MEMY-1805 harvest: vision-fixhub (part 11)

vision-fixhub/court-01/d9cb822212f3da16707a3693beec4ee05dc1b2ef8eef1ddae3b3fd29bd19e69f.md

@@ -0,0 +1,50 @@
+Case 9:09-cv-80469-KAM Document 81 Entered on FLSD Docket 07/02/2010 Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+JANE DOE I|
+Plaintiff,
+CASE NO.: 09-80469-CIV-MARRA
+VS.
+JEFFREY EPSTEIN
+and
+Defendants.
+/
+PLAINTIFF'S COUNSEL'S RESPONSE TO COURT'S ORDER TO SHOW CAUSE
+Plaintiff's counsel responds to the Court's Order to Show Cause, and states:
+Plaintiff's counsel apologizes to the Court for a failure to finalize a Joint
+Scheduling Conference Report and Order and to file same with the Court in accordance
+with the Court's Order.
+The parties did exchange a number of drafts of the Joint Scheduling Report
+and proposed Order but despite efforts to finalize it did not do so. There was some delay
+in effecting service on Defendant
+who is believed to have been avoiding
+service, and this accounts for part of the delay in filing the Report and Proposed Order,
+although it certainly does not excuse it.
+The parties have been involved in settlement discussions for some time, and
+reached a resolution of the claims in this and the State court companion case this week,
+and all claims have been resolved. Defendant has filed a Joint Stipulation and proposed
+Order indicating the resolution of this case.
+
+
+Case 9:09-cv-80469-KAM Document 81 Entered on FLSD Docket 07/02/2010 Page 2 of 2
+Respectfully submitted,
+BY: s/ Isidro M.
+ISIDRO M.
+Florida Bar No. 437883
+LAW FIRM, P.A.
+224 Datura Street, Suite 900
+West Palm Beach, FL 33401
+Telephone: (561) 832-7732
+Telecopier: (561) 832-7137
+e-mail: isidrogarcia@bellsouth.net
+CERTIFICATE OF SERVICE
+¡ HEREBY CERTIFY that a true and correct copy of the foregoing was furnished VIA
+ECM TRANSMISSION to: Robert D. Critton, Esq. and Michael Pike, Esq., BURMAN
+CRITTON LUTTIER & COLEMAN, Counsel for Defendant EPSTEIN, 515 N. Drive, Suite
+400, West Palm Beach, Florida 33401 and to Bruce Reinhart, Esq., BRUCE REINHART,
+P.A., Counsel for Defendant
+_. 250 S. Australian Avenue, Suite 1400, West Palm
+Beach, Florida 33401 this 2nd day of July. 2010.
+BY:s/ Isidro M.
+ISIDRO M.
+2

vision-fixhub/court-01/d9cb822212f3da16707a3693beec4ee05dc1b2ef8eef1ddae3b3fd29bd19e69f.receipt.json

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+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "d9cb822212f3da16707a3693beec4ee05dc1b2ef8eef1ddae3b3fd29bd19e69f",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "fa206f08ab591dadf9ed5246fb76705bed6ac113d2d7f7cc56e7346aa697c2d0",
+  "output_sha256": "e18565350f1869573333f33ed21bbfce4e51c6b24ce28ee0a8152f8dad6c5c2a",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}

vision-fixhub/court-01/d9cf963ec5a9b3326d8145d4ce8be22892837e950ffd0d83a4826f578fa28130.md

@@ -0,0 +1,151 @@
+503$818088-CV-80419aK Memesument 469-1 Entered on FLSD Docket 02/17/2010 Page 1 of 4
+AO 88A (Rev. 01/09) Subpoena to Testify at a Deposition or to Produce Documests in a Civil Action
+UNITED STATES DISTRICT COURT
+for the
+Southern District of Florida
+Jane Doe No. 2
+Plaintiff
+V.
+Civil Action No. 08-CV-80119-MARRA/JOHNSO
+Jeffrey Epstein
+Defendant
+(If the action is pending in another district, state where:
+R TO PRODUCE DOCUMENTS IN A CIV
+To: Alfredo Rodriguez
+11349 SW 86 Lane, Miami, FL
+c, and plade set f07 / 25/08 5:24pm
+below to testify at a
+eposition to be taken in this civil action. If you are an organization that is not a party in this case, you must designang
+ne or more officers, directors, or managing agents, or designate other persons who consent to testify on your behalf /
+about the following matters, or those set forth in an attachment:
+Place: Kress Court Reporting
+1031 Ives Dairy Road, Suite 228, Bldg. 4
+North Miami, EL 33179.
+Date and Time:
+07/29/2009 11:00 am
+The deposition will be recorded by this method: Court Reporter and Videographer
+• Production: You, or your representatives, must also bring with you to the deposition the following documents,
+electronically stored information, or objects, and permit their inspection, copying, testing, or sampling of the
+material:
+Any and all journals, notes, diaries, writings or other documents referring or relating to Jeffrey Epstein or events or
+incidents occurring at his residence located at 358 El Brillo Way, Palm Beach, Florida, including without limitation, the
+joumal you described to Palm Beach Police that contains names of girls who visited the residence.
+he provisions of Fed. R. Civ. P. 45(c), relating to your protection as a person subject to a subpoena, and Ru
+i (d) and (e), relating to your duty to respond to this subpoena and the potential consequences of not doing so, a
+attached.
+Date:
+07/24/2009
+CLERK OF COURT
+OR
+Signature of Clerk or Deputy Clerk
+The name, address, e-mail, and telephone number of the attorney representing (name of party)
+Mermelstein & Horowitz, P.A. - Adam D. Horowitz, Esq.
+18205 Biscayne Blvd., Suite 2218, Miami, FL 33160
+Tel: 305-931-2200 - email: ahorowitz@sexabuseattorney.com
+forney's signatu
+Jane Doe No. 2
+., who issues or requests this subpoena, are:
+
+A
+
+
+505258928008-CV-8QHerhantaAMhels@Aqument 469-1 Entered on FLSD Dpck 02/17/281209 Page 2 9f4
+AO 88A (Rev. 01/09) Subpoena to Testify at a Deposition or to Produce Documents in a Civil Action (Page 2)
+Civil Action No. 08-CV-80119-MARRA/JOHNSO
+PROOF OF SERVICE
+(This section should not be filed with the court unless required by Fed. R. Cir. P. 45.)
+This subpoena for (name of individual and title, if any)
+was received by me on (dare)
+• 1 personally served the subpoena on the individual at (place)
+on (date)
+; or
+• I left the subpoena at the individual's residence or usual place of abode with (name)
+, a person of suitable age and discretion who resides there,
+on (dale)
+, and mailed a copy to the individual's last known address; or
+• I served the subpoena on (name of individual)
+, who is
+designated by law to accept service of process on behalf of (name of organization)
+on (date)
+; or
+• I returned the subpoena unexecuted because
+• Other (specify):
+_;or
+Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also
+tendered to the witness fees for one day's attendance, and the mileage allowed by law, in the amount of
+$
+My fees are S
+for travel and S
+for services, for a total of $
+I declare under penalty of perjury that this information is true.
+0.00
+Date:
+Server's signature
+Prinied name and title
+Server's address
+Additional information regarding attempted service, etc:
+
+
+508.3e12108-CV-80HekfanKsAM/melDacument 469-1
+Entered on FLSD Dacked 0.7!1742-07-9o0gPage 3 2f,4
+MERMELSTEIN & HOROWITZ PA
+ATTORNEYS AT LAW
+stuart S. Mermelstel
+Tel 305.931.2200
+Fax 305.931.0871
+ssm@sexabuseattorney.com
+18205 Biscayne Bivo
+Suite 221€
+Miami, Florida 33160
+www.sexabuseattorney.com
+July 24, 2009
+Via Process Server
+Alfredo Rodriguez
+11349 SW 86th Lane
+Miami, FL 33173
+Re: Jane Does v. Jeffrey Epstein
+Dear Mr. Rodriguez:
+As you are aware, your deposition has been rescheduled to July 29, 2009 at 11:00 a.m. dueto
+your car problems on the previously scheduled date of July 23, 2009. We will provide car service to
+ransport you to and from the deposition. The car will pick you up at 9:45 a.m. on Wednesday,
+July 29, 2009. Please review the witness and document subpoena you are being provided by the
+process server.
+Thank you for your attention to this matter.
+Very truly yours,
+Stuart S. Mermelstein
+SSM/Ir
+
+
+Case 9:08-cv-80119-KAM Document 469-1 Entered on FLSD Docket 02/17/2010 Page 4 of 4
+RETURN OF SERVICE
+UNITED STATES DISTRICT COURT
+MIAMI-DADE District of Florida
+Case Number: 08-CV-80119-MARRA/JOHNSO
+Plaintiff:
+JANE DOE NO. 2
+VS.
+Defendant:
+JEFFREY EPSTEIN
+For.
+Adam D Horowitz
+MERMELSTEIN & HOROWITZ P.A
+18205 Biscayne Bolevard
+Suite 2218
+Miami, FL 33160
+Received by MIAMI-DADE PROCESS, INC. on the 24th day of July, 2009 at 4:00 pm to be served on ALFREDO
+RODRIGUEZ, 11349 SW 86 LANE, MIAMI, FL
+I, RAFAEL (BUDA)
+do hereby affirm that on the 25th day of July, 2009 at 5:24 pm, I:
+Individually Served the within named person with a true copy of this SUBPEONA TO TESTIFY AT DEPOSITION
+OR TO PRODUCE DOCUMENTS IN A CIVIL ACTION with the date and hour endorsed thereon by me, pursuant
+to State Statutes.
+I certify that I am over the age of 18, have no interest in the above action, and am a Process Server, in good
+standing, in the judicial circuit in which the process was served and have proper authority in the jurisdiction in which
+this service was made.. Under penalties of perjury, I declare that I have read the foregoing document and that the
+facts stated in it are true F.S. 92.525 Verification of documents.
+MIAMI-DADE PROCESS, INC.
+247 S.W. 8 Street # 293
+Miami, FL 33130-3513
+(786) 486-2832
+Our Job Serial Number: 2009001154
+Copyright © 1992-2006 Database Services, Inc. - Process Server's Toolbox VE.2w

vision-fixhub/court-01/d9cf963ec5a9b3326d8145d4ce8be22892837e950ffd0d83a4826f578fa28130.receipt.json

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+{
+  "byte_delta": -55,
+  "dataset": "marble-joined",
+  "doc_id": "d9cf963ec5a9b3326d8145d4ce8be22892837e950ffd0d83a4826f578fa28130",
+  "engine": "marble-apple-vision",
+  "event_count": 5,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]",
+  "idempotent": true,
+  "input_sha256": "19d0b789cc9c0774e46636ea760b3c283d35f79b3ac8156e869d587b23f1d476",
+  "output_sha256": "115385966dcd2707386a39d5a21dcd9ffa8743abe522263e521137465231deeb",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}

vision-fixhub/court-01/d9cfb773ab43486e65074e9a3b0db52f8780c2bc34ff16c777c941a63a0885cd.md

@@ -0,0 +1,23 @@
+Case 9:08-cv-80736-KAM Document 258 Entered on FLSD Docket 09/22/2014 Page 1 of 1
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+NO. 08-80736-CIV-MARRA
+JANE DOE #1 and JANE DOE #2,
+Plaintiffs,
+VS.
+UNITED STATES OF AMERICA,
+Defendant.
+SEP 22 2014
+STEVEN M. LARIMORE
+CLERK U. S. DIST. CT.
+S. D. of FLA. - W.P.B..
+ORDER
+THIS CAUSE is before the Court upon Petitioners' Motion to Seal their Response in
+Opposition to Epstein's Motion for a Protective Confidentiality Order (DE 250).
+It is hereby ORDERED and ADJUDGED that the Motion to Seal (DE 250) is DENIED.
+The Clerk of Court shall unseal DE 251. This Order shall not be sealed.
+DONE AND ORDERED in
+sat West Palm Beach, Palm Beach County, Florida,
+this 21" day of September, 2014.
+KENNETH A. MARRA
+United States District Court

vision-fixhub/court-01/d9cfb773ab43486e65074e9a3b0db52f8780c2bc34ff16c777c941a63a0885cd.receipt.json

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+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "d9cfb773ab43486e65074e9a3b0db52f8780c2bc34ff16c777c941a63a0885cd",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "35cb4e3550bd8577a65b50b30044f171604116ee10d4ab59eadd307df0a031f3",
+  "output_sha256": "f78562d61ff00d934c9bf8433a2f490bb2050255c0babd1999c03449bc788f40",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}

vision-fixhub/court-01/d9f8d9fb8e6bf9b3a3e2a554d18facbaa224b6e4aad7032eadd0b448bfc88587.md

@@ -0,0 +1,89 @@
+Case 9:08-cv-80119-KAM Document 63-1 Entered on FLSD Docket 03/25/2009 Page 1 of 3
+•.
+•.
+AFFIDAVIT OF JACK A. GOLDBERGER, ESQUIRE
+STATE OF FLORIDA
+COUNTY OF PALM BEACH
+) SS
+)
+BEFORE ME, the undersigned authority, personally appeared
+having personal knowledge and being duly sworn, deposes and says:
+I, Jack A. Goldberger, have personal knowledge of the matters set
+forth herein. I am an attorney licensed to practice in the State of Florida since
+1978. I am a partner with the law firm of Atterbury Goldberger & Weiss, P.A.,
+located at One Clearlake Centre, Suite 1400, 250 Australian Avenue South, West
+Palm Beach, FL 33401.
+2.
+My practice includes and specializes in the defense of criminal
+matters. I am board certified in criminal law. I have been and currently am the
+criminal defense attorney for JEFFREY EPSTEIN.
+3.
+I represented Mr. EPSTEIN in the negotiation of and entering into a
+Non-Prosecution Agreement with the United States Attorney's Office (USAO) for
+the Federal Southern District of Florida. The terms and conditions of the Non-
+Prosecution Agreement also entailed the entering of a Plea Agreement with the
+State Attorney's Office, Palm Beach County, State of Florida. (The Non-
+Prosecution Agreement shall hereinafter be referred to as the "NPA").
+By its terms, the NPA took effect on June 30, 2008. Also, pursuant
+to the terms of the NPA, any criminal prosecution against EPSTEIN is deferred
+as long as the terms and conditions of the NPA are fulfilled by EPSTEIN.
+
+
+
+Case 9:08-cv-80119-KAM Document 63-1 Entered on FLSD Docket 03/25/2009 Page 2 of 3
+5.
+The criminal matters against EPSTEIN remain ongoing until the
+NPA expires by its terms in late 2010, and as long as the USAO determines
+EPSTEIN has complied with those terms and conditions. The threat of criminal
+prosecution against EPSTEIN by USAO in the Southern District of Florida
+continues presently and through late 2010.
+6.
+Pursuant to the terms of the NPA, the USAO possesses the right to
+declare that the agreement has been breached, give EPSTEIN's counsel notice,
+and attempt to move forward with a prosecution. As of the date of this Affidavit,
+the USAO has taken the position on a number of occasions that it might consider
+the following actions by EPSTEIN to be a breach of the NPA.
+• Investigation by EPSTEIN (by and through his attorneys) of this Plaintiff
+and the other Plaintiffs in other pending civil cases for purposes of
+defending the civil actions;
+• EPSTEIN's contesting damages in this action and other civil actions.
+• EPSTEIN or his legal representatives making statements to the press
+about this Plaintiff or the other Plaintiffs.
+• Using the word "jail" instead of "imprisonment" in the plea agreement with
+the Palm Beach County State Attorney's Office.
+7.
+EPSTEIN, through counsel, submitted a Freedom of Information
+Act request to the Federal Bureau of Investigation (FBI) for documents relating to
+this and the other cases; the FBI denied the request stating the materials are at
+this time exempt from disclosure because they are in an investigative file, i.e. the
+matter is still an ongoing criminal investigation.
+Page - 2 -
+
+
+Case 9:08-cv-80119-KAM Document 63-1 Entered on FLSD Docket 03/25/2009 Page 3 of 3
+The NPA expires in late 2010.
+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 oaths
+acknowledgments, personally
+appeared
+Jack A. Goldberger, Esquire, 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 ! relied upon the following form of identification of the
+above named person: Awon Personally
+_, and that an oath was/was
+not taken.
+this 4 day or han an fal 20 he county and Sal as adoreat.
+tary Public State of Flork
+LE Ros
+(SEAW EVER TOMBSO
+Petri
+NAME:
+KIn E RiSIN
+NOTARY PUBLIC/STATE OF FLORIDA
+COMMISSION NO.: DD 489790
+MY COMMISSION EXPIRES:
+11|13/2009
+Page - 3 -

vision-fixhub/court-01/d9f8d9fb8e6bf9b3a3e2a554d18facbaa224b6e4aad7032eadd0b448bfc88587.receipt.json

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+{
+  "byte_delta": -47,
+  "dataset": "marble-joined",
+  "doc_id": "d9f8d9fb8e6bf9b3a3e2a554d18facbaa224b6e4aad7032eadd0b448bfc88587",
+  "engine": "marble-apple-vision",
+  "event_count": 4,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]",
+  "idempotent": true,
+  "input_sha256": "e230f59f16f2b6f7821ad3ce2e2b1d07e21412e34e7bb144e6182afc30dbe1ec",
+  "output_sha256": "acd41c2a55ecef668291daf438a547185e7138fb3e1e5e7bee75e914a3e710ab",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}

vision-fixhub/court-01/da3bd204d5f17284a17d61e9c58c702e8ad7b9a7d9f17b1886f26dd5c2243d74.md

@@ -0,0 +1,29 @@
+Case 1:19-cv-10577-LJL-DCF Document 50 Filed 05/08/20
+
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+JANE DOE 1000,
+Plaintiff,
+V.
+DARREN I. INDYKE and RICHARD D. KAHN
+in their capacities as the executors of the ESTATE
+OF JEFFREY EDWARD EPSTEIN,
+Defendants.
+CASE NO. 1:19-CV-10577-LJL-DCF
+NOTICE OF APPEARANCE
+PLEASE TAKE NOTICE that the undersigned attorney hereby appears as counsel for
+defendants Darren |. Indyke and Richard D. Kahn, in their capacities as the Executors of the
+Estate of Jeffrey E. Epstein, in the captioned action. I certify that I am admitted to practice in
+this Court. All notices given or required to be given in this case shall be served upon the
+undersigned.
+Dated: New York, New York.
+May 8, 2020
+By:_Is/Valerie Sirota
+Valerie Sirota
+TROUTMAN SANDERS LLP
+875 Third Avenue
+New York, NY 10022
+212.704.6000
+Valerie.Sirota@troutman.com
+Attorneys for Defendants
+To: All Counsel of Record (via ECF)

vision-fixhub/court-01/da3bd204d5f17284a17d61e9c58c702e8ad7b9a7d9f17b1886f26dd5c2243d74.receipt.json

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+{
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+  "dataset": "marble-joined",
+  "doc_id": "da3bd204d5f17284a17d61e9c58c702e8ad7b9a7d9f17b1886f26dd5c2243d74",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\"]",
+  "idempotent": true,
+  "input_sha256": "070535007395adbf6f46b8949b2b0e8129237b9b25a45f6d079df0430b546689",
+  "output_sha256": "d6c3f0656b5a38d88a2ea9c63228021944353d885d8afa8f53d614693c6cdb73",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}

vision-fixhub/court-01/da56a64d9ec3df7b9881afb88a082f304756a5ba96dca6829716599c16b75077.md

