by Epstein, Jane removed her clothes. Epstein
+then during the massage touched Jane on her breasts and vagina, and he grabbed her hand and placed
+it on his penis. Epstein masturbated himself during the massage. Epstein then left money for Jane.
+14.
+As a result of this encounter with Epstein, Jane experienced confusion, shame,
+humiliation and embarrassment, and has suffered severe psychological and emotional injuries.
+Mermelstein & Horowitz, P. A.
+- 3 -
+3 of 7
+
+
+Case 9:09-cv-80802-KAM Document 1 Entered on FLSD Docket 05/28/2009 Page 4 of 7
+COUNT I
+Sexual Assault and Battery
+15.
+Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above.
+16.
+Epstein made an intentional, unlawful offer of offensive sexual contact toward Jane
+Doe, creating a reasonable fear of imminent peril and sexual assault.
+17.
+Epstein intentionally inflicted harmful or offensive sexual contact on the person of
+Jane Doe.
+18.
+Epstein tortiously committed a sexual assault and battery on Jane Doe. Epstein's acts
+were intentional, unlawful, offensive and harmful.
+19.
+Epstein's plan and scheme in which he committed such acts upon Jane Doe were done
+willfully and maliciously.
+20.
+As a direct and proximate result of Epstein's assault on Jane, she has suffered and will
+continue to suffer severe and permanent traumatic injuries, including mental, psychological and
+emotional damages and loss of enjoyment of life.
+WHEREFORE, Plaintiff Jane Doe No. 6 demands judgment against Defendant Jeffrey
+Epstein for compensatory damages, punitive damages, costs, and such other and further relief as this
+Court deems just and proper.
+21.
+22.
+23.
+of decency.
+COUNT II
+Intentional Infliction of Emotional Distress
+Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above.
+Epstein's conduct was intentional or reckless.
+Epstein's conduct with a minor was extreme and outrageous, going beyond all bounds
+MERMELSTEIN & HOROWITZ, P. A.
+- 4-
+4017
+
+
+•
+Case 9:09-cv-80802-KAM Document 1 Entered on FLSD Docket 05/28/2009 Page 5 of 7
+24.
+Epstein committed willful acts of child sexual abuse on Jane Doe. These acts resulted
+in mental or sexual injury that caused or were likely to cause Jane Doe's mental or emotional health
+to be significantly impaired.
+25.
+Epstein's conduct caused severe emotional distress to Jane Doe. Epstein knew or had
+reason to know that his intentional and outrageous conduct would cause emotional distress and
+damage to Jane Doe, or Epstein acted with reckless disregard of the high probability of causing
+severe emotional distress to Jane Doe.
+26.
+As a direct and proximate result of Epstein's intentional or reckless conduct, Jane Doe
+has suffered and will continue to suffer severe mental anguish and pain, psychological and emotional
+injuries and los of enjoyment of life..
+WHEREFORE, Plaintiff Jane Doe No. 6 demands judgment against Defendant Jeffrey
+Epstein for compensatory damages, costs, punitive damages, and such other and further relief as this
+Court deems just and proper.
+COUNT III
+Coercion and Enticement to Sexual Activity in Violation of 18 U.S.C. §2422
+27. Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above.
+28.
+Epstein used a facility or means of interstate commerce to knowingly persuade,
+induce or entice Jane Doe, when she was under the age of 18 years, to engage in prostitution or
+sexual activity for which any person can be charged with a criminal offense.
+29. On June 30, 2008, Epstein entered a plea of guilty to violations of Florida §§ 796.07
+and 796.03, in the 15th Judicial Circuit in and for Palm Beach County (Case nos. 2008-cf-
+009381AXXXMB and 2006-cf-009454AXXXMB), for conduct involving the same plan and
+scheme as alleged herein.
+MERMELSTEIN & HOROWITZ, P. A.
+- 5-
+5 of 7
+
+
+Case 9:09-cv-80802-KAM Document 1 Entered on FLSD Docket 05/28/2009 Page 6 of 7
+30.
+As to Plaintiff Jane Doe, Epstein could have been charged with criminal violations of
+Florida Statute §796.07(2) (including subsections (c), (d), (e), (f), (g), and (h) thereof), and other
+criminal offenses including violations of Florida Statutes §§798.02 and 800.04 (including
+subsections (5), (6) and (7) thereof).
+31.
+Epstein's acts and conduct are in violation of 18 U.S.C. §2422.
+32.
+As a result of Epstein's violation of 18 U.S.C. §2422, Plaintiff has suffered personal
+injury, including mental, psychological and emotional damages.
+33.
+Plaintiff hired Mermelstein & Horowitz, P.A. (f/k/a Herman & Mermelstein, P.A.), in
+this matter and agreed to pay them a reasonable attorneys' fee.
+WHEREFORE, Plaintiff Jane Doe No. 6 demands judgment against Defendant Jeffrey
+Epstein for all damages available under 18 U.S.C. §2255(a), including without limitation, actual and
+compensatory damages, costs of suit, and attorneys' fees, and such other and further relief as this
+Court deems just and proper.
+JURY TRIAL DEMAND
+Plaintiff demands a jury trial in this action on all claims so triable.
+Dated: May 27, 2009
+Respectfully submitted,
+By:
+i that
+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 Plaintiff
+18205 Biscayne Blvd., Suite 2218
+Miami, Florida 33160
+Tel: 305-931-2200
+Fax: 305-931-0877
+MERMELSTEIN & HOrOWITZ, P. A.
+- 6-
+6 of 7
+
+
+Case 9:09-cv-80802-KAM Docu@IVILICOVER SHEESD Docket 05/28/2009 Page 7 of 7