@@ -0,0 +1,217 @@
+Case 9:08-cv-80119-KAM Document 392 Entered on FLSD Docket 11/03/2009 Page 1 of 7
+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,
+PLAINTIFF JANE DOE NO. 4'S MOTION FOR PROTECTIVE
+ORDER AGAINST SECOND DAY OF DEPOSITION OF PLAINTIFF
+EXTENDING PAST SEVEN HOURS IN THE AGGREGATE,
+AND INCORPORATED MEMORANDUM OF LAW
+Plaintiff, Jane Doe No. 4, by and through undersigned counsel, hereby files this Motion
+for Protective Order Against Second Day of Deposition of Plaintiff Extending Past Seven Hours
+in the Aggregate, and Incorporated Memorandum of Law, as follows:
+Introduction
+Plaintiff Jane Doe filed a similar Motion for Protective Order on October 29, 2009
+seeking relief from Defendant taking her deposition for a second day. (DE 378). Plaintiff Jane
+Doe No. 4 seeks essentially the same relief limiting her deposition to seven hours, and,
+accordingly, Jane Doe No. 4 joins in Jane Doe's Motion for Protective Order. As discussed
+below, a deposition of Jane Doe No. 4 longer than seven hours in the aggregate would be
+contrary to Fed.R.Civ.P. 30(d)(1), S.D.Fla.L.R. 26.1(K), and this Court's Consolidation Order.
+(DE 98).
+1
+
+
+Case 9:08-cv-80119-KAM Document 392 Entered on FLSD Docket 11/03/2009 Page 2 of 7
+Background
+2.
+Pursuant to Court Order, Plaintiff Jane Doe No. 4's deposition was taken on
+October 27, 2009.
+The deposition lasted from approximately 11:00 a.m. until 6:04 p.m.
+Defendant's counsel stopped his questioning at that time, stating that he had another
+appointment.
+3.
+Defendant has subsequently demanded that Jane Doe No. 4 appear for a second
+day of deposition. The parties have tentatively agreed that this second day of deposition will
+take place on November 17, 2009.
+4.
+Plaintiffs' counsel has calculated the aggregate time Jane Doe No. 4 has spent in
+deposition thus far, deducting time spent in breaks, and has determined that Plaintiff Jane Doe
+No. 4 has spent five hours and thirty five minutes in deposition. This calculation has been
+provided to Defendant's counsel, and has not been disputed.
+5.
+For the reasons set forth below, Jane Doe No. 4 should not be required to
+complete her deposition for a period longer than one hour and twenty five minutes. This will
+provide Defendant with an aggregate total of seven hours deposition time of Jane Doe No. 4.
+Discussion
+Rule 30(d)(1), Fed.R.Civ.P., provides a limit on the time that may be taken for a
+6.
+deposition:
+Unless otherwise stipulated or ordered by the court, a deposition is
+limited to one day of seven hours.
+The Court must allow
+additional time consistent with Rule 26(d)(2) if needed to fairly
+examine the deponent ...
+Consistent with Fed.R.Civ.P. 30(d)(1), S.D.Fla.L.R. 26.1(K) provides that "lu]nless otherwise
+authorized by the Court or stipulated by the parties, a deposition is limited, under Fed.R.Civ.P.
+30(d) to one day of seven hours."
+2
+
+
+Case 9:08-cv-80119-KAM Document 392 Entered on FLSD Docket 11/03/2009 Page 3 of 7
+7.
+This one day, seven hour limit was waived under the Court's Consolidation Order
+for circumstances that are not present in the deposition of Jane Doe No. 4. Specifically, the
+Court's Order consolidating cases dated May 14, 2009 (DE 98) waives the seven hour limit so
+that the multiple Plaintiffs' attorneys in these cases may have an adequate opportunity to
+question witnesses with regard to each particular Plaintiff:
+For depositions, Local Rule 26.1K (limiting deposition time to one
+day of seven hours) is waived so as to allow each party an
+adequate opportunity to develop fully the record as it may relate to
+that party. However, this waiver shall not be construed as
+authority for any party to take unnecessarily long depositions, or
+abuse the process. Any abuses of this waiver shall result in the
+imposition of appropriate sanctions against the offending party.
+(Order, p. 4, 9l 8) (emphasis supplied).
+8.
+This waiver does not apply to the deposition of a Plaintiff taken by the Defendant.
+Defendant's counsel is the only attorney asking questions at this deposition. There are two other
+Plaintiffs' attorneys attending the deposition, one of which has appeared by telephone. It is
+unlikely that either of these Plaintiffs' attorneys will ask questions of Jane Doe No. 4 because
+nothing in the testimony indicates that their clients had any contact with Jane Doe No. 4.
+Plaintiffs' counsel may have some questions of Jane Doe No. 4 in the nature of clarification of
+testimony, but Jane Doe No. 4's counsel does not seek to use any part of Defendant's seven hour
+aggregate for purposes of those questions, which will be brief and be made at the end of the
+deposition.
+Separate and apart from the time limit for depositions under the federal and local
+rules, the questioning of Jane Doe No. 4 thus far has been argumentative, hostile, badgering and
+abusive.
+Substantial portions of the questioning have not related to any legitimate discovery
+purpose. For example, the first exhibit marked by Defendant's attorney at the deposition was the
+3
+
+
+Case 9:08-cv-80119-KAM Document 392 Entered on FLSD Docket 11/03/2009 Page 4 of 7
+Proposal for Settlement that Defendant's counsel served earlier in the case. Defendant's attorney
+badgered Jane Doe No. 4 regarding this Proposal for Settlement, questioning whether she
+received and understood Defendant's settlement proposal. Such a line of questioning is highly
+improper and plainly not designed to lead to admissible testimony or the discovery of admissible
+evidence. As another example, Jane Doe No. 4 testified early in her deposition that the first three
+massages approximately she gave to Jeffrey Epstein were not sexual and she did not remove any
+clothes. Beginning with approximately the fourth massage, during her junior year of high school
+when she was 16 years old, she was asked progressively to remove more clothes and engage in
+more activities of a sexual nature. Over approximately a two-year period, she would engage in
+massages in which she was naked and sexual activity occurred approximately twice a week
+during periods in which Epstein was in Palm Beach. She made it clear early in her testimony
+that she did not recall the exact dates in which these massages occurred. Despite this,
+Defendant's counsel engaged in flurries of identical questions demanding exact dates, berating
+and badgering the witness, on repeated occasions throughout the course of the deposition. As
+demonstrated by these examples, a substantial portion of the deposition thus far has consisted of
+abusive questioning and not legitimate discovery.'
+' There are other instances of abuse by Defendant's counsel at Jane Doe No. 4's deposition.
+S.D.Fla.L.R. 30.1(A)(5) defines abusive deposition conduct to include the following:
+Questioning that unfairly embarrasses, humiliates, intimidates, or
+harasses the deponent, or invades his or her privacy absent a clea
+tatement on the record explaining how the answers to suc
+questions will constitute, or lead to, competent evidence admissible
+at trial.
+At the present time, Plaintiff's attorneys have not yet received the copy of the transcript of Jane
+Doe No. 4's deposition taken on October 27, 2009. Upon receipt, Plaintiff's attorney will file the
+transcript to demonstrate the abusive practices engaged in by Defendant's attorney.
+4
+
+
+Case 9:08-cv-80119-KAM Document 392 Entered on FLSD Docket 11/03/2009 Page 5 of 7
+10. This is not a commercial case, in which the questioning must necessarily be
+focused on numerous complex commercial documents. In Dunkin Donuts, Inc. v. Mary's
+Donuts, Inc., 206 F.R.D. 518 (S.D.Fla. 2002), the Court allowed the Plaintiff to depose the
+Defendant's accountant and corporate representative for an additional seven hours because it was
+a complex commercial case involving seven years of commercial activity and 10,000 pages of
+documents. Id. at 522. See also Pace v. City of Palmetto, 2007 WL 470477 (S.D.Fla. 2007)
+(granting a party one hour additional deposition time because the deponent had not read
+documents in advance, and was taking an inordinate amount of time during the deposition to read
+documents). The nature of this case, for damages arising from sexual misconduct, does not
+warrant a deposition in excess of seven hours.
+11.
+Under Fed.R.Civ.P. 30(d)(1), S.D.Fla.L.R. 26.1(K) and the Court's Consolidation
+Order (DE 98), it is the Defendant's burden to demonstrate why more than seven hours of
+deposition time is necessary for a particular Plaintiff. Not only can Defendants not make such a
+demonstration, the deposition of Jane Doe No. 4 emphatically demonstrates that more than seven
+hours of deposition time would only provide Defendant with a license for abuse, which is plainly
+part and parcel of Defendant's strategy to intimidate and harass the Plaintiffs in these cases.
+12.
+Plaintiff Jane Doe No. 4 is willing to sit for a second day of deposition for a
+period of no longer than one hour and twenty five minutes, giving Epstein an aggregate of seven
+hours of deposition time. Under the circumstances, any more deposition questioning will clearly
+be abusive. This additional one hour twenty five minutes of deposition time is more than enough
+time for Defendant to complete any remaining legitimate questions of Jane Doe No. 4.
+WHEREFORE, Plaintiff respectfully requests a protective order consistent with
+Fed.R.Civ.P. 30(d)(I) and S.D.Fla.L.R. 26.1(K), as well as this Court's Consolidation Order,
+5
+
+
+Case 9:08-cv-80119-KAM Document 392 Entered on FLSD Docket 11/03/2009 Page 6 of 7
+providing Defendant with no more than an additional one hour and twenty five minutes of
+deposition time of Jane Doe No. 4, and for such other and further relief as this Court deems just
+and proper.
+CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1.A.3
+Undersigned counsel has conferred with Defendant's counsel in a good faith effort to
+resolve the issues raised in this motion, and has been unable to do so, as Defendant's counsel has
+advised that Defendant opposes this motion.
+Dated: November 3, 2009.
+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
+CERTIFICATE OF SERVICE
+I hereby certify that on November 3, 2009, I electronically filed the foregoing document
+with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
+served this day to all parties on the attached Service List in the manner specified, either via
+transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized
+manner for those parties who are not authorized to receive electronically Notices of Electronic
+Filing.
+Is/ Stuart S. Mermelstein
+6
+
+
+Case 9:08-cv-80119-KAM Document 392 Entered on FLSD Docket 11/03/2009 Page 7 of 7
+SERVICE LIST
+DOE vs. JEFFREY EPSTEIN
+United States District Court, Southern District of Florida
+Jack Alan Goldberger, Esq.
+jgoldberger@agwpa.com
+Robert D. Critton, Esq.
+rcritton@bclclaw.com
+James
+bedwards@rra-law.com
+Isidro Manuel
+isidrogarcia@bellsouth.net
+Jack
+jph@searcylaw.com
+Katherine Warthen Ezell
+KEzell@podhurst.com
+Michael James Pike
+MPike@bclclaw.com
+Paul G. Cassell
+cassellp@law.utah.edu
+Richard Horace Willits
+lawyerwillits@aol.com
+Robert C. Josefsberg
+rjosefsberg@podhurst.com
+7

vision-fixhub/court-01/da56a64d9ec3df7b9881afb88a082f304756a5ba96dca6829716599c16b75077.receipt.json

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vision-fixhub/court-01/da64e9d43afe3e8d7b681d8da073314bb2def5909df3d1edebb687ad936c87c4.md

@@ -0,0 +1,236 @@
+Case 9:09-cv-80469-KAM Document 28 Entered on FLSD Docket 05/29/2009 Page 1 of 9
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+JANE DOE NO. 2,
+Plaintiff,
+CASE NO.: 08-CV-80119-MARRA/
+VS.
+Defendant.
+JANE DOE NO. 3,
+Plaintiff,
+CASE NO.: 08-CV-80232-MARRA/
+VS.
+Defendant.
+JANE DOE NO. 4,
+Plaintiff,
+CASE NO.: 08-CV-80380-MARRA/
+VS.
+Defendant.
+JANE DOE NO. S,
+Plaintiff,
+CASE NO.: 08-CV-80381-MARRA/JOHNSON
+VS.
+
+
+Case 9:09-cv-80469-KAM Document 28 Entered on FLSD Docket 05/29/2009 Page 2 of 9
+Defendant.
+JANE DOE NO. 6,
+Plaintiff,
+CASE NO.: 08-CV-80994-MARRA/
+VS.
+Defendant.
+JANE DOE NO. 7,
+Plaintiff,
+CASE NO.: 08-CV-80993-MARRAJ
+VS.
+Defendant.
+C.M.A.,
+CASE NO.: 08-CV-80811-MARRA/
+Plaintiff,
+VS.
+Defendant.
+JANE DOE,
+Plaintiff,
+CASE NO.: 08-CV-80893-MARRA/
+
+
+Case 9:09-cv-80469-KAM Document 28 Entered on FLSD Docket 05/29/2009 Page 3 of 9
+VS.
+Defendant.
+JANE DOE NO. II,
+Plaintiff,
+CASE NO.: 08-CV-80469-MARRA/
+VS.
+Defendant.
+JANE DOE NO. 101,
+Plaintiff,
+CASE NO.: 09-CV-80591-MARRAJ
+VS.
+Defendant.
+JANE DOE NO. 102,
+Plaintiff,
+CASE NO.: 09-CV-80656-MARRA/
+VS.
+Defendant.
+MOTION TO RESCHEDULE HEARING
+
+
+Case 9:09-cv-80469-KAM Document 28 Entered on FLSD Docket 05/29/2009 Page 4 of 9
+COMES NOW Robert C. Josefsberg, as co-counsel for Jane Doe 101 and 102, and
+respectfully requests either a rescheduling of this Court's hearing (just rescheduled for June, 12,
+2009) or in the alternative, permission to appear by telephone at said hearing, on the following
+grounds:
+1) On Wednesday, June 10, 2009, undersigned counsel, his wife and two granddaughters
+will be traveling to Hanover, New Hampshire for counsel's 50* College Reunion, and an
+opportunity for his two high school granddaughters to visit colleges in the Northeast. Counsel is
+scheduled to return to South Florida on Tuesday, June 16".
+2) Counsel is very appreciative and supportive of the Court's scheduling a hearing on the
+Defendants' Motion to Stay. That hearing was scheduled (within the last 3 hours) for Friday,
+June 12" at 10:00 a.m., right in the middle of Robert Josefsberg's reunion visit.
+3) If Robert Josefsberg cannot attend, Jane Doe 101 and 102 will be well represented by
+co-counsel who can and will appear in person at said hearing on June 12, 2009. However,
+Robert Josefsberg is lead counsel and would prefer to be present during said hearing.
+4) In the event that this hearing cannot be rescheduled for June 4, 5, 8 or 9", or June 17",
+18"' or 19", Robert Josefsberg requests permission to appear at said June 12th hearing by
+telephone.
+WHEREFORE, Robert Josefsberg requests the relief requested above.
+
+
+Case 9:09-cv-80469-KAM Document 28 Entered on FLSD Docket 05/29/2009 Page 5 of 9
+Dated May 29, 2009.
+Respectfully submitted,
+PODHURST ORSECK, P.A.
+Attorneys for Plaintiffs Jane Doe No. 101
+and Jane Doe No. 102
+By:
+s/ Robert C. Josefsberg
+Robert C. Josefsberg
+Fla. Br No. 040856
+rjosefsberg@podhurst.com
+Katherine W. Ezell
+Fla. Bar No. 114771
+kezell@podhurst.com
+City National Bank Building
+25 W. Flagler Street, Suite 800
+Miami, FL 33130
+Telephone: (305) 358-2800
+Facsimile: (305) 358-2382
+
+
+Case 9:09-cv-80469-KAM Document 28 Entered on FLSD Docket 05/29/2009 Page 6 of 9
+CERTIFICATE OF SERVICE
+WE HEREBY CERTIFY that on this _
+_ day of May, 2009, we electronically filed the
+foregoing document with the Clerk of the Court using CM/ECF. We also certify that the foregoing
+document is being served this day on all counsel of record identified on the attached Service List
+either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other
+authorized manner for those counsel or parties who are not authorized to receive electronically
+Notices of Electronic Filing.
+Respectfully submitted,
+PODHURST ORSECK, P.A.
+Attorneys for Plaintiffs Jane Doe No. 101
+and Jane Doe No. 102
+By:
+s/Katherine W. Ezell
+Robert C. Josefsberg
+Fla. Br No. 040856
+rjosefsberg@podhurst.com
+Katherine W. Ezell
+Fla. Bar No. 114771
+kezell@podhurst.com
+City National Bank Building
+25 W. Flagler Street, Suite 800
+Miami, FL 33130
+Telephone: (305) 358-2800
+Facsimile: (305) 358-2382
+
+
+Case 9:09-cv-80469-KAM Document 28 Entered on FLSD Docket 05/29/2009 Page 7 of 9
+SERVICE LIST
+JANE DOE NO. 2 v. JEFFREY EPSTEIN
+Case No. 08-CV-80119-MARRA/
+United States District Court, Southern District of Florida
+Robert Critton, Esq.
+Michael J. Pike, Esq.
+Burman, Critton, Luttier & Coleman LLP
+515 North Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+Phone: (561) 842-2820
+Fax: (561) 515-3148
+rcrit@bclclaw.com
+mpike@bclclaw.com
+Counsel for Defendant, Jeffrey Epstein
+Jack Goldberger, Esq.
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue South, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561) 659-8300
+Fax: (561) 835-8691
+jagesq@bellsouth.net
+Co-Counsel for Defendant, Jeffrey Epstein
+Bruce E. Reinhart, Esq.
+Bruce E. Reinhart, P.A.
+250 South Australian Avenue, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561) 202-6360
+Fax: (561) 828-0983
+ecf@brucereinhartlaw.com
+Counsel for Co-Defendant,
+Jack Scarola, Esq.
+Jack P.
+, Esq.
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+Phone: (561) 686-6300
+Fax: (561) 383-9456
+isx @searcylaw.com
+jph@searcylaw.com
+Counsel for Plaintiff C.M.A.
+
+
+Case 9:09-cv-80469-KAM Document 28 Entered on FLSD Docket 05/29/2009 Page 8 of 9
+Adam Horowitz, Esq.
+Stuart Mermelstein, Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Blvd., Suite 2218
+Miami, FL 33160
+Phone: (305) 931-2200
+Fax: (305) 931-0877
+ahorowitz@sexabuseattorney.com
+smermelstein@sexabuseattorney.com
+Counsel for Plaintiffs in Related Cases Nos. 08-80069, 08-80119,08-80232, 08-80380, 08-
+80381, 08-80993, 08-80994
+Spencer Todd Kuvin, Esq.
+Theodore Jon Leopold, Esq.
+Leopold Kuvin, P.A.
+2925 PGA Boulevard, Suite 200
+Palm Beach Gardens, FL 33410
+Phone: (561) 515-1400
+Fax: (561) 515-1401
+skuvin@leopoldkuvin.com
+tleopold@leopoldkuvin.com
+Counsel for Plaintiff in Related Case No. 08-08804
+Richard Willits, Esq.
+Richard H. Willits, P.A.
+2290 10* Ave North, Suite 404
+Lake Worth, FL 33461
+Phone: (561) 582-7600
+Fax: (561) 588-8819
+lawyerwillits@aol.com
+reelrhw@hotmail.com
+Counsel for Plaintiff in Related Case No. 08-80811
+Brad
+1, Esq.
+Law Office of Brad
+& Associates, LLC
+2028
+Street, Suite 202
+Hollywood, FL 33020
+Phone: (954) 414-8033
+Fax: (954) 924-1530
+bedwards@rra-law.com
+be@bradedwardslaw.com
+Counsel for Plaintiff in Related Case No. 08-80893
+Isidro Manuel
+Esq.
+Elkins & Boehringer
+224 Datura Avenue, Suite 900
+
+
+Case 9:09-cv-80469-KAM Document 28 Entered on FLSD Docket 05/29/2009 Page 9 of 9
+West Palm Beach, FL 33401
+Phone: (561) 832-8033
+Fax: (561) 832-7137
+isidrogarcia @ bellsouth.net
+Counsel for Plaintiff in Related Case No. 08-80469

vision-fixhub/court-01/da64e9d43afe3e8d7b681d8da073314bb2def5909df3d1edebb687ad936c87c4.receipt.json

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vision-fixhub/court-01/da761627de879bbaf20c7825dd760042a1a5f791477bb0714f4646c627d2e224.md

@@ -0,0 +1,34 @@
+Case 9:08-CV-80381-KAM Document 9-1 Entered on FLSD Docket 06/13/2008 Page 1 of 2
+
+
+
+Case 9:08-cv-80381-KAM Document 9-1 Entered on FLSD Docket 06/13/2008 Page 2 of 2
+AFFIDAVIT OF RICHARD BARNETT
+I, Richard Barnett, being duly sworn, do depose and state as follows:
+2.
+I am over the age of 18, am otherwise competent to testify and
+base the following on my personal knowledge.
+On May 7, 2008, I received copies of the summons and complaint
+in four lawsuits:
+a. Jane Doe #2 v. Jeffrey Epstein, Case No. 08-CV-80119,
+b. Jane Doe #3 v. Jeffrey Epstein, Case No. 08-CV-80232,
+c. Jane Doe #4 v. Jeffrey Epstein, Case No. 08-CV-80380, and
+d. Jane Doe #5 v. Jeffrey Epstein, Case No. 08-CV-80381.
+I do not now, nor have I ever resided at 9 East 71st Street, New
+York, New York.
+FURTHER AFFIANT SAYETH NAUGHT.
+RICHARD BARNETT
+Sworn and subscribed before me
+this 12" day of June 2008 by
+Richard Barnett, who
+is personally known to me. f-or did provide
+s identificatior.
+intries
+NOTARY PUBL
+STATE OF NEWYOR!
+MY COMMISSION EXPIRES:
+LAUREN J. KWINTNER
+Notary Public, State of New York
+No. 02KW6016686
+Qualified in New York County
+Commission Expires November 30, 20 1°

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vision-fixhub/court-01/da8403b39be323f810f41cd1d35aa98d8219ba1fdb1f27a63ebc5a3c5af1c487.md

@@ -0,0 +1,55 @@
+Case 9:08-cv-80736-KAM Document 261 Entered on FLSD Docket 10/08/2014 Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO. 08-80736-CIV-MARRA/
+JANE DOE 1 and JANE DOE 2,
+Plaintiffs
+V.
+UNITED STATES OF AMERICA,
+Defendant
+INTERVENOR EPSTEIN'S UNOPPOSED MOTION FOR A SUPPLEMENTAL
+PROTECTIVE ORDER
+Now comes Intervenor, Jeffrey Epstein, who moves that this Honorable Court
+issue a supplemental Protective Order that would expand the limited Protective Order
+allowed in its decision Granting in Part and Denying in Part the Intervenors' Motion for a
+Protective Confidentiality Order. [D.E. 255 at 4]. The purpose of the proposed
+supplement to the previously ordered Protective Order is to require that any party would
+be required to file under seal any portion of the plea negotiation correspondence between
+the Government and Epstein's counsel, whether offered as an exhibit or quoted from in
+the content of a pleading or motion. Such a redacted filing would in all other respects be
+filed as a public filing unless subject to other orders of the Court, and each party would
+reserve the right to move to unseal any redacted pleading or sealed exhibit. After
+consultation with their counsel, both the Plaintiffs and the Government do not oppose the
+allowing of this Motion.
+1
+
+
+Case 9:08-cv-80736-KAM Document 261 Entered on FLSD Docket 10/08/2014 Page 2 of 2
+Respectfully submitted,
+JEFFREY EPSTEIN
+By His Attorneys,
+Is/Roy Black
+Roy Black
+Jackie Perczek
+BLACK, SREBNICK, KORNSPAN
+& STUMPF, P.A.
+201 So. Biscayne Blvd., Suite 1300
+Miami, Florida 33131
+Tele: (305) 371-6421
+Fax: (305) 358-2006
+rblack@royblack.com
+jperczek@royblack.com
+/sl
+G. Weinberg
+G. Weinberg
+20 Park Plaza, Suite 1000
+Boston, Massachusetts 02116
+Tele: (617) 227-3700
+Fax: (617) 338-9538
+owlmgw@att.net
+CERTIFICATE OF SERVICE
+I HERE CERTIFY that a true copy of the foregoing was filed via CM/ECF, this
+8** day of October, 2014.
+Is/Roy Black
+Roy Black
+2

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vision-fixhub/court-01/dab5cc39d15579828fe99ff7ba599bc2ee4ef8d960e8f4fd4827662521a77117.md

@@ -0,0 +1,173 @@
+Case 9:08-cv-80381-KAM Document 134 Entered on FLSD Docket 11/20/2009 Page 1 of 4
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CIV-80119-MARRAI,
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-08380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+DEFENDANT EPSTEIN'S MOTION TO ATTEND MEDIATION
+AND MEMORANDUM IN SUPPORT THEREOF
+(AS TO CMA v. EPSTEIN AND |
+- 08-CIV-80811)
+Defendant, JEFFREY EPSTEIN, by and through his undersigned attorneys,
+moves this Court for an order allowing him to attend mediation in the above-styled
+matter and as grounds set forth would state:
+The Court entered a no contact order which may apply to Carolyn
+Andriano, [DE 238].
+Plaintiff's counsel and plaintiff,
+have no objection to Mr.
+Epstein attending deposition, mediation and obviously trial.
+3.
+Therefore, Defendant, Jeffrey Epstein, in an abundance of caution,
+requests that the court enter the attached proposed Agreed Order which shall not
+
+
+Case 9:08-cv-80381-KAM Document 134 Entered on FLSD Docket 11/20/2009 Page 2 of 4
+Page 2
+preclude him from attending Plaintiff
+trial of this case.
+deposition, mediation, or the
+Rule 7.1 Certification
+Defense counsel has spoken with Plaintiff's counsel and he has no objection to
+the entry of the proposed agreed order.
+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 20 day of _November_ 2009
+Respectfully submitted,
+By:
+ROBERT D. CRITTON, JR., ESQ.
+Florida Bar No. 224162
+crit@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)
+
+
+Case 9:08-cv-80381-KAM Document 134 Entered on FLSD Docket 11/20/2009 Page 3 of 4
+Page 3
+Certificate of Service
+Jane Doe No. 2 v. Jeffrey Epstein
+Case No. 08-CV-80119-MARRA/JOHNSON
+Stuart S. Mermelstein, Esq.
+Brad
+Esq.
+Adam D. Horowitz, Esq.
+Rothstein Rosenfeldt Adler
+Mermelstein & Horowitz, P.A.
+401 East Las Olas Boulevard
+18205 Biscayne Boulevard
+Suite 1650
+Suite 2218
+Fort Lauderdale, FL 33301
+Miami, FL 33160
+Phone: 954-522-3456
+305-931-2200
+Fax: 954-527-8663
+Fax: 305-931-0877
+bedwards@rra-law.com
+ssm@sexabuseattorney.com
+Counsel for Plaintiff in Related Case No.
+ahorowitz@sexabuseattorney.com
+08-80893
+Counsel for Plaintiffs
+In related Cases Nos.
+08-80069, 08- Paul G. Cassell, Esq.
+80119, 08-80232,
+08-80380, 08-80381, Pro Hac Vice
+08-80993, 08-80994
+332 South 1400 E, Room 101
+Salt Lake City, UT 84112
+Richard Horace Willits, Esq.
+801-585-5202
+Richard H. Willits, P.A
+801-585-6833 Fax
+2290 10* Avenue North
+cassellp@law.utah.edu
+Suite 404
+Co-counsel for Plaintiff Jane Doe
+Lake Worth, FL 33461
+561-582-7600
+Isidro M.
+, Esq.
+Fax: 561-588-8819
+Law Firm, P.A
+Counsel for Plaintiff in Related Case No.
+224 Datura Street, Suite 900
+08-80811
+West Palm Beach, FL 33401
+reelrhw@hotmail.com
+561-832-7732
+561-832-7137 F
+Jack Scarola, Esq.
+isidrogarcia@bellsouth.net
+Jack P.
+, Esa.
+Counsel for Plaintiff in Related Case No.
+Searcy
+Denney
+Scarola Barnhart & 08-80469
+Shipley, 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
+
+
+Case 9:08-cv-80381-KAM Document 134 Entered on FLSD Docket 11/20/2009 Page 4 of 4
+Page 4
+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
+skuvin@leopoldkuvin.com
+Counsel for Plaintiff in Related Case No.
+08-08804
+Counsel for Plaintiffs in Related Cases
+Nos. 09-80591 and 09-80656
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Counsel for Defendant Jeffrey Epstein

vision-fixhub/court-01/dab5cc39d15579828fe99ff7ba599bc2ee4ef8d960e8f4fd4827662521a77117.receipt.json