+The JS-44 civil cover sheet and the information contained herein neither replace nor supplement the filing, and service of pleading 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 the Court for the purpose of initiating the civil docket
+sheet. (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.)
+|(a) PLAINTIFFS
+JANE DOE NO. 8,
+(b) COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF
+DEFENDANTS
+JEFFREY EPSTEIN
+COUNTY OF RESIDENCE OF FIRST LISTED DEFENDANTNEW YORK
+(IN U.S. PLAINTIFF CASES ONLY)
+PALM BEACH COUNTY
+(EXCEPT IN U.S. PLAINTIFF CASES)
+(c) ATTORNEYS (FIRM NAME, ADDRESS, ANDTELEPHONE NUMBER)
+ATTORNEYS (IF KNOWN)
+Mermelstein & Horowitz, P.A., 18205 Biscayne Blvd., Suite 2218,
+Miami, FL 33160, (305) 931-2200
+(d) CIRCLE COUNTY WHERE ACTION AROSE: PALM BEACH
+9:09Cv 80802- KAm -LRJ
+II. BASIS OF JURISDICTION
+(PLACE AN X ONE BOX ONLY)
+• 1. U.S. Government
+X 3. Federal Question
+Plaintiff
+(U.S. Government Not a Party)
+• 2. U.S Government
+• 4. Diversity
+Defendant
+(Indicate Citizenship of Parties in Item
+III. CITIZENSHIP OF PRINCIPAL PARTIES
+(For Diversity Case Only)
+AND ONE FOR DEFENDANT
+DEF Incorporated of Principal Place of
+04 04
+Citizen of This State
+Business in This State
+Citizen of Another State
+02 x 2
+Incorporated and Principal Placeof 05
+Citizen or Subject of a Foreign Country • 3 • 3
+Business in Another State
+Foreign Nation
+06 06
+IV. CAUSE OF ACTION
+(CITE THE U.S. CIVIL STATUTE UNDER WHICH YQJ ARE FILING AND WRITE A BRIEF STATEMENT OF CAUSE
+DO NOT CITE JURISDICTIONAL STATUTES UNLESS DIVERSITY.)
+ACTION FOR COERCION AND ENTICEMENT TO SEXUAL ACTIVITY OF MINOR UNDER 18 U.S.C. §52422 AND 2255(a) AND SUPPLEMENTAL STATE
+LAW CLAIMS
+IVa. 5 days estimated (for both sides) to try entire case
+V. NATURE OF SUIT
+(PLACE AN X IN ONE BOX ONLY)
+A CONTRACT
+A TORTS
+110 insurance
+0000
+120M.
+Acl
+140 Negoliable Instrument
+150 Recovery of Overpayment
+Judgment
+• 151 Medicare Act
+D 152 Recovery of Deluted
+Student Loans (Excl
+Velerans) B
+• 153 Recovery of Overpayment
+of Veteran's Benefts B
+• 160 Sackholder's Suits
+• To Diner Gorad
+• 185 Contract Product Liability
+PERSONAL INJURY
+CI 310 Airplane
+• 362 Personal injury Med Maipractice
+C 315 Airplane Product Liability
+0365 Personal Injury-Product Liabilly
+© 320 Assaut, Libel & Slander
+C 330 Federal Employers' Liabilly
+injury Product Lintity
+© 340 Marine
+D 345 Marine Product Liabilty
+PERSONAL PROPERTY
+• 350 Motor Vehicie
+© 355 Motor Vehicle Product Labity C 370 Oihar Fraud
+X 360 Other Personal Injury
+© 371 Truth in Lending B
+© 360 Other Personnel
+Property Damage
+O 385 Property Damage
+Product Liabilly
+B FORFEITURE
+PENALTY
+• 610 Agricuffure
+© 625 Drug Related Seizure
+of Property 21 USC 801
+© 630 Liquor Laws
+• 840 R.R. & Truck
+© 050 Airline Rega
+• 060 Occupational
+Safety/Heath
+• 690 Other
+A BANKRUPTCY
+A OTHER STATUS
+• 422 Appeal 28 USC 158
+• 423 Windrawal 28 USC 157
+• 400
+Status Reappointment
+• 410 Antitrust
+• 430
+Banks and Banking
+• 450
+Commerca/iC Rates/eic. B
+400
+Deportation
+© 470 Rackeleer Influenced and
+A REAL PROPERTY
+A CIVIL RIGHTS
+B PRISONER PETITIONS
+A PROPERTY RIGHTS
+• 820 Copyrights
+• 840 Trademark
+B SOCIAL SECURITY
+O 351 HIA (1395M)
+8B2 Black Lung (R23)
+D863 DIWC/DIWW(405(gi)
+© 804 SSIO Tale XVI
+D 865 RSI (405(g0)
+• 210 Land Condemnalien
+220 Forecisure B
+00
+230 Rent Lease & Ejectment
+240 Torts to Land
+245 Tert Product Liabilty
+• 290 Al Other Reai Property
+• 442 Employment
+• 443 Housing/Accommodations
+• 444 Welfare
+• 440 Other Chi Rights
+• 510 Motions to Vacate Santence
+• 530 General*
+Seas Parats
+540 Mandamus & Other*
+*A or B
+A LABOR
+X 710 Fair Labor Standards
+• 720 Labor Managemest
+Relationa B
+• 730 Labor Management
+Reporting & Disciosure
+Act
+1740 Raiway Labor A
+i 780 Other Labor Litigati
+• 791 Employee Ret. Inc
+Securly Act B
+A FEDERAL TAX SUITS
+Securlies/ Commodies/
+Exchange
+O 875 Customer Chalenge
+12USC3410
+0 891
+Agnicultural Act
+D 892
+Economic Stabilization Al
+8800
+Environmental Matters
+Energy Alocation Act
+0 685
+Freedom af Information Act
+• 900
+Appeai of Fee Determinalion
+Under Equal Access to
+Justice
+• 950 Constlutionality of State
+Statutes
+• 880 Other Statutory Actions*
+* A or B
+Declaralory relef and state law claims
+for defamation
+VI. ORIGIN
+* 1. Original
+Proceeding
+VII. REQUESTED
+IN COMPLAINT
+• 2. Removed from • 3. Remanded from • 4. Refilled
+• 6. Multidistrict Litigation
+Appeal to District Judge from
+State Court
+Appellate Court
+• 5. Transferred from another district
+(Specify)
+Magistrate Judgment
+CHECK IF THIS IS A
+• CLASS ACTION DEMANDS
+��� UNDER F.R.C.P. 23
+Check YES only if demanded in X YES
+complaint
+JURY DEMAND:
+• NO
+/Ill. RELATEL
+CASE(S) IF AN'
+(See Instructions):
+(SEE ATTACHED)
+JANE DOE NO 2M JEFFREY EPSTEIN, CASE NO.: 08-CV-80232
+• JANE DOE NO EM JEFFREY EPSTEIN
+CASE NO: 08-CV-80381-MARRA
+JANE DOENIO EM JEFFREYEPSTEIN, CASE NO.:08-CV-80994-MARRA
+: JANE DOE NO. 7V.
+RETEN EAT, EASTEN CASE NO E COSET ANARA
+; C.M.A. v. CASE NO.: 08- CV-80811 -MARRA
+JANE DOE V. JEFFRE
+IFFEREYEPSTEIN, CASE NO.: 08-CV- 80469-MARRA/JOHNSON, JANE DO
+_; JANE DOE NO. 102 v. JEFFREY EPSTEIN, CASE NO.: 08- CV-80656-
+DATE
+5/27/09
+UNITED STATES DISTRICT COURT
+> REV:3194
+SIGNATURE OF ATTORNEY OF RECORD
+FOR OFFICE USE ONLY: Receipt No. 54h 345 Amou
+Mm/350K
+Date Paid:
+M/ifp

vision-fixhub/court-01/90b02cd96cd74e96de1124a0e316c49a1f4de0e183f83427f93eb1bda2900a55.receipt.json

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vision-fixhub/court-01/90c790cb0ef7031a3b756f71cd3168795d12de85a7d19708591e3f5c463a245c.md

@@ -0,0 +1,38 @@
+ca389.239V682484 2RKD8FF B8EUmERt 128
+Fined 34933121 Papage 91 dr 1
+HADDON
+MORGAN
+FOREMAN
+Haddon,
+and
+L, P.C
+Laura A. Menninger
+150 East 10th Avenue
+Denver, Colorado 8020:
+PH 303.831.7364 X 303.832.2628
+www.hmflaw.com
+Imenninger@hmflaw.com
+December 2, 2021
+VIA ECF
+The Honorable John G. Koeltl
+United States District Court
+Daniel
+Moynihan
+United States Courthouse
+500 Pearl Street
+New York, NY 10007-1312
+Re:
+Doe v. Indyke, et al., 1:20-cv-000484-JGK-DCF
+Dear Judge Koeltl:
+I write to withdraw Ms. Maxwell's November 22, 2021 letter request for permission
+to use the unredacted release in her defense in Case No. 20-cr-330-AJN. Due to
+regulep that this Court vacate procedis harence presenty so for 23 pare also
+December 6, 2021.
+Respectfully Submitted,
+Laura A. Menninger
+CC: Counsel of Record via ECF
+The couserence schooled
+der 12/6/211
+" Canceled.
+so ordeed.
+19/3/21 u.S.D.5.

vision-fixhub/court-01/90c790cb0ef7031a3b756f71cd3168795d12de85a7d19708591e3f5c463a245c.receipt.json

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vision-fixhub/court-01/90d96d1059399584427055001a2cbcb5977fc20fa207c566848456a33853f5e8.md

@@ -0,0 +1,26 @@
+Case 9:08-cv-80119-KAM Document 337-1 Entered on FLSD Docket 10/05/2009 Page 1 of 1
+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,
+ORDER
+Upon Plaintiffs' Jane Doe Nos. 2-7' Unopposed Motion for Enlargement of Time to
+Respond to Defendant's Motions to Compel Independent Medical Examination, and good cause
+being shown, it is hereby
+ORDERED that Plaintiffs' Motion is granted. Plaintiffs shall have an enlargement of
+time until October 13, 2009, to respond to the Defendant's Motions to Compel Independent
+Medical Examinations of Jane Does 2-7.
+DONE AND ORDERED in
+, in Ft. Lauderdale, Broward County, Florida, this
+day of
+_ 2009.
+DISTRICT COURT JUDGE
+1

vision-fixhub/court-01/90d96d1059399584427055001a2cbcb5977fc20fa207c566848456a33853f5e8.receipt.json

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vision-fixhub/court-01/90fd7ad02a127cd440c8f93b0bfb0df1ca201a186f70feb2f949425d1d961000.md

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+Case 9:08-cv-80380-KAM Document 32 Entered on FLSD Docket 07/21/2008 Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80380-MARRA/
+JANE DOE NO. 4,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+DECLARATION OF JEFFREY M. HERMAN REGARDING SERVICE
+OF PROCESS AND THIS COURT'S ORDER TO SHOW CAUSE
+Jeffrey M. Herman, deposes and states as follows:
+I am counsel for Plaintiff in this action. After the parties' briefed the issue of service
+of process on Defendant Jeffrey Epstein, this Court found valid service under New York law and
+entered an Order to Show Cause Why Default Should Not be Entered Against Defendant Jeffrey
+Epstein, dated July 16, 2008.
+I submit this Declaration to correct what appears to be a factual error in the Court's
+Order to Show Cause. I do so even though this error is in Plaintiff's favor.
+3.
+In the Order to Show Cause, this Court finds that "It]he process server also mailed a
+copy of the summons and complaint to Defendant on May 5, 2008, via first class mail. (DE 6)." It is
+my understanding that the Affidavit of Service (DE 6) crosses out language regarding mail to the
+Defendant, and that the process server in this case did not mail a copy of the Summons and
+Complaint to the Defendant's New York address. In none of the papers Plaintiff filed in this matter
+is it asserted that the Summons and Complaint was mailed, nor did Plaintiff claim that service was
+valid under New York law.
+
+
+Case 9:08-cv-80380-KAM Document 32 Entered on FLSD Docket 07/21/2008 Page 2 of 2
+CASE NO.: 08-CV-80380-MARRA/
+Under penalties of perjury, I declare the foregoing to be true and correct.
+Dated: July 21, 2008.
+s/ Jeffrey M. Herman
+Jeffrey M. Herman
+Herman & Mermelstein, P. A.
+2
+www.hermanlaw.com

vision-fixhub/court-01/90fd7ad02a127cd440c8f93b0bfb0df1ca201a186f70feb2f949425d1d961000.receipt.json

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vision-fixhub/court-01/9101cd599019dafbe2fd5cd56b53660cf736865b0790aede5a6e29cd27596cf3.md

@@ -0,0 +1,98 @@
+Case 9:08-cv-80119-KAM Document 487-2 Entered on FLSD Docket 03/12/2010 Page 1 of 3
+Dep
+IN THE CIRCUIT COURT OF THE 15™H
+JUDICIAL CIRCUIT IN AND FOR PALM
+BEACH COUNTY, FLORIDA
+Case No: 502008CA37319XXXX MB AB
+B.B.,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+PLAINTIFF'S NOTICE OF TAKING VIDEOTAPED DEPOSITION
+PLEASE TAKE NOTICE THAT THE UNDERSIGNED ATTORNEY WILL TAKE THE DEPOSITION OF:
+NAME:
+DATE AND TIME:
+LOCATION:
+Jean Lue Bruhel
+November 3, 2009
+Esquire Court Reporters
+10:00 AM
+515 N. Flagler Drive
+West Palm Beach, FL 33401
+upon an oral examination before a Notary Public or officer authorized by law to take depositions in
+the State of New York, The oral examination will continue from day to day until completed. The
+depositions are being taken for purposes of discovery, for use at trial or are being taken for such
+other purposes as are permitted under the Rules of the Court
+WE HEREBY CERTIFY that a true and correct copy of this Notice was mailed this
+day of October, 2009 to: Jack A. Goldberger, Esq., 250 Australian Avenue, Suite 1400, West Palm
+Beach, FL 334101; Bruce E. Reinhart, Esq., 250 Australian Avenue South, Suite 1400, West Palm
+Beach, FL. 33401; Robert D. Critton, Jr., Michael J. Pike, 515 North Flagler Drive, Suite 400, West
+Palm Beach, FL 33401.
+LEOPOLD-KUVIN, P.A.
+2925 PGA Boulevard, Suite 200
+Palm Beach Gardens, FL 33410
+(561) 513-1404
+(561) 515-140
+By:_
+Spencér//
+Kuvin, Esq.
+Florida Bar No: 089737
+CO. JE, DI
+
+
+Case 9:08-CV-80119-KAM Document 487-2 Entered on FLSD Docket 03/12/2010 Page 2 of 3
+Depo
+IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT
+IN AND FOR PALM BEACH COUNTY, FLORIDA
+CIVIL DIVISION
+L.M.,
+)
+Plaintiff,
+CASE NO.: 502008CA028051XXXXMB AD
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+)
+NOTICE OF TAKING DEPOSITION
+PLEASE TAKE NOTICE that the attorney for Defendant in the above-styled
+cause will take the deposition of Jean Luc Bruhnel on November 3, 2009 at 10:00
+a.m. for the purposes of discovery at the following location:
+Esquire Court Reporters
+515 N Flagler Dr
+West Palm Beach, FL 33401-4321
+Said deposition will be taken before Esquire Court Reporters, a Notary Public or
+any officer authorized to administer oaths by the laws of the State of Florida, and a
+person who is neither a relative, nor employee, nor attorney, nor counsel of any of the
+parties and who is neither a relative nor employee of such attorney or counsel, and who
+is not financially interested in the action.
+Said deposition will be taken pursuant to Florida Rules of Civil Procedure in such
+cases provided. Said oral examination will continue from hour to hour and from day to
+day until completed.
+D
+
+
+Case 9:08-cv-80119-KAM Document 487-2 Entered on FLSD Docket 03/12/2010 Page 3 of 3
+Case No. 502008CA028051XXXXMB AD
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that a true and correct copy of the foregoing has been served
+via U.S. Mail and Facsimile this ZCk day of October, 2009 to: Michael Burman, Esq., &
+Robert D. Critton, Jr., Esq., Burman, Critton, et al., 515 North Flagler Drive, Suite 400,
+West Palm Beach, FL 33401; Jay Howell, Esq., Jay Howell & Assoc., 644 Cesery
+Boulevard, Suite 250, Jacksonville, FL 32211; and Jack Alan Goldberger, Esq., Atterbury
+Goldberger et al., 250 Australian Ave. South, Suite 1400, West Palm Beach, FL 33401
+and a courtesy copy to Tama Kudman, Esq., 444 PGA Boulevard, Suite 600, West Palm
+Beach, Florida 33410.
+ROTHSTEIN ROSENFELDT ADLER
+Attorneys for Plaintiff
+401 East Las Olas Blvd., Suite 1650
+Fort Lauderdale, Florida 33394
+Telephone (954) 522-3456
+Telecopier (954) 527-8663
+By:
+ERR
+Florida Bar No. 542075
+bedwards@rra-law.com
+William J. Berger
+Florida Bar No. 197701
+wberger@rra-law.com