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vision-fixhub/court-01/dae6f98bcf59efa220b28c69ab3413e2699907b672e449bfe9ee6ebf91e0824f.md

@@ -0,0 +1,197 @@
+Case 9:09-cv-80469-KAM Document 34-1 Entered on FLSD Docket 06/08/2009 Page 1 of 5
+The Psychological Trauma Center
+a division of Preventive Psychiatry Associates Medical Group, Inc.
+Medical Director: Gilbert W. Kliman, M. D.
+2105 Divisadero St., San Francisco, CA 94115
+Phone (415)292-7119 Fax (415) 749-2802
+www.expertchildpsuchiatry.com
+Forensic Child Psychiatric Evaluations, Life Care Plans de Testimony
+DECLARATION OF GILBERT KLIMAN, M. D.
+June 4, 2009
+RE: EXPECTATION OF HARM FROM DISCLOSING THE PLAINTIFFS' IDENTITIES
+IN DOES V JEFFREY EPSTEIN
+1. I, Gilbert W. Kliman, M.D., of 2105 Divisadero Street, San Francisco, California,
+CA. Physicians License G55912, declare the following under penalty of perjury:
+2. I have been retained by plaintiffs' law firm, Mermelstein & Horowitz, to give expert
+testimony. If called as a witness, I would testify truthfully and competently concerning
+my psychiatric findings about each of the plaintiffs' alleged experiences of sexual abuse,
+and the enduring effects that I find each of the young women have suffered as a direct
+result of the sexual acts perpetrated by the defendant.
+3. I have been asked to respond to the Defense motion, which requests that some of the
+plaintiffs, who are now adults, should be publicly named. It is my opinion that
+involuntary public disclosure will result in the plaintiffs experiencing revictimization,
+albeit by a justice system that is designed to protect them. If their identities are released,
+the victims will be at-risk of having their personal lives scrutinized by friends, extended
+family, spouses, children, fellow students, employers and fellow employees, the media
+and general public. This type of exposure humiliates many victims and represents another
+betrayal of trust. Public exposure places the plaintiffs at further risk of stigmatization,
+shame and retraumatization.
+4. Due to traumatization the plaintiffs are arrested in their development, and even those
+who are now legally adults are arrested in part to adolescent aspects of psychology.
+5. The plaintiffs do not hold their heads high with pride for having been sexually
+controlled by Mr. Epstein. They hold their heads low with shame. The internal life of a
+typical adolescent, into late adolescence and early adult years in the best of
+circumstances, usually involves generous proportions of self-consciousness, shame, selfabsorption and self-doubt and self-blame about sexual acts.
+
+1
+
+
+Case 9:09-cv-80469-KAM Document 34-1 Entered on FLSD Docket 06/08/2009 Page 2 of 5
+6. Clinically harmful levels of shame, self-consciousness, self-doubt and self-blame are
+even more prominent among victims of molestations than among the general population.
+7. Molested teenagers are particularly vulnerable to wrongful manipulations and special
+clinical harms from the experiences of shame and humiliation. In fact, shame and efforts
+to cope with it played an underlying role in the harm to each plaintiff. Each was lured
+into Mr. Epstein's sexual lair with the promise of overcoming bodily and sexual shame
+by earning money and bettering their lot in life. The defendant capitalized on their sexual
+naiveté, insecurities and effort to better themselves, and he worked hard to overcome
+their shame at his enlistment of them in his selfish gratifications.
+8. The defendant who wishes to make their identities public is one whom the criminal
+justice system has already determined is a person who has already committed a crime of
+child molestation. That surely means he has already exploited and manipulated the girls'
+state of adolescent sexuality, including their embarrassment, awkwardness and bodily
+self-consciousness. He perverted their nascent and developing moral structures by posing
+as a generous, avuncular mentor who could coach them about their bodies, sex and love.
+The exploitation of adolescent bodies, sex and love is - from a psychoanalytic point of
+view - an influence on the developing moral conscience of the children, as well as on
+their sexual urges. Now the ravaging of their internal and private moral conscience is
+intended by the perpetrator to be made a public ravaging.
+9. Among sexual trauma victims, the insidious and destructive persistence of shame,
+humiliation and associated self-blame is well-documented (Finkelhor and
+Stigmatization, as experienced by a sexual trauma victim, has especially painful and
+pathologic consequences. Shame lingers and becomes integrated within the adolescent
+victim's malleable emerging identity, character structure and self image. Moral clarity is
+distorted. Perceptions of self-blame and guilt are magnified. The impact of shame lends
+to cultivating a self image of being "spoiled goods."
+10. Stigmatization following sexual trauma results in long-term risks that can negatively
+shape multiple facets of adult development: sexual, emotional, interpersonal and
+vocational. Stigmatization, which is generally to be avoided among psychiatric patients,
+increases risks among those - as in our plaintiffs as a group - who experience clinical
+depression and self-destructive behaviors: drug use, criminal activity, even prostitution.
+Stigmatization following abuse is associated with delinquency due to increased anger
+and affiliation with deviant peers (Feiring et al., 2007).
+11. Shame and guilt are important dimensions of both complex and single event,
+posttraumatic stress disorder (PTSD). Symptoms of shame are associated with feelings of
+helplessness and powerlessness, which each of the plaintiffs endorsed experiencing in
+relation to Mr. Epstein.
+
+
+Case 9:09-cv-80469-KAM Document 34-1 Entered on FLSD Docket 06/08/2009 Page 3 of 5
+12. The DSM-IV-TR recognizes both powerlessness and helplessness as requisite parts of
+the traumatic experience in Criterion A for the diagnosis of posttraumatic stress disorder
+Seligman, recent Past President of the American Psychological
+Association, coined relevant terms of "learned helplessness and "Loss of Personal Locus
+of Control." See Seligman, M.P. 1975: Helplessness, Depression, Development and
+Death. W. H. Freeman, San Francisco). The teenaged girls suffered the loss of personal
+locus of control to a much more experienced, sexually aggressive, powerful and
+dominant, manipulative perpetrator.
+13. Releasing names of the plaintiffs to the public will reenact experiences of
+powerlessness and helplessness in the face of a boundary violation. Repetition and
+reenactment represent central features of Criterion B in the DSM-IV-TR diagnosis of'
+posttraumatic stress disorder trauma. In effect, release of their identity and public
+intrusion into their personal life represents a reenactment of the shame of sexual
+traumatization. Repetition and reenactment are central pathologies that afflict sexual
+trauma survivors.
+14. Victims of sexual abuse often rely upon some form of dissociation, splitting or denial,
+as a defensive means to manage overwhelming affects associated with the sexual trauma.
+Each of the plaintiff girls has employed some variation of this defense, both during the
+massages and then subsequently following disclosure of the abuse. Primitive,
+maladaptive responses of this nature will become additionally reinforced as a result of
+public disclosure.
+15. Another aspect of the plaintiffs' experience, which is recognized by DSM-IV-TR, is
+that the trauma was associated with human design factors (such as cruel intention to do
+harm, rape, torture). Trauma of this origin has a tendency to produce more "severe or
+long lasting" posttraumatic stress disorder than natural events (DSM IV TR p. 464). A
+policy of deliberate revelation of the names of the victims would reinforce the sense of
+design, pattern and policy of human intentions.
+16. Negative expectations about significant activities are noted in DSM-IV-TR, as part of
+Criterion C. Symptoms of foreshortened future are characteristic of a traumatized
+individual's clinical course (C4). They expect revictimization. They expect bad outcomes
+(C7) in their social, educational, vocational, relational plans. They are hypervigilant
+(Criterion D4) for further trauma, and this affects lifestyle choices and future planning.
+Hypervigilance is part of the arousal set of criteria. Public disclosure of the victims'
+identity will aggravate existing symptoms of hypervigilance.
+17. The DSM-IV-TR diagnostic category of "chronic" is justified for each of the
+plaintiffs. Scientific literature shows that the prognostic consequences of PTSD and
+residual effects may last for decades (U.S. Dept. of Health, 2005; Issues in Child Abuse
+Prevention Number 9 Autumn1998: Long-term Effects of Child Sexual Abuse, Paul E
+Mullen and Jillian Fleming). The lasting impact upon character, identity and moral
+development will probably affect long-term influences upon adult development. It is
+more probable than not that stigmatization associated with public disclosure of the
+3
+
+
+Case 9:09-cv-80469-KAM Document 34-1 Entered on FLSD Docket 06/08/2009 Page 4 of 5
+plaintiffs" identities will intensify the scope, nature and severity of the chronic symptom
+course.
+18. In addition to PTSD, shame and humiliation themselves have also been associated
+with causing clinical depression. Coexisting PTSD and clinical depression places the
+plaintiff's at increased risk for re-victimization and high risk sexual behaviors (e.g.,
+sexually transmitted disease, premature pregnancy, rape) (Nelson, 2002), and at greater
+risk to victimize others (Filipas and Ullman, 2006; Desai, Centers for Disease Control,
+2002) who are in their control. Studies have also shown that chronic symptoms of PTSD,
+in association with a single episode of Major Depressive Disorder, can produce lifetime
+adjustment difficulties, which include suicidality (Oquendo et al, 2005; Dube et al, CDC,
+2001; Rohde, J. Am. Acad. Child and Adolescent Psychiatry 2005). The plaintiffs will be
+additionally vulnerable to these clinical outcomes, if they suffer the stigmatization and
+humiliation associated with public disclosure of their identities.
+19. Alternative hypothesis: I have applied the evidence shown from examination and
+testing of the plaintiffs and relevant observations and information from other
+professionals while testing an alternative hypothesis: that no harm would result from
+public disclosure of the plaintiffs' identities. During the evaluations with the six
+plaintiffs, I used generally acceptable criteria for establishing whether a DSM-IV-TR
+disorder occurred. I established that there were provable and diagnosable injuries,
+primarily posttraumatic stress disorder and comorbid depression. Based upon these
+diagnostic signs, it is more probable than not, that exposing the plaintiff's identity to the
+public is not a trivial concern or one without substantial clinical repercussions. I believe
+that most child, adolescent and adult psychiatrists would share the opinion that additional
+psychiatric injury will result from such exposure.
+20. However, consider for the sake of argument, that my diagnostic conclusions are
+incorrect, notwithstanding having fulfilled standard psychiatric evaluation procedures of
+taking a history from multiple sources, videotaping and transcribing my initial interview,
+and reviewing available medical and legal documents. Even if this was the case, and my
+diagnostic conclusions were faulty, I believe that multiple experts, even those who may
+now propose publication of the victims' names, would still come to a conclusion that the
+plaintiff's suffered sexual abuse, and in some cases, multiple acts of ongoing abuse, at the
+hands of Jeffery Epstein. Even without developing a subsequent disorder, there is much
+clinical evidence and scientific literature showing likelihood of substantial psychiatric
+harm to these sexually abused plaintiffs.
+21. To form these conclusions, I have used my extensive experience in forming these
+opinions. That experience is both as a treating child psychiatrist and separately as a
+forensic psychiatrist. I have treated hundreds of minor patients, as well as additionally
+evaluated hundreds of children and adolescents who have suffered sexual abuse. I have
+made long term followups of many of the children and have treated many adults who
+have been molested as adolescents. It is my opinion, with a reasonably high degree of
+medical certainty that the defense motion to allow public disclosure of the plaintiffs'
+identities is clinically and ethically a wrongful plan. The act of revealing their identities
+against their wishes places the plaintiffs at risk, in the best of circumstances, of suffering
+4
+
+
+Case 9:09-cv-80469-KAM Document 34-1 Entered on FLSD Docket 06/08/2009 Page 5 of 5
+an aggravation of existing diagnostic concerns. It is more probable than not that releasing
+personal identities will
+an exacerbation and magnification of symptoms lending to
+increased risk of revictimization and retraumatization.
+I declare under penalty of perjury under the laws of the State of California that the
+foregoing statements are true and correct, and that this declaration was executed at San
+Francisco, California on June 4, 2009.
+Sincerely,
+Babel Kina 1D
+Gilbert Kliman, M.D.
+Distinguished Life Fellow, American Psychiatric Association
+Senior Fellow, American Academy of Child and Adolescent Psychiatry
+Brockman Award Holder, for Distinguished Lifetime Contributions to
+Psychoanalysis and Psychiatry, bestowed by the American College of Psychoanalysis and
+Psychiatry
+LEONID NAKHODKIN <
+Сомм.# 1791115
+NOTARY PUBLIC-CALIFORNIA
+ÔTY & COUNTY OF SAR FRANCISCO
+Mr Covu. Exp. FEB. 27, 2012
+State of California, City & County of San Francisco
+Subscribed and sworn to (or affirmed) before me on this
+do more, by Gilbert Kinceeu
+proved to me on the basis of sailsfactory evidence
+i do no need a lockde .
+5

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vision-fixhub/court-01/daf5bf48cefd41a366de5cbaec568d064fd462893595143702eaa202e8979493.md

@@ -0,0 +1,115 @@
+Case 9:09-cv-80469-KAM Document 23 Entered on FLSD Docket 05/29/2009 Page 1 of 4
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+JANE DOE NO. 2,
+Plaintiff,
+CASE NO.: 08-CV-80119-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 3,
+Plaintiff.
+CASE NO.: 08-CV-80232-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 4,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 5,
+Plaintiff,
+CASE NO.: 08-CV-80380-MARRA/
+CASE NO.: 08-CV-80381-MARRA/C_
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+
+
+Case 9:09-cv-80469-KAM Document 23 Entered on FLSD Docket 05/29/2009 Page 2 of 4
+JANE DOE NO. 6,
+Plaintiff,
+CASE NO.: 08-CV-80994-MARRA
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 7,
+Plaintiff,
+CASE NO.: 08-CV-80993-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+C.M.A.,
+Plaintiff,
+CASE NO.: 08-CV-80811-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE,
+Plaintiff,
+CASE NO.: 08-CV-80893-MARRAJ_
+vS.
+JEFFREY EPSTEIN et al,
+Defendants.
+-2-
+
+
+Case 9:09-cv-80469-KAM Document 23 Entered on FLSD Docket 05/29/2009 Page 3 of 4
+DOE II,
+Plaintiff,
+CASE NO.: 09-CV-80469-MARRA/
+VS.
+JEFFREY EPSTEIN et al,
+Defendants.
+JANE DOE NO. 101,
+Plaintiff,
+CASE NO.: 09-CV-80591-MARRA/JOHNSON
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 102
+Plaintiff,
+/
+CASE NO.: 09-CV-80656-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+UNITED STATES' NOTICE OF LIMITED APPEARANCE
+AS AMICUS CURIAE TO FILE RESPONSE TO COURT'S ORDER
+REQUESTING POSITION ON DEFENDANT'S MOTION TO STAY [DE 99]
+Comes now the United States, by and through the undersigned Assistant United States
+Attorney, and makes this limited appearance to file via CM/ECF its response to the Court's
+Order requesting the position of the United States on Defendant Jeffrey Epstein's Motion to
+Stay Proceedings [DE 99]. By filing this notice of limited appearance and its response, the
+United States does not make itself a party to this litigation and takes no position with respect
+-3-
+
+
+Case 9:09-cv-80469-KAM Document 23 Entered on FLSD Docket 05/29/2009 Page 4 of 4
+to the outcome of any of the civil suits. By filing this notice of limited appearance and
+response, the United States also does not waive any procedural or statutory bars to suit.
+Respectfully submitted,
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+S/A
+A.
+Villafaña
+VILLAFAÑA
+Assistant United States Attorney
+Florida Bar No. 0018255
+500 East Broward Boulevard, 7th Floor
+Ft. Lauderdale, FL 33394
+Telephone: 954-356-7255
+Facsimile: 954-356-7230
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on May 28, 2009, I electronically filed the foregoing
+document with the Clerk of the Court using CM/ECF. According to the Court's website, counsel
+for all parties are able to receive notice via the CM/ECF system.
+S/A.
+Villafaña
+A.
+VILLAFAÑA
+Assistant United States Attorney
+-4-

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vision-fixhub/court-01/db0a74843145c8e4d7e6fa7d0fe9fc342a95a8ece35e67239a3c7aafc2f35a21.md

@@ -0,0 +1,227 @@
+Case 9:08-cv-80119-KAM Document 443-1 Entered on FLSD Docket 12/29/2009 Page 1 of 4
+Page 308
+JANE DOE NO. 2,
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA/
+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
+VOLUME III OF III
+/
+VIDEO-CONFERENCED AND VIDEOTAPED DEPOSITION OF
+JANE DOE NO.
+4
+Tuesday, October 27, 2009
+11:11 - 6:05 p.m.
+250 Australian Avenue South
+Suite
+115
+West Palm Beach, Florida 33401
+Reported By:
+Cynthia I
+1, RPR, FPR
+Notary Public, State of Florida
+Prose Court Reporting
+(561) 832-7500
+cc1ec48b-651e-487e-Bbb1-b2f478ed0edd
+
+
+Case 9:08-cv-80119-KAM Document 443-1 Entered on FLSD Docket 12/29/2009 Page 2 of 4
+Page 311
+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
+(561) 832-7500
+*****
+CONTINUED DIRECT EXAMINATION
+THE VIDEOGRAPHER: It is the beginning of
+Tape Number 3. We're back on the record at
+4:19.
+BY MR. LUTTIER:
+l. All right. When did you have your first
+abortion?
+A.
+Sixteen.
+l. Which would have been -- what year was
+that?
+A. I think it was, I don't remember, but I
+think it was when I was 16.
+l. Let's see, you were a senior --
+A.
+A sophomore.
+e.
+-- you were 17 when you were a senior,
+right?
+A.
+It might have been my sophomore or junior
+year. I don't remember.
+e.
+Sophomore or junior year in high school?
+A.
+Yeah.
+e. And where did you have that abortion?
+A. I don't remember what the place was
+called, The Pres -- Pres --
+l. Presidential Women's Clinic?
+PROSE COURT REPORTING AGENCY, INC.
+1(601-051-976-2934)
+cc1ec48b-651e-487e-Bbb1-b2t478edOedd
+
+
+Case 9:08-cv-80119-KAM Document 443-1 Entered on FLSD Docket 12/29/2009 Page 3 of 4
+Page 312
+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
+A.
+e.
+A.
+Yeah, I think so.
+Over on Congress Avenue?
+Yeah.
+And did you register under your real name?
+A.
+Yeah.
+e.
+Did anybody go with you?
+A. Yeah.
+Who?
+A.
+And who was the daddy of that baby?
+A.
+e.
+A.
+And who paid for it?
+A.
+Do you know what it cost?
+$300, I think.
+Was that the first time you were pregnant?
+A. Yeah.
+l. And would you agree with me, that age 16
+to have to go have an abortion was traumatic to you?
+MR. MERMELSTEIN: Objection to form.
+THE WITNESS: Yeah.
+BY MR. LUTTIER:
+e.
+When was your second abortion?
+A.
+In my senior year in high school.
+That was when you were 17?
+(561) 832-7500
+PROSE COURT REPORTING AGENCY, INC.
+ce1ec48b-651e-487e-8bb1-b2f478edOedd
+
+
+Case 9:08-cv-80119-KAM Document 443-1 Entered on FLSD Docket 12/29/2009 Page 4 of 4
+Page 313
+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
+was.
+(561) 832-7500
+A.
+e.
+A.
+Yes.
+And where did you get that one?
+Same place.
+You registered under your real name?
+A.
+Yes.
+l. Did anybody go with you?
+A.
+Yes.
+Who?
+A.
+Who was the daddy?
+A.
+e.
+A.
+Who paid for it?
+Now, I, I assume at some point in your
+life somebody explained to you what birth control
+A. Yeah.
+l. After you aborted one child, didn't you
+use birth control to keep from getting pregnant?
+A. Yeah, I did. I was using birth control.
+e. And so, obviously, if you had the baby,
+your first baby if you were pregnant at 16 --
+A. I wasn't using birth control then.
+MR. MERMELSTEIN: How about letting him
+finish. Let him finish.
+PROSE COURT REPORTING AGENCY, INC.
+ce1ec48b-651e-487e-Bbb1-b21478edOedd

vision-fixhub/court-01/db0a74843145c8e4d7e6fa7d0fe9fc342a95a8ece35e67239a3c7aafc2f35a21.receipt.json

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vision-fixhub/court-01/db28e5a6be31a5165704787d8b78e44475bbbbb9892b955596dd9ca8f3063034.md

@@ -0,0 +1,104 @@
+Case 1:20-cv-02365-LJL-DCF Document 35 Filed 08/13/21 Page 1 of 5
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+JANE DOE,
+Plaintiff.
+V.
+DARREN K INDYKE and RICHARD D. KAHN, in
+their capacities as executors of THE ESTATE OF
+JEFFERY E. EPSTEIN,
+Defendants.
+Case No. 1:20-cv-02365-LJL-DCF
+CO-EXECUTORS' STATEMENT ON PLAINTIFF'S
+APPLICATION TO PROCEED ANONYMOUSLY
+TROUTMAN PEPPER
+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,
+Co-Executors of the Estate of Jeffrey E. Epstein
+
+
+
+Case 1:20-cv-02365-LJL-DCF Document 35 Filed 08/13/21 Page 2 of 5
+Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey
+E. Epstein (the "Co-Executors")', respectfully submit this Statement On Plaintiff Jane Doe's
+("Plaintiff") Application to Proceed Anonymously (ECF No. 31) (the "Application").
+I. The Co-Executors Have Never Opposed The Right Of Alleged Victims To Maintain
+Anonymity And Do Not Do So Here.
+The Co-Executors have never sought to prevent any alleged victim of Mr. Epstein from
+proceeding anonymously; they do not do so here. To the contrary, after Mr. Epstein's death, the
+Co-Executors established and funded in its entirety the independently administered Epstein
+Victims' Compensation Program, which gave Mr. Epstein's alleged victims the opportunity to
+resolve their claims in complete confidence if they so desired.? The Program ultimately awarded
+nearly $125 million to approximately 150 eligible claimants.?
+Nevertheless,
+in this unique situation, the Co-Executors have determined that it is
+appropriate to bring to the Court's attention material facts not contained in Plaintiff's Application,
+so that the Court can rule on it with the benefit of all relevant information, as follows: (1) Plaintiff
+(2) Plaintiff has,
+and (3) Plaintiff has
+' The captions in Plaintiff's Notice of Motion to Proceed Anonymously (ECF No. 29), Memorandum of Law in
+Support of Plaintiff's Application to Proceed Anonymously (ECF No. 31), and the Declaration of Daniel J. Kaiser
+(ECF No. 30) list more than two dozen defendants who are not parties to this action. Plaintiff's Complaint (ECF No.
+1), which has not been amended, was brought only against Darren K. Indyke and Richard D. Kahn, in their capacities
+as executors of the Estate of Jeffrey E. Epstein. Accordingly, this Statement is filed on behalf of the Co-Executors
+only.
+2 No claimant who participated in the Program is bound by any rules of confidentiality—to the contrary, they are free
+to tell their stories publicly.
+' See https://www.epsteinvep.com/documents/67.(The Declaration of Bennet J. Moskowitz, filed contemporaneously
+herewith, provides true and correct copies of all
+- 2-
+
+
+
+Case 1:20-cv-02365-LJL-DCF Document 35 Filed 08/13/21 Page 3 of 5
+Il.
+Plaintiff's
+As Plaintiff explains in her Application, when determining whether to permit a party to
+proceed under a pseudonym, the Second Circuit considers at least ten non-exhaustive factors
+pursuant to Sealed Plaintiff. Doe v. Zinsou, 2019 U.S. Dist. LEXIS 131520, at *7-8 (S.D.N.Y.
+Aug. 6, 2019) (Ramos, J.) (citing Sealed Plaintiff v. Sealed Defendant, 537 F.3d 185, 188-89 (2d
+Cir. 2008)). Relevant to this discussion are the factors related to Plaintiff's identity.
+Plaintiff is
+and has
+In fact, Plaintiff's
+, as follows:
+This
+- 3-
+
+
+
+Case 1:20-cv-02365-LJL-DCF Document 35 Filed 08/13/21 Page 4 of 5
+Plaintiff also volunteered
+Plaintiff has also
+Plaintiff was also
+Accordingly, it is subject to judicial notice. See, e.g., Sharette v. Credit Suisse Int'l, 127 F.
+(ellipsis in original)).
+- 4-
+
+
+
+Case 1:20-cv-02365-LJL-DCF Document 35
+Filed 08/13/21
+
+Plaintiff
+III. Conclusion
+While the Co-Executors take no position on Plaintiff's Application to Proceed
+Anonymously, they believe the Court should decide it with the benefit of all relevant information.
+Dated: New York, New York
+August 13, 2021
+Respectfully submitted,
+TROUTMAN PEPPER |
+SANDERS LLP
+875 Third Avenue
+New York, New York 10022
+By: _Is/ Bennet J. Moskowitz
+Bennet J. Moskowitz
+Attorneys for Defendants Darren K. Indyke and
+Richard D. Kahn, Co-Executors of the Estate of
+Jeffrey E. Epstein
+- 5-
+

vision-fixhub/court-01/db28e5a6be31a5165704787d8b78e44475bbbbb9892b955596dd9ca8f3063034.receipt.json

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+}

vision-fixhub/court-01/db467d68d53553387a1fca33ad1798b9c25350b20dac4e90bbf5adf3c0b834ba.md

@@ -0,0 +1,547 @@
+Case 9:09-cv-80656-KAM Document 38 Entered on FLSD Docket 07/10/2009 Page 1 of 16
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+JANE DOE NO. 2,
+Plaintiff
+VS.
+JEFFREY EPSTEIN,
+Defendant
+JANE DOE NO. 3,
+Plaintiff
+CASE NO: 08-CV-80232-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant
+JANE DOE NO. 4,
+Plaintiff
+CASE NO: 08-CV-80380-MARRA/_
+VS.
+JEFFREY EPSTEIN,
+Defendant
+
+
+Case 9:09-cv-80656-KAM Document 38 Entered on FLSD Docket 07/10/2009 Page 2 of 16
+JANE DOE NO. 5,
+Plaintiff
+CASE NO: 08-CV-80381-MARRA/_
+VS.
+JEFFREY EPSTEIN,
+Defendant
+JANE DOE NO. 6.
+Plaintiff
+CASE NO: 08-CV-80994-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant
+JANE DOE NO. 7,
+Plaintiff
+CASE NO: 08-CV-80993-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant
+2
+
+
+Case 9:09-cv-80656-KAM Document 38 Entered on FLSD Docket 07/10/2009 Page 3 of 16
+CASE NO: 08-CV-80811-MARRA/
+C.M.A.,
+Plaintiff
+VS.
+JEFFREY EPSTEIN,
+Defendant
+JANE DOE,
+Plaintiff,
+CASE NO. 08-CV-80893-CIV-MARRA/_
+Vs.
+JEFFREY EPSTEIN, et al.
+Defendant.
+DOE II,
+CASE NO: 09-CV-80469-MARRA/
+Plaintiff
+VS.
+JEFFREY EPSTEIN, et al.
+Defendants.
+3
+
+
+Case 9:09-cv-80656-KAM Document 38 Entered on FLSD Docket 07/10/2009 Page 4 of 16
+JANE DOE NO. 101,
+Plaintiff
+CASE NO: 09-CV-80591-MARRA/|
+VS.
+JEFFREY EPSTEIN,
+Defendant
+JANE DOE NO. 102,
+Plaintiff
+CASE NO: 09-CV-80656-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant
+PLAINTIFF JANE DOE'S MOTION TO COMPEL ANSWERS TO PLAINTFF'S FIRST
+REQUEST FOR PRODUCTION
+Plaintiff Jane Doe, hereby moves this Court for an order compelling defendant,
+Jeffrey Epstein, to answer her first request for production or, in the alternative, to prove
+that his invocation of his Fifth Amendment privilege is proper. Jane Doe also requests
+production of a privilege log.
+Jane Doe has propounded 16 requests for production, including such
+straightforward requests as requests for production of:
+4
+
+
+Case 9:09-cv-80656-KAM Document 38 Entered on FLSD Docket 07/10/2009 Page 5 of 16
+Request No. 1: Copies of all telephone records;
+Request No. 2: Photos of the inside of your home located at 358 El Brillo Way,
+Palm Beach, Florida, that depict the rooms) where massages took place (including
+massage table).
+Request No. 10: Correspondence between Epstein and federal prosecutors;
+Request No. 12: Personal tax returns;
+Request No. 13: Photocopies of Epstein's passport;
+Request No. 14: A statement of net worth; and
+Request No. 16: Medical records.
+In response to each and every one of these requests, Epstein has given the
+following response (with only minor variations here and there):
+Defendant is asserting his U.S. constitutional privileges. I intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+This Court should order Epstein to provide all of the requested information or, in
+the alternative, prove that his Fifth Amendment invocations are valid. It is for the court,
+not the claimant, to determine whether the hazard of incrimination is justified. United
+States v. Argomaniz, 925 F.2d 1349, 1355 (11th Cir. 1991). "A court must make a
+particularized inquiry, deciding, in connection with each specific area that the
+5
+
+
+Case 9:09-cv-80656-KAM Document 38 Entered on FLSD Docket 07/10/2009 Page 6 of 16
+questioning party wishes to explore, whether or not the privilege is well-founded." Id.
+Typically this is done in an in camera proceeding wherein the person asserting the
+privilege is given the opportunity "to substantiate his claims of the privilege and the
+district court is able to consider the questions asked and the documents requested by
+the summons." Id.
+Here Epstein has made boilerplate invocation of the Fifth Amendment to each
+and every request propounded by Jane Doe, including for example the request for
+correspondence with federal prosecutors and for production of federal tax returns. This
+obviously is not a request with Fifth Amendment implications, as the information has
+already been fully disclosed to the Government.
+For all these reasons, the Court should compel Epstein to answer the requests or
+provide a particularized justification for his Fifth Amendment invocation with regard to
+each request.
+Epstein's "cut and paste" response to the request for production also blatantly
+disregards the requirements for invoking privilege under the Court's local rules. Local
+rule 26.1.G very specifically requires the preparation of a privilege log with respect to all
+documents and oral communications (among other things) that are withheld on the
+basis of privilege. Epstein has failed to prepare such a log, making it impossible for
+Jane Doe to effectively challenge his generic assertions. Indeed, with respect to a few
+requests, Epstein has stated: "Further, the request may include information subject to
+work product or an attorney-client privilege." Of course, the whole purpose of forcing a
+defendant to prepare a privilege log is to force the defendant to decide whether or not
+6
+
+
+Case 9:09-cv-80656-KAM Document 38 Entered on FLSD Docket 07/10/2009 Page 7 of 16
+information is privileged. An assertion that something "may" be privileged is obviously
+woefully deficient. The Local Rules do not permit this tactic, and Epstein should be (at a
+minimum) promptly required to produce a privilege log.
+For all these reasons, the Court should compel Epstein to provide a privilege log
+and to answer the interrogatories or provide a particularized justification for his Fifth
+Amendment invocation with regard to each request.
+It should be noted that (with minor exceptions) the only grounds on which Epstein
+can refuse to answer the request for production is proof of a valid Fifth Amendment
+privilege. This the only objection Epstein has asserted (with minor exceptions). As a
+result, any other objections to production are deemed waived. See Local Rule
+26.1G.3.(a) ("Any ground [for an objection] not stated in an objection within the time
+provided by the Federal Rules of Civil Procedure, or any extensions thereof, shall be
+waived.").
+SPECIFIC REQUESTS FOR PRODUCTION
+For the convenience of the court - and in compliance with Local Rule 26.1 H
+(party filing motion to compel shall list specific requests in succession) - Jane Doe's
+requests for production and Epstein's objections are as follows:
+Request No. 1: Copies of all telephone records in your or your attorney's possession
+from 2002 through 2005 that in any way relate to you (including all phone lines owned
+by you or that were used to contact girls for the purposes of scheduling massages for
+you.)
+Defendant is asserting his U.S. constitutional privileges. I intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time | cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+7
+
+
+Case 9:09-cv-80656-KAM Document 38 Entered on FLSD Docket 07/10/2009 Page 8 of 16
+representation. Accordingly, I assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States
+: Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+Request No. 2: All massage appointment books, diaries, computer calendars or
+scheduling entities, scheduling books or any other writing or correspondence that
+contains the names of any of the girls that were called, contacted, scheduled or who
+otherwise went to your home located at 358 El Brillo Way, Palm Beach, Florida, for the
+purpose of giving you a massage.
+Defendant is asserting his U.S. constitutional privileges. | intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+Request No. 3: Any and all documentation in your possession that contains Plaintiff's
+name or that refers to Plaintiff, directly or indirectly, (includes e-mails, letters, message
+pads, diaries, appointment books, computer print outs).
+Defendant is asserting his U.S. constitutional privileges. I intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my federal constitutional rights under
+the Filth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+Request No. 4: Any and all photos, videos, downloaded digital prints or any other visual
+depiction of Plaintiff, or of any other known or suspected minor females introduced to
+you, directly or indirectly, by Plaintiff.
+8
+
+
+Case 9:09-cv-80656-KAM Document 38 Entered on FLSD Docket 07/10/2009 Page 9 of 16
+Defendant is asserting his U.S. constitutional privileges. I intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+Request No. 5: Photos of the inside or your home located at 358 El Brillo Way, Palm
+Beach, Florida, that depict the rooms) where the massages too place (including
+massage table).
+Defendant is asserting his U.S. constitutional privileges. | intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time | cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+Request No. 6: Any and all documentation of cancelled checks or evidence of payment
+to Plaintiff of any kind and for any reason whatsoever.
+Defendant is asserting his U.S. constitutional privileges. I intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time | cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+9
+
+
+Case 9:09-cv-80656-KAM Document 38 Entered on FLSD Docket 07/10/2009 Page 10 of 16
+Request No. 7: All discovery information obtained by you or your attorneys as a result
+of the exchange of discovery in the State criminal case against you or the Federal
+investigation against you.
+Defendant is asserting his U.S. constitutional privileges. I intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my tederal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States Constitution.
+Drawing an adverse
+inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+In addition to and without waiving his constitutional
+privileges, the information sought is privileged and confidential, and
+inadmissible to the terms of the deferred prosecution agreement, Federal
+Rule of Evidence 410 and 408, and § 90.410, Fla. Stat.'
+Further, the
+request may including information subject to work product or an attorneyclient privilege.
+Request No. 8: All financial documents evidencing asset transfers from 2005 to present
+for you personally or any company or corporation owned by you.
+Defendant is asserting his U.S. constitutional privileges. | intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+"Jane Doe does not intend to use these materials to draw a forbidden inference of guilt from the mere
+the non-prosecution agreement, nothing in that agreement bars discovery of information relevant to this
+10
+
+
+Case 9:09-cv-80656-KAM Document 38 Entered on FLSD Docket 07/10/2009 Page 11 of 16
+Request No. 9: Any documents or other evidentiary materials provided to local, state,
+or federal law enforcement investigators or local, state or federal prosecutors
+investigating your sexual activities with minors.
+Defendant is asserting his U.S. constitutional privileges. | intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+In addition to and without waiving his constitutional
+privileges, the information sought is privileged and confidential, and
+inadmissible pursuant to the terms of the deferred prosecution agreement,
+Fed. Rule of Evidence 410 and 408, and § 90.410, Fla. Stat. 2
+Further,
+the request may include information subject to work product or an
+attorney-client privilege.
+Request No. 10: All correspondence between you and your attorneys and state or
+federal law enforcement or prosecutors (includes, but not limited to, letters to and from
+the States Attorney's office or any agents thereof).
+Defendant is asserting his U.S. constitutional privileges. | intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States
+Constitution.
+Drawing
+an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+In addition to and without waiving his constitutional
+privileges, the information
+sought is privileged and confidential, and
+inadmissible pursuant to the terms of the deferred prosecution agreement,
+* Jane Doe does not intend to use these materials to draw a forbidden inference of guilt from the mere
+fact of plea discussions, but rather for other purposes.
+These materials are also likely to lead to the
+discovery of other admissible evidence.
+To the extent that Epstein relies on the non-prosecution
+agreement, nothing in that agreement bars discovery of information relevant to this lawsuit.
+11
+
+
+Case 9:09-cv-80656-KAM Document 38 Entered on FLSD Docket 07/10/2009 Page 12 of 16
+Fed. Rule of Evidence 410 and 408, and § 90.410, Fla. Stat. Further,
+the request may include information subject to work product or an
+attorney-client privilege.
+Request No. 11: Any and all documents reflecting your current net worth.
+Defendant is asserting his U.S. constitutional privileges. | intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+Request No. 12: Personal tax returns for all years from 2002 through the present.
+Defendant is asserting his U.S. constitutional privileges. | intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States
+Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution; overly broad.
+Request No. 13: A photocopy of your passport, including any supplemental pages
+reflecting travel to locations outside the 50 United States between 2002 and 2008,
+including any documents or records regarding plane tickets, hotel receipts, or
+transportation arrangements.
+" Jane Doe does not intend to use these materials to draw a forbidden inference of guilt from the mere
+fact of correspondence in connection with plea discussions, but rather for other purposes. These
+naterials are also likely to lead to the discovery of other admissible evidence. To the extent that Epstein
+relies on the non-prosecution agreement, nothing in that agreement bars discovery of information relevant
+to this lawsuit.
+12
+
+
+Case 9:09-cv-80656-KAM Document 38 Entered on FLSD Docket 07/10/2009 Page 13 of 16
+Defendant is asserting his U.S. constitutional privileges. I intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, 1 assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution. In addition to and without waiving his constitutional
+protections and privileges, the scope of information is so overbroad that it
+seeks information that is neither relevant nor reasonably calculated to lead
+to the discovery of admissible evidence; compiling such information over a
+six year period would be unduly burdensome and time consuming.*
+Request No. 14: A sworn statement of your net worth (including a detailed financial
+statement depicting all current assets and liabilities).
+Defendant is asserting his U.S. constitutional privileges. I intend to respond to all
+relevant questions regarding this lawsuit, however, my attorneys have counseled me
+that at the present time I cannot select authenticate, and produce documents relevant to
+this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to
+effective representation. Accordingly, I assert my federal constitutional rights under the
+Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States
+Constitution.
+Drawing an adverse inference under these circumstances would
+unconstitutionally burden my exercise of my constitutional rights, would be
+unreasonable, and would therefore violate the Constitution.
+Request No. 15: All financial statements or affidavits produced by you for any reason,
+to any person, company, entity or corporation since 2005.
+Defendant is asserting his U.S. constitutional privileges. 1 intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+* Jane Doe believes that Epstein used overseas travel as a means of obtaining underage girls for sexual
+purposes and for avoiding criminal prosecution for such activities. Also, providing a copy of a passport is
+hardly "burdensome." Also, given the fact that Epstein is likely to have used the services of a travel agent
+or another intermediary, it should not be difficult for him to provide evidence of his overseas travels from
+such intermediaries.
+13
+
+
+Case 9:09-cv-80656-KAM Document 38 Entered on FLSD Docket 07/10/2009 Page 14 of 16
+States Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution; overly broad.
+Request No. 16: All medical records of Defendant Epstein from Dr. Stephan Alexander.
+Defendant is asserting his U.S. constitutional privileges. I intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my tederal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+CONCLUSION
+For all these reasons, the Court should compel Epstein to answer the request for
+production, or provide a particularized justification for his Fifth Amendment invocation
+with regard to each request. Epstein should also be required to provide a privilege log.
+Counsel for Jane Doe have conferred with opposing counsel on the issues raised in this
+motion, and no resolution was possible.
+DATED July 10, 2009
+Respectfully Submitted,
+J.l
+J.
+ROTHSTEIN ROSENFELDT ADLER
+Las Olas City Centre
+401 East Las Olas Blvd., Suite 1650
+Fort Lauderdale, Florida 33301
+Telephone (954) 522-3456
+Facsimile (954) 527-8663
+Florida Bar No.: 54207:
+E-mail: bedwards@rra-law.com
+14
+
+
+Case 9:09-cv-80656-KAM Document 38 Entered on FLSD Docket 07/10/2009 Page 15 of 16
+and
+Paul G. Cassell
+Pro Hac Vice
+332 S. 1400 E.
+Salt Lake City, UT 84112
+Telephone: 801-585-5202
+Facsimile:
+801-585-6833
+E-Mail:
+cassellp@law.utah.edu
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on July 10, 2009, I electronically filed the foregoing
+document with the Clerk of the Court using CM/ECF. I also certify that the foregoing
+document is being served this day on all parties on the attached Service List in the
+manner specified, either via transmission of Notices of Electronic Filing generated by
+CM/ECF or in some other authorized manner for those parties who are not authorized to
+receive electronically filed Notices of Electronic Filing.
+S/
+J.
+J.
+15
+
+
+Case 9:09-cv-80656-KAM Document 38 Entered on FLSD Docket 07/10/2009 Page 16 of 16
+SERVICE LIST
+Jane Doe V. Jeffrey Epstein
+United States District Court, Southern District of Florida
+Jack Alan Goldberger, Esq.
+Jgoldberger@agwpa.com
+Robert D. Critton, Esq.
+rcritton@bclclaw.com
+Isidro Manual
+isidrogarcia@bellsouth.net
+Jack
+iph@searcylaw.com
+Katherine Warthen Ezell
+KEzell@podhurst.com
+Michael James Pike
+MPike@bclclaw.com
+Paul G. Cassell
+cassellp@bclclaw.com
+Richard Horace Willits
+lawyerswillits@aol.com
+Robert C. Josefsberg
+rjosefsberg@podhurst.com
+Adam D. Horowitz
+ahorowitz@sexabuseattorney.com
+Stuart S. Mermelstein
+ssm@sexabuseattorney.com
+William J. Berger
+wberger@rra-law.com
+16

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vision-fixhub/court-01/db4db5346da855457ad2d6aeb03c562a6ee0502e86f6496e80783e99003a4381.md