vision-fixhub/court-01/9101cd599019dafbe2fd5cd56b53660cf736865b0790aede5a6e29cd27596cf3.receipt.json

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vision-fixhub/court-01/910e5de81f8c2abb82a37b26663635670e9aeb763c25e81b439e3a697e20009a.md

@@ -0,0 +1,109 @@
+Filing # 110771414 E-Filed 07/24/2020 03:23:53 PM
+CA FLORIDA HOLDINGS, LLC,
+Publisher of THE PALM BEACH POST,
+Plaintiff,
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+DIVISION: AG
+V.
+DAVE ARONBERG, as State Attorney of
+Palm Beach County, Florida; SHARON R.
+BOCK, as Clerk and Comptroller of Palm
+Beach County, Florida,
+Defendants.
+COPY
+AMENDED REQUEST FOR PRODUCTION OF DOCUMENTS
+Plaintiff, CA FLORIDA HOLDINGS, LLC, Publisher of THE PALM BEACH POST, by
+and through their undersigned counsel, hereby requests that Defendant, SHARON R. BOCK, as
+Clerk and Comptroller of Palm Beach County, Florida, produce all materials requested herein at
+the offices of the undersigned counsel within thirty (30) days from the date hereof, or such shorter
+time as may be ordered by the Court, pursuant to Rule 1.350, Fla. R. Civ. P.
+DEFINITIONS AND INSTRUCTIONS
+"Epstein Grand Jury Materials" shall refer to all evidence, testimony, documents,
+transcripts, notes, bills and other items used in or presented to the grand jury in and for Palm Beach
+County, Florida in the prosecution of Jeffrey E. Epstein, date of birth January 20, 1953, Palm
+Beach Circuit Court Case No. 50-2006-CF-009454 AXX.
+2.
+"Clerk" shall refer to the Office of the Clerk and Comptroller of Palm Beach County,
+Florida established by the Fla. Constitution, Article V, Section 16.
+*** FILED: PALM BEACH COUNTY, FL SHARON R BOCK, CLERK. 07/24/2020 03:23:53 PM ***
+
+
+3.
+"State Attorney" shall refer to the Office of State Attorney for Palm Beach County, Florida
+established by Fla. Constitution, Article V, Section 17.
+DOCUMENTS REQUESTED
+Copies of all logs, notations, registers, lists and entries that show the delivery of Epstein
+Grand Jury Materials from the Clerk to the State Attorney. The specific materials delivered need
+not be disclosed or produced.
+Copies of all logs, notations, registers, lists and entries that show the return of Epstein
+With reum of pacin
+Grand Jury Materials by the State Attorney to the Clerk. The specific materials returned need not
+be disclosed or produced.
+3.
+Copies of all communications between the Clerk and the State Attorney concerning the
+storage, possession, delivery, receipt and control of Epstein Grand Jury Materials. The specific
+materials referenced need not be disclosed or produced.
+4.
+Copies of all logs, notations, registers, lists and entries that show the general types of
+Epstein Grand Jury Materials in the possession of the Clerk, without revealing their contents.
+Copies of all logs, notations, registers, lists and entries that show the delivery of Epstein
+Grand Jury Materials to the Federal Bureau of Investigation. The specific materials referenced need
+not be disclosed or produced.
+6.
+Copies of all logs, notations, registers, lists and entries that show the delivery of Epstein
+Grand Jury Materials to the United States Department of Justice and/or any Office of the United
+States Attorney. The specific materials referenced need not be disclosed or produced.
+2
+
+
+Copies of all subpoenas and any judicial process served upon the Clerk for production of
+Epstein Grand Jury Materials.
+8.
+Copies of all communications between the Clerk and the United States Department of
+Justice, or the Federal Bureau of Investigation or any Offices of the United States Attorney
+concerning Epstein Grand Jury Materials. The specific materials referenced need not be disclosed
+or produced.
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on this 24th day of July 2020, a copy of the foregoing has been
+electronically filed with the Florida E-File Portal for e-service on all parties of record herein.
+Respectfully submitted,
+NOT A
+GREENBERG TRAURIG, P.A.
+Altorneys for CA Florida Holdings, LLC,
+Publisher of The Palm Beach Post
+Stephen A. Mendelsohn, Esq.
+5100 Town Center Circle, Suite 400
+Boca Raton, Florida 33486
+Telephone: (561) 955-7629
+Facsimile: (561) 338-7099
+By: Is/ Stephen A. Mendelsohn
+STEPHEN A. MENDELSOHN
+Florida Bar No. 849324
+mendelsohns@gtlaw.com
+smithl@gtlaw.com
+FLService@gtlaw.com
+3
+
+
+By: Is/ Michael J Grygiel
+MICHAEL J GRYGIEL
+(Admitted Pro Hac Vice)
+54 State St., 6th Floor
+Albany, New York 12207
+Telephone: (518) 689-1400
+Facsimile: (518) 689-1499
+grygielm@gtlaw.com
+By: Is/ Nina D. Boyajian
+NINA D. BOYAJIAN
+(Admitted Pro Hac Vice)
+1840 Century Park East, Suite 1900
+Los Angeles California 90067
+Telephone: (310) 586-7700
+Facsimile: (310) 586-7800
+boyajiann@gtlaw.com
+riveraal@gtlaw.com
+ACTIVE 516467
+NOT A CERTIF
+4

vision-fixhub/court-01/910e5de81f8c2abb82a37b26663635670e9aeb763c25e81b439e3a697e20009a.receipt.json