@@ -0,0 +1,1709 @@
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 1 of 32
+1
+.. D.C.
+THE UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA (FILED by_
+CASE NO. 08-80736-CIV-MARRA
+JUL 1 7 2008
+STEVEN M. LARIMORE
+CLERK US. DIST CT
+S. D. of FLA. - MIAMI
+IN RE: JANE DOE,
+Plaintiff,
+VS.
+UNITED STATES OF AMERICA,
+Defendant.
+ORIGINAL
+JUL 1 8/2008
+STEVEN M. LARIMORE
+CLERK U.S. DIST. CT
+S.D. of FLA. - MIAMI
+./
+Federal Courthouse
+West Palm Beach, Florida
+July 11, 2008
+10:15 a.m.
+The above entitled matter came on for
+Emergency Petitioner for Enforcement of Crime Victim
+Rights before the Honorable Kenneth A. Marra,
+pursuant to Notice, taken before Victoria Aiello,
+Court Reporter, pages 1-32.
+For the Plaintiff:
+Esquire
+For the Defendant: Dexter Lee, AUSA
+Maria Villafana, AUSA
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 2 of 32
+2
+1
+2
+(Call to Order of the Court).
+THE COURT: Good morning. Please be seated.
+This is the case of In Re: Jane Doe, Case
+4
+Number 08-80736-Civ-Marra. May I have counsel state
+5
+their appearances, please?
+6
+MR. LEE: Good morning, Your Honor. May it
+7
+please the Court, for the United States of America,
+8
+9
+we have Maria Villafana, Assistant United States
+Attorney and Dexter Lee, Assistant United States
+10
+Attorney. And we have seated in the front row FBI
+11
+Special Agent Becker Kendall and Jason Richards.
+12
+13
+14
+15
+16
+Thank you, Your Honor.
+MR.
+: Good morning, Your Honor. Brad
+on behalf of the petitioners. Petitioners
+are also in the courtroom today. This petition is
+styled on her behalf.
+17
+18
+THE COURT: Good morning. All right. We're
+here on the petitioner's motion to enforce her
+19
+20
+21
+22
+rights as a victim under 18 USC 3771. I have
+received the petition, the government's response and
+the victim's reply, which was filed, I guess, this
+morning. So, You want to proceed, counsel?.
+23
+24
+MR.
+at the podium?
+: Yes, Your Honor. You prefer me
+25
+THE COURT: It is easier for us to hear you.
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 3 of 32
+3
+1
+2
+3
+MR.
+: Your Honor, as a factual
+background, Mr. Epstein is a billionaire that
+sexually abused and molested dozens and dozens of
+4
+girls between the ages of 13 and 17 years old. And
+5
+6
+through cooperating victims, that evidence can be
+proven. Because of his deviant appetite for young
+7
+8
+girls, combined with his extraordinary wealth and
+power, he may just be the most dangerous
+sexual
+9
+predator in U.S. history. This petitioner is one of
+10
+the victims and she is in attendance today. Another
+11
+one of Mr. Epstein's victims is also in attendance
+12
+13
+today. She would be able to provide evidence that
+she provided-- that Mr. Epstein paid her to provide
+14
+him over 50 girls for the purposes of him to
+15
+sexually abuse. Therefore, the undercurrents of the
+16
+petition are clear. The plea bargain that was
+17
+worked out for Mr. Epstein in light of the offenses
+18 that he committed is clearly unfair to the point
+19
+that if anybody looks at the information, it is
+20
+unconscionable.
+21
+THE COURT: Well, I mean, is that for me?
+22
+That's not my role. That's the prosecutor's role to
+23
+apply, would it not? I can't force them to bring
+24
+criminal charges. What do I have to do with that.
+25
+MR.
+: Okay.
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 4 of 32
+4
+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
+THE COURT: That may be your opinion, that
+may be your client's opinion, but I presume that the
+government is aware that that's your client's
+opinion. How does that change anything?
+MR.
+: That's my problem. I'm not
+sure that the government is aware that is
+petitioner's opinion and that's why we're here
+today, just to enforce the victim's rights under 18
+USC 3771, Crime Victims Rights Act, and all we are
+asking is to order that the plea agreement that has
+been negotiated in this case--
+THE COURT: How do you know there is a plea
+agreement? The plea agreement is with the State of
+Florida, wasn't it?
+MR.
+: There was a state charge with
+one victim that I'm aware of. And the plea
+agreement as to that one victim was 18 months in the
+county jail. But along with that, the Palm Beach
+County Sheriff investigating this case was getting
+no action out of the local authorities and sent this
+to the FBI.
+THE COURT: It was actually the Palm Beach--
+Town of Palm Beach Police, not the Sheriff's Office.
+MR.
+: I'm sorry, Judge. And that's
+why the FBI got involved because Michael Feeter
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 5 of 32
+5
+1
+wrote a scathing letter to the State Attorney about
+2
+Mr. Epstein receiving preferencial treatment by
+3
+local authorities.
+4
+Before the FBI took the case, they went
+5 behind the victim's back, and this is our motion,
+6
+without the victim's input and allowing her the
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+right to meaningfully confer with the government,
+which is a right that she can assert at this time.
+They worked out a plea deal where if Mr. Epstein
+would plead to this other charge regarding another
+victim in the state court case, they would agree to
+not prosecute him for all of the federal charges of
+what they were aware of in federal court..
+THE COURT: So that's already apparently
+taken place, correct?
+MR.
+: I don't know if it has taken
+place. I'm not sure exactly what stage it is in. I
+know it is supposed to be attached at some point in
+time to a state court plea.
+THE COURT: Hasn't he already plead guilty,
+though?
+25
+MR.
+: If he did plead guilty, it is
+my understanding and belief that the agreement with
+the federal government and with the U.S. Attorney's
+Office wasn't signed on that day. So it is still my
+
+
+Case 9:08-cV-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 6 of 32
+6
+1
+belief, I could be wrong, but that that agreement
+2
+hasn't been completed as of this time.
+3
+THE COURT: So let's assume it hasn't been
+4
+completed.
+5
+MR.
+: Okay. Then petitioner would
+6
+like the right to confer with--
+7
+THE COURT: You can go in the conference
+8
+room. We've got the FBI agents, you've got the
+9 assigned prosecuting attorney. You have got a
+10 conference room. You've got your client. Go and
+11
+talk. Confer. And then it is up government to
+12
+decide what to do, correct?
+13
+MR.
+: In a way, Your Honor, that's
+14
+very similar to what happened in In Re: |
+and PB
+15
+case where there is a plea agreement negotiated and
+16
+then the victim gets the right to confer.
+17
+THE COURT: It's already negotiated. What
+18
+am I supposed to do?
+19
+MR.
+: Order that the agreement that
+20
+was negotiated is invalid and it is illegal as it
+21
+did not pertain to the rights of the victim.
+22
+THE COURT: I can order you into the
+23
+conference room. Then the government can do what it
+24
+chooses. It can agree to prosecute or it can agree
+25
+to going forward with the agreement it had already
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 7 of 32
+7
+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
+reached and after consulting your client and in
+taking into consideration your client's views,
+decide to go forward anyway. I can't make them
+prosecute him. I can't-- All I can do is, at best,
+say confer with the victim, consider the victim's
+input before you make a decision or reconsider the
+decision you already made in view of the victim's
+input, if it is possible for you to do that.
+So if
+I invalidate the agreement, what's the best you can
+get? The right to confer?
+MR.
+: Exactly. That is all we can.
+THE COURT: So why can't you go into the
+conference room now, take as much time as you feel
+you need and confer?
+MR.
+: Judge, at this time I'd like to
+move ore tenus to add the victim that's in the
+courtroom to this conference with the U.S.
+Attorney's Office.
+THE COURT: So is that Jane Doe 2 for
+purposes of this?
+MR.
+: Exactly, Your Honor.
+THE COURT: All right. Let me hear from the
+government then.
+MR. LEE:. Good morning, Your Honor. May it
+please the Court.
+
+
+Case 9:08-cV-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 8 of 32
+8
+1
+2
+3
+4
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Let me update the Court on the status of
+various matters.
+The agreement to defer prosecution
+to the State of Florida was signed and completed by
+December of 2007. Mr. Epstein's attorneys saught a
+higher review within the Department of Justice and
+it took a number of months for that to come to
+fruition. When it came to fruition, he ended up
+pleading guilty on June 30, 2008 to two charges in
+state court, and he was sentenced to a term of
+incarceration of 18 months, with another 12 months
+of community control after the completion of his
+sentence, and he is currently incarcerated as we
+speak.
+We have two arguments, Your Honor. First,
+insofar as the right that they claim under
+3771 (a) (5), their right to confer in the case, we
+respectfully submit that there was no case in
+federal court and, indeed, none was contemplated if
+the plea agreement was to be successfully completed,
+since it contemplated the State of Florida sentence
+on the criminal charges. So as long as certain
+conditions were met and certain federal interests
+were vindicated, the federal government was
+satisfied that this was an appropriate disposition.
+Insofar as the best effort, Your Honor, we
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 9 of 32
+9
+1
+have cited the Attorney General's guidelines.
+The
+2
+guidelines do say that you should normally advise
+3
+victims of plea negotiations and the terms of the
+4
+plea, but they recognize that there are times when
+5
+they may not be appropriate or could cause some harm
+6
+or prejudice, and they set out six factors which are
+7
+to be considered, non-exhaustive factors.
+8
+we have advised, in the declaration of AUSA
+9 Villafana that when the subject of having Mr.
+10
+Epstein concede that he would be convicted of an
+11
+enumerated offense for purposes of a cause of action
+12
+13
+under 18 USC 2255, there was a rather strenuous
+objection from Mr. Epstein's counsel that the
+14
+15
+federal government was inducing some effort to
+either fabricate claims, enhance claims or embellish
+16
+claims and if this agreement ultimately could not be
+17
+18
+consumated, then we'd have a federal prosecution on
+our hands, and we did not want to be in a positin of
+19
+creating additional impeachment material.
+20
+I can't say that the stand by Mr.
+21
+that the arguments of inducement in a subsequent
+22 civil action can be made by any criminal victim,
+23
+that is true. It is another thing for that
+24
+inducement to have come before the prosecution
+25
+arguing about the credibility and veracity of the
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 10 of 32
+10
+1
+individual. That was a considerably strong point, in
+2
+essence,
+in not discussing those terms with the
+3
+victims as might ordinarily be done if those
+4
+considerations did not exist.
+5
+So, first, Your Honor, we believe that
+6
+3771 (a) (5) does not apply.
+7
+THE COURT:
+Well, what about the language in
+8
+the statute that suggests that a victim can bring a
+9 claim or seek enforcement of his or her rights under
+10 the statute before a case is filed? What does that
+11 refer to?
+12
+MR. LEE: Your Honor, we believe that's a
+13
+venue provision essentially telling an individual if
+14
+there is no exigent case, there is no case of United
+15
+States versus So And So, then you seek to enforce
+16
+your rights, then you can go in and do so in the did
+17
+18
+court where the offense occurred. This is not
+saying, necessarily, that rights exist, but if you
+19
+20
+believe they exist, here is the place where you're
+going to have to lodge it, and the Court will have
+21
+to decide.
+22
+Now, there are certain of the eight rights
+23
+accorded in 3771(a) that could come up before any
+24
+25
+charge is filed. For instance, let's say somebody
+believes that the perpetrator of the crime is going
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 11 of 32
+11
+to try to harm them or threatened them or
+intimidated them into not testifying or cooperating
+3 with the government and, of course, no indictment
+4
+has been returned. If an individual went to the
+5
+government and believed that the individual had not
+6
+7
+8
+acted appropriately, they can go to the district
+court and say I need to have my rights under
+3771 (a) (1) enforced because those people are
+9 threatening me, and the government hasn't done
+10 enough. That would be a situation.
+11
+But we're talking really here about (a) (5),
+12
+which is the right to consult in the case and we
+13
+respectfully submit that there is not case until a
+14
+charge has been filed.
+15
+16
+17
+18
+19
+20
+21
+THE COURT: So, what about the circuit case
+that was actually pending case had to do with a plea
+agreement in a pending case?
+MR. LEE: Yes. The distinction between the
+case and the instant case, Your Honor, is
+this. In
+, they had negotiated with BP
+Petroleum for a plea and it was always contemplated
+22
+23
+24
+25
+that there was going to be a federal prosecution.
+The distinction in this case was that there was
+already a pending state prosecution and the
+objective for both sides was to keep it in state
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 12 of 32
+12
+1
+court and the federal government's objective was to
+2
+ensure that there were sufficient safeguards in the
+3
+state court proceedings and concessions made by Mr.
+4
+Epstein so that federal interests, particularly a
+5
+cause of action for damages for the victims of the
+6
+sexual exploitation could be preserved. So that's
+7
+the key distinction because there was no federal
+8
+case, there was no federal criminal charge
+9
+contemplate so long as the agreement could be
+10 reached.
+11
+THE COURT: All right. So they want me to
+12
+invalidate your non-prosecution agreement.
+13
+MR. LEE: Your Honor, we respectfully submit
+14
+that 3771 does not grant authority of this Court to
+15
+do so. In the
+case, for instance, Your Honor,
+16
+there was a plea agreement that was entered into and
+17
+18
+district court, of course, entertained a plea
+agreement and exercised its judicial discretion in
+19
+terms of whether to accept it or not. The victims
+20
+were encouraged to go to district court and say, you
+21
+know, we didn't hear about this. We should have,
+22
+and we object to it for the following reasons. The
+23
+district court take that into account. There is no
+24
+plea agreement before this Court. There will be no
+25
+plea proceedings in this court. That was all done
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 13 of 32
+13
+1
+in state court several weeks ago. So that's another
+2
+basis for distinguishing
+3
+THE COURT: All right. So is there any
+4
+point in conferring with these victims?
+5
+MR. LEE: Your Honor, I will always confer,
+6
+7
+sit down with Jane Doe 1 and 2, with the two agents
+and Ms. Villafana. We'll be happy to sit down with
+8
+them.
+9
+THE COURT: But it wouldn't make any
+10 difference in terms of the outcome. Would maybe
+11
+give them the benefit of your explanation of why you
+12
+did what you did and why you came to the conclusion
+13 you did, but it is not going to change your decision
+14 in any way.
+15
+MR. LEE: If it is going to change, it would
+16
+have to be done at a level higher than mine, your
+17 Honor.
+18
+THE COURT: What was-- I didn't understand
+19
+your statement earlier that Mr. Epstein wanted some
+20 kind of review of higher authority within the
+21
+Department in terms of whether or not the federal
+22
+23
+24
+25
+government was going to insist on preserving any
+civil claims.
+MR. LEE: Your Honor, of the agreement was
+consumated by the parties in December of 2007. Mr.
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 14 of 32
+14
+1
+Epstein's attorneys wanted a further review of the
+2
+agreement higher up within the Department of Justice
+3
+and they exercised their ability to do that.
+4
+THE COURT:
+Meaning? Again, I'm trying to
+5
+understand. He wasn't happy with the agreement that
+he had signed?
+7
+MR. LEE: Basically, yes. And was trying to
+8
+maintain that the agreement should be set aside or
+9
+more favorable terms.
+10
+THE COURT: Now, in terms of -- You don't
+11 dispute that Jane Doe 1 and 2-- First of all, do you
+12
+have an objection to Jane Doe 2 being added as a
+13
+petitioner in this case?
+14
+MR. LEE: No, I don't.
+15
+THE COURT: I'll grant that request.
+16
+You don't dispute that they're victims
+17
+within the meaning of the Act.
+18
+MR. LEE: It depends to which -- There is one
+19
+20
+Jane Doe-- Well, there is one individual who is one
+of Mr.
+' clients who we do not believe to
+21
+been a victim. If these are SN and CW, then we have
+22
+no objection and I can discuss-- If I may have a
+23
+moment, Your Honor.
+24
+Your Honor, thank you. I have been
+25
+corrected. We have no objection.
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 15 of 32
+15
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+THE COURT: |
+Okay.
+MR. LEE: We agree they're victims.
+THE COURT: Now, what is your position,
+then, regarding the right of a victim of a crime
+that is potentially subject to federal prosecution
+to be, to have input with the prosecutor, your
+office, before a resolution or decision not to
+prosecute is made? Do you say that there is no
+right to confer under those circumstances because
+there is no "case pending" so any decision not to
+prosecute, there is no right to confer but that
+right to confer only is triggered once there is an
+indictment or an information filed?
+MR. LEE: That is correct, Your Honor. The
+Attorney General guidelines which were published in
+May of 2005 provide that the rights in 3771(a) (1
+through 8) accrue when a charge is filed in federal
+18
+court. Now, that my change after the I
+19
+decision. It is under consideration. But that's
+20 the government's position.
+21
+THE COURT: Al1 right. And so -- Are you
+22 saying all of the rights--
+23
+24
+25
+MR. LEE: Your Honor, some of the rights
+clearly will only pertain after a charge has been
+filed. The one that pertains to notice of public
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 16 of 32
+16
+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
+hearing, public proceedings, though, can't apply
+until there are public proceedings to be had.
+Of course, these guidelines are a floor and
+not a ceiling. They're to be applied with common
+sense.
+If somebody-- If charges of assault were
+being investigated and somebody would come in and
+say the perpetrator whom you're investigating is
+getting ready to indict has been threatening me,
+following me, and I need help because he or she is
+going to do something bad to me and try to take care
+of me before I can testify in the grand jury, this
+person would not be turned away because a charge
+hasn't been filed yet. Those guidelines would be
+applied with common sense.
+But specifically insofar as a (a) (5), which
+is the right to consult with the attorney for the
+government in the case, that would not accrue until
+there is a days. And, in our view, a case doesn't
+come into being until charges are filed.
+THE COURT: And are there any reported
+decisions that you are aware of where any court has
+found a right to confer before charges are filed?
+MR. LEE: I'm not aware of any, Your Honor.
+THE COURT: All right. Thank you.
+MR. LEE: Thank you, Your Honor.
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 17 of 32
+17
+1
+THE COURT:
+Counsel?
+2
+MR.
+: I would just like to address
+3
+that
+decision. They're asking you that you
+4
+just simply ignore it because the decision clearly
+5
+was a decision made because as it is a direct result
+6
+of a plea deal being worked out prior to the victims
+7
+being able to speak.
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+THE COURT: But there was a pending case,
+though, correct?
+MR.
+: As I understand the decision--
+THE COURT: As I understand the plea deal, it
+was negotiated prior to charges being filed. Then
+there was a filed case and then the court had the
+ability to accept the plea or not. And at that
+point, you would have the ability to entertain or
+assert an objection because you weren't consulted
+about the plea.
+So there was a proceeding or case in which
+you can assert a right to confer. How do you do
+that before a case is filed? How do you enforce the
+government or force the government to consult about
+not filing a case? Every case they have to consult
+with the victim before they decide not to prosecute?
+MR.
+: No, there are limitations. I
+think in my reply I refer to the case of U.S. V.
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 18 of 32
+18
+1
+Rubin where they discussed that very scenario
+2
+stating there at least has to be criminal charges
+3
+contemplate by the government before these rights
+4
+kick in.
+The rights under (d) (3) and (a) (5), the
+5
+right to confer and the
+case clearly states
+6
+7
+clearly rights under the CBRA apply before
+prosecution is under way. Logically, this includes
+8
+the CBRA establishments of a victim's reasonable
+9 right to confer with the attorney for the
+10
+government. And, that's read in the plain reading
+11 of the statutes as well.
+12
+This first case in interpreting it, I think
+13
+14
+it's pretty clear the distinction they're making
+between BP and this case. Is it a distinction
+15
+16
+withoug a real difference in that the court is
+saying you have this right before the case is filed
+17
+which is exactly what we are saying. And the result
+18 in that case was they filed the case, later let him
+19
+plea out to some sweet deal. And in this case, what
+20
+we have is they avoid that by deciding not to file.
+21
+Either way, you deprive the victim of their right
+22
+before making that decision.
+23
+And the main problem that the court had in
+24
+, as it states, the victims do have rights when
+25
+there is an impact and the eventual sent is
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 19 of 32
+19
+1
+substantially less. Whereas here, their input is
+2
+received after the parties have reached a tentative
+3
+deal. Well, the government just stated the deal was
+4
+reached back in October of 2007. However, attached
+5
+to their response is a letter to my client
+6
+petitioner, dated January 10, 2008, after the time
+7
+then counsel just put on the record that the deal
+8
+was already finalized and it starts, the opening
+9 paragraph talks about whether they wanted the
+10 victims to have the right to confer. It says, this
+11
+case is currently under investigation. This is
+12
+January 2008. This case has been a lengthy process
+13
+and we request your continued patience while we
+14
+conduct a thorough investigation. Sounds like the
+15
+exact opposite of, we want you to come in and confer
+16
+and let us know what you really feel about this.
+17
+That is our biggest problem with what has
+18 happened here, is that she just wasn't given a voice
+19
+and if somebody would have heard her, we believe
+20
+there would have been a different outcome. To go
+21
+back into a room right now and talk, after there has
+22
+already been a plea negotiated without Your Honor
+23
+ordering that in this case the plea deal needs to be
+24
+25
+vacated, it is illegal and give her her rights.
+THE COURT: Well, would you agree or not
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 20 of 32
+20
+2
+3
+that Mr. Epstein plead guilty to the state charges
+probably at least, in part, in reliance upon the
+fact that he had an agreement with the federal
+4
+government they weren't going to prosecute? would
+5
+you concede that or would would present evidence to
+6
+that effect?
+7
+MR.
+: Of course we would. Yes, of
+8
+course. Sure.
+9
+THE COURT: So you agree that Mr. Epstein is
+10 now sitting in the Palm Beach County Jail a
+11
+12
+13
+convicted felon serving 18 months of imprisonment,
+at least in material part, because he relied upon
+the government's non-prosecution agreement?
+14
+MR.
+: Yes. I agree that he is sitting
+15
+there because he is guilty and maybe he took the
+16
+plea rather than going to trial and being found
+17
+18
+19
+20
+21
+22
+23
+24
+guilty later in part because of this non-prosecution
+agreement that was worked out behind the other
+victims' backs. I would agree with that.
+THE COURT: So he accepted the State's deal
+in part because he knew he had an agreement from the
+federal government that they weren't going to
+prosecute.
+MR.
+: I presume. I speculate that is
+25
+true.
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 21 of 32
+21
+1
+THE COURT:
+So you want me now, then, to set
+2
+aside the government's agreement with him because
+3
+4
+there was no conferring, yet he has already accepted
+a plea agreement and is sitting in custody, in part,
+in reliance on that agreement. I mean, I can undo
+6
+the agreement in your theory, but how do I-- Mr.
+7
+Epstein, in a sense, would then be adversely
+8
+affected by my actions when he acted in reliance
+9 upon the agreement. How does that work?
+10
+11
+MR.
+: Certainly, we're only asking
+you to vacate the agreement. I understand and your
+12
+point is well taken. And I believe that at that
+13
+point in time his rights may kick in and say, wait,
+14 I was relying on this other deal so I wouldn't be
+15
+prosecuted for these hundreds of other girls that I
+16
+molested; that I plead guilty over here to the one
+17
+18
+19
+20
+21
+22
+23
+girl that I will admit to molesting. So maybe I can
+get to withdraw my plea. But the last thing he wants
+to do because if he ends up going to trial, I'll be
+in prison for the rest of his life like any other
+person who ever did this crime would be. He could
+have that argument, I guess, but still wouldn't
+really work well for him.
+24
+25
+THE COURT: All right. So you still think I
+should set aside the agreement, require the
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 22 of 32
+22
+1
+government to confer?
+2
+3
+MR.
+: Work out a plea negotiation
+commensorate with the crimes that he committed and
+4
+that are favorable after they confer with the
+5
+victims. And it is within their discretion. Of
+6
+course, they can decide on their own that, hey, I
+7
+think that the agreement was fair after they have
+8
+talked with the victims.
+That could happen. I
+9
+don't know if a reasonable person that would do
+10 that, but it could happen.
+11
+12
+THE COURT: Apparently, you are not
+suggesting that that these person are not
+13
+reasonable.
+14
+15
+16
+MR.
+: I'm suggesting they haven't
+conferred with the victims and that if they took
+into consideration what these two in the courtroom
+17
+18
+19
+20
+21
+22
+23
+24
+25
+have to say, I don't think that we'd be in this same
+position right now.
+THE COURT: They have never spoken to your
+client about what happened to them?
+MR.
+: They have spoken to them about
+what happened. Maybe not about what the girls
+wanted to happen as a result of this case, which is
+part of conferring to decide that these girls wanted
+money on their own, which is basically what this--
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 23 of 32
+23
+1
+this non-prosecution agreement entails that has
+2
+language that he'll agree to liability in a civil
+3
+case. That's not what these girls-- They want
+4
+justice.
+They want him in prison now more than
+5
+ever. The reason they stated they kept this
+6
+agreement from the girls and they basically conceded
+7
+8
+we didn't tell the girls about this agreement, well,
+the reason is because they would have objected and
+9 they wouldn't have been able to sign off on this and
+10 the victims would have had a voice, and we'd still
+11
+been going through litigation. The exact problem
+12
+13
+14
+they tried to prevent, at least in their terms which
+was the impeachment of these girls at a later trial,
+is still available to anybody once the civil suits
+15
+are filed anyway.
+16
+They have three arguments. One, we didn't
+17
+have to talk to them. Iwo, we did talk to them sort
+18
+of. And if you don't buy that, the reason we didn't
+19
+talk to them, we were trying to prevent them from
+20 being impeached later. None of them trump the
+21 victims' rights to confer prior to plea
+22
+23
+24
+25
+negotiations.
+That's why, Your Honor, we would ask
+this Court to enter an order vacating that previous
+plea agreement as illegal, ask them to confer with
+the victims once again or for the first time and
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 24 of 32
+24
+1
+work out a negotiated plea to that accord.
+2
+3
+THE COURT: well, all you can ask them to do
+is confer. I can't ask them to do anything beyond
+4
+that. I mean, it is up to them to negotiate.
+5
+MR.
+: I wouldn't quarrel with that.
+6
+7
+THE COURT: Now, having learned today, I
+guess, that the agreement was signed when, in
+8
+October?
+9
+10
+11
+12
+13
+14
+15
+16
+MR.
+: October 2007, I heard.
+THE COURT: About eight or nine months ago,
+is there any need to rush to a decision in this
+matter? The decision has already been made. You
+filed this, I think, on the presumption that the
+agreement was about to take place and you wanted to
+be able to confer beforehand and you weren't sure
+what was going on.
+17
+MR.
+: Precisely, Your Honor. And I'm
+18 holding the letters that are exhibits that they were
+19
+writing to my client during the year of 2008 telling
+20
+her how lengthy of a process this was going to be
+21
+and be patient. So, right, I was completely in the
+22
+dark about when this agreement was signed.
+23
+THE COURT: In view of the fact that this
+24
+25
+agreement has already been consumated, and you want
+me to set it aside, as opposed to something that's
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 25 of 32
+25
+1
+2
+3
+4
+5
+6
+7
+B
+4: 17
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+about to occur, would you agree that-- and I have
+done this very quickly because of the petition and
+your allegation that something was about to happen.
+I'm not blaming you.
+MR.
+: I was mistaken.
+THE COURT: I'm not blaming you for doing
+that. In view of what you know now, is there any
+need to treat this as an emergency that has to be
+decided by tomorrow?
+MR.
+: I can't think of any reason in
+light of what we just heard.
+THE COURT: Mr. Lee, do you have anything
+else you wanted to add? Does either side think I
+need to take evidence about anything? If I do,
+since this is not an emergency anymore, I can
+probably find a more convenient time to do that. I
+don't have the time today to take evidence. But if
+you do believe that I should take evidence on this
+issue.
+MR.
+: It may be best if I conferred
+with the U.S. Attorney's Office on that and we can
+make a decision whether it is necessary or whether
+Your Honor deemed it was necessary for you to make a
+decision.
+THE COURT: I want to know what your
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 26 of 32
+26
+1
+2
+3
+respective positions are because it may be something
+in terms of having a complete record, and this is
+going to be an issue that's it going to go to the
+4
+Eleventh Circuit, may be better to have a complete
+5
+record as to what your position is and the
+6
+government's is as to what actions were taken. And
+7
+I don't know if I have enough information, based on
+8
+9
+Ms. Villafana's affidavit or I need additional
+information. And because it is not an emergency, I
+10 don't have to do something quickly, we can play it
+11 be ear and make this into a more complete record for
+12
+the court of appeals.
+13
+MR.
+: If there is a time where it is
+14
+15
+16
+17
+necessary to take evidence, Your Honor is correct in
+stating that it is not an emergency and it doesn't
+need to happen today. And, I will confer with the
+government on this and if evidence needs to be
+18
+19
+20
+21
+22
+23
+24
+25
+taken, it be taken at a later date. It doesn't seem
+like there will be any prejudice to any party.
+THE COURT: Mr. Lee, do you have any
+thoughts? You want to consult with Mr.
+?
+MR. LEE: There may be a couple of factual
+matters that I need to chat with petitioner's
+counsel on. If we can reach agreement on those as
+to what was communicated to CW and what time, if
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 27 of 32
+27
+1
+they don't dispute that, then we don't think it will
+be necessary to have an evidentiary hearing. But if
+3
+we can agree, fine or maybe we can't. We'll talk
+4
+about it.
+THE COURT: All right. So why don't you let
+6
+me know if you think an evidentiary hearing is
+7
+necessary. If there are additional stipulations you
+8
+want to enter into or supplement what has already
+9 been presented, you can do that.
+10
+Now, the other issue I want to take up,
+11
+though, is the government filed its response to the
+12
+petition under seal. And so I want to know why.
+13
+What is in there that at this point needs to be
+14
+under seal? Is there anything in there that's
+15
+16
+confidential, privileged, anything that's different
+from what you hve said here in open court that
+17
+requires that to be sealed?
+18
+MR. LEE: Well, Your Honor, on our motion to
+19
+seal was based on two reasons. One that dealt with
+20
+individuals or minors at the time that the offense
+21
+occurred. So we were attempting to protect the
+22
+privacy of those individuals. And also it dealt
+23
+with negotiations with Mr. Epstein which were in the
+24
+nature of plea negotiations, which we treat as
+25
+confidential. Normally, they're not aired out in
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 28 of 32
+28
+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
+open court. So those were our two reasons.
+THE COURT: All right. But I guess the
+letters you attached only related to Mr.
+client.
+MR. LEE: Three of them, yes, Your Honor.
+THE COURT: Are you prepared, Mr.
+to waive any issues regarding the release of those
+documents that relate to your clients?
+MR.
+: Judge, I think it would be
+appropriate to redact the names of the clients as
+they have done.
+THE COURT: I don't think the names are in
+there.
+MR.
+: I think they're redacted.
+They're blacked out. I have no problem with
+releasing those documents. I'm not sure that's part
+of the deal. But if it is--
+MR. LEE: It is.
+MR.
+: Okay. I'll waive.
+THE COURT: You really don't have any
+objection to those letters that were sent to them
+being released to the public?
+MR.
+: Of course not, Judge.
+THE COURT: Then what is there about the
+plea agreement or the negotiations that is in the
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 29 of 32
+29
+1
+response that we really haven't already kind of--
+2
+3
+MR. LEE: Your Honor, there was a
+confidentiality agreement in the deferral of
+4
+prosecution to the State of Florida.
+so we were
+5
+trying
+to maintain the confidentiality of the
+6
+negotiations that occurred since we had discussions
+7
+during those negotiations as one of the reasons why
+8
+we decided not to tell all of the individuals what
+9
+10
+11
+was going on.
+THE COURT: But is that still necessary,
+that confidentiality or is that kind of moot at this
+12
+point?
+13
+14
+15
+MR. LEE: Well, we would like it sealed.
+Admittedly, what happened today in open court has
+probably weakened our argument. I don't dispute
+16
+that.
+17
+THE COURT: In your opinion, anything in
+18 particular, any paragraph in the response or in Ms.
+19
+Villafana's affidavit that you think is particularly
+20
+troublesome that should remain under seal?
+21
+22
+MR. LEE: May I have a moment, Your Honor?
+THE COURT: Yes.
+23
+MR. LEE: Thank you. Your Honor, one aspect
+24
+of this in the notification letters that were
+25
+dispatched to individuals which were attached to Ms.
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 30 of 32
+30
+1
+Villafana's declaration, there is a citation to a
+2
+clause in the agreement that was reached regarding
+3
+the damages remedy under 18 USC 2255 that was
+4
+subject to the constitutionality agreement, we
+5
+believe that should still remain confidential.
+6
+THE COURT: But hasn't the fact that this
+7
+provision was part of the agreement again been
+8
+aired? Is there any secret to it anymore?
+9
+MR. LEE: The actual text of it has not been
+10 aired. The existence of it has been heard but the
+11 actual text has not and we believe it should still
+12
+remain confidential.
+13
+THE COURT: Okay. Any other argument on
+14
+that issue?
+15
+MR. LEE: No, Your Honor. Thank you.
+16
+THE COURT: Ms. Villafana wants to speak to
+17
+you.
+18
+MR. LEE: Your Honor, one item that I'd like
+19
+to bring to the court's attention. We had advised
+20 Mr. Epstein and his attorneys that if we were to
+21
+dislose some of the agreement, we would give them
+22
+advance notice and ability to lodge an objection. We
+23
+would like an opportunity to do that.
+24
+THE COURT: All right. But you're not
+25
+disclosing. It would be by my order that it would
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 31 of 32
+31
+1
+be disclosed.
+2
+3
+MR. LEE: Yes, Your Honor. And we just would
+like to register that we believe it should remain
+4
+confidential.
+5
+THE COURT: All right.
+6
+MR.
+: Your Honor, I don't see any
+7
+authority for keeping that under seal.
+8
+THE COURT: I agree.
+The fact that there is
+9 this preserved right on behalf of the victims to
+10
+pursue a civil action is already a matter of public
+11
+record; the exact text of the clause-- I don't see
+12
+that disclosing the text of the clause when the fact
+13
+that the clause exists is already a matter of public
+14
+record. It is not harmful in any way to Mr. Epstein
+15
+or the government and the letters to the victim that
+16
+the victim can disclose those letters, they're not
+17
+under any confidentiality obligation or restriction
+18
+and they're free to disclose it themselves if they
+19
+choose to. So I don't see that there is any real
+20
+public necessity to keep the response sealed in view
+21
+of what we discussed already on the record and the
+22 victim's ability to disclose those provisions of
+23
+their own choosing, if they wish. So, in view of
+24
+the public policy that matters filed in court
+25
+proceedings should be open to the public and sealing
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 32 of 32
+32
+1
+should only occur in circumstances that justife the
+2
+need to restrict public access, I'm going to deny
+3 the motion to seal the response and allow that to be
+4
+viewed.
+5
+All right. So I'll let both of you confer
+6 about whether there is a need for any additional
+7
+evidence to be presented. Let me know one way or
+the other. If there is, we'll schedule a hearing.
+If there isn't and you want to submit some
+additional stipulated information, do that, and then
+I'll take care of this in due course.
+MR.
+: Thank you, Your Honor.
+THE COURT: All right.
+MR. LEE: Thank you, Your Honor.
+MS. VILLAFANA: Thank you, Your Honor.
+THE COURT: You're welcome.
+(Proceedings concluded.)
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+I hereby certify that the foregoing is true
+and correct to the best of my ability.
+Victoria Aiello, Court Reporter