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vision-fixhub/court-01/9124fea47bc8a523dfcbdda57ca493fe088fd4cb77ffdc9fd83c6920186394b4.md

@@ -0,0 +1,720 @@
+Case 9:08-cv-80994-KAM Document 24-3 Entered on FLSD Docket 04/02/2009 Page 1 of 14
+IN THE FIFTEENTH JUDICIAL CIRCUIT COURT
+IN AND FOR PALM BEACH COUNTY, FLORIDA
+CASE NO. 50 2008CA020614XXXXMB AF
+JANE DOE II,
+Plaintiff,
+COPY
+VS.
+JEFFREY EPSTEIN and
+Defendants.
+/
+COURT REPORTER'S TRANSCRIPT OF
+PROCEEDINGS HAD BEFORE
+THE HONORABLE DIANA
+DATE:
+PLACE:
+March 3, 2009
+Palm Beach County Courthouse
+205 N. Dixie Highway
+West
+Palm Beach, Florida 33401
+EXHIBI "C"
+
+
+Case 9:08-cv-80994-KAM Document 24-3 Entered on FLSD Docket 04/02/2009 Page 2 of 14
+2
+1
+2
+3
+4
+5
+6
+7
+B
+9
+10
+11
+12
+APPEARANCES:
+LAW FIRM, P.A.
+224 Datura Avenue
+Suite 900
+West Palm Beach, Florida 33401
+Counsel for Plaintiff
+BY:
+ISIDRO M.
+1, ESQUIRE
+BURMAN, CRITTON, LUTTIER & COLEMAN
+515 N. Flagler
+Drive
+Suite 400
+West Palm Beach, Florida 33401
+Counsel for Defendant
+BY: ROBERT D. CRITTON, JR.,
+ESQUIRE
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+...
+(561)
+835-0220
+
+
+Case 9:08-CV-80994-KAM Document 24-3 Entered on FLSD Docket 04/02/2009 Page 3 of 14
+11
+1
+2
+3
+4
+5
+6
+7
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+that but I'd just like to do that.
+THE COURT: Right. And if you want to
+contact the other individuals saying, you know,
+I'm the one that's questioning whether or not
+these need to be before one judge. You may have
+a different perspective than your colleagues who
+are prosecuting some of the cases.
+I understand the damages. I'm not
+saying consolidate. I'm saying transfer. It's
+not a consolidation issue. Everybody gets that
+confused for some reason. The words are very
+different out of my mouth, your mouth and how
+they're written.
+So let me go ahead and take a gander at
+this. I did read it last night. I'm not sure
+that we need to get -- we need names?
+MR. CRITTON: Right. Well, here's what some
+of the issues are is that, as an example -- if I
+could approach the bench.
+THE COURT: Sure.
+MR. CRITTON: This is some of the
+information that we've obtained through discovery
+from some of the -- from at least in this
+instance, it would be this particular Jane Doe.
+THE COURT: You know who Jane Doe is I take
+
+
+Case 9:08-cv-80994-KAM Document 24-3 Entered on FLSD Docket 04/02/2009 Page 4 of 14
+12
+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
+it?
+MR. CRITTON: Right.
+THE COURT: You know who the Jane Doe is?
+MR. CRITTON: Yes, correct. And so this
+particular lady has kept in part a diary and
+she -- which appears to have started some time --
+this is not in any way significant -- but some
+time after she learned that she could file a
+lawsuit. I think she's also been to Oakwood
+Center some time after she learned she could file
+a lawsuit and seek damages from Mr. Epstein.
+There's no history of this lady
+beforehand other than in some of the Oakwood
+records where she was Baker Acted, she started
+drinking beer at 16, she started Xanax at 16,
+started marijuana at 15, that she's sexually
+active.
+So how she has interacted -- she has a
+claim for emotional damages, mental pain and
+anguish, psychiatric-type damages. How she's
+interacted with friends, with family, the events
+in her life, school, work, her interpersonal
+relationships both with men and let's -- we'll
+use an example men here, but other individuals.
+She's saying that this event with Mr. Epstein,
+U.s. Legal Support
+
+
+Case 9:08-CV-80994-KAM Document 24-3 Entered on FLSD Docket 04/02/2009 Page 5 of 14
+13
+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
+this sexual assault and whatever occurred during
+these events is that -- has caused her damage.
+And therefore damages in the case such
+as the emotional, mental, psychiatric-type
+damages are completely subjective, I mean
+separate and apart from any medical bills that
+may be -- which are clearly intangible. So these
+are intangible damages. And the jury is
+instructed, you know, you advise the greater
+weight of the evidence, what's fair and
+reasonable under the circumstances.
+So what we would have is basically this
+young lady's testimony as to what she claims her
+damages are and what the circumstances are with
+her situation with Mr. Epstein. She claims on
+page 13, you know, I love this guy, I'm dating
+this guy Chris. On page 15 --
+THE COURT: Is this part of a diary for
+treatment?
+MR. CRITTON: I have no idea what it is. It
+was just produced in response to discovery. And
+she apparently started in, I think this is
+December of '08. You know I took Jay Lyntenis'
+girl to the zoo, had an amazing day, I love her,
+i.e., the girl.
+We have so much fun. I want a
+
+
+Case 9:08-cv-80994-KAM
+Document 24-3 Entered on FLSD Docket 04/02/2009 Page 6 of 14
+14
+1
+2
+3
+4
+5
+6
+7
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+baby especially with him. Okay. So I know who
+this person is. We are all so open together, I
+love him and Jay and
+, what do I do with
+Chris, who is another guy in her life.
+All right. This is circumstances where
+this young lady is saying, 1o0k, Jeffrey Epstein
+has ruined my life from a damage standpoint,
+okay. Let me depose other individuals with whom
+you've had a relationship. And what if it turns
+out - as with some of these girls did -- is they
+had relationships or had escapades or
+circumstances with individuals, older men similar
+to Mr. Epstein well before Mr. Epstein.
+And this girl, I don't know one way or
+the other, but let's assume she had a situation
+where she was assaulted or molested or raped, '
+that all is going to affect her emotional and her
+mental pain and anguish and it will all factor
+into evaluating damages.
+You know, it's not something that I'm
+going to spread around. I'm happy to keep it,
+you know, within the confines of the discovery of
+this case. But if she says every other
+relationship in my life has been perfect but Jeff
+Epstein has done this to me and it has affected
+
+
+Case 9:08-cV-80994-KAM Document 24-3 Entered on FLSD Docket 04/02/2009 Page 7 of 14
+15
+1
+2
+3
+4
+5
+6
+7
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+my ability to trust men and my sexual
+relationships with other men, which is part of
+her interpersonal relationships, okay, let's talk
+to MI
+THE COURT: When does your client allege
+that she had her first encounter with
+Mr. Epstein?
+MR:
+: At what age?
+THE COURT: Well, what year?
+MR. CRITTON: June of '03.
+MR.
+•: June of '03, Judge.
+'MR. CRITTON: She claims from June of '03
+through November of '04.
+MR.
+: She was I believe 16 at the
+beginning and ended at 17. She was a minor
+during all this time.
+THE COURT: June of '03 to now is six years.
+Let me hear from Mr.
+MR.
+: Judge, in the criminal case
+that was filed against Mr. Epstein, he would not
+have had a right to do this type of discovery and
+I -- if I could hand up --
+THE COURT: They wouldn't care about the
+women.
+MR.
+Right. Well, I mean --
+• U.S. Legal Support
+
+
+Case 9:08-cV-80994-KAM Document 24-3 Entered on FLSD Docket 04/02/2009 Page 8 of 14
+16
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
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+THE COURT: This is damages. There's no --
+they weren't seeking damages at the time.
+MR.
+•: Right. And we have not alleged
+in the complaint or in the answers to
+interrogatories that her ability to have a
+relationship with a man has been affected by