vision-fixhub/court-01/db4db5346da855457ad2d6aeb03c562a6ee0502e86f6496e80783e99003a4381.receipt.json

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vision-fixhub/court-01/db515d36da38686dff4701894a466748ad792e91588ea45a1dd20df8f38d1d1a.md

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+Case 9:08-cv-80119-KAM Document 286 Entered on FLSD Docket 09/02/2009__ Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CIV-80119-MARRA/J
+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
+pion fata
+SEP 0 2 2009
+ORDER
+This matter came before the Court on Defendant, JEFFREY EPSTEIN'S, Motion
+For Extension of Time in which to Respond to Plaintiff, Jane Doe's Motions to Compel
+Responses to Request to Produce, Answers to Request for Admissions, and Answers to
+(DE# 280)
+Interrogatories. Having considered Defendant's motion and Plaintiff's counsel being in
+agreement with the requested extension, it is HEREBY ORDERED and ADJUDGED
+that:
+Defendant's motion is GRANTED. Defendant shall Respond to Plaintiff's
+Motions to Compel Responses to Request to Produce, Answers to Request for
+Admissions, and Answers to Interrogatories.
+on or before September 7, 2009.
+
+
+Case 9:08-cv-80119-KAM Document 286 Entered on FLSD Docket 09/02/2009 Page 2 of 2
+DONE and ORDERED the 2 day or Sept:.
+→ 2009.
+-forman
+Kennet A Mam LINNEAR. JonsaD
+United States Distriet Judge
+MAGIATDATE
+Courtesy Copies:
+Counsel of Record

vision-fixhub/court-01/db515d36da38686dff4701894a466748ad792e91588ea45a1dd20df8f38d1d1a.receipt.json

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vision-fixhub/court-01/db660bd71022bb2a72bfba1de3c8b27f51314d7f4d358bac06bb75e98aa912cf.md

@@ -0,0 +1,34 @@
+Case 1:20-cv-00484-JGK-DCF Document 100 Filed 03/12/21 Page 1 of 1
+Troutman Pepper
+875 Third Avenue
+New York, New York 10022
+Sanders LLP
+troutman"
+pepper
+troutman.com
+Bennet J. Moskowitz
+bennet.moskowitz@troutman.com
+March 12, 2021
+VIA ECF
+The Honorable John G. Koeltl
+United States District Court
+Southern District of New York
+Daniel
+Moynihan Courthouse
+500 Pearl Street
+New York, NY 10007
+Re:
+Jane Doe v. Darren I. Indyke and Richard D. Kahn, in their capacities as
+executors of the Estate of Jefferey E. Epstein, and Ghislaine Maxwell
+No. 1:20-cv-00484-JGK-DCF
+Dear Judge Koeltl:
+We represent Defendants Darren _. Indyke and Richard D. Kahn, as Co-Executors
+of the Estate of Jefferey E. Epstein (the "Co-Executors"), in the above-referenced action.
+Pursuant to the Court's Memorandum Opinion and Order dated March 8, 2021, we write
+to confirm that the stipulation and the additional conditions specified therein are
+acceptable to the Co-Executors.
+Very truly yours,
+/s/ Bennet J. Moskowitz
+Bennet J. Moskowitz
+Cc:
+All counsel of record (via ECF)

vision-fixhub/court-01/db660bd71022bb2a72bfba1de3c8b27f51314d7f4d358bac06bb75e98aa912cf.receipt.json

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vision-fixhub/court-01/db91455612be238080bd87982eeea17964868332835f2b16f5e1431398b4c0da.md

@@ -0,0 +1,204 @@
+Case 9:08-CV-80119-KAM Document 362-4 Entered on FLSD Docket 10/21/2009 Page 1 of 8
+Case 9:08-CV-80119-KAM Document 247-5 Entered on FLSD Docket 08/05/2009 Page 1 of 8
+Jane Doe #5
+V.
+Jeffrey Epstein
+AFFIDAVIT OF RICHARD C.W.| M.D.
+STATE OF FLORIDA
+COUNTY OF SEMINOLE
+On this day personally appeared before me, the undersigned authority, Richard
+C.W.1
+M.D., who, being by me first duly sworn under oath deposes and says:
+1.
+My name is Richard C.W.
+M.D. I am over the age of majority, and make
+this affidavit and declaration upon the basis of personal knowledge of the factual matters
+contained herein.
+2.
+since 1996.
+I have maintained a private practice in psychiatry and forensic psychiatry
+3.
+I, also, currently serve as a Courtesy Clinical Professor of Psychiatry at the
+University of Florida, College of Medicine, Gainesville, Florida; Affiliate Professor, Dept of
+Psychiatry and Behavioral Medicine, University of South Florida; and Professor of
+Psychiatry, Department of Medical Education, University of Central Florida College
+Medicine.
+4.
+I received my undergraduate degree from the Johns
+University and
+1
+D
+
+
+Case 9:08-cv-80119-KAM Document 362-4 Entered on FLSD Docket 10/21/2009 Page 2 of 8
+Case 9:08-cv-80119-KAM Document 247-5 Entered on FLSD Docket 08/05/2009 Page 2 of 8
+medical degree from the University of Florida College of Medicine, Gainesville, Florida.
+I served as a Lieutenant Commander in the United States Navy, where I
+researched and evaluated biological and neurochemical factors associated with the onset of
+psychiatric disorders and served as a representative to the Joint Services Task Force
+planning Operation Homecoming, the return of POW's from Vietnam.
+Thave previously served as an assistant clinical professor at the University of
+South Florida College of Medicine, directed one of the ten model mental health centers in
+the United States, and served as a medical consultant to the Kennedy Space Center.
+7.
+I am a former member of the academic faculty at the University of Texas, in
+Houston, Texas where I served as Assistant Professor and then Associate Professor of
+Psychiatry and Internal Medicine, Director of Clinical Research, Director of Residency
+Training, Chief of the Consultation/Liaison Service, and Chief Psychiatrist at the M.D.
+Cancer Hospital in Houston.
+8.
+I, also, have served as a Professor of Internal Medicine and Psychiatry at the
+Medical College of Wisconsin where I was appointed Chief of Psychiatry at the Milwaukee
+County and Froedtert Hospitals.
+In addition, I have served as a Professor of Psychiatry and Internal Medicine
+and Associate
+at the University of Tennessee College of Medicine, Memphis.
+10. The amended complaint filed by Jane Doe #5 against Jeffrey Epstein makes
+2
+
+
+Case 9:08-cv-80119-KAM Document 362-4 Entered on FLSD Docket 10/21/2009 Page 3 of 8
+Case 9:08-cv-80119-KAM Document 247-5 Entered on FLSD Docket 08/05/2009 Page 3 of 8
+sensitive allegations of sexual assault and abuse upon a minor and seek damages in excess
+of $50 million. Jane Doe #5 alleges confusion, shame, humiliation, embarrassment, and
+severe psychological and emotional injuries. It is further alleged that she suffered, and will
+continue to suffer, severe
+and permanent traumatic injuries, including mental,
+psychological, and emotional damages.
+11.
+She alleges the intentional infliction of emotional distress and that Mr.
+Epstein's conduct caused severe emotional distress, severe mental anguish and pain.
+12. She further alleges that she has suffered personal injury including mental,
+psychological and emotional damage.
+13.
+Plaintiff's counsel has retained an expert witness, Dr. Kliman of the
+Psychological Trauma Center, a division of Preventive Psychiatry Associates Medical
+Group, Inc., of San Francisco, California, of which Gilbert W. Kliman, MD, is the medical
+director. Dr. Kliman's initial records indicate the following concerning Jane Doe #5.
+14. Plaintiff reports she went to three different schools in the eighth grade. (Page
+3, GK Contemp note)
+15. Plaintiff reports "I have had girls be mean to me and even rumor that they
+would slice my throat when I was younger." (Page 4, GK Contemp note)
+16. Plaintiff noted that she had caught her mother and stepfather having sex.
+(Page 7, GK Contemp note)
+3
+
+
+Case 9:08-cv-80119-KAM Document 362-4 Entered on FLSD Docket 10/21/2009 Page 4 of 8
+Case 9:08-cv-80119-KAM Document 247-5 Entered on FLSD Docket 08/05/2009 Page 4 of 8
+17.
+"I got kicked out when I was 18 (by both parents). (Page7, GK Contemp note)
+18.
+Plaintiff noted that her mother suffers from depression/stress. (Page 7, GK
+Contemp note)
+19.
+Plaintiff noted that during her sophomore and junior years of high school she
+drank every weekend and started trying drugs. (Page 7, GK Contemp note)
+20.
+"Her problems began during adolescence." (Page 7, GK Contemp note)
+21. Family psychiatric history includes: a history of a blood relative having been
+sexually abused, plaintiff's mother was physically abused by sisters, and plaintiff's father
+"was very irresponsible as a father figure when I was growing up" and used drugs. (Pages
+7 and 8, GK Contemp note)
+22.
+Plaintiff noted "My stepfather hit me on a few occasions. But on one
+occasion, I lost hearing in my ear for two weeks." (Page 8, GK Contemp note)
+23. Plaintiff reported that she has been sexually active since age 13 and had 8-10
+partners. (Page 8, GK Contemp note)
+24.
+Plaintiff reported that she had been raised by her father between ages 12 to 18
+and that she found her childhood hard to remember, unhappy and painful. (Page 8, GK
+Contemp note)
+25. Plaintiff reports that her drug use has included marijuana and pain pills
+without prescription and that on several occasions she has drunk too much alcohol. (Page
+!
+4
+
+
+Case 9:08-cv-80119-KAM Document 362-4 Entered on FLSD Docket 10/21/2009 Page 5 of 8
+Case 9:08-cv-80119-KAM Document 247-5 Entered on FLSD Docket 08/05/2009 Page 5 of 8
+9, GK Contemp note)
+26.
+Plaintiff reported that her mother's sisters had paid a male to rape her (the
+mother) in a closet at school. She had been raped three times, twice in childhood and once
+on a date. Also, an uncle raped the mother. (Page 1, GK Follow-up note)
+27. Plaintiff reported having suicidal thoughts in the 9i or 10th grade. (Page 4,
+GK Follow-up note) (Pre-Epstein)
+28.
+All of the above show that this plaintiff came from an unstable and disturbed
+home, had been subject to previous physical and sexual abuse, was fearful, isolated, and
+had had suicidal ideation priot to meeting Mr. Epstein. For further elaboration of her
+history and background, access to all available records is crucial if one is to fully
+understand the impact of any of these events on her subsequent behavior and proportion
+the impact of specific events, if any, or her current and future level of function.
+29. In Dr. Kliman's initial replenishment retainer agreement and fee schedule
+(date 7/18/08), in a heading entitled "Regarding Full Disclosure," Dr. Kliman notes that
+prior to deposition, counsel will make every effort necessary to provide experts with
+information requested by the experts including: 1) a list of all depositions, statements,
+declarations, and motions in the case, 2) a copy of any requested items, and 3) most
+importantly, a list of all medical, clinical, school, and work records known to the attorney
+in the case.
+5
+
+
+Case 9:08-cv-80119-KAM Document 362-4 Entered on FLSD Docket 10/21/2009 Page 6 of 8
+Case 9:08-cv-80119-KAM Document 247-5 Entered on FLSD Docket 08/05/2009 Page 6 of 8
+30.
+Dr. Kliman notes on page 8 of his contract opinion formation that he will not
+form opinions, give reports, or testify in certain circumstances.
+These include
+circumstances where he has reason to believe a retaining attorney has "available important
+and relevant documents which are being deliberately withheld from us." "We define such
+as documents in possession of retaining attorney, which we have requested or that we have
+stated would ordinarily be part of medical opinion formation on the topics concerning.
+which our input is requested." We request the same.
+31. It is critical for an IME examiner to be able to make a cogent assessment of
+any plaintiff and to understand their medical, social, academic, psychological and
+psychiatric condition/state prior to any act of alleged victimization. There are a number of
+variables that combine to determine the effects of such alleged victimization, including the
+type and character of the alleged assault, and key victim variables such as demographics,
+psychological reactions at the time of the trauma, previous psychiatric or psychological
+history, previous victimization history, current or previous psychological difficulties, and
+general personality dynamics and coping style, as well as sociocultural factors such as drug
+use/abuse; poverty; social inequity and/or inadequate social support; any previous history
+of abuse within or outside the family; whether individuals were abused by strangers,
+acquaintances or family members; and whether there was any history of indiscriminate
+behavior that may have placed them at increased risk. It is important to know if there had
+6
+
+
+Case 9:08-cv-80119-KAM Document 362-4 Entered on FLSD Docket 10/21/2009 Page 7 of 8
+Case 9:08-cv-80119-KAM Document 247-5 Entered on FLSD Docket 08/05/2009 Page 7 of 8
+been previous sexual conduct, contact with police or welfare agencies, alcohol or drug
+use/abuse, voluntary sexual activity, contraceptive use, genital infections, or apparent
+indifference to previous abuse.
+It is also essential to understand the plaintiff's level of emotional support,
+whether any significant psychiatric illnesses were present, whether they were taking any
+medications (prescribed or non-prescribed), whether there had been previous suicide
+attempts, thoughts, plans, etc.
+33. Knowledge of plaintiff's relationships to her family and familial factors,
+including social disadvantage, family instability, impaired parent/child relationship, and
+parental adjustment difficulties is also critical.
+34.
+It is, therefore, crucial that the independent medical examiner has available to
+him a full and complete record that includes medical, previous legal, social, criminal,
+academic, psychological and psychiatric records/data; psychological tests; laboratory tests;
+and clinical, hospital, physician records. These, in essence, are the same and similar records
+that plaintiff's expert witness (Dr. Kliman) feels are essential for him to do an appropriate
+evaluation. To obtain the necessary information, it will be necessary to identify the plaintiff
+by name. Such identification will not humiliate the plaintiff since all we are requesting is
+pertinent information as noted above relative to their past medical and psychiatric histories
+and conduct. We would concur and request of the court that the same and such other
+7
+
+
+Case 9:08-cv-80119-KAM Document 362-4 Entered on FLSD Docket 10/21/2009 Page 8 of 8
+Case 9:08-cv-80119-KAM Document 247-5 Entered on FLSD Docket 08/05/2009 Page 8 of 8
+similar information be made available to us to conduct our examination.
+Respectfully submitted,
+ichard C. W
+Courtesy Clinical Professor of Psychiatry, University of Florida, College of Medicine
+Affiliate Professor, Department of Psychiatry and Behavioral Medicine, University of South
+Florida
+Professor of Psychiatry, Department of Medical Education, University of Central Florida
+College of Medicine

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vision-fixhub/court-01/dbb558a7c23a4cbcec4ed857ee63ef39017779ff58e8927ef6a2f30733d3798c.md

@@ -0,0 +1,55 @@
+Case 9:09-cv-80591-KAM Document 25-1 Entered on FLSD Docket 05/21/2009 Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No. 9:09-CV-80591-KAM
+Jane Doe 101,
+Plaintiff,
+VS.
+Jeffrey Epstein,
+Defendant.
+CERTIFICATION OF JAY P. LEFKOWITZ
+Jay P. Lefkowitz, P.C., Esquire, pursuant to Rule 4B of the Special Rules Governing the
+Admission and Practice of Attorneys, hereby certifies that (1) I have studied the Local Rules of'
+the United States District Court for the Southern District of Florida; and (2) I am a member in
+good standing of the bars of the State of New York and District of Columbia, and am admitted to
+practice before the United States Supreme Court, the United States Courts of Appeals for the
+District of Columbia Circuit, Second Circuit, Fourth Circuit, Fifth Circuit, Eighth Circuit, Ninth
+Circuit, and Eleventh Circuit, the United States District Courts for the District of Columbia,
+Southern District of New York, Eastern District of Michigan, Eastern District of Wisconsin, and
+District of Colorado, and the United States Tax Court.
+
+
+Case 9:09-cv-80591-KAM Document 25-1 Entered on FLSD Docket 05/21/2009 Page 2 of 2
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that a true and correct copy of the foregoing Motion for Limited
+Appearance, Consent to Designation and Request to Electronically Receive Notices of Electronic
+Filings was electronically filed with the Clerk of the Court using CM/ECF. I also certify that the
+foregoing document is being served this day on all counsel of record identified on the following
+Service List in the manner specified by CM/ECF on this _ day of May, 2009
+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 subminod,
+ROBERT D. CRITTON, JR., ESQ.
+Florida Bar #617296
+npike@bclclaw.com
+BURMAN, CRITTON, LUTTIER & COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+(Counsel for Defendant Jeffrey Epstein)

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vision-fixhub/court-01/dbbfee4674e02acccd0b35dccfbfab9b8a4e3bddde5ab417fed6d5d9f3120d6e.md

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+Case 9:08-cV-80119-KAM Document 545-2 Entered on FLSD Docket 05/12/2010 Page 1 of 7
+Case 9:08-CV-80119-KAM Document 333-1
+Entered on FLSD Docket 09/30/2009
+
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA-I
+JANE DOE NO. 2,
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+DEFENDANT JEFFREY EPSTEIN'S RESPONSE & OBJECTIONS TO
+PLAINTIFF'S REQUEST FOR PRODUCTION OF NET WORTH
+DOCUMENTS DATED JUNE 29, 2009
+Defendant, JEFFREY EPSTEIN, by and through his undersigned
+attorneys, serves his Responses and Objections to the Request for Production of
+Net Worth Documents and states:
+Request No. 1: All Federal and State income tax returns, including all
+W-2 forms, 1099 forms and schedules, for tax years 2003-2008.
+Response and Objections to Request Number 1: Defendant is
+asserting specific legal objections including but not limited to relying on certain
+U.S. constitutional privileges in declining at present to respond to this request for
+production
+on advice from my counsel that | cannot provide
+answers/responses to questions relating to my financial history and conditior
+without waiving my Fifth Amendment and I must accept this advice or risk losing
+my Sixth Amendment right to effective representation. Accordingly, I assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments
+as guaranteed by the United States Constitution. Drawing an adverse inference
+under these circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable and would therefore violate the
+Constitution.
+Responding to the above financial request would require Epstein to
+identify information regarding the offenses that were the prior subject of a federal
+investigation as set forth in more detail in a supplementary response available to
+be provided to the court in camera and ex parte to the extent the good faith
+assertion of the privilege is in question. The Fifth Amendment is a safe harbor for
+
+
+
+Case 9:08-cv-80119-KAM Document 545-2 Entered on FLSD Docket 05/12/2010 Page 2 of 7
+Case 9:08-cv-80119-KAM Document 333-1 Entered on FLSD Docket 09/30/2009 Page 2 of 7
+Page 2
+all citizens, including those who are innocent of any underlying offense, however
+responding to this and other relating inquiries have the potential to provide
+link in a chain of information that would be protected. More specifically, the act of
+producing the above information may implicitly communicate statements of fact in
+that they would implicitly authenticate the requested information, require Epstein
+to admit that the requested information exists and admit that same were in his
+possession, custody and control. The very act of production itself may therefore
+provide a link in the chain of evidence adverse to Epstein, see generally United
+States v Hubbell 520 US 27, 36 (2000)
+In addition to and without waiving his constitutional privileges, Defendant
+also objects as the request for production as unreasonable, overbroad,
+confidential, proprietary in nature and seeks information that is neither relevant to
+the subject matter of the pending action nor does it appear to be reasonably
+calculated to lead to the discovery of admissible evidence. The specific
+intormation requested as to tax returns also seeks information that is confidential
+and protected by federal law, 26 USC 6103. Further, Plaintiff's Complaint alleges
+a time period of "in or about 2004-2005." Plaintiff's request seeks information for
+a time period from 2003-2008.
+To the extent this court rules that some or all of the requested information
+be produced, it should not be produced without limitations (including
+confidentiality, and should only be produced at the very end of litigation but
+before trial in order for Plaintiff to establish her burden making it apparent that
+punitive damages can be awarded.
+Request No. 2:
+All documents relating to the assets, liabilities,
+income, expenses and net worth of Defendant, including without limitation, the
+following for each of the past five (5) years.
+a.
+b.
+C.
+annual financial reports;
+balance sheets;
+income statements;
+cash flow statements;
+e.
+f.
+quarterly financial reports;
+budget reports; and
+financial analysis
+Response and Objections to Request Number 2: Defendant is
+asserting specific legal objections including but not limited to relying on certain
+U.S. constitutional privileges in declining at present to respond to this request for
+production based on
+advice from my counsel that I cannot provide
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments
+
+
+Case 9:08-cv-80119-KAM Document 545-2 Entered on FLSD Docket 05/12/2010 Page 3 of 7
+• Case 9:08-CV-80119-KAM Document 333-1 Entered on FLSD Docket 09/30/2009 Page 3 of 7
+Page 3
+as guaranteed by the United States Constitution. Drawing an adverse inference
+under these circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable and would therefore violate the
+Constitution.
+Responding to the above financial request would require Epstein to
+identify information regarding the offenses that were the prior subject of a federal
+investigation as set forth in more detail in a supplementary response available to
+be provided to the court in camera and ex parte to the extent the good faith
+assertion of the privilege is in question. The Fifth Amendment is a safe harbor for
+all citizens, including those who are innocent of any underlying offense, however
+responding to this and other relating inquiries have the potential to provide
+link in a chain of information that would be protected. More specifically, the act of
+producing the above information may implicitly communicate statements of fact in
+that they would implicitly authenticate the requested information, require Epstein
+to admit that the requested information exists and admit that same were in his
+possession, custody and control. The very act of production itself may therefore
+provide a link in the chain of evidence adverse to Epstein, see generally United
+States v Hubbell 520 US 27, 36 (2000)
+In addition to and without waiving his constitutional privileges, Defendant
+also objects as the request for production as unreasonable, overbroad,
+confidential, proprietary in nature and seeks information that is neither relevant to
+the subject matter of the pending action nor does it appear to be reasonably
+calculated to lead to the discovery of admissible evidence. Further, Plaintiff's
+Complaint alleges a time period of "in or about 2004-2005." Plaintiff's request
+seeks information for a time period of the past five (5) years.
+To the extent this court rules that some or all of the requested information
+be produced, it
+should not be produced without limitations including
+confidentiality), and should only be produced at the very end of litigation but
+before trial in order for Plaintiff to establish her burden making it apparent that
+punitive damages can be awarded.
+Request No. 3:
+All documentation which refer or relate to financing or
+loans requested or applied for by the Defendant, including loan applications,
+appraisals, financial spreadsheets, etc.
+Response and Objections to Request Number 3: Defendant is
+asserting specific legal objections including but not limited to relying on certain
+U.S. constitutional privileges in declining at present to respond to this request for
+production based on advice from my counsel that I cannot provide
+answers/responses to questions relating to my financial history and condition
+without waiving my Fifth Amendment and I must accept this advice or risk losing
+ny Sixth Amendment right to effective representation. Accordingly, I assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments
+
+
+Case 9:08-cv-80119-KAM Document 545-2 Entered on FLSD Docket 05/12/2010 Page 4 of 7
+Case 9:08-cv-80119-KAM Document 333-1 Entered on FLSD Docket 09/30/2009 Page 4 of 7
+Page 4
+as guaranteed by the United States Constitution. Drawing an adverse inference
+under these circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable and would therefore violate the
+Constitution.
+Responding to the above financial request would require Epstein to
+identify information regarding the offenses that were the prior subject of a federal
+investigation as set forth in more detail in a supplementary response available to
+be provided to the court in camera and ex parte to the extent the good faith
+assertion of the privilege is in question. The Fifth Amendment is a safe harbor for
+all citizens, including those who are innocent of any underlying offense, however
+responding to this and other relating inquiries have the potential to provide a
+producing the above information may implicitly communicate statements of fact in
+that they would implicitly authenticate the requested information, require Epstein
+to admit that the requested information exists and admit that same were in his
+possession, custody and control. The very act of production itself may therefore
+provide a link in the chain of evidence adverse to Epstein, see generally United
+States v Hubbell 520 US 27, 36 (2000)
+In addition to and without waiving his constitutional privileges, Defendant
+also objects as the request for production as unreasonable, overbroad,
+confidential, proprietary in nature and seeks information that is neither relevant to
+the subject matter of the pending action nor does it appear to be reasonably
+calculated to lead to the discovery of admissible evidence. Further, Plaintiffs
+Complaint alleges a time period of "in or about 2004-2005." Plaintiff's request
+seeks information for a time period of January 1, 2002 to present.
+To the extent this court rules that some or all of the requested information
+be produced, it should not be produced without limitations (including
+confidentiality), and should only be produced at the very end of litigation but
+before trial in order for Plaintiff to establish her burden making it apparent that
+punitive damages can be awarded.
+Request No. 4:
+Any and all appraisals indicating fair market value of
+real estate or other property of Defendant.
+Response and Objections to Request Number 4: Defendant is
+asserting specific legal objections including but not limited to relying on certain
+U.S. constitutional privileges in declining at present to respond to this request for
+production based
+answers/responses to questions relating to my financial history and condition
+without waiving my Fifth Amendment and I must accept this advice or risk losing
+my Sixth Amendment right to effective representation. Accordingly, 1 assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments
+as guaranteed by the United States Constitution. Drawing an adverse inference
+
+
+Case 9:08-cv-80119-KAM Document 545-2 Entered on FLSD Docket 05/12/2010 Page 5 of 7
+Case 9:08-CV-80119-KAM Document 333-1 Entered on FLSD Docket 09/30/2009 Page 5 of 7
+Page 5
+under these circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable and would therefore violate the
+Constitution.
+Responding to the above financial request would require Epstein to
+identify information regarding the offenses that were the prior subject of a federal
+investigation as set forth in more detail in a supplementary response available to
+be provided to the court in camera and ex parte to the extent the good faith
+assertion of the privilege is in question. The Fifth Amendment is a safe harbor for
+all citizens, including those who are innocent of any underlying offense, however
+responding to this and other relating inquiries have the potential to provide
+a
+link in a chain of information that would be protected. More specifically, the act of
+producing the above information may implicitly communicate statements of fact in
+that they would implicitly authenticate the requested information, require Epstein
+to admit that the requested information exists and admit that same were in his
+possession, custody and control. The very act of production itself may therefore
+provide a link in the chain of evidence adverse to Epstein, see generally United
+States v Hubbell 520 US 27, 36 (2000)
+In addition to and without waiving his constitutional privileges, Defendant
+also objects as the request for production as unreasonable,
+overbroad,
+confidential, proprietary in nature and seeks information that is neither relevant to
+the subject matter of the pending action nor does it appear to be reasonably
+calculated to lead to the discovery of admissible evidence. Further, Plaintiff's
+Complaint alleges a time period of "in or about 2004-2005." Plaintiff's request
+seeks information for a time period of January 1, 2002 to present.
+To the extent this court rules that some or all of the requested information
+be produced, it
+should not be produced without limitations including
+confidentiality), and should only be produced at the very end of litigation but
+before trial in order for Plaintiff to establish her burden making it apparent that
+punitive damages can be awarded.
+Request No. 5:
+Any and all documents referring or relating to
+investment or savings accounts, including without limitation, account statements
+and summaries.
+Response and Objections to Request Number 5: Defendant is
+asserting specific legal objections including but not limited to relying on certain
+U.S. constitutional privileges in declining at present to respond to this request for
+production based
+on
+advice
+from my counsel that | cannot provide
+answers/responses to questions relating to my financial history and condition
+without waiving my Fifth Amendment and I must accept this advice or risk losing
+my Sixth Amendment right to effective representation. Accordingly, I assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments
+as guaranteed by the United States Constitution. Drawing an adverse inference
+
+
+Case 9:08-cv-80119-KAM Document 545-2 Entered on FLSD Docket 05/12/2010 Page 6 of 7
+Case 9:08-CV-80119-KAM Document 333-1 Entered on FLSD Docket 09/30/2009 Page 6 of 7
+Page 6
+under these circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable and would therefore violate the
+Constitution.
+Responding to the above financial request would require Epstein to
+identify information regarding the offenses that were the prior subject of a federal
+investigation as set forth in more detail in a supplementary response available to
+be provided to the court in camera and ex parte to the extent the good faith
+assertion of the privilege is in question. The Fifth Amendment is a safe harbor for
+all citizens, including those who are innocent of any underlying offense, however
+responding to this and other relating inquiries have the potential to provide
+link in a chain of information that would be protected. More specifically, the act of
+producing the above information may implicitly communicate statements of fact in
+that they would implicitly authenticate the requested information, require Epstein
+to admit that the requested information exists and admit that same were in his
+possession, custody and control. The very act of production itself may therefore
+provide a link in the chain of evidence adverse to Epstein, see generally United
+States v Hubbell 520 US 27, 36 (2000)
+In addition to and without waiving his constitutional privileges, Defendant
+also objects as the request for production as unreasonable,
+overbroad,
+confidential, proprietary in nature and seeks information that is neither relevant to
+the subject matter of the pending action nor does it appear to be reasonably
+calculated to lead to the discovery of admissible evidence. Further, Plaintiff's
+Complaint alleges a time period of "in or about 2004-2005." Plaintiff's request
+seeks information for a time period of January 1, 2002 to present.
+To the extent this court rules that some or all of the requested information
+be produced, it
+should not be produced without limitations including
+confidentiality), and should only be produced at the very end of litigation but
+before trial in order for Plaintiff to establish her burden making it apparent that
+punitive damages can be awarded.
+Certificate of Service
+WE HEREBY CERTIFY that a true copy of the foregoing has been sen
+U.S. Mail, and facsimile to the following addressees this A day o
+2009.
+Adam D. Horowitz, Esq.
+Jeffrey Marc Herman, Esq.
+Stuart S. Mermelstein, Esq
+18205 Biscayne Boulevaro
+Suite 2218
+Miami, FL 33160
+Jack Alan Goldberger
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+
+
+Case 9:08-CV-80119-KAM Document 545-2 Entered on FLSD Docket 05/12/2010 Page 7 of 7
+•- Case 9:08-CV-80119-KAM Document 333-1
+Entered on FLSD Docket 09/30/2009 Page 7 of 7
+Page 7
+305-931-2200
+Fax: 305-931-0877
+ahorowitz@hermanlaw.com
+iherman@hermanlaw.com
+Irivera@hermanlaw.com
+Counsel for Plaintiff Jane Doe #2
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Co-Counsel for Defendant Jeffrey
+Epstein
+ROBERT D. CRITÓN, JR., ESQ.
+Florida Bar No. 224162
+[crit@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
+Fax: 561-515-3148
+(Co-counsel for Defendant Jeffrey Epstein)

vision-fixhub/court-01/dbbfee4674e02acccd0b35dccfbfab9b8a4e3bddde5ab417fed6d5d9f3120d6e.receipt.json

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vision-fixhub/court-01/dbde43e82948f05e552228f48bf7b1f941597cdc374274b328357484bcc44ede.md

@@ -0,0 +1,23 @@
+Case 9:08-cv-80736-KAM Document 66 Entered on FLSD Docket 04/14/2011 Page 1 of 1
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No. 08-80736-Civ-Marra/
+JANE DOE #1 and JANE DOE #2
+v.
+UNITED STATES
+[PROPOSED| ORDER GRANTING JANE DOE #1 AND JANE DOE #2'S UNOPPOSED
+MOTION TWO WEEK EXTENSION OF TIME AND FOR PERMISSION TO FILE AN
+OVERLENGTH REPLY TO GOVERNMENT RESPONSES TO THEIR MOTIONS
+THIS CAUSE comes before the Court on Jane Doe #1 and Jane Doe #2's Unopposed
+Motion for Two Week Extension of Time and for Permission to File an Overlength Reply to
+Government Responses to Their Motions, filed April 13, 2011.
+It is ORDERED AND ADJUDGED that the Motion is GRANTED. The victims may file
+replies to responses to the Government's pending motions (DE #58, 59, 60, and 62) on or before
+May 2, 2011. They may also file a reply in support of their Motion for Finding of Violations of
+the Crime Victims' Rights Act not to exceed 27 pages in length.
+DONE AND ORDERED in
+at West Palm Beach, Palm Beach County, Florida,
+this 13" day of April, 2011.
+K
+KENNETH A. MARRA
+United States District Judge

vision-fixhub/court-01/dbde43e82948f05e552228f48bf7b1f941597cdc374274b328357484bcc44ede.receipt.json

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vision-fixhub/court-01/dbe413725260b8f8bd376aad778adacb911074232c1de0944526ca76d2cdbb61.md

@@ -0,0 +1,191 @@
+Case 9:09-cV-80591-KAM Document 66-1 Entered on FLSD Docket 07/29/2009 Page 1 of 5
+The Psychological Trauma Center
+a division of Preventive Psychiatry Associates Medical Group, Inc.
+Medical Director: Gilbert W. Kliman, M. D.
+2105 Divisadero St., San Francisco, CA 9411:
+Phone (415)292-7119 Fax (415) 749-2802
+www.experichildposchiatry.com
+Forensic Child Psychiatric Evaluations, Life Care Plans & Testimony
+DECLARATION OF GILBERT KLIMAN, M. D.
+June 4, 2009
+RE: EXPECTATION OF HARM FROM DISCLOSING THE PLAINTIFFS' IDENTITIES
+IN DOES V JEFFREY EPSTEIN
+1. 1, Gilbert W. Kliman, M.D., of 2105 Divisadero Street, San Francisco, California,
+CA. Physicians License G55912, declare the following under penalty of perjury:
+2. I have been retained by plaintiffs' law firm, Mermelstein & Horowitz., to give expert
+testimony. If called as a witness, I would testify truthfully and competently concerning
+my psychiatric findings about each of the plaintiffs' alleged experiences of sexual abuse,
+and the enduring effects that I find each of the young women have suffered as a direct
+result of the sexual acts perpetrated by the defendant.
+3. I have been asked to respond to the Defense motion, which requests that some of the
+plaintiffs, who are now adults, should be publicly named. It is my opinion that
+involuntary public disclosure will result in the plaintiffs experiencing revictimization,
+albeit by a justice system that is designed to protect them. If their identities are released,
+the victims will be at-risk of having their personal lives scrutinized by friends, extended
+family, spouses, children, fellow students, employers and fellow employees, the media
+and general public. This type of exposure humiliates many victims and represents anothe
+betrayal of trust. Public exposure places the plaintiffs at further risk of stigmatization
+4. Due to traumatization the plaintiffs are arrested in their development, and even those
+who are now legally adults are arrested in part to adolescent aspects of psychology.
+5. The plaintifts do not hold their heads high with pride tor having been sexually
+absorption and self-doubt and self-blame about sexual acts.
+
+A
+1
+
+
+Case 9:09-cv-80591-KAM Document 66-1 Entered on FLSD Docket 07/29/2009 Page 2 of 5
+6. Clinically harmful levels of shame, self-consciousness, self-doubt and self-blame are
+even more prominent among victims of molestations than among the general population.
+7. Molested teenagers are particularly vulnerable to wrongful manipulations and special
+clinical harms from the experiences of shame and humiliation. In fact, shame and efforts
+to cope with it played an underlying role in the harm to each plaintiff. Each was lured
+into Mr. Epstein's sexual lair with the promise of overcoming bodily and sexual shame
+by earning money and bettering their lot in life. The defendant capitalized on their sexual
+naiveté, insecurities and effort to better themselves, and he worked hard to overcome
+their shame at his enlistment of them in his selfish gratifications.
+8. The defendant who wishes to make their identities public is one whom the criminal
+justice system has already determined is a person who has already committed a crime of
+child molestation. That surely means he has already exploited and manipulated the girls'
+state of adolescent sexuality, including their embarrassment, awkwardness and bodily
+self-consciousness. He perverted their nascent and developing moral structures by posing
+as a generous, avuncular mentor who could coach them about their bodies, sex and love.
+The exploitation of adolescent bodies, sex and love is - from a psychoanalytic point of
+view - an influence on the developing moral conscience of the children, as well as on
+their sexual urges. Now the ravaging of their internal and private moral conscience is
+intended by the perpetrator to be made a public ravaging.
+9. Among sexual trauma victims, the insidious and destructive persistence of shame,
+humiliation and associated self-blame is well-documented (Finkelhor and
+_, 1985).
+Stigmatization, as experienced by a sexual trauma victim, has especially painful and
+pathologic consequences. Shame lingers and becomes integrated within the adolescent
+victim's malleable emerging identity, character structure and self image. Moral clarity is
+distorted, Perceptions of self-blame and guilt are magnified. The impact of shame lends
+to cultivating a self image of being "spoiled goods."
+10. Stigmatization following sexual trauma results in long-term risks that can negatively
+shape multiple facets of adult development: sexual, emotional, interpersonal and
+vocational. Stigmatization, which is generally to be avoided among psychiatric patients,
+increases risks among those - as in our plaintifts as a group - who experience clinical
+depression and self-destructive behaviors: drug use, criminal activity, even prostitution.
+Stigmatization following abuse is associated with delinquency due to increased anger
+and affiliation with deviant peers (Feiring et al., 2007).
+11. Shame and guilt are important dimensions of both complex and single event,
+posttraumatic stress disorder (PTSD). Symptoms of shame are associated with feelings of
+helplessness and powerlessness, which each of the plaintiffs endorsed experiencing in
+relation to Mr. Epstein.
+
+
+Case 9:09-cV-80591-KAM Document 66-1 Entered on FLSD Docket 07/29/2009 Page 3 of 5
+12. The DSM-IV-TR recognizes both powerlessness and helplessness as requisite parts of
+the traumatic experience in Criterion A for the diagnosis of posttraumatic stress disorder
+Seligman, recent Past President of the American Psychological
+Association, coined relevant terms of "learned helplessness and "Loss of Personal Locus
+of Control." See Seligman, M.P. 1975: Helplessness, Depression, Development and
+Death. W. H. Freeman, San Francisco). The teenaged girls suffered the loss of personal
+locus of control to a much more experienced, sexually aggressive, powerful and
+dominant, manipulative perpetrator.
+13. Releasing names of the plaintiffs to the public will reenact experiences of
+powerlessness and helplessness in the face of a boundary violation. Repetition and
+reenactment represent central features of Criterion B in the DSM-IV-TR diagnosis of'
+posttraumatic stress disorder trauma. In effect, release of their identity and public
+intrusion into their personal life represents a reenactment of the shame of sexual
+traumatization. Repetition and reenactment are central pathologies that afflict sexual
+trauma survivors.
+14. Victims of sexual abuse often rely upon some form of dissociation, splitting or denial,
+as a detensive means to manage overwhelming attects associated with the sexual trauma.
+Each of the plaintiff girls has employed some variation of this defense, both during the
+massages and then subsequently following disclosure of the abuse. Primitive,
+maladaptive responses of this nature will become additionally reinforced as a result of
+public disclosure.
+15. Another aspect of the plaintiffs' experience, which is recognized by DSM-IV-TR, is
+that the trauma was associated with human design factors (such as cruel intention to do
+harm, rape, torture). Trauma of this origin has a tendency to produce more "severe or
+long lasting" posttraumatic stress disorder than natural events (DSM IV TR p. 464). A
+policy of deliberate revelation of the names of the victims would reinforce the sense of
+design, pattern and policy of human intentions.
+16. Negative expectations about significant activities are noted in DSM-IV-TR, as part of
+Criterion C. Symptoms of foreshortened future are characteristic of a traumatized
+individual's clinical course (C4). They expect revictimization. They expect bad outcomes
+identity will aggravate existing symptoms of hypervigilance.
+17. The DSM-IV-TR diagnostic category of "chronic" is justified for each of the
+auntills. Scientifie literature shows that the prognostic consequences of PTSD an
+esidual effects may last for decades (U.S. Dept. of Health, 2005; Issues in Child Abus
+Prevention Number 9 Autumn1998: Long-term Effects of Child Sexual Abuse, Paul E
+Mullen and Jillian Fleming). The lasting impact upon character, identity and moral
+development will probably affect long-term influences upon adult development. It is
+more probable than not that stigmatization associated with public disclosure of the
+3
+
+
+Case 9:09-cv-80591-KAM Document 66-1 Entered on FLSD Docket 07/29/2009 Page 4 of 5
+plaintiffs' identities will intensify the scope, nature and severity of the chronic symptom
+course.
+18. In addition to PTSD, shame and humiliation themselves have also been associated
+with causing clinical depression. Coexisting PTSD and clinical depression places the
+plaintiff's at increased risk for re-victimization and high risk sexual behaviors (e.g.,
+sexually transmitted disease, premature pregnancy, rape) (Nelson, 2002), and at greater
+risk to victimize others (Filipas and Ullman, 2006; Desai, Centers for Disease Control,
+2002) who are in their control. Studies have also shown that chronic symptoms of PTSD,
+in association with a single episode of Major Depressive Disorder, can produce lifetime
+adjustment difficulties, which include suicidality (Oquendo et al, 2005; Dube et al, CDC,
+2001; Rohde, J. Am. Acad. Child and Adolescent Psychiatry 2005). The plaintiffs will be
+additionally vulnerable to these clinical outcomes, if they suffer the stigmatization and
+humiliation associated with public disclosure of their identities.
+19. Alternative hypothesis: I have applied the evidence shown from examination and
+testing of the plaintiffs and relevant observations and information from other
+professionals while testing an alternative hypothesis: that no harm would result from
+public disclosure of the plaintiffs' identities. During the evaluations with the six
+plaintiffs, I used generally acceptable criteria for establishing whether a DSM-IV-TR
+disorder occurred. I established that there were provable and diagnosable injuries,
+primarily posttraumatic stress disorder and comorbid depression. Based upon these
+diagnostic signs, it is more probable than not, that exposing the plaintiff's identity to the
+public is not a trivial concern or one without substantial clinical repercussions. I believe
+that most child, adolescent and adult psychiatrists would share the opinion that additional
+psychiatric injury will result from such exposure.
+20. However, consider for the sake of argument, that my diagnostic conclusions are
+incorrect, notwithstanding having fulfilled standard psychiatric evaluation procedures of
+taking a history from multiple sources, videotaping and transcribing my initial interview,
+and reviewing available medical and legal documents. Even if this was the case, and my
+diagnostic conclusions were faulty, I believe that multiple experts, even those who may
+now propose publication of the victims' names, would still come to a conclusion that the
+plaintiff's suffered sexual abuse, and in some cases, multiple acts of ongoing abuse, at the
+hands of Jeffery Epstein. Even without developing a subsequent disorder, there is much
+clinical evidence and scientific literature showing likelihood of substantial psychiatric
+harm to these sexually abused plaintiffs.
+21. To form these conclusions, I have used my extensive experience in forming these
+opinions. That experience is both as a treating child psychiatrist and separately as a
+forensic psychiatrist. I have treated hundreds of minor patients, as well as additionally
+evaluated hundreds of children and adolescents who have suffered sexual abuse. I have
+made long term followups of many of the children and have treated many adults who
+have been molested as adolescents. It is my opinion, with a reasonably high degree of
+medical certainty that the defense motion to allow public disclosure of the plaintiffs'
+identities is clinically and ethically a wrongful plan. The act of revealing their identities
+against their wishes places the plaintiffs at risk, in the best of circumstances, of suffering
+4
+
+
+Case 9:09-cv-80591-KAM Document 66-1 Entered on FLSD Docket 07/29/2009 Page 5 of 5
+an aggravation of existing diagnostic concerns. It is more probable than not that releasing
+personal identities will f
+an exacerbation and magnification of symptoms lending to
+increased risk of revictimization and retraumatization.
+I declare under penalty of perjury under the laws of the State of California that the
+foregoing statements are true and correct, and that this declaration was executed at San
+Francisco, California on June 4, 2009.
+Sincerely
+Gilbert Kliman, M.D.
+Distinguished Life Fellow, American Psychiatric Association
+Senior Fellow, American Academy of Child and Adolescent Psychiatry
+Brockman Award Holder, for Distinguished Lifetime Contributions to
+Psychoanalysis and Psychiatry, bestowed by the American College of Psychoanalysis and
+Psychiatry
+LEONID NAKHODKIN
+Соми. # 1791115
+NOTARY PUBLIC-CALIFORMA
+DITY & COUNTY OF SAN FRANCISO
+ty Cow. Exp. FEe: 27, 2012 H
+State of California, City & County of San Francisco
+subscibed and sworn to (or affimed) before me on the
+yay of undory by Gilbert Klinkeen
+proved me petrol shopped peter me
+5