+Mr. Epstein's conduct.
+We have alleged that she has been
+hospitalized for depression, anxiety but we have
+not alleged any damages concerning -- the only
+reason this would be relevant is if we were
+making a claim at her ability to have either
+sexual relations or to have emotional relations
+with men was effected by her experience with
+Mr. Epstein.
+So this damages' claim is just a smoke
+screen to attempt to get evidence to show the
+jury that this woman has had other consensual
+relationships with young men that are
+approximately her age what I would characterize
+as a slut defense.
+She had it coming to her
+because she engaged in other voluntarily
+consensual --
+THE COURT: Mr. Critton wouldn't try the
+slut defense in my courtroom, I'm sure.
+
+
+Case 9:08-cV-80994-KAM Document 24-3 Entered on FLSD Docket 04/02/2009 Page 9 of 14
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+MR.
+: Maybe not, but certainly that's
+the way this discovery is going. And, Judge,
+what --
+THE COURT: What are the damages you think
+your client is seeking?
+MR.
+: She is seeking emotional
+distress
+damages for depression and anxiety and
+she has been hospitalized at the Oakwood Center.
+Her friend -- she was on the phone to a friend
+who called the sheriff's office because she
+thought she was suicidal. The sheriffs
+responded. They Baker Acted her that day and
+they took her eventually to the Oakwood Center.
+THE COURT: How do we know it's not
+intertwined with her rejection by three other men
+since Mr. Epstein?
+MR.
+: Well, even if it was related to
+her rejection by three other men -- you mean
+other men's rejection of her?
+THE COURT: Yeah. Well, how do you not know
+that? I mean you can't do it until you do
+discovery. Has anybody attempted to review the
+records from Oakwood to find out what's going on?
+MR. CRITTON: It's like a one-time visit
+when she was Baker Acted and then there's some
+
+
+Case 9:08-cv-80994-KAM Document 24-3 Entered on FLSD Docket 04/02/2009 Page 10 of 14
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+other --
+THE COURT: She didn't receive treatment?
+MR. CRITTON: She received treatment for
+that day and she's been back a couple of times.
+She's on medication. Again, I don't know what or
+the extent but she's got -- her medical bills are
+de minimis.
+Again as an example, Judge, did the
+Court have an opportunity to 1ook at the case
+that I also attached to the motion? Because
+there's a case that's almost on all fours with .
+this which I attached to our motion which is
+called Balles versus Russo.
+THE COURT: Right.
+MR. CRITTON: It was a case where the
+plaintiff was sued -- the plaintiff sued the
+former owners of a house of prostitution. So
+that part is different, but within it there were
+a number of claims including a sexual assault
+claim and they sought emotional pain, humiliation
+and emotional distress.
+Within the complaint that was filed in
+this particular case, she is seeking severe
+emotional distress, mental anguish, humiliation,
+embarrassment, past and future, compensatory
+v.s. Legal Support
+
+
+Case 9:08-cv-80994-KAM Document 24-3 Entered on FLSD Docket 04/02/2009 Page 11 of 14
+19
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+humiliation, loss of reputation, mental anguish,
+pain and suffering, the same type of damages.
+And what the Court said --
+THE COURT: How old is she now?
+MR.
+: She's 21 now.
+MR. CRITTON: She's 21 now. What the Court
+said is, you know, if you'd only brought this
+claim under 796 evidence of past issues, it's not
+an issue. You can't use this defense for
+anything, but because you brought these other
+claims which include, you know, sexual assault
+and you're seeking damages for other causes of
+action since the information sought by discovery
+may be relevant or may lead to the discovery of
+admissible evidence in one or more of the other
+causes of action or determination of damages, we
+cannot conclude the trial court parted from
+essential requirements of law in granting --
+THE COURT: So in other words, she's not
+only seeking -- she's seeking current emotional
+damage as a result of this relationship and
+you're trying to find out if she had prior
+relationships that perhaps could be intertwined
+with it so that it's not just Mr. Epstein's --
+MR. CRITTON: Right. A perfect example is
+
+
+Case 9:08-cv-80994-KAM Document 24-3 Entered on FLSD Docket 04/02/2009 Page 12 of 14
+20
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+one of the cases that I have is there's a young
+Lady who claims that she was molested in the past
+and raped, pretty significant issues, well in
+advance of her even meeting with Mr. Epstein.
+And they seem to play a large role in her
+psychiatric and psychological evaluation.
+We're going to come to the Court in
+this case as we have others and ask for a
+psychological evaluation of this lady, and if she
+was raped or if she was molested or just she had
+a bad experience or some -- whether it was a
+young or old man assaulted her in some fashion,
+that may play a role in her damages and what --
+THE COURT: What I'm going to allow for
+discovery purposes only not necessarily getting
+it in at the time trial are two years before her
+first encounter with Mr. Epstein and anything
+subsequent.
+MR.
+•: Judge, I just wanted to say on
+the record because I forgot to mention it,
+there's also -- I did state an objection to the
+identity of people that are unrepresented in this
+courtroom. They have rights too. So what I --
+THE COURT: Well, my suggestion is that you
+send those people a letter and tell them that
+
+
+Case 9:08-cv-80994-KAM Document 24-3 Entered on FLSD Docket 04/02/2009 Page 13 of 14
+21
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+you're going to disclose them and if they have a
+problem with it that they come to see me before
+you disclose it.
+So I'm going to give you 20 days to
+respond to this rather than the usual five and
+that will give you time to put these people on
+notice and if they want to come visit with me and
+have a John Doe, I'll have a John Doe hearing
+but, you know, this is her case. She's doing it.
+She's the one seeking damages, and he is entitled
+to be able to confront other individuals to find
+out information that may be relevant to the
+damages she's seeking or she can drop the
+damages. That's her choice. If you seek
+damages, you've got to do it - if you could put
+that in an order so that we have a time for him
+to do this.
+Just fill out an order, hand it back up
+to me and I'll deal with it.
+(The proceedings were concluded.)
+u.s. Legal Support
+
+
+• Case 9:08-CV-80994-KAM Document 24-3 Entered on FLSD Docket 04/02/2009 Page 14 of 14
+22
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+REPORTER'S CERTIFICATE
+THE STATE OF FLORIDA,
+COUNTY OF PALM BEACH.
+I, Teresa Bell, Court Reporter, certify that
+I was authorized to and did stenographically report
+the foregoing proceedings and that the transcript is a
+true and complete record of my stenographic notes.
+I further certify that the proceedings were
+taken at the time and place shown herein and that all
+counsel and persons as hereinabove shown were present.
+I further certify that I am not a relative,
+employee, attorney or counsel of any of the parties,
+nor am I a relative or employee of any of the parties'
+attorney or counsel connected with the action, nor am
+I financially interested in the action.
+Dated this 11th day lens Bolt.
+TERESA BELL,
+Court Reporter
+(561)
+835-0220