vision-fixhub/court-01/dbe413725260b8f8bd376aad778adacb911074232c1de0944526ca76d2cdbb61.receipt.json

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vision-fixhub/court-01/dc1ad867615bd26d17fe03df953d6db7f2f2c68d5fab5288452788b90ffd9f4c.md

@@ -0,0 +1,145 @@
+Case 1:19-cv-10577-LJL-DCF Document 25 Filed 01/31/20 Page 1 of 4
+BOIES
+| SCHILLER
+FLEXNER
+Telephone: (212) 446-2300
+Email: jischiller@bsfllp.com
+January 31, 2020
+VIA ECE
+The Honorable Lora G. Schofield
+District Court Judge
+United States District Court
+Southern District of New York
+40 Foley Square
+New York, NY 10007
+Re: Jane Doe 1000 v. Indyke et al., Case No. 19-cv-10577
+Dear Judge Schofield,
+Pursuant to Individual Rules III.A. 1 and III.C.2, Plaintiff Jane Doe 1000 hereby responds
+to Defendants' request for a pre-motion conference in connection with their anticipated motion to
+dismiss. Dkt. 24. Plaintiff's claims are timely under New York's statutes of limitation and the
+doctrine of equitable estoppel, and Defendants' proposed motion "to dismiss" Plaintiff's request
+for punitive damages is procedurally improper. For the following reasons, the Court should deny
+Defendants" anticipated motion in its entirety.'
+I. Plaintiff's Claims Are Timely Under New York Law.
+Plaintiff's claims are timely under New York's CPLR § 215(8)(a), which provides:
+"Whenever it is shown that a criminal action against the same defendant has been commenced
+with respect to the event or occurrence from which a claim governed by this section arises, the
+plaintiff shall have at least one year from the termination of the criminal action ... to commence
+the civil action." (Emphasis added). Here, Epstein's criminal action in this District terminated on
+August 29, 2019. Compl. 9| 36. Because Plaintiff filed the Complaint less than three months later,
+the action is timely under CPLR 215(8)(a). Defendants' arguments against CPLR § 215(8)(a)'s
+application to these facts are meritless.
+First, Defendants' argument that CPLR § 215(8)(a) does not apply because Plaintiff was
+not named as a victim in Epstein's indictment is incorrect. New York courts have held that CPLR
+§ 215(8)(a) is "plain, clear and unambiguous" that it does not require that the plaintiff be "the
+victim or the specific person upon whom the crime had been committed." Clemens v. Nealon, 202
+A.D.2d 747, 749 (N.Y. App. Div. 1994).
+Second, Defendants' narrow construction of § 215(8)(a)'s "event or occurrence" language
+is improper, especially in light of the breadth of Epstein's indictment. The charges were not limited
+to crimes committed against specific victims. For example, the overt acts alleged for the sex
+trafficking conspiracy charge were enticing and recruiting multiple victims, "including minor
+" To the extent the Court allows Defendants to file a motion to dismiss, Plaintiff requests 30 days from the
+date of Defendants' motion to file an opposition, with Defendants' reply brief due 10 days thereafter.
+BOIES SCHILLER FLEXNER LLP
+55 Hudson Yards, New York, NY 10001 | (t) 212.446.2300 | () 212.446.2350 | www.bsfllp.com
+
+
+Case 1:19-cv-10577-LJL-DCF Document 25 Filed 01/31/20 Page 2 of 4
+victims identified herein." Compl., Ex. A (S.D.N.Y Indictment) I| 22(a) (emphasis added). As
+another example, the Indictment's sex trafficking count charged Epstein with the sex trafficking
+of "numerous individuals ... including but not limited to Minor Victim-l." Id. Il 24. Nor did the
+Indictment describe the sex trafficking conspiracy as exclusively targeting minor victims—it
+explicitly acknowledged that some victims were not underage at the time of the sexual abuse. Id.
+• 11 ("[Epstein] knew that many of his New York victims were underage."). The Indictment was
+targeted at Epstein's sex-trafficking scheme as a whole, and that scheme is the event or occurrence
+from which Plaintiff's civil claims arose. See Kashef v. BNP Paribas S.A., 925 F.3d 53, 56-57,
+62 (2d Cir. 2019) (guilty plea conceding "knowledge of the atrocities being committed in Sudan"
+allowed victims of the atrocities in Sudan use 215(8)(a) because causes of action arose out of
+defendant's general conspiracy with Sudan to violate U.S. sanctions put in place to stop atrocities).
+Because Plaintiff's claims arise out of this common scheme, they fall within CPLR § 215(8)(a).
+The cases Defendants cite are inapposite because the criminal charges in those cases were
+much narrower than Epstein's, and related to events that occurred on specified dates. See
+Christodoulou v. Terdeman, 262 A.D.2d 595, 596 (N.Y. App. Div. 1999) (prosecution commenced
+only in connection with events on two dates); Gallina v. Thatcher, No. 2017-52980, 2018 N.Y.
+Misc. LEXIS 8435, at *3 (Sup. Ct. Oct. 23, 2018) (indictment "charged [the defendant] for
+incidents occurring on three (3) specific dates"). Epstein's Indictment was much broader, covering
+sexual abuse that occurred "over the course of many years" "from at least in or about 2002, up to
+and including at least in or about 2005." S.D.N.Y. Indictment 99| 1-2, 8, 20, 24 (emphases added).
+Plaintiff's claims are therefore timely under CPLR § 215(8)(a) because the scheme the S.D.N.Y.
+Indictment targeted is the event or occurrence from which Plaintiff's civil claims arise.
+Plaintiff's claims are also timely under CPLR § 213-c, which provides for a twenty year
+limitations period for "all civil claims or causes of action brought by any person for physical,
+psychological or other injury or condition suffered by such person as a result of conduct which
+would constitute rape" or other enumerated sex crimes. The Complaint alleges that Epstein
+sexually assaulted Plaintiff by forcible compulsion multiple times within the past twenty years.
+See Compl. 9| 50, 51. Plaintiff's claims fall squarely within CPLR § 213-c's coverage. Defendants'
+assertion that CPR § 213-c does not apply because "the 20-year SOL does not apply
+retroactively" is meritless. CPLR § 213-c's text contains no such limitation, and was revised last
+year (increasing the limitations period from 5 to 20 years) specifically to allow claims such as
+Plaintiff's to proceed. See June 17, 2019, New York Committee Report, 2019 NY S.B. 6574 (NS)
+(noting that "victims who have suffered in silence for decades have bravely spoken about their
+abuse, and have also laid bare the state's limited ability to prosecute their abusers due to the
+passage of time" and that "this bill would increase the time period in which the victim could bring
+a civil suit for these offenses to twenty years").
+Defendants also assert that Plaintiff's claims are untimely under New York's borrowing
+statute, CPLR § 202. This argument fails for two reasons. First, CPLR § 202 only applies to nonresidents who are injured outside of New York, and the controlling date for determining a
+plaintiff's residence is the date on which the cause of action accrued, not the date on which the
+action was commenced. See, e.g., DeMartino v.
+cenuthe date on which the
+1. 148 A.D.2d 568, 570 (N.Y. App. Div.
+1989). Under the borrowing statute, the phrases "resident" and "domicile" are not synonymous.
+"Rather, the determination of whether a plaintiff is a New York resident, for purposes of CPLR
+202, turns on whether [she] has a significant connection with some locality in the State as the result
+
+
+Case 1:19-cv-10577-LJL-DCF Document 25 Filed 01/31/20 Page 3 of 4
+of living there for some length of time during the course of a year." Antone v. Gen. Motors Corp.,
+473 N.E.2d 742, 746 (N.Y. 1984). The fact that Plaintiff currently lives in New Jersey is irrelevant.
+At the time of her repeated sexual assaults, Plaintiff was a resident of New York—she lived in
+Epstein's apartment building on 66" Street in Manhattan, where he housed other victims. Compl.
+9140. When Plaintiff escaped Epstein, she stayed in New York and moved into a Salvation Army
+apartment. Compl. I| 46. Because Plaintiff had a significant connection with New York at the
+time her cause of action accrued, she was a resident of New York, and CPLR § 202 does not apply.
+Second, even if New York's borrowing statute did apply and Plaintiff's claims were
+otherwise untimely, they would still not be barred because CPLR § 215(8)(a) provides for civil
+actions to commence within one year from the termination of the criminal
+action ... notwithstanding that the time in which to commence such action has already expired."
+II. Plaintiff Has Sufficiently Pled Facts Supporting Equitable Estoppel and Tolling.
+Even if Plaintiff's claims were otherwise time-barred under New York's statutes of
+limitation (they are not), they would still be timely under the doctrine of equitable estoppel.
+Defendants assert that Plaintiff "fails to meet her burden to allege extraordinary circumstances
+sufficient to justify tolling or equitable estoppel." Dkt. 24 at 2. But the Complaint alleges in detail
+the methods of intimidation and control that Jeffrey Epstein and his co-conspirators used to deter
+their victims from seeking justice. Equitable estoppel applies "where it would be unjust to allow
+a defendant to assert a statute of limitations defense," Zumpano v. Quinn, 849 N.E.2d 926, 929
+(N.Y. 2006), due to "deception, concealment, threats, or other misconduct," Zoe G. v. Frederick
+F.G., 208 A.D.2d 675, 675 (N.Y. App. Div. 1994). The Complaint alleges that Epstein and his
+co-conspirators manipulated victims using "financial power, promises, and threats;" that Plaintiff
+was "terrified of Epstein, who repeatedly threatened her and made representations about his
+wealth, power, and connections;" and that Epstein forced Plaintiff to meet with a prominent lawyer
+who gathered information about Plaintiff's family's financial situation that Epstein later used "to
+intimidate her and to keep her compliant in his sex-trafficking scheme." Compl. 99l 27, 40, 43.
+The allegations concerning Epstein's purposeful silencing of his victims (and Plaintiff specifically)
+easily provide the requisite "extraordinary circumstances" for equitable tolling.
+Because equitable estoppel and equitable tolling are fact-specific doctrines, Defendants'
+attempt to resolve the issue with a motion to dismiss is inappropriate, and any motion challenging
+whether or not those doctrines apply should be reserved until after discovery. See, e.g., Carelock
+v. United States, 2015 WL 5000816, at *8 (S.D.N.Y. Aug. 20, 2015).
+I. The Court Should Address Punitive Damages After Discovery
+Federal Rule 12(b)(6) allows a defendant to file a motion to dismiss for "failure to state a
+claim upon which relief can be granted." Defendants' request for the Court to dismiss Plaintiff's
+claim for punitive damages does not relate to either of Plaintiff's clams (battery and intentional
+infliction of emotion distress) and does not relate to the sufficiency of the allegations in the
+Complaint. The issue of what type of damages to which Plaintiff is entitled should therefore be
+dealt with at a later stage of this litigation. See, e.g., Okyere v. Palisades Collection, LLC, 961 F.
+Supp. 2d 522, 536 (S.D.N.Y. 2013) (denying "motion to "dismiss' plaintiff's request for punitive
+damages as procedurally premature").
+
+
+Case 1:19-cv-10577-LJL-DCF Document 25 Filed 01/31/20 Page 4 of 4
+Respectfully submitted,
+Is/ Joshua I. Schiller
+David Boies, Esq.
+Joshua I. Schiller, Esq.
+Sigrid S. McCawley, Esq.
+cc: Counsel of Record (via ECF)

vision-fixhub/court-01/dc1ad867615bd26d17fe03df953d6db7f2f2c68d5fab5288452788b90ffd9f4c.receipt.json

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vision-fixhub/court-01/dc1df20190709f67bba971b8ca2f8931fc8a6b3f8ef3397cb5146101a71b5e2f.md

@@ -0,0 +1,202 @@
+Case 9:08-cv-80119-KAM Document 443 Entered on FLSD Docket 12/29/2009 Page 1 of 5
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CIV-80119-MARRA/I
+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
+EPSTEIN'S REPLY TO PLAINTIFES' RESPONSE TO MOTION TO COMPEL
+PRESIDENTIAL WOMEN'S CENTER TO COMPLY WITH SUBPOENA DUCES TECUM
+AND INCORPORATED MOTION TO COMPEL PRESIDENTIAL WOMEN'S CENTER TO
+COMPLY WITH SUBPOENA DUCES TECUM REGARDING JANE DOE NO. 4
+Defendant, Jeffrey Epstein ("Epstein"), submits this reply to Plaintiffs', Jane Doe Nos. 2,
+3 and 5-8 ("Plaintiffs"), Response to Epstein's Motion to Compel Presidential Women's Center
+to Comply with Subpoena Duces Tecum (DE #442) and also moves to compel Presidential
+Women's Center to Comply with Subpoena Duces Tecum Regarding Jane Doe No. 4, and states:
+On December 2, 2009, Epstein filed a Motion to Compel Presidential Women's
+Center to Comply with Subpoena Duces Tecum ("Motion to Compel") (DE #431).
+2.
+Since the filing of the Motion to Compel (DE #431), Presidential Women's
+Center notified undersigned counsel that it does not have any records for Jane Doe Nos 2, 3, 5, 6
+and 8!
+'Epstein did not serve a subpoena on Presidential Women's Center for Jane Doe No. 7.
+
+
+Case 9:08-cv-80119-KAM Document 443 Entered on FLSD Docket 12/29/2009 Page 2 of 5
+Thus, unless circumstances change in the future, the issues in Epstein's Motion to
+Compel and the subpoenas to Presidential Women's Center regarding Jane Doe Nos. 2, 3, 5, 6
+and 8 are moot at the current time.
+MOTION TO COME PRESIDE ON TED COMPLY WITH
+4.
+In her deposition, Jane Doe No. 4 testified that she had three abortions, at least
+two of which was performed at Presidential Women's Center. See 10/27/09 Deposition of Jane
+Doe No. 4 at 311-313, excerpt attached as Exhibit A.
+5.
+On November 13, 2009, Epstein issued a subpoena (attached as Exhibit B) to
+Presidential Women's Center for records relating to Jane Doe No. 4.
+6.
+Jane Doe No. 4 did not object to said subpoena.
+7.
+Presidential Women's Center represented they will not produce records without a
+court order or a signed HIPAA release from the patient.
+8.
+On December 18, 2009, counsel for Epstein requested Jane Doe No. 4 provide an
+executed release for Presidential Women's Center. To date, no release has been received.
+Accordingly, Epstein requests the Court enter an order compelling Presidential
+Women's Center to comply with the November 13, 2009 subpoena duces tecum within five (5)
+days of the Court's order.
+10.
+This discovery is obviously relevant and discoverable and, again, Jane Doe No. 4
+(also represented by counsel for Jane Doe Nos. 2, 3 and 5-8) did not object to the subpoena. As
+the Court stated in its September 4, 2009 Order (DE #289), "lu]nder these circumstances, where
+Plaintiff is seeking to recover expenses associated with these complex medical issues, full
+knowledge of Plaintiff's past and present medical, psychological, familial and social histories is
+essential." See DE #289 at 4; see also DE #377 at 10 ("As a global matter, Plaintiffs clearly and
+2
+
+
+Case 9:08-cv-80119-KAM Document 443 Entered on FLSD Docket 12/29/2009 Page 3 of 5
+unequivocally place their sexual history in issue by their allegations that Epstein's actions in this
+case has negatively affected their relationships.... To deny Epstein this discovery [regarding
+past sexual history], would be tantamount to barring him from mounting a defense.").
+WHEREFORE, Epstein respectfully requests the Court enter an order compelling
+Presidential Women's Center to produce documents responsive to the subpoena duces tecum
+regarding Jane Doe No. 4 and attached to this Motion as Exhibit A within five (5) days of the
+Court's order and grant any additional relief the Court deems just and proper.
+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
+Respectfully submitted,
+_s/ Michael J. Pike
+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
+303 Banyan Blvd., Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Counsel for Defendant Jeffrey Epstein)
+Certificate of Service
+Jane Doe No. 2 v. Jeffrey Epstein
+Case No. 08-CV-80119-MARRA/.
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Boulevard
+1 Esq.
+Brad Daffe, Weasing,
+Lehrman, PL
+424 N. Andrews Avenue, Suite #2
+, Fistos &
+3
+
+
+Case 9:08-cv-80119-KAM Document 443 Entered on FLSD Docket 12/29/2009 Page 4 of 5
+Suite 2218
+Fort Lauderdale, FL 33301
+Miami, FL 33160
+305-931-2200
+Phone: 954-524-2820
+Fax: 954-524-2833
+Fax: 305-931-0877
+brad@pathtojustice.com
+ssm@sexabuseattorney.com
+ahorowitz/@sexabuseattorney.com
+Counsel for Plaintiff in Related Case No. 08-
+80893
+Counsel for Plaintiffs
+In related Cases Nos. 08-80069, 08-80119, 08-
+. 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.
+2290 10* Avenue North
+801-585-5202
+801-585-6833 Fax
+Suite 404
+cassellp@law.utah.edu
+Lake Worth, FL 33461
+Co-counsel for Plaintiff Jane Doe
+561-582-7600
+Fax: 561-588-8819
+Counsel for Plaintiff in Related Case No. 08-
+80811
+reelrhw@hotmail.com
+Isidro M.
+1, Esq.
+a 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.
+1, Esq.
+Searcy Denney Scarola Barnhart & Shipley,
+Sounsel for Plaintif 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
+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 Nos.
+Bruce E. Reinhart, P.A.
+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
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+4
+
+
+Case 9:08-cv-80119-KAM Document 443 Entered on FLSD Docket 12/29/2009 Page 5 of 5
+Theodore J. Leopold, Esq.
+Spencer T. Kuvin, Esq.
+Leopold, Kuvin, P.A.
+2925 PGA Blvd., Suite 200
+Palm Beach Gardens, FL 33410
+561-684-6500
+Fax: 561-515-2610
+Counsel for Plaintiff in Related Case No. 08-
+08804
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Counsel for Defendant Jeffrey Epstein
+5

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