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+.Case 9:08-cv-80119-KAM Document 2 Entered on FLSD Docket 02/06/2008 Page 1 of 1
+AO (Rev. 10/93) Summons in a Civil Action
+United States District Court
+DISTRICT OF Florida
+SUMMONS
+Southern
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+TO: JEFFREY EPSTEIN, individually:
+9 East 71st Street
+New York, NY 10021
+CASE NO. 08-CV-80119-MARRA-|
+YOU ARE HEREBY SUMMONED and required to serve upon PLAINTIFF'S ATTORNEY,
+Jeffrey M. Herman, Esq.
+Stuart S. Mermelstein, Esq.
+Herman & Mermelstein, P.A.
+18205 Biscayne Boulevard, Suite 2218
+Miami, Florida 33160
+(305) 931-2200
+an answer to the complaint which is herewith served upon you, within 20 days after service of this summons upon you,
+exclusive of the day of service. If you fail to do so, judgment by default will be taken against you for the relief demanded in the
+complaint. You must also file your answer with the Clerk of this Court within a reasonable period of time after service.
+February 6, 2008
+SUMMONS-
+DATE
+Clarence Maddox
+Clerk of Court
+s/ Vernice
+Deputy Clerk
+U.S. District Courts
+-

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vision-fixhub/court-01/916221a5bd48a62a965f0c61536d2d6bf10d7a948cc5cd7574c97020378a4182.md

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+Case 9:08-cv-80119-KAM Document 328-3 Entered on FLSD Docket 09/25/2009 Page 1 of 6
+can you take me?" And my stepfather stayed home that day. So he's like, "No, you can't
+take.her. She needs.to.walk to work.". And I was like, "Well, this is only like my second
+day. And you know, mom said she was going to take me to work by car. So I had been,
+like, getting ready and not, you know, I didn't leave, you know, so many hours prior to
+be at work 'cause I didn't have to walk there. And he's like, "No. That's your problem.
+You're going to end up walking there. So if you're late that's your fault. That's not our
+problem at all." So I got upset, and I was like, whatever. So I ended up walking to work.
+And of course I was late, 'cause I had to walk two miles. And um, I got fired because it
+was my like second, third day of work. And uh, they just said—you know, I explained to
+them exactly what had happened, that I didn't have transportation, and what I just told
+you. And um, basically, I lost my job. So he got upset that I had no responsibilities and
+ended up saying that, you know, "You need to be kicked out." Which I thought was very
+absurd and stupid, but those are his rules. He's very strict. Like, he has a certain
+standard.
+07:00
+Okay. Now, you also liked to be out a lot. Was he upset about you being out a lot?
+Um, yes. He got upset about that also. But when I went out, it wasn't like I went out and
+partied. I just wanted to be with my friends. 'Cause like I said also, when I was with my
+friends, I put them so much as like my family, that I grew so close to them, that when
+I'm with my friends, like my close friends, I feel just comfortable and stressful—-like,
+stress-relieved, I guess. Like all my stress is gone. And comfortable.
+07:36
+Dr: Kliman: Now again. Following up things that you listed in various questionnaires. You
+mentioned one time you caught your mother and stepfather having sex. And that seemed
+to be your first knowledge, or first understanding of sex. Could you explain to me what
+that reference is?
+08:08
+Yeah, well I, I've you know, I mean, don't get me wrong. I've heard of, you know, about
+sex when I was younger from people. But I was never, you know, knowledged of what is
+was exactly. And I caught——do you want me to give you the exact scenario of what
+happened?
+Well, sure.
+Um, my stepfather grounded me and put me in my room at one of their friend's houses,
+like, "Stay here. Don't go anywhere." And I was like, "Okay." So I had to use the
+restroom, you know, at some point when I was sitting in the room. So I want
+This was at a friend's house?
+08:38
+Not my friend. Like their friend's. They were watching their house or whatever they
+GPEEENDANTS
+
+3
+
+
+Case 9:08-cv-80119-KAM Document 328-3 Entered on FLSD Docket 09/25/2009 Page 2 of 6
+were doing.
+I see.
+Yeah. They were house-sitting. And you know, I had to use the restroom. So I wanted to
+ask him before, "Can I use the restroom?" 'cause he'd said, "Don't go anywhere." So I
+walked in the pool room, where they play pool. And she was on the table with her legs
+open, with no clothes on. And he was on his knees. And it just like really grossed me
+out. Extremely, ugh, just grossed me out. And um, you know, of course, they were
+embarrassed. But she, you know, bought me like a little video for a kids. Like, a cartoon
+video that explained sex. And what guys and girls have and, stuff like that.
+09:31
+So was this oral sex they were having?
+I didn't see them in the act. But you know, she was on the table butt naked. And he was
+on his knees. So basically it was going to become oral sex I guess.
+So you didn't see very much of what he was doing?
+приство
+No.
+But you figured it out at some point.
+
+Yeah.
+Did you immediately understand?
+PS, Pretty much. They tried to lie to me at first. And say that you know, he was checking her
+down there 'cause she had a bump or something. Like, uh, cancer or whatever. And I
+was just like, I'm not stupid. You know, I'm not that unaware of sex. Like, I know about
+it. I know what happens.
+10:16
+So they made some effort then to educate you through a film?
+Yes.
+Now, were you very upset by seeing this event?
+I was. Yes.
+Di. Kliman:
+Tell me about your upset.
+(beep I just felt like, very like, I don't know what it was, but I was very jealous of like, my
+mom. Not like jealous of her, but like, I didn't like other guys talking to her or touching
+her. Like, it really made me like, angry inside. Like very angry. Like when they would
+hold hands and stuff, it made me like, get really like—
+4
+
+
+Case 9:08-cv-80119-KAM Document 328-3 Entered on FLSD Docket 09/25/2009 Page 3 of 6
+• - Even if your stepfather held her hand?
+Yes.
+10:53
+Did you become more jealous after that? Or were you already jealous?
+A I was jealous before that of like, the holding hands. And I didn't want them to benaked.
+- together: 1 didn't want them to see each other naked. I have no idea why I was like that.
+But I was. I didn't like guys trying to flirt with her: I was very overprotective of her, I
+guess. And when I saw that, it just like, like, really grossed me out.
+Dr. Kliman: Was he naked at that time?
+Dr. Kliman: Had you seen him naked at times?
+Mistler No.
+So you've never walked in on him and found him in the shower,
+Befall No.
+Or anything like that. You mentioned that your mother suffers from depression and
+stress.
+get Yes. to thad a rely bad chilhood. When she was growing up, um, do you want me to
+Sure.
+11:48
+Matay Baically her mother, my grandmed Dick And ok of with Did and ye at the fins.
+And basically found this guy named Dick. And took off with Dick and left all the kids
+with my mom's father. So there was four babies, like four kids, with my mom's dad. My
+mom's dad was very lenient, and didn't really care about school, didn't give them any
+discipline, and didn't care what they did. He had, you know, one of the type of parents
+that, "Do whatever you want, I don't care." There was no guidelines. And then my mom
+caught him with another guy. And her older sisters...she's not a twin, but she has a set of
+twin sisters that are probably like five years older than her. And they used to like, stick
+her in closets and spray Windex in her eyes, and hit her over the head with the phone,
+and abuse her, basically. And they've gotten her raped at school. She also got molested
+by her uncle. And now she's around forty-three to forty-four. I'm really bad with
+remembering ages. And she has, including me, she has four kids. But I'm never there,
+because you know, I have my own life. So right now she has three kids. And she also
+has a one-year-old like I do. And she has a four-year-old and a nine-year-old. So she
+5
+
+
+Case 9:08-CV-80119-KAM Document 328-3 Entered on FLSD Docket 09/25/2009 Page 4 of 6
+just, she stresses out about little stuff and is very like, for instance, I was there yesterday.
+And my little brother dropped a bowl of cereal all over the floor. And I was like, "'Mom,.
+calm down." 'Cause she just
+Gets agitated.
+13:28
+Very.
+Let me go back to these abuse experiences that your mother had, if I understand them.
+First, she was abandoned by—
+By her mom.
+Dr. Kliman: By her mom. Do you think it was a total abandonment?
+All From what my mom says, it was. And then my grandmother of course always defends
+Okay. But then your mom caught your grandfather, that her father.
+Ragply Hereal father.
+With another guy.
+(взятков, Yos.
+Dr. Kliman: And how did she catch him?
+NA She said she went down to the basement and another guy was with him.
+Well, were they having sex?
+Dr. Kliman: And what did she see?
+14:09
+All, She said she say everything. Like him, I think he, I don't know who was on who, but a
+guy and a guy. And she just freaked out, 'cause she never even knew about stuff like that,
+you know.
+How old was she?
+She said she was young. I cannot give you a specific age 'cause I have no idea. Um, she
+was probably anywhere from around eight to fifteen years of age, I have no idea.
+Honestly, I don't know. But I know she was young.
+6
+
+
+Case 9:08-cv-80119-KAM Document 328-3 Entered on FLSD Docket 09/25/2009 Page 5 of 6
+Dr. Kliman: Okay. You mentioned also, I think you mentioned, that she was raped in school.
+Yeah, her sisters—-something about her sisters paid this guy to try to rape her in a closet
+at school. Um, I don't know how far it went. She didn't get into it with me. If it got far or
+not. But I know that her sisters paid a guy to rape her in a closet at school. She's actually
+been raped three times.
+15:10
+During her childhood, or?
+Twice during her childhood and once as like an adult, on a date.
+How old do you think she was when closet effort at raping her occurred?
+She was either in the beginning of high school or the end of middle school. I'm not a
+hundred percent sure. She never gave me really facts. She said she was young.
+And did the rape actually occur? That her sisters paid a guy to do?
+Um, I don't know exactly if it did. She didn't get into that. I'm not sure.
+But you do think she's been raped three times, according to what she's told you?
+Yes. She got raped by her uncle. And then a rape, like a roofie. They slipped something
+in her drink when she was an adult. And then the closet thing. But I don't know if that
+necessarily went through. But I know her uncle and the other one. I know the whole
+stories.
+16:17
+Which uncle is that?
+I've never met him in my entire life. Um,
+I'm glad.
+(lita, Um, yeah, It makes me sick But one, ques he lives in New York. Um, I think it's
+my mom's dad's side of the family somehow.
+So that would be your mom's dad's brother, probably?
+воззводу
+Probably, but I don't think it's that close. I don't know how
+Okay.
+Al I don't know if they just call him "uncle", but 1 now that he's a part of the family. He's
+like a cousin. A second cousin or something, I don't know.
+So he could be a cousin?
+7
+
+
+Case 9:08-cv-80119-KAM Document 328-3 Entered on FLSD Docket 09/25/2009 Page 6 of 6
+• Yeah, but he's definitely, he was definitely older than her.
+And how old was she?
+17:05
+Mila She was young. She was like, she said she was around like five to seven years old I
+think. She was really young. And you know, he was like married I think, with kids. Or
+he had like a family, and he uh, was like, was touching her.
+How about her sisters? Did they get touched also?
+Rafabag She's never told me that. No.
+Dr. Kliman: Has she told you that he raped her? Or that he touched her? Or both?
+Um, I don't think that he used his penis. But he used his fingers on her.
+Dr. Kliman: And then she was raped once on a date?
+18:08
+Yeah, I don't know the exact age or time. But I know she was older. And she went on a
+date with this guy. And he basically slipped something in her drink. And she said she
+was conscious of what was going on, but she couldn't like scream or move. And him and
+his friend took her back to a place and raped her.
+So two guys raped her?
+Yes.
+When did your mother tell you the first of anything about this at first. Let me put it
+better because I didn't ask it well. What was the first thing you learned about your
+mother's misfortunes of being sexually abused?
+18:49
+предка
+• Like how old was I?
+Yeah. How old were you is a good way to put it.
+Um. I was probably in my young teens. She told me I think.
+Was it before Mr. Epstein or after Mr. Epstein?
+Before.
+And what did she first tell you?
+8

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vision-fixhub/court-01/91944ad47fc3235bc80d0193e5d57f15ccb8528ed5f499aeca83eaa770d6dd9f.md

@@ -0,0 +1,49 @@
+Case 9:08-cv-80119-KAM Document 303-5
+Case 9:08-cv-80119-KAM Document 291-5
+-
+Entered on FLSD Docket 09/16/2009 Page 1 of 1
+Entered on FLSD Docket 09/08/2009 Page 1 of 1
+IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT,
+IN AND FOR PALM BEACH COUNTY, FLORIDA
+Case No: 502004DR01223SXXXXMB
+Division: FB
+MEMO OF DISPOSITION
+-VS-
+Petitioner
+VS
+[v] Present w/Ceunsel:.
+I J Not Present
+[ ] Called/contacted clerk
+PRESTON SCOTT VINYARD
+Respondent,
+[V) Present w/Ceunsel.
+1] Not Present
+I ] Called/contacted clerk
+Type of Heating: dema Judgement f
+Date of hearing: 10-6-0
+Heard by Judge:
+Kath
+Service:
+[V Executed by:_
+PBSO
+| ] Unexecuted by:
+Court Extends Injunction For/Till
+Court Appoints:
+_ returo on 933-04
+10-1-05
+[ ] Guardian Ad Litem
+[ ] BIP
+1] Other
+Case Disposition
+[ ] DA - Dismissed After hearing
+Case Reopened:
+[] Yes
+] DA - Dismissed Before hearin
+}DJ - Disposed by Judg
+Petitioner's New Address
+Respondent's New Address:
+Sherrle Norton
+Deputy Clerk
+memodisp.frm
+
+"E"

vision-fixhub/court-01/91944ad47fc3235bc80d0193e5d57f15ccb8528ed5f499aeca83eaa770d6dd9f.receipt.json

